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STATEMENT OF FACTS

BACKGROUND

The Kingdom of Rahad is a constitutional monarchy which occupies the western third
of the Nomad Coast, characterized by arid and semi-arid lands. It has a population of 3.5 million
according to the February 2014 census and has a GDP at US$ 11 billion as of January 2016. It
borders the newly-industrializing rich state of Atania which covers the eastern two-thirds of the
Nomad Coast and with a GDP of US$80 billion. Rahad and Atan share a common link of cultural
heritage as both countries descend from Clan Atan. The Clan Atan was the original inhabitants of
the Kin Canyon Complex located between the present border of Rahad and Atania. One of the
17 original clans of Atan, the Clan Kin, remained in the complex which they venerated as the
birthplace of their ancestors. The whole Atan Clan shares a common legend of Teppa, the Nomad
Coast hero. The 17 unified Atan Clan recognized the heroic deeds of Teppa but the Clan Kin
honored her the most by establishing the Sisters of the Sun, an order of women who wears
miniature replicas of Ruby Sipar the ceremonial shield raised by Teppa symbolizing peace and
unity of the clans.

As a result of low record of rainfall, the entire Nomad Coast experienced sustained
drought condition even until the present day. Rahad was forced to import water from the other
countries at great expense. The continuing phenomenon of drought will likely to result in a long
term shortage of water for the entire Nomad Coast. Hence, imbued with the dilemma of the serious
water crisis, Queen Teresa of the Kingdom of Rahad ordered the implementation of a
comprehensive program to extract water.

GREAT INATA AQUIFER

The Great Inata Aquifer (the Aquifer) is the largest underground source of fresh water in
the Nomad Coast which the people have relied upon its discharge for many generations. As a
result of the drought condition of the entire Nomad Coast from the year 1983 to 1988s, the
Kingdom of Rahad imported water from the other countries at great expense. The Rahadi Ministry
of Water then with ta team of hydrologist from Canada mapped out the sources of Rahads
subterranean fresh water. The detailed map showed that the Aquifer covered more than 274,000
square kilometers within the Nomad Coast, of which 65% was located in Rahad and only 35% in
Atania. On 1993, the Rahadi Minister of Water and Agriculture on his speech, promised to
preserve and protect the shared fresh water resources notwithstanding the fact that the Rahad
also experienced drought conditions.

In 1999, drought conditions returned to the region. This prompted the follow-up report in
2000, from a team of hydrologists that concluded that the Aquifer contained approximately 35
cubic kilometers of extractable fresh water. Due to the increasingly serious water crisis of Rahad
because of the continuing and present drought conditions and with the desire to improve access
of water for the people, Queen Teresa ordered to begin the implementation of a comprehensive
program to extract water from the Great Inata Aquifer. The Inata Logistic and Scientific
Association as directed by Queen Teresa reported the output of their study on the feasibility and
long term effects of directly tapping the Aquifer to meet Rahads domestic need for water. The
report was subjected to a blind independent peer review before being accepted for publication in
the International Journal of Hyrdology.

SAVALI PIPELINE OPERATIONS

As ordered by Queen Teresa, the Bureau of the Interior enacted a program that would
extract water in the Great Inata Aquifer which 65% of which is located in Rahad. The Bureau
prepared a plan for a network of 30 pump wells located in Rahads northern territories to be
connected by a subterranean pipeline system (the Savali Pipeline), which as to the
establishment and until present time provided a reliable source of water to Rahads farmlands.
Rahad nonetheless limited the drilling for the extraction of water to areas more than 15 kilometers
outside the Complexs buffer zone. Such act is in compliance to the World Heritage Committees
recommendation that Rahad will ensure that the Savali pipeline project develops and implements
targets for improving the conservation of the Kin Canyon Complex which is located near the
Aquifer.

KIN CANYON COMPLEX

The Kin Canyon Complex (the Complex) is a group of 3 canyons cut by long-extinct
rivers straddling the border between Atania and Rahad. The canyons that constitute the complex
are located at the deepest part of a greater wadi system. The complex was described by National
Geographic 2015 as a continuing source of some of the most fascinating insights into early
human civilizations. In 1990, Rahad and Atania jointly proposed that the Kin Canyon Complex
be included on UNESCOs World Heritage list as a cultural and natural heritage. Such proposal
was granted and the Kin Canyon Complex was declared as a mixed heritage site on 1994.

SISTERS OF THE SUN AND THE RUBY SIPAR

According to a legend, Teppa, a warrior of the Clan Kin, persuaded all the 17 Atan Clans to
defend the Kin Canyons against the Ifans raiders. Under Teppas leadership, the united clans
defeated the invaders. Upon the victory, Teppa raised the Ruby Sipar - a ceremonial shield laden
with jewels - and declared peace. In recognition of Teppas heroic deeds, the Kin established the
Sisters of the Sun, an order of women dedicated to protect and preserve the culture and traditions
of the Kin. The Sisters even at present, serve as mediators in local disputes. The members wear
miniature replicas of the Ruby Sipar as a symbol of loyalty to the order of the Sisters. At present,
the Kin migrated to the east of the complex in Atania but they remain to be politically isolated by
the rest of the Atanian society.

The original Ruby Sipar was uncovered by an archeologist in the excavation project in the
Complex, after confirming its authenticity it was then placed on a public display in the Complex
Cultural Center.

Due to the rapid increase of the rates of food deprivation and related illness brought about
by the drought conditions resulting to serious water crises and the denial of access to water to
the Kin, the Sisters of the Sun lead peaceful demonstrations and protest. One of the elders of the
Sisters, Sister Carla Dugo, engaged in a hunger strike to protest and made a statement that the
Atanian governments deprivation of access to water resulted in depriving them also of the ability
to continue traditional farming that had been their primary source of sustenance. As the crises of
severe deprivation continues, over 5000 Sisters of the Sun who proudly wear Ruby Sipar to
prosper peace and unity congregated in the plaza together with the hundreds of Kin joining Sister
Dugo in her peaceful protest.

With the large crowd of people refusing to disperse until their cries will be heard, President
Vhen of Atania issued an order in banning, destroying, and seizing the Ruby Sipar and declaring
it as a symbol of sedition. The original Ruby Sipar was removed from the Complex Cultural Center
as the Atanian government avers that it can no longer accept its for public display. The
demonstrators were arrested and up to this moment remain in prison.

Carla Dugo fled to Rahad and during intake interviews voluntarily gave the original Ruby
Sipar to the border agents. She told them that she took the original Ruby Sipar from the storage
to ensure its protection, and because it belongs to the Kin wherever they are. The Ruby Sipar
was then delivered to the Rahadi Ministry of Culture which displayed it publicly and treated it with
respect and veneration.

KIN MIGRANTS

The Clan Kin crossed into Rahad for two reasons: the fear of arrest and also because of
starvation as the result of the continued severe deprivation and denial to access of water. The
Rahadi Immigration Department agents reported that as many as 100,000 Kin had crossed into
Rahad. This led to the Rahadi Parliament enacting the Kin Humanitarian Assistance Act (KHAA)
which provided that Kin identified as Sisters of the Sun and their family members were deemed
to be fleeing persecution and were therefore entitled to all of the rights and privileges of refugees
under Rahadi immigration law. All other Kin entering Rahad were permitted to apply for refugee
status. KHAA ordered the Government to establish three temporary camps to where Kin entering
the country were to be housed until other arrangements can be made or until they deem it safe to
return to their homeland. As of the moment the Kin who crossed the border reached to
approximately 800,000.

The International Rescue Committee, which monitored the conditions at the camps,
reported that the number of Kin in Rahad exceeded the capacity of the facilities created to receive
them and the national infrastructure was being stretched beyond the breaking point. The Rahadi
National Times in its 13 October 2013 publication reported that some of Kin migrants who had
qualified the refugee status is engaging in petty crimes. The article also quoted numerous Rahadi
citizens who expressed concern about the social and economic costs of attempting to integrate
the Kin into their new society.

On December 2015, the Parliament adopted the Border Protection Act (BPA) which
requested that the Queen among others, that Rahad will obtain a financial compensation from the
government of Atania. The compensation will cover the massive costs that Rahad had to bear as
a result of Rahads humanitarian response to the influx of the Kin. Queen Teresa then instructed
her Government to engage in discussions with Atania insisting among others the sharing of
humanitarian burdens. However, upon receiving the memorandum that demanded compensation,
the spokesman for the Atanian Foreign Ministry, in a press conference, dismissed the
memorandum averring that it is unworthy of reply.

SUBMISSION BEFORE THE INTERNATIONAL COURT OF JUSTICE (I.C.J)

The Kingdom of Rahad (Respondent) and the Federation of the Clans of Atan (Applicant)
refer this dispute to the court by a Special Agreement.