The survivors' lawyer, Dali Mpofu, said former mines minister Susan Shabangu had labelled the violent labour dispute a criminal act, paving the way for heavy-handed police action, an accusation she denied.
The 34 strikers were gunned down by police at the Lonmin platinum mine north of Johannesburg during a work stoppage on August 2012.
Years earlier, in 2008, Shabangu, then a deputy minister of safety and security, told the police to kill criminals.
At the hearing Mpofu claimed that by describing action by striking workers at Marikana as "acts of criminality", the police would know how they were expected to respond.
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"You knew that the re-characterisation of what was going on at Lonmin, of those people to criminals, would bring them within the ambit of your statement, namely that they must be killed," said Mpofu.
"You knew what the characterisation would do, it was going to militarise the situation and bring about state-sponsored violence," Mpofu argued at an inquiry into the killings.
The Marikana massacre has been widely compared to apartheid-era atrocities.
The unrest is believed to have claimed more than 40 lives, including those of some police and security guards.
The government has admitted it mishandled the strike.