6th Justice P.N.

Bhagwati International Moot Court Competition on Human Rights, 2016

ARGUMENTS ADVANCED

1. Whether the State of Soremon has interfered in the matters of the State of
Boremon?
It is most humbly put forth that the State of Soremon has failed to realize through
concrete efforts, the States right to sovereignty, territorial integrity and political
independence1, particularly to the people living in the BoLR region. The principle of nonintervention in the internal affairs of States also signifies that a State of Soremon should
not otherwise intervene in a dictatorial way in the internal affairs of States of Boremon.
1.1. The State of Soremon has no stake in the affairs Boremon and has illegally
deployed its Army in the BoLR region by violating international law.
I. The UNMOGSB was deployed to supervise the ceasefire between Soremon and
Boremon. Its functions were to investigate complaints of ceasefire violations and
submit findings to each party and to the U.N. secretary-general. Under the terms of
the ceasefire, it was decided that both armies would withdraw and a plebiscite would
be held in Lola and Ramola to give their people the right to self-determination. But,
Soremon chose not to hold the plebiscite2. No State or group of States has the right to
intervene, directly or indirectly, for any reason whatever, in the internal or external
affairs of any other State. Consequently, armed intervention and all other forms of
interference or attempted threats against the personality of the State or against its
political, economic and cultural elements are in violation of international law 3. The
UN General Assembly adopted a Declaration on the Inadmissibility of Intervention
1

UN Charter, Article 2(4)-The prohibition of the threat or use of force in international relations.
7 Official Compromis.
3
UN General Assembly, Friendly Relations Declaration, 1970.
2

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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
and Interference in the Domestic Affairs of States. The International Court was in no
doubt about the existence of the principle in the Nicaragua case4.
II. In the Corfu Channel case5 the International Court regarded:
the alleged right of intervention as the manifestation of a policy of force, such as
has, in the past, given right to the most serious abuses and as such cannot, whatever
be the present defects in international organization, find a place in international law.
Military intervention can also increase the intensity of the violence by adding troops,
firepower and another armed group to an already volatile environment. In Somalia6 in
1993, UN and US forces engaged Somali leader General Muham- mad Farah Aidid in
the most intense fighting since 19917. NATOs air campaign over Kosovo8 and Serbia
in 1999 led to accelerated expulsion of Albanians by Serb soldiers and to physical
destruction in Belgrade9. Armed groups can manipulate the supply of food to civilians
as a means of repression, political bargaining or forced migration 10. The practice was
common in Angola, Bosnia and Herzegovina11 and Ethiopia, for example. Food and
medicine can also be diverted to sustain soldiers12 and militia instead of unarmed
civilians, as happened in Somalia and Sudan.

Infra N. 12.
Albania v. United Kingdom, ICJ Reports (1949).
6
Taylor B. Seybolt, Humanitarian Military Intervention: The Conditions for Success and Failure, 2003.
7
Ibid.
8
J. Eriksson, The International Response to Conflict and Genocide: Lessons from the Rwanda Experience,
Synthesis Report (Steering Committee of the Joint Evaluation of Emergency Assistance to Rwanda,
Copenhagen, 1996)
9
Clarke Independent, Learning from Somalia: The Lessons of Armed Humanitarian Intervention.
10
J.M. Taw, The Perils Of Humanitarian Assistance In Armed Internal Conflicts: Somalia in the 1990s, Small
Wars and Insurgencies, vol. 15, no. 2 (autumn 2004), pp. 519; and Taylor Seybolt, The myth of neutrality,
Peace Review, vol. 8, no. 4 (Dec. 1996).
11
S.L. Burg and P.S. Shoup, The War in BosniaHerzegovina: Ethnic Conflict and International Intervention.
12
A. De Waal, Famine Crimes: Politics and the Disaster Relief Industry in Africa (Indiana University Press:
Bloomington, Ind., 1997); and J. Macrae and A. Zwi, Famine, Complex Emergencies and International Policy
in Africa: An Overview.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
1.2. The State of Soremon has violated the customary rules of international law which
protects the States from the Non-Interference of any other State.
I.

The State of Soremon in recruiting, training, arming, equipping, financing, supplying

and otherwise encouraging, supporting, aiding, and directing military and paramilitary
actions in and against the areas of BoLR, had violated its treaty obligations to BoLR
under Article 2 (4) of the United Nations Charter13. The State of Soremon had
breached international law by:
i.

violating the sovereignty of the State of Boremon by:

armed attacks against BoLR by air and land;

aerial trespass into BoLR airspace;

efforts by direct and indirect means to coerce and intimidate the

Government of Boremon.

ii.

using force and the threat of force against the State of Boremon.

iii.

intervening in the internal affairs of the State of Boremon.

iv.

killing, wounding and kidnapping citizens of the State of Boremon.

In The Republic of Nicaragua v. The United States of America14 ICJ decided that the
United States of America is under an obligation to make reparation to the Republic of
Nicaragua for all injury caused to Nicaragua by the breaches of obligations under
customary international law not to use force against another State, not to intervene in
its affairs and not to violate its sovereignty. The said violation was not only an
unlawful act but also a breach of the principles of humanitarian law underlying
the Hague Convention No. VIII of 190715. The prohibition of intervention is a

13

United Nations Charter, Article 2 (4)- All Members shall refrain in their international relations from the threat
or use of force against the territorial integrity or political independence of any State, or in any other manner
inconsistent with the Purposes of the United Nations.
14
The Republic of Nicaragua v. The United States of America, 70 ICJ Report (1986).
15
Hague Conventions, Geneva Academy Of International Humanitarian Law And Human Rights, Rule Of Law
In Armed Conflicts, 1907.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
corollary of every states right to sovereignty, territorial integrity and political
independence16. What is prohibited is dictatorial interference in what the
International Court of Justice referred to in Nicaragua as matters which each State is
permitted, by the principle of State sovereignty, to decide freely. One of these is the
choice of a political, economic, social and cultural system, and the formulation of
foreign policy.17 Since the reach of international law is constantly changing, so too is
the line between what is, and what is not, covered by the principle of nonintervention.
As the International Court of Justice said in its 1986 judgment in the Nicaragua case,
"the principle of non-intervention involves the right of every sovereign State to
conduct its affairs without outside interference; though examples of trespass against
this principle are not infrequent, the Court considers that it is part and parcel of
customary international law. [ ...] international law requires political integrity [ ... ]
to be respected18".
2. The actions of the State of Boremon are fully in conformity with the basic principles
of international law and were necessary to maintain the unity and integrity in the
nation.
It is most humbly put forth that Mr. Kamaal Khan attempted to bring into hatred and
contempt towards the Government of Boremon established and thus acted against the
laws of Sedition and also the elections of 2015 were fair and genuine. Therefore, the State
of Boremon denies all such perfidious allegations by the State of Soremon.

16

Lassa Francis Lawrence Oppenheim; International Law: Volume I, Peace (1905); Volume II, War, (1906).
Operative Part Of The Court's Judgment: Military and Paramilitary Activities in and against Nicaragua
(Nicaragua v. United States of America, ICJ Reports 1986).
18
The Republic of Nicaragua v. The United States of America, ICJ Reports (1986) p.106, para. 202.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
2.1. The arrest of Late Mr. Kamaal Khan was justified and in fact necessary to defend
integrity of Boremon.
I.

Late Mr. Kamaal Khan, who was the president of Gilly Bucket United Movement
(GBUM), in his speech stated that, it is high time that the people of the BoLR must
either join the Soremon Union or self-proclaim independence as self-determination
is their basic fundamental internally recognized right.19 Even in India waging, or
attempting to wage war, or abetting waging of war, against the Government of India
grants Capital Punishment20.
According to the United States Code, If two or more persons in any State or
Territory, or in any place subject to the jurisdiction of the States, conspire to
overthrow, put down, or to destroy by force the Government of the States, or to levy
war against them, or to oppose by force the authority thereof, or by force to prevent,
hinder, or delay the execution of any law of the States, or by force to seize, take, or
possess any property of the States contrary to the authority thereof, they shall each be
fined under this title or imprisoned not more than twenty years, or both21.

II.

This was clear attempt to bring into hatred and contempt or disaffection towards, the
Central Government of Boremon established by law. This excerpt, being against the
integrity and sovereignty of the State of Boremon, was an act of sedition22. Hence the
arrest of Mr. Kamaal Khan was necessary. The arrest was not a planned massacre.
The death of Mr. Kamaal Khan is an internal criminal matter of the State of Boremon.
Thorough investigations are required in this case so that the real enemy of democracy
can be sought out. The State of Boremon is ready to allow maintain full transparency
regarding the investigation of the case

19

16 Official Compromise.
Indian Penal Code, Section 121- Waging, or Attempting To Wage War, or Abetting Waging of War, Against
The Government Of India.
21
United States Code, Chapter 115, Title 18, Section 2384 - Treason, Sedition, and Subversive Activities.
22
Pakistan Penal Code, 1860, 124(A)- Sedition.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
2.2 Government of Boremon aims at bringing peace and security to the land and to
build lives of dignity and respect.
I.

Much before the adoption of Human Rights Declaration by UN the sacred faith in
Islam of the State had exhorted human beings to follow tenets of human values23.
Under Article 8 and 9 of the Constitution of Pakistan, every human life has been
given inflexible importance. In the case of Benazir Bhutto v. President of Pakistan24 it
has been observed, that while interpreting fundamental rights, the approach of the
Court should be keeping in view the ideas of the people, socio-economic and politico
culture values which in Pakistan are enshrined in the Objective Resolution25 so as to
extend benefit of the same to the maximum possible. In the case of Arshad Mahmood
v. Government of Punjab26 it is held that the Constitution is a living document which
portrays the aspirations and genius of the people and aims at creating progress, peace,
welfare, amity among the citizens.

II.

Article 927 stipulates that no person shall be deprived of life and liberty save in
accordance with law. Article 428 deals with the right of individuals to be dealt with in
accordance with law. The said Article stipulates; to enjoy the protection of law and
to be treated in accordance with law is the inalienable right of every citizen, wherever
he may be and of every other person for the time being within Pakistan.
Therefore under the light of the evidence of law and judgment of cases produced,
State of Boremon denies its involvement in any state sponsored riots in the region of

23

Ministry Of Human Rights: Message from the Prime Minister of Pakistan on International Human Rights
Day, 10th December, 2014.
24
Benazir Bhutto v. President of Pakistan, PLD (1998) SC 388.
25
Objectives Resolution, 1949, Principle 11: The integrity of the territories of the federation, its independence
and all its rights, including its sovereign rights on land, sea and air shall be safeguarded.
The Constitution of Pakistan, Article 2A: The objectives Resolution to form part of substantive provisions.
26
Arshad Mahmood v. Government of Punjab, PLD (2005) SC 193.
27
Constitution of Pakistan, Article 9- Security of Person.
28
Constitution of Pakistan, Article 4- Right of individuals to be dealt with in accordance with law, etc.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
BoLR or any other place in the country itself. Since the government is bound to
protect its people.
2.3.The State of Boremon has conducted the free and fair elections in the BoLR region as
agreed in the treaty of Romia.
I.

The elections were free and fair as it was based on popular adult franchise and one
vote one value. In September, 2015 the State of Boremon agreed that it shall release
Mr. Kamaal Khan and provided opportunity to the people of BoLR to establish a
democracy which will be free from interference from the State of Boremon and in
turn, the State of Soremon shall not indulge in any deployment of its forces in BoLR
or Boremonian region. In the month of October, 2015 a fresh elections were held in
BoLR by the Boremon government. Mr. Zakeer Sakia, the President of the Boremon
United Mission was declared to have won the elections29.

II.

A neutral, impartial and balanced mechanism for the management of elections to

ensure transparency through the presence of party agents and observers, and to ensure
that complaints are determined promptly and effectively by an independent and
impartial authority, such as an electoral commission or the courts30 were conducted.
Everyone had the right to take part in the government of their country and had an
equal opportunity to become a candidate for election. The criteria for participation in
government was determined in accordance with national constitutions and laws and
was not be inconsistent with the State's international obligations. Thus as a universal,
equal and sacred suffrage31, the elections of 2015 were fair.

29

20 and 21 Official Compromise.

Declaration on Criteria for Free and Fair Elections, Paris, 26 March 1994.
31
DCFFE, Principles And Standard No. 3- Candidature, Party and Campaign Rights and Responsibilities.
30

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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
3. Whether the State of Soremon has acted in violation and has breached the spirit of
international law by deploying is Army.
It is most humbly put forth that State of Soremon has illegally deployed its Army in the
BoLR region by violating international law which is causing loss of lives and property of
the people of BoLR and therefore is under obligation to make full reparation for the
injury caused by that act.
3.1. The State of Soremon has illegally deployed its Army in the BoLR region by
violating international law which is causing loss of lives and property of the people
of BoLR.
I.

The International Court of Justice in Armed Activities on the Territory of the Congo32
found that the acts committed by the UPDF and officers and soldiers of the UPDF
were in clear violation of the obligations under the Hague Regulations of 190733,
Articles 25, 27 and 28, as well as Articles 43, 46 and 47 with regard to obligations of
an occupying Power. These obligations are binding on the Parties as customary
international law. Uganda also violated the following provisions of the international
humanitarian law and international human rights law instruments, to which both
Uganda and the DRC are parties:
i.

Fourth Geneva Convention34- Articles 27 and 32 as well as Article 53 with

regard to obligations of an occupying Power;

ii.

International Covenant on Civil and Political Rights35- Articles 6, paragraph 1,

and 7;

32

Democratic Republic of the Congo v. Uganda, ICJ Report 2005.

Regulations concerning the Laws and Customs of War on Land,Convention (IV),The Hague, 18 October
1907.
34
Geneva Convention relative to the Protection of Civilian Persons in Time of War, Geneva, 12 August 1949.
35
General Assembly, International Covenant on Civil and Political Rights, Resolution 2200A (XXI) of 16
December 1966 .
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
iii.

First Protocol Additional to the Geneva Conventions36- Articles 48, 51, 52, 57,
58 and 75, Paragraphs 1 and 2;

iv.
II.

African Charter on Human and Peoples' Rights37- Articles 4 and 5;

According to a well-established rule of a customary nature, as reflected in Article 3 of

the Fourth Hague Convention38 respecting the Laws and Customs of War on Land of
1907 as well as in Article 91 of Protocol I additional to the Geneva Conventions39 of
1949, a party to an armed conflict shall be responsible for all acts by persons forming
part of its armed forces. A troop of 600 Soremons well trained and deadly members
of a special Black Panther Battalion force entered BoLR and established a temporary
camp at the Hills in 201540. The State of Soremon did not even adhere to the ARSDB
in which Boremon agreed that it shall provide opportunity to the people of BoLR to
establish a democracy and in turn, the State of Soremon shall not indulge in any
deployment of its forces in BoLR or Boremonian region. But out of 600 members of
troop who were camping at BoLR hills and waiting for the Soremon Governments
orders to attack, only 400 members were ordered to return to Soremon and rest of the
200 were ordered to remain in BoLR41.
3.2. The State of Soremon has illegally annexed the area of BoLR is under obligation
to make full reparation for the injury caused by that act.

I.

The will of the people to freely determine their political status goes back many years
and was clear to all participants in the Rambouillet Conference42. One of the
conditions of the partition of Soremon imposed by Great Kritain was that the rulers of

36

Protocol Additional to the Geneva Conventions of 12 August, 1949.

African Charter on Human and Peoples' Rights (Banjul Charter), 1960.
38
The Hague Convention (IV) respecting the Laws and Customs of War on Land, 1907, Art. 3- A belligerent
party which violates the provisions of the said Regulations shall, if the case demands, be liable to pay
compensation.
39
Protocol Additional to the Geneva Convention, 1949, Article 91- Responsibility.
40
18 Official Compromise.
41
20 Official Compromise.
42
Rambouillet Conference on Kosovo, 1999.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
princely states would have the right to opt for either Soremon or Boremon or remain
independent Though King Tintumon signed the Instrument of Accession on 26
October 1947, Soremons Governor-General who was a Kritish National accepted the
accession, added the proviso that it would be submitted to a popular referendum since
"only the people, not the King Tintumon, could decide where the Lola-Ramola wanted
to live."43. The people of the 'Northern Areas' had revolted against the Maharaja of
Lola & Ramola on the eve of the lapse of Great Kritish paramountcy in June 1947 and
opted to join Boremon. Hence, these areas were no longer part of Maharaja's
kingdom44. The preamble45 of The Agreement for the Right of Self-Determination and
to establish a Democratic set up in BoLR, to which The State of Soremon and The
State of Boremon had agreed to realizes the notion of democracy. Thus by forcefully
imposing its jurisdiction on BoLR, the State of Soremon is has illegally annexed the
area of BoLR and is liable for reparation of the damages as the people are the region
are deprived of their right to self-determination.
II.

In Democratic Republic of the Congo v. Uganda46 the DRC asks the Court to adjudge
and declare that Uganda is under an obligation to make reparation to the DRC for all
injury caused by the violation by Uganda of its obligations under international law.
The Court observes that it is well established in general international law that a State
which bears responsibility for an internationally wrongful act is under an obligation to
make full reparation for the injury caused by that act. Upon examination of the case
file, given the character of the internationally wrongful acts for which Uganda has
been found responsible, the Court considers that those acts resulted in injury to the
DRC and to persons on its territory. Having satisfied itself that this injury was caused

43

6 Official Compromis.
9 Official Compromis.
45
ARSDB, 2015, Preamble- Realizing the significance of the notion of Democracy Realizing the
significance of the notion of Democracy
46
Supra N. 32.
44

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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
to the DRC by Uganda, the Court finds that Uganda has an obligation to make
reparation accordingly.
3.3. The State of Soremon broke the agreement of compensation towards the State of
Boremon and therefore owes a sum of Rs 55 crores (with interest).
Its not just the territorial disputes that refuse to fade away between the two states

I.

even after 67 years of the Partition. The division of assets and liabilities of the country
post-1947 remains incomplete to this day. The State of Soremon has yet to cough up
money equivalent to the present-day value of the assets the State of Boremon was
entitled to receive them post-Partition. As per the agreement between political
leaderships of the two sides.
II.

As a part of agreement of partition the State of Soremon owed a sum of Rs. 75 crores
to the Sate of Boremon. The Government of Soremon paid only the first installment
of Rs. 20 crores47. Boremon was a newly formed country. It needed to set up an entire
new system of government, constituencies and infrastructures. It was practically
impossible to start a country from a scratch with no financial support. The Sate of
Soremon broke the agreement and thus owes the Sate of Boremon the left over sum of
money and since more than 60 years have passed, they also should pay a nominal
interest on such amount.

4. Whether the State of Soremon is constantly depriving the people of BoLR region
their basic human rights?
It is most humbly put forth that Soremon has violated several human rights of the people
of Azad Lola & Ramola (ALR) and Gilly Buket. Adopted by the General Assembly on
December 10, 1948, the Universal Declaration of Human Rights48 (UDHR) is one of the

47
48

5 Official Compromis.
Universal Declaration of Human Rights, Palais de Chaillot, Paris, 1948.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
first major achievements of the United Nations. Human rights are much more than wellmeaning aspirations set to legal language. They are an essential part of United Nations
Charter, Universal Declaration of Human Rights and various Customary International
Law as well as International Humanitarian Law.
4.1. The State of Soremon has deprived the people of BoLR, especially in the ALR
region, their right to live quality life with peace.
I.

Frequent clashes of army troops have created havoc in the BoLR region and this has
been depriving the citizens of their right to live their lives with peace. On a similar
stance, claims of human rights abuses have been made against the Indian Armed
Forces and armed insurgents operating in Jammu and Kashmir49 which has gained
enough global criticism by various Human Rights organizations and activists. Human
life is considered very important under the constitutions of both India and Pakistan. In
Syed Mansoor Ali Shah and 4 Others v. Government of Punjab, Through Housing,
Physical and Environmental Pln.50 the court stated that the Constitution of Pakistan
under the Article 951 protects the life of person. The cases where life of citizen is
degraded, the quality of life is adversely affected and health hazards are created
affecting large number of people, amounts to deprivation of life, which referred article
prohibits. Life, in the 5th and 14th amendments of the U.S. Constitution52
corresponding to Article 2153 as observed by Field, J. in Munn v. Illinois54, means
something more than mere animal existence and the inhibition against the
deprivation of life extends to all those limits and faculties by which life is enjoyed

49

Asia Watch and Physicians for Human Rights (PHR), 1992.

Syed Mansoor Ali Shah and 4 Others v. Government of Punjab, Through Housing, Physical and
Environmental Pln., P L D (2007) Lahore 403.
51
Constitution of Pakistan, Article 9- Security of Person.
52
Constitution of the United States of America- Amendment XIV.
53
Constitution of India, Article 2- Right to Life and Personal Liberty
54
Munn v. Illinois, (1876) 94 US 113 at page 142.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
Supreme Court in Kharak Singh v. State of U.P.55 earmarked this very wide field for
the operation of Article 21. In Shehla Zia v. WAPDA56 the court stated that life is
more than mere animal existence and the inhibition against the deprivation of life
extends to all those limits and faculties by which life is enjoyed under Article 9 of the
constitution of Pakistan. Similar instance in Ethiopia has gained global disgrace57.
II.

The elimination of war, violence, and armed conflict has been a political and
humanitarian objective of the global community. Yet that objective remains
unachieved58. War-related health threats are a rising concern as the number of people
forced to flee their homes due to violent conflict has currently exceeded 51 million,
the highest levels since the Second World War. This includes both internally
displaced persons and refugees. Half of these are children59. The UN General
Assembly and the former UN Commission on Human Rights have emphasized on
necessity of peace in Declaration on the Preparation of Societies for Life in Peace60
and the Declaration on the Right of Peoples to Peace61. The WHO was incepted
with the spirit of promoting the health of all peoples and recognizes in the Preamble
of its Constitution that health and peace are interrelated notions, stating that, the
health of all peoples is fundamental to the attainment of peace and security and is
dependent upon the fullest co-operation of individuals and States.62 Violence has
devastating consequences on human health, affecting both combatants and civilians63.
While some of the morbidity and mortality relates to the direct effects of violence,
much of the civilian health impact is due to indirect consequences such as

55

Kharak Singh v. State of U.P., AIR (1963) SC 1295 para 17

Shehla Zia v.WAPDA, PLD (1994) SC
57
Ethiopia: Lethal Force Against Protesters Military Deployment, Terrorism Rhetoric Risk Escalating Violence.
58
Health And Human Rights Journal, The Right to Life in Peace: An Essential Condition for Realizing the
Right to Health, Number 1, Volume 17, June 4, 2015.
59
S. Schmemann, In Refugee Statistics, A Stark Tale Of Global Strife, The New York Times (June 20, 2014).
60
Declaration on the Preparation of Societies for Life in Peace, (A/RES/33/73), 15 December 1978.
61
Declaration on the Right of Peoples to Peace (A/RES/39/11), 12 November 1984.
62
World Health Organization, Constitution of the World Health Organization. Preamble, 3 (July 22, 1946)
63
Ibid.
56

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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016
displacement and limited access to food, clean water, and health care64. In fact, in the
agreement of ARSDB65 the Parties agreed to establish, by mutual efforts, peace in the
territory of BoLR, to decline to resort to any violent activities and to refrain from
intervention of any kind into the affairs of BoLR, which the State of Soremon failed
to do.

64

R. Waldman, Public Health In War: Pursuing The Impossible, Harvard International Review 27/1 (Spring
2005), pp. 60-63.
65
The Agreement for the Right of Self-Determination and to establish a Democratic set up in BoLR, Romia,
September 6, 2015, Article 1- Obligation to establish peace in the territory of BoLR and adherence to the
principle of Non-intervention.
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6th Justice P.N. Bhagwati International Moot Court Competition on Human Rights, 2016

PRAYER

Wherefore, in the light of the Facts Stated, Issues Raised, Argument Advanced and
Authorities Citied, it is most humbly prayed by the State of Boremon that the Honble Cour
Internationale De Justice may on the differences between the State of Boreman and the State
of Soreman on Right to Self-Determination and Establishment of Democracy in BoLR that:
1. The State of Soremon has interfered in the matters of the State of Boremon.
Therefore the State of Soremon should withdraw its troop from the BoLR region.
2. The actions of the State of Boremon are fully in conformity with the basic
principles of international law. Therefore the State of Soremon must refrain from
making such assertions.
3. The State of Soremon has acted in violation of human rights and has breached the
spirit of international law. There the State of Soremon must make reparation.
4. The State of Soremon must cough up money equivalent to the present-day value
of the assets the State of Boremon was entitled to receive post-partition
5. A State of Democracy, in the territory of BoLR must be instated by the ICJ either
by allowing BoLR to merge with Boremon or by establishing a full-fledged
democracy in the region.
And to pass any such other Order, Discretion and Judgment as this Honble Court may deem
fit in the interest of Justice, Equity and Good Conscience.
All of which is respectfully submitted
SD/- ______________________
Counsel for the State of Boremon
Place: The Hague, The Netherlands

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on behalf of the Respondent15