You are on page 1of 1

A very good morning Your Excellencies, this is Agent 2 on behalf of the applicants.

If your excellencies permit, the agent would now like to proceed to the next issue. Much obliged.

The next issue which the agent most respectfully submits is that The islands which are now located within the territorial waters of Nimroth are the territory of Nimroth, and Winroth is not entitled under international law to exercise its sovereignty over the islands. In this regard, as it has been established that the whole of the Elin River falls within the territory of Nimroth, it is contended that with regard to current position of the River, both the newly emerged island X and Tokano Island are within the territorial waters of Nimroth and hence come under the jurisdiction of Nimroth.
With regard to the agreement entered into by the Raja of Gundustan and Colonial Arcadia, it is clearly stated that the boundary of Nimroth extends to the eastern bank of the Elin River and thus the new territory gained by the Republic of Nimroth should be cessed by Winroth. This includes Tokano Island and Island X. Nimroth, with regard to the provisions of the agreement, should be granted unquestionable jurisdiction over both Tokano island and Island X and the continental shelf. The continental shelf and the said islands shall remain under the jurisdiction of Nimroth due to the following factors. Firstly, the continental shelf has always been a part of Nimroth and no other state can lay claim upon it. Secondly, Tokano island is a sovereign territory of Winroth which should be ceded to Nimroth in accordance with the agreement entered into by Colonial Arcadia and King of Gundustan and Island X, which predominantly lies over the contested continental shelf and only the northern part of the island lies within the ambit of the territorial waters of Winroth, Nimroth has already sent its navy to the island and has established it as its territory through conquest. In Kasikili/Sedudu Island (Botswana/Namibia). 1999 ICJ 1045 (December 13), the Court awarded an island in the Chobe River to Botswana based on an 1890 treaty between the United Kingdom and Germany. The treaty, which had English and German versions, described the boundary of their colonies and protectorates along the river. It rejected various claims by Namibia related to subsequent practice under the treaty, occupancy and use of the island, and prescription (adverse possession).

You might also like