Professional Documents
Culture Documents
IN THE MATTERS OF
PROSECUTOR VS. MUSTAFA ALIAS 4TH FIR-RA
AND
PROSECUTOR VS. RHAEGAR TARGAREYAN
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TABLE OF CONTENTS
INDEX OF AUTHORITIES .......................................................................................................................................... 3
STATEMENT OF JURISDICTION ............................................................................................................................ 6
CHARGES FRAMED ...................................................................................................................................................... 7
QUESTIONS PRESENTED........................................................................................................................................... 8
STATEMENT OF FACTS.............................................................................................................................................. 9
SUMMARY OF PLEADINGS................................................................................................................................... 12
PLEADINGS .................................................................................................................................................................... 13
1. THIS HONOURABLE COURT HAS THE JURISDICTION TO TRY THE CASE OF
ACCUSED NO.1, GENERAL MUSTAFA. .......................................................................................................... 13
1.1.
1.2.
The Territory of White Land is a part of the State of Black Land. ............................................... 13
1.2.1.
1.2.2.
The evidence against the Accused credibly proves the conduct beyond reasonable doubt.. 16
2.1.1.
Firos faith The World Under His Light Intent of the Crime .......................................... 16
2.1.2.
2.1.3.
2.1.4.
2.2.
The elements of the Crimes against Humanity enlisted under the Rome Statute is satisfied.
18
2.2.1.
Knowledge and Intent of the Conduct The foremost element is fulfilled: ..................... 18
2.2.2.
2.2.3.
2.2.4.
3.1.1.
The Tear gas shells fired was an arbitrary act as the procession was peaceful ............ 21
3.1.2.
Rhaegar Targareyan was responsible for the genocide of more than 100 people of the
FIROS religious community. .............................................................................................................................. 21
3.2.
The elements of Genocide enlisted under the Rome Statute is satisfied. .................................... 25
3.2.1.
The elements of the Crimes against Humanity enlisted under the Rome Statute is
satisfied. 26
4. RHAEGAR TARGAREYAN IS CRIMINALLY LIABLE UNDER ARTICLE 7 OF THE
ROME STATUTE FOR CRIMES AGAINST HUMANITY. ..................................................................... 28
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4.1. Rhaegar Targareyan has breached the fourth Geneva Convention of 1949 and Protocol II,
to which Black Land is a signatory....................................................................................................................... 28
4.2.
4.3. Rhaegar Targareyan has breached the UN Convention against Torture and Other Cruel,
Inhuman or Degrading Treatment or Punishment 1984, to which Black Land is a signatory .......... 30
PRAYER ............................................................................................................................................................................ 31
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INDEX OF AUTHORITIES
I.
CASES:
Tobar Doctrine
II.
BOOKS REFERRED:
Kanade, Jai and Kanade Vishal, Introduction to Public International Law, Lexis Nexis
Publications
Oppenheim L., Oppenheims International Law, Vol.1 (9th Ed. 1996, ed. Robert
Jennings & Arthur Watts)
Stephen, J., 1872, The Indian Evidence Act, with an Introduction on the Principles of
Judicial Evidence, Calcutta: Thacker, Spink & Co.
III.
DICTIONARIES:
Corpus JurisSecundum, Vol. 77, 2005, West Thompson Publishing, New York.
Sweet and Maxwell, Whartons Law Lexicon, 14th Edition (2004), West Groups,
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IV.
CONVENTIONS:
Protocol II of the Additional protocols to the Geneva Convention, 12th August 1949
V.
VI.
E-SOURCES:
www.inc-int.org
www.ijmonitor.org
www.iccnow.org
www.un.org
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VII.
WEBLINKS:
https://www.icc-cpi.int/about/witnesses
http://www.un.org/en/universal-declaration-human-rights/
https://www.icc-cpi.int/darfur/albashir/Documents/AlBashirEng.pdf
http://www.icc-cpi.int/pages/record.aspx?uri=1918951
https://www.icc-cpi.int/about/witnesses
https://www.icc-cpi.int/drc/lubanga
https://www.icc-cpi.int/drc/katanga/Documents/KatangaEng.pdf
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STATEMENT OF JURISDICTION
The Honble Courts Pre-trial Chamber has jurisdiction to try the instant matter under Article
61(1) of the Rome Statute of International Criminal Court.
Article 61(1) - Confirmation of the charges before trial
Within a reasonable time after the person's surrender or voluntary appearance before the
Court, the Pre-Trial Chamber shall hold a hearing to confirm the charges on which the
Prosecutor intends to seek trial. The hearing shall be held in the presence of the Prosecutor
and the person charged, as well as his or her counsel.
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CHARGES FRAMED
1. That a charge has been framed against Accused No. 1, General Mustafa, for the
offence of Crimes against Humanity under Article 7(1)(a) of the Rome Statute;
2. That the first charge has been framed against Accused no. 2, Rhaegar Targareyan for
the offence of Genocide under Article 6(b) of the Rome Statute;
3. That the second charge has been framed Accused No. 2, Rhaegar Targareyan for the
offence of Crimes against Humanity under Article 7(1)(i) and Article 7(1) (g)-6 of
the Rome Statute.
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QUESTIONS PRESENTED
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STATEMENT OF FACTS
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PROTESTS:
A survey by the The Times of Black Land on the condition of the Firos community
revealed the poor education rate, discrimination and rejection of job opportunities for
them in the State. This report created further furor in the country. To oppose the
policies of the country, the Community under the leadership of the FIR-RA took out
a procession. Tear gas shells were fired by the Paramilitary to bring the people under
control and restore law and order. There were two bombs exploded in the procession
that released asphyxiating fumes, which resulted in the deaths of more than 100
people.
CHARGES AGAINST RHAEGAR TARGAREYAN:
An FIR was filed regarding the kidnapping of eight persons including three men, four
women and a boy between 13 and 14 years of age. They had been reported missing
since February 10, 2014. On February 17, two of the allegedly kidnapped persons
came back with scars and bruises and the brutally assaulted bodies of the three girls
were recovered from the outskirts of the Capital City. In an interview of the survivors
conducted by a senior Journalist, Lorres Tyrell, they indicated the involvement of the
Targareyan regime in the abduction.
UNREST OF THE FIROS COMMUNITY:
Post this incident, the community started organizing itself into groups. They
demanded a nation free of Targareyans and declaration of Firos as the national
religion of the country. The Nationwide membership of the Firos religion increased
to 49% within three months. The City of White Land had soon become an all Firos
city-state, becoming a haven for all kinds of Firos community. As per a report by the
Sons of Harpy, FIR RA became the de facto administrator of the city. People
flooded into White Land in lieu of an annual tax paid to the FIR-RA. However no
documentary proof could be produced. Children were holding banners stating
Article 21.
THE TEMPLE OF ASTOPORE:
A temple in Astopore belonging to the Old Gods Faith caught fire and the
Governmnet stepped in for rescue efforts. No dead bodies Recovered and the officers
P a g e | 12
saw some red clad men who were heavily armed. The temple edifice was completely
burnt.
CHARGES AGAINST GENERAL MUSTAFA:
The Incident of Astopore led to investigation by the Police and they came to the
conclusion that the fire was caused with the intent to instill terror among the people.
They apprehended a man trying to cross the international border illegally with an aim
to reach Blue Land. He was interrogated and indicated the involvement of FIR-RA in
the incident. The police had also found highly sophisticated arms and ammunitions in
the possession of that witness, which had distinct marks of a fire ring and the logo of
Mustafa Pvt. Ltd. It was a common belief amongst that the ownership and control of
the said company lies with the FIR-RA, who is named Mustafa.
Three days later, a local newspaper flashed reports about a pit of decomposed bodies
of men and women about five miles from Astopore, which were mutilated and had
burn marks. Forensics suggested the same time of all deaths.
TERRITORY OF WHITE LAND:
The King of Black Land promulgated an ordinance declaring White Land an
Unstable Territory and defence forces took positions around White Land. The US
representative to the UN released a statement wherein White Land was denied
recognition by the States of the UN Security Council and other member States of the
UN.
In furtherance of the above issues, the matter has been brought before this Honble
Court.
P a g e | 13
SUMMARY OF PLEADINGS
P a g e | 14
PLEADINGS
1. THIS HONOURABLE COURT HAS THE JURISDICTION TO TRY THE CASE
OF ACCUSED NO.1, GENERAL MUSTAFA.
The challenge to the jurisdiction of this Honourable Court will not hold, for the following
reasons; a) Black Land is signatory to the Rome Statute; b) The Territory of White land is
a part of the State of Black Land.
1.1. Black Land is signatory to the Rome Statute.
The State of Black Land became a member of the United Nations on 1970. 1 In 1999,
It became a signatory to the Rome Statute. 2 The Statute has various jurisdictions
under which the ICC can admit the matters. Article 11 and 12 of the Rome Statute
establish the jurisdiction of this Honourable Court to the parties of the Convention.3
1.2. The Territory of White Land is a part of the State of Black Land.
The State is commonly defined as a community which consists of a territory and a
population subject to organized political authority and such a state is characterized
by sovereignty.4 Contrary to the claims of the Territory of White Land, it is not to be
construed as a separate state. It is a part of the State of Black Land.
1.2.1. Criterion of Statehood is not fulfilled.
The State as a person of International Law should possess the following
qualifications:
A permanent population
A defined Territory
Government
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While the territory of White Land, like any other city of a State, may claim the
first two of the constituents, it does not have the capacity to enter into relations
with the other States. Also, there is no documentary proof of the
Governments collection of taxes has no documentary proof whatsoever. The
Government is said to be in effective control of the State when the majority of
the population of such a State obeys the commands of such Government with
a reasonable expectancy of permanence. 6 So, the concept of effective
Control of the Government of the territory is disputed.
Capacity to enter into relations is a distinguishing element of Statehood by
many jurists.7 A State is independent, if it is supreme in its own right and it is
not subject to the superior authority of other State or States.8
White Land had during a press conference expressed willingness to be a part
of the International Community.9 However, when White Land is not sovereign
and independent, it cannot do so. As held in the Austro-German Customs
Union Case, it has been held, As long as these restrictions do not place the
State under the legal Authority of another State, the former remains, as
independent State however extensive and burdensome those obligations may
be.10
1.2.2. Recognition of White Land as a State.
The Statement of the US Representative to the UN and the refusal to recognize
the Sovereignty of the State of White Land by the State of Black land is a
clear reflection of the Tobar Doctrine. If the Government has come into ower
by extra-constitutional means, such Government ought not to be recognized.11
The report of the Sons of Harpy and Homeland Security and the letter sent by
General Mustafa for declaration of White Land as a free state is indicative of
the extra-constitutional means of appointment of Government.12
Kanade, Jai and Kanade Vishal, Introduction to Public International Law, Lexis Nexis Publications, P. 102
Id.
8
Supra 6
9
Page 11, Moot Proposition
10
PCIJ Ser. A/B, no.41 (1931)
11
Supra 6
12
Page 6 and 8, Moot Proposition
7
P a g e | 16
In Republic of Somalia vs. WoodHouse Drake Carey Suisse S.A.13, The court
held that the factors to be taken into account in deciding whether a
government exists as a government of a state are:
Hence, in the light of the above arguments, the challenge to the Jurisdiction to this
Honourable Court in the trial of accused No.1 is refutable.
13
(1993) Q.B.54
P a g e | 17
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fall under the Category of Overview witnesses and are therefore admissible.
2.1.2. Presence of Red-Clad Men is further evidence:
The proposal of an All-Firos City-state was accepted and soon thereafter, a
temple belonging to the Old Gods faith caught fire. The presence of red-clad
men at the borders of Astopore and veiled men near the temple when the
edifice was burnt also establishes a presumption of the Accuseds
involvement. 19
2.1.3. Witness X is a credible conclusive witness:
A man, who was caught by the local police trying to cross the border illegally,
confessed to delivering a package to the mentioned temple. He also confessed
that this was the will of GOD through the FIR-RA and that his child was held
captive by them, further establishes the direct involvement of General Mustafa
in the Crime.20
Witness Protection protocols are a legitimate practice and procedure under the
Rome Statute in the ICC. The Court has a number of protective measures that
can be granted to witnesses who appear before the Court and other persons at
risk on account of testimony given by a witness. The Court's protection system
is founded on best practices which are aimed at concealing a witness'
interaction with the Court from their community and from the general
public.21 Hence, the accuseds claim of his right to a fair trial being infringed
is baseless as revealing the identity of the witness is the Courts prerogative.
2.1.4. Pit of dead Bodies near Astopore:
To establish beyond reasonable doubt that the crimes against humanity of
murder has in reality been committed by General Mustafa, the incident where
a pit filled with decomposed bodies of men and women was found needs to be
analysed. The pit had been unearthed barely five 5 miles from the outskirts of
Astopore and the bodies were badly mutilated and showed burn marks while
the putrefaction suggested same time of all the deaths. Therefore it is clear that
18
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the first condition of killing of one or more person has been established.
22
2.2. The elements of the Crimes against Humanity enlisted under the Rome Statute is
satisfied.
Each human being inherently possesses certain natural rights, which is bestowed
upon him since his birth. No State or organisation has the power to deprive an
individual of these rights.23
Crime against humanity means any of the following acts when committed as part of
a widespread or systematic attack directed against any civilian population, with
knowledge of the attack.24
The three elements to constitute the offence under Article 7(1)(a) are the conduct of
murder, the conduct committed as part of a widespread or systematic attack directed
against a civilian population and the knowledge of the perpetrator regarding the
same.25
2.2.1. Knowledge and Intent of the Conduct The foremost element is fulfilled:
The introduction to Article 7 of the Rome Statute clarifies the requisite
participation in and knowledge of a widespread or systematic attack against a
civilian population. However, the last element should not be interpreted as
requiring proof that the perpetrator had knowledge of all characteristics of the
attack or the precise details of the plan or policy of the State or organization.
In the case of an emerging widespread or systematic attack against a civilian
population, the intent clause of the last element indicates that this mental
element is satisfied if the perpetrator intended to further such an attack. 26
22
Id. 18
http://www.un.org/en/universal-declaration-human-rights/, 6th October 11:30 pm
24
Article 7, The Rome Statute of the International Criminal Court. The Rome Statute is a treaty that reinforces
these rights across the world with an aim to protect these humane rights from being violated in any manner. This
treaty is based on conscious consensus of states which are mindful and recognise the need for the protection and
prevention of any infringement of these human rights. States are determined and empowered to act individually
and collectively in the preservation of these rights. In pursuance of the same, the Rome Statute has enumerated
what constitutes as a crime against Humanity.
25
Article 7(1)(a), Rome Statute of the International Criminal Court, Elements of Crimes, (United Nations Doc.
PCNICC/2000/1/Add.2 (2000)
26
Supra 22
23
P a g e | 20
29
27
Article 25 (3)(a) - Individual criminal responsibility - In accordance with this Statute, a person shall be
criminally responsible and liable for punishment for a crime within the jurisdiction of the Court if that person Commits such a crime, whether as an individual, jointly with another or through another person, regardless of
whether that other person is criminally responsible
28
Article 7 (1) (3) (Introduction to Crimes against Humanity) The acts need not constitute a military attack. It is
understood that policy to commit such attack requires that the State or organization actively promote or
encourage such an attack against a civilian population.
29
Article 16 of the Protocol II of the Additional protocols to the Geneva Convention, 12 th August 1949
30
White Land is not a separate state and is to be considered a part of Black Land. The state of Black land is
signatory to the Protocol II of the Additional Protocols of the Geneva Convention.
P a g e | 21
P a g e | 22
efforts, which in itself suggests that they had been ordered by their Military
Chief of staff Rhaegar to not allow or block any of the victims from escaping
the poisonous gas bomb fumes. This is indicative of an intent to systematically
eliminate a part of the religious community thereby amounting to genocide.
31
P a g e | 23
3.1.2.1.
Rhaegar Targareyan has violated the the Protocol for the Prohibition of
37
Later that night, 200 men and women were admitted to city hospitals with
complaints of severe respiratory distress. The doctor found that the
symptoms indicating usage of toxic chemicals, of these patients show
influx of fumes, which had severely damaged their respiratory tract. The
attendants pointed out the complaints were similar to those exposed to the
35
ICT-Y (1995)
International Committee of Red Cross Report (2005)
37
Article II, Clause 2, CONVENTION ON THE PROHIBITION OF THE DEVELOPMENT, PRODUCTION,
STOCKPILING AND USE OF CHEMICAL WEAPONS AND ON THEIR DESTRUCTION
36
P a g e | 24
the
founding
texts
of
the
P a g e | 25
of
the
Rome
Statute.
Article 69(2), in addition to the main principle of orality of evidence,
envisages the admission of evidence other than by the testimony of a
witness at trial. Article 69(3) also provides that parties may submit
relevant evidence.
Since neither the Statute nor any Rule bars or limits the admission of he
arsay evidence inthe situation presented here, the Chamber has the di
scretionary power to admit, in itssearch for the truth, the evidence pur
suant to the general admissibility principlesfound in Article 69(2), (3)
and (4) and Rule 63(2).
Therefore by virtue of hearsay evidence being admissible in International
jurisprudence and before the International Criminal Court, the following
evidences clearly showing Targareyans intent and involvement in the bomb
explosion leading to genocide of innocents must be taken into accord:
Two days after the event, the local radio channel Radio Nine aired a prerecorded tape, which said, The procession was silent and peaceful. There
were no signs of unnecessary revolt and aggression from the FIROS
community. The forces were able to take care of the situation, but our
commander did not want us to waste any time. 44
An independent survey conducted by a Group of Journalists known as the
Sons of Harpy, working for peace and harmony and aided by various
international organizations revealed that the bombs were highly
sophisticated. The explosives used were of the type, which were available
to the military forces of Black Land. They had been invented during the
time of Great War to secure territories from transgression by Targareyan
Army.
P a g e | 26
45
P a g e | 27
3.2.1. The elements of the Crimes against Humanity enlisted under the Rome
Statute is satisfied.
Each human being inherently possesses certain natural rights, which is bestowed
upon him since his birth. No State or organization has the power to deprive an
individual of these rights.46
Crime against humanity means any of the following acts when committed as
part of a widespread or systematic attack directed against any civilian
population, with knowledge of the attack.47
The elements to constitute the offence under Article 7(1)(i)(a), element
(6)48,(7)49 and (8)5051
The introduction to Article 7 of the Rome Statute clarifies the requisite
participation in and knowledge of a widespread or systematic attack against a
civilian population. However, the last element should not be interpreted as
requiring proof that the perpetrator had knowledge of all characteristics of the
attack or the precise details of the plan or policy of the State or organization. In
the case of an emerging widespread or systematic attack against a civilian
population, the intent clause of the last element indicates that this mental
element is satisfied if the perpetrator intended to further such an attack. 52
In the light of the above arguments and the evidence given, it is adduced that
Rhaegar Targareyan has not only harbored hatred against the entire Firos
community but has used his position of power in the State and enforced the
disappearance of almost 200 members of the Firos community. These include
the abduction and torture of the adult male victim, the sexual assault of the boy
46
P a g e | 28
and abducted women alongwith the intent to cause remove such person or
persons from the protection of the law for a prolonged period of time.
Further, the discovery of three bodies of women who were murdered is
indicative of the elements of crime under Article 7(1) (g-6) being fulfilledIn a leading case, before this Honourable Court , under Article 7 (1)(g-6), Anto
Furundija. the Tribunals judges also confirmed that rape may be used as a tool
of genocide. Rape may also amount to () an act of genocide, if the requisite
elements are met, and may be prosecuted accordingly. A landmark precedent
was set in 1998 when ICTYs sister tribunal the ICTR rendered a judgement in
Akayesu case in which it was concluded that rape constitutes genocide.53
From the above context, it is clear that first, the death of a group of men and
women was caused by General Mustafa, second, this attack was systematically
planned and executed by the red clad men against the civilian population of
Black land, particularly constituted against the believers of the Old Gods Faith
and thirdly, General Mustafa alias the 40th FIR-RA actively promoted and
encouraged such attacks by way of propagation of Article 21 fulfils the third
requirement under Article 7(1) (a) of the Rome Statute.
Similar Cases where Leaders have been convicted of various crimes against
humanity before this Honourable Court are Prosecutor vs. Germaine Katanga54,
Prosecutor vs. Ahmad Al-Mahdi 55 , Prosecutor vs. Dominic Ongwen 56 and
Prosecutor vs. Thomas Lubanga Dyilo57 and Prosecutor vs. Furundija.58
Hence, after the arguments presented and evidence adduced, it can be inferred that Rhaegar
Targareyan is criminally liable under Article 7(1)(i) and 7(g-6) of the Rome Statute for
Crimes against Humanity.
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GENEVA CONVENTION relative to the Protection of civilian Persons in time of war of 12 August 1949
Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims
of Non-International Armed Conflicts (Protocol II) Adopted on 8 June 1977 by the Diplomatic Conference on
the Reaffirmation and Development of International Humanitarian Law applicable in Armed Conflicts
61
Supra 59
62
Supra 60
63
Page 5, Moot Proposition
64
Page 155,Article 31, Geneva Convention (relative to the Protection of civilian persons in time of war) 1949
65
Id.
60
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One of the men abducted, who spoke about his ordeal publicly to a newspaper, was
repeatedly asked Where are the weapons? What is FIR-RA planning to do, next?66
His interrogation continued for two days. He was not allowed to sleep. They did not
believe him when he said he did not know anything, and starting beating him up. He
was made to see two men sexually assaulting a young boy.
They gave him a series of injections against his will and both the man and the boy
were given bare minimum food just to keep them alive.67
It can be seen that Targareyan has also blatantly used his power as Chief of staff of
the Armed Forces and head of Homeland security and violated Article 3268 of the
Convention which expressly states- The High Contracting Parties specifically agree
that each of them is prohibited from taking any measure of such a character as to
cause the physical suffering or extermination of protected persons in their hands.
This prohibition applies not only to murder, torture, corporal punishment, mutilation
and medical or scientific experiments not necessitated by the medical treatment of a
protected person, but also to any other measures of brutality whether applied by
civilian or military agents.
4.2. There is sufficient evidence to convict Rhaegar Targareyan of Crimes against
Humanity
These two victims become Crimes-based witnesses before the International
Criminal Court as they are those who have suffered harm and testify as witnesses
about what happened to them. The man categorically stated he heard the men, taking
names such as Boss, Targareyan etc. thereby clearly indicating Rhaegar
Targareyans involvement in the abduction.69
The man and the boy had scars and bruises all over their body which showed clear
signs of torture and inhumane treatment.
The man also stated that he witnessed girls shrieking for mercy and almost 200 other
members of his community, being subjected to detention and torture.
66
Supra 64
Id.
68
Page 155,Article 32, Geneva Convention (relative to the Protection of civilian persons in time of war) 1949
69
Witnesses, (https://www.icc-cpi.int/about/witnesses)
67
P a g e | 31
Additionally bodies of three girls were recovered from the outskirts of the Capital
City a week later after the abduction took place. They had been brutally assaulted.70
The discovery of these bodies in relation with the FIR that had been filed of eight
persons missing including four women and the testimonies of the key witnesses are
suggestive of Rhaegar Targareyans involvement in assaulting and murdering them in
course of the abduction.
4.3. Rhaegar Targareyan has breached the UN Convention against Torture and Other
Cruel, Inhuman or Degrading Treatment or Punishment 1984, to which Black Land
is a signatory
Article 5 of the Universal Declaration of Human Rights and Article 7 of the
International Covenant on Civil and Political Rights, both of which provide that no
one shall be subjected to torture or to cruel, inhuman or degrading treatment or
punishment, form the basis of the UN Convention against Torture and other cruel,
inhuman or degrading treatment or punishment, 1984.
The Convention also derives its principles from the Declaration on the Protection of
All Persons from Being Subjected to Torture and Other Cruel, Inhuman or Degrading
Treatment or Punishment, adopted by the General Assembly on 9 December 1975.
Black Land as a signatory, is bound to support, enforce and uphold this Convention.
However Rhaegar Targareyan, the Military chief of Black Land has blatantly violated
these principles by abducting, detaining, interrogating and committing various acts of
torture on innocent civilians belonging to the Firos community.
Hence, in light of all the arguments made above, Rhaegar Targareyan should be held
criminally liable under Article 7 of the Rome Statute for Crimes against humanity.
70
Supra 63
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PRAYER
In the light of Issues raised, arguments advanced and authorities cited, the Prosecution
humbly submits that this Honble Chamber may be pleased to:
1. Declare that Substantial evidence has been brought against both the
accused.
2. Allow the Trial and approve the evidence against Accused No.1
General Mustafa.
3. Allow the Trial and approve the evidence against Accused No.2
Rhaegar Targareyan.
4. Grant reparation to the victims affected by the incidents leading to
these cases.
And
Any other order as it deems fit in the interest of equity, justice and good
conscience.
For This Act of Kindness, the Prosecution Shall Duty Bound Forever Pray.
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