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6th Amity International Moot Court Competition, 2016

The State of Black Land is one of the most prominent states in the Middle East. The state has
witnessed a turbulent past with birth and collapse of many faiths, cultures and dynasties. One
fourth of its area is covered by desert, which is bisected by the river LIFE-SEA. It runs a course
from the North-East regions of the country to South West regions of the country. (Annexure)
Black Land has had a constitutional monarchy since its birth from the Great War of 1970. The
war led to the disintegration of the State of Westeros into Black Land and Blue Land.
Though there have been many lieges in Westeros, it was the Royal Family of Targareyans which
encouraged an insurgency leading to the eventual break-up of Westeros. The control of Black
Land, ultimately, fell into the hands of Targareyans.
Black Land is a petroleum-based economy. It has a large export market of petroleum products
across the world. Black Land was admitted as a member of the United Nations in 1970.
Black Land population has been divided into two communities on the basis of religion- The Old
Gods Faith and the Firos faith. There is a common belief among the people of Blackland that Old
Gods faith is intrinsic to Black Land having been born in temples of the Old Gods. A section of
the historians believe that the temples of the Old Gods date back to 320 B.C. A number of its
religious places, in and around Astopore, have been declared as heritage sites by UNESCO.
The other religion called Firos has found prominence recently with the Purification Movement
which started two hundred years ago in the eastern world by a reformist leader who went by the
name-1st FIR-RA. Firos has since, spread across the world and has been accepted by a majority
of people in the Westeros.
Firos is headed by a group of Red Priests. They traditionally wear red stones and red capes with
their sigil that consists of a ring of fire around a red eye, which is considered to be the eye of the
God of Light. Red Priests periodically elect their FIR-RA, who is worshipped as living Gods.
The election follows an elaborate ceremony. Every Sunday the local priests of Firos conduct
meetings, called Conclaves. Elaborate discourses are directed at the followers about their
religious practices. One of the basic traits of the Firos religion is their disdain towards idol
worshippers and temple goers.
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6th Amity International Moot Court Competition, 2016

In 1996, the 30th FIR-RA and his brethren Red Priests published a document which was meant to
be a guide for the better understanding of religion and its ultimate goal. As answered in an
interview to a local newspaper by the 30th FIR-RA, the effort was to create a better world. The
document was called World under His Light
A few notable excerpts from the document:

Article 1: All fellow brothers of the God of Light shall be guided by the Angels dressed
in red to align them to the Heaven of Fire where He would drink all their sorrows in a
gold cup.

Article 15: God of Light spreads His wings to take the whole world under His shelter.

Article 16: All fellow brothers emanate from that God whose light illuminates the
darkness in the hearts of non-believers. They are to believe in Him and only Him alone.

Article 20: Fellow believers unite for the night is dark and full of fears.

Article 21: .. And to cleanse this unholy world marred by several sins, let the blood
spill of those who have become corrupt and feed this good earth with that red wine and
quench her thirst.

This text became one of the most widely read documents. It was distributed to the public free of
cost. The Red Priests were inundated with invites for interviews and conferences to speak on the
holy document. Owing to this, the 30th FIR-RA witnessed a mass propagation of Firos religion
throughout the continent. Simultaneously, this document was taken note of by the United
Nations. International pressure and a likelihood of outbreak of a civil war forced the State to ban
it for its provocative language. In 1999, Black Land became a signatory to the Rome Statute
owing to growing external pressure especially from members of the United Nations Security
However, internally the economic status of the followers of Firos continued to be dismal. The
decennial consensus had repeatedly highlighted an upsurge in the rate of unemployment. The
resultant poverty amongst the majority of people following Firos religion contributed to rise in
sectarian violence.

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6th Amity International Moot Court Competition, 2016

The critiques of the government in a World Conference of Economics held in Capital City of
Black Land took note of the King adopting a policy of Minimal State Intervention in public

The State was advised to proclaim that its role would be merely confined to

administration of the country and collection of taxes. The government opposed such a move by
criticizing them as Rants of Unsatisfied Sceptics.
All this while, the Targareyans had maintained a neutral attitude towards the prevalent religious
polarity in the country. In one of the interviews given to a prominent News Channel World News
on July 11, 2013, Rhaegar Targareyan, Chief of Staff of the Armed Forces and Head, Homeland
Security stated:
The Government has been doing a lot for its citizens. It has opened schools and colleges. It has
collaborated with various world economies to create job opportunities by opening gates for
foreign direct investment and establishment of MNCs. However, the problem is with our people.
On one hand, they want better job opportunities and poverty alleviation and on the other they do
not encourage their kids to join Government schools and work hard. Instead, they sent their
children to Conclave Spiritual Schools. These are poorly managed institutions and beyond any
scope for betterment. Look at other religions which are older than Firos. They have all managed
to harmonize modernization and culture.
The statement did not go well with the FIROS community. It led to a series of protests against
the royal family and the government. The capital city faced severe unrest, and violent revolts.
The 40th FIR-RA and the College of Red Priests immediately withdrew their support to the
government in power. They demanded a public apology from Rhaegar Targareyan and his
immediate resignation from his office.
The followers of other religions including those of Old Gods faith condemned the statement for
its insensitivity. One of the National Dailies Times of Black Land conducted the first religioncentric survey in January 2014 titled Position of Firos in Black Land. The findings were as
1. 45% of the followers of Firos were non-matriculates.

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6th Amity International Moot Court Competition, 2016

2. 90% of the followers of the FIROS had faced discrimination from other persons on the
basis of it being a foreign religion. They have been called at many times as invaders and
3. 63% of the followers of Firos had admitted to have faced rejection from job interviews
and otherwise and been called as fanatics.
This report created a further uproar in the country. The FIR-RA and their supporters demanded
ousting of the Targareyans for their inaction, inadequate control over the affairs of the country
and the subsequent dismal state of the Firos community. The College of Red Priests organized a
mass procession on February 10, 2014 in the Capital City where all the participants were seen
dressed in red, with black wristbands. They took out a procession holding candles. Nearly ten
thousand people belonging to the Firos Community and their supporters joined the procession.
The sheer magnitude of protestors showed their determined attitude to resist authority. The
situation appeared explosive. Rhaegar Targareyan swiftly called two Divisions of Paramilitary
Forces to restore law and order.

He wanted normalcy to be restored. The soldiers had

appropriated all neighboring buildings. One division surrounded the procession. The slogan
shouting continued. A few pelted stones at the troops. Tear gas shells were fired. Some men
inside the procession were seen pointing their air guns at the roof-tops. After about fifteen
minutes, two bombs exploded inside the procession releasing asphyxiating fumes and gases. It
caused stampede and immediately scattered the procession. The soldiers did not allow rescue
efforts. The procession was subdued finally within eight hours.
Later that night, 200 men and women were admitted to city hospitals with complaints of severe
respiratory distress. The doctor found that the symptoms 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 poisonous gas.
By morning, a news report flashed that out of 200 persons had been admitted to various hospitals
across the city seeking relief against exposure to certain gases. More than 100 did not respond to
the treatment and died.
Two days after the event, the local radio channel Radio Nine aired a pre-recorded tape, which
said, The procession was silent and peaceful. There were no signs of unnecessary revolt and
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6th Amity International Moot Court Competition, 2016

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.
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.
The large number of casualties further alienated the Firos community. They demanded
immediate resignation of Rhaegar Targareyan from his office.
A First Information Report was filed on February 14, 2014 regarding the kidnapping/ abduction
of eight persons. These numbers included three men, four women, and a boy between 13 and14
years of age. They had been reported to be missing since February 10, 2014. On February 17,
2014 two of the allegedly kidnapped persons came back bearing scars and bruises all over their
bodies. Bodies of three girls were recovered from the outskirts of the CAPITAL CITY. They
had been brutally assaulted. One of the senior journalists Lorres Tyrell interviewed the man and
the boy from the group of people that had been abducted. Following interview was published in
the magazine Black Land Today:
Q. Where were you since the day of the procession?
Man- I was picked up by a black van soon after the procession was trounced by the forces of
the government.

We were amongst the bystanders who had come to witness the event. We had come to
know about the procession from the Sunday Conclave held in our neighborhood. I was
bundled into a black SUV by four men with masked faces.

Q. Where did they take you and what happened there?

Man- We were taken to a dungeon which was poorly lit. I saw this boy blindfolded, tied to a
chair right next to me. They blindfolded me as well. I was repeatedly asked Where are
the weapons? What is FIR-RA planning to do, next? I told them I didnt know anything.
The interrogation continued for two days. I was not allowed to sleep. They did not
believe me. Then the beating started. Finally, when they opened my blindfolds, I was
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6th Amity International Moot Court Competition, 2016

made to see two men sexually assaulting this boy. They gave me a series of injections,
which made me dizzy. I was hallucinating. Everything seemed to be blurred. We were
both given bare minimum food just to keep us alive. Later we were thrown out on a busy
street. We managed our way to our homes. I heard them, taking names such as Boss,
Targareyan etc.
Boy - (Silent..started crying)

Were there any other people held captive?

Man- There were many, almost 200 facing same atrocities. We heard the shrieks of girls
begging for mercy. A few of the captives managed to escape during the hours of
darkness. Only God could save us. May fire burn these sinful souls!
This interview raised many eyebrows. Many local leaders within the FIR-RA community started
organizing themselves into groups. They demanded a nation free of Targareyans and declaration
of FIROS as the national religion of the country. Within three months the nation-wide
membership of the FIROS community increased to 49% of the total population of Black Land.
Many people of other communities began harboring apprehension towards Firos community,
which had allegedly tabled discussions on World under His Light.
On routine patrolling, the local police constable found pamphlets with ARTICLE 21 written in
bold lying near one of the places, where the Sunday Conclave was routinely held.
The seat of the FIR-RA, in the City of White Land, had soon become an all-Firos city-state.
There were reports by various independent NGOs that police was not allowed inside the
territories of the city. An investigation committee was set up by the Homeland Security
Department to probe the internal situation. Though its final report was not published by the
government the interim drafts were made public by the Sons of Harpy. The initial report and the
subsequent findings of this group revealed the followinga. The city has become a haven for all kinds of people belonging to Firos community.
b. The FIR-RA has become the De-Facto administrator of the city.
c. The locals have confessed to interviewers that due to alienation of Firos community by
the government people were flooding to this state within a state in lieu of an annual tax
to be paid to FIR-RA. However, no documentary proof could be produced.

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6th Amity International Moot Court Competition, 2016

d. One of the pictures taken by a journalist of Sunday Conclaves has revealed what seems to
be arms training with lethal weapons. Even the children were holding banners stating
Article 21.
These revelations started many news hour debates. Citizens belonging to other religions
expressed serious concerns about the internal security of the country, especially the followers of
the Old Gods faith. The administration and governance seemed to have collapsed.
The local news channel owned and operated by the college of Red Priests broadcasted an all
Firos meeting conducted at the residence palace of the 40th FIR-RA where a proposal to make an
all Firos state was unanimously accepted.
On September 12, 2014 a temple belonging to the Old Gods faith caught fire late in the evening.
The fire spread across to the crops of farmers residing in the village of Astopore situated adjacent
to the temple. The government of Black Land immediately pressed in rescue efforts. Initially, at
the borders of Astopore, some of the officers witnessed resistance from some red clad men, who
were all heavily armed. Later they managed to enter Astopore and reach the Temple. The edifice
had been totally burnt. No dead bodies were recovered. The Police Commissioner in a press
conference that followed indicated the presence of veiled persons with fire torches in hand at the
vehicle parking space near the Temple.
Press Conference
Date: September 14, 2014
Statement by the Investigating Officer
Though we are still on our way to locate those masked men, it

would be difficult to explain the actual cause of the fire. However,

one thing can be said with affirmation that this was not an accident.
It was rather a concerted effort to instill terror in the minds of the
people at large and ignite a civil war.

On September 15, 2014, the Border Protection Force of Black Land apprehended a man trying to
cross the international border illegally with an aim to reach Blue Land. He was subsequently
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6th Amity International Moot Court Competition, 2016

handed over to the local police of Black Land which was functioning under the Homeland
Security Department. On interrogation he stated:
I am a small fish in the sea filled with sharks and whales. I am a poor man. Sir, I dont know
much. I was asked at one of the Sunday meetings to carry a package to that temple. I didnt know
its contents. On inquiry, I was told that it was Gods will through FIR-RA. I had to do, for they
had kept my child captive and threatened to kill him.
The police had also found highly sophisticated arms and ammunitions in the possession of that
witness (hereinafter referred as Witness X). The weapons had two distinct marks one of a fire
ring, what seemed to be a red eye, and the logo of Mustafa Pvt. Ltd.
In a local news channel Sansani Todays hourly debate, the origin and mission of a business
house called Mustafa Pvt. Ltd. Came to surface. However, there were no clear evidence at the
debate and therefore, the ownership and role of Mustafa Pvt. Ltd. remained a mystery. It was
common belief amongst the people of Old Gods community, that this company had been
engaged in supplying arms and ammunitions to the Firos community and was managed and
operated by MUSTAFA alias 40th FIR-RA.
Three days later, a local newspaper flashed reports about a pit filled with decomposed bodies of
men and women. It had been unearthed barely five 5 miles from the outskirts of Astopore. The
bodies were badly mutilated and showed burn marks. Forensic experts examined the dead bodies
but nothing could be said, affirmatively, about their identity. However, the putrefaction
suggested same time of all the deaths.
Pressure mounted upon the government to probe the incident of September 12, 2014 and
determine responsibility. Many countries across the world imposed trade restrictions due to poor
Human Rights and volatile conditions within the State. The inefficiency of the internal
machinery of the State was a matter of concern for the international community.
The Royal Office headed by the King, in consultation with Homeland Security Department,
released a letter sent to the Government of Black Land by General Mustafa alias 40th Fir-Ra
declaring White Land as a free state. The letter stated that they had renounced all ties and
relationships with Black Land and this new state of White Land shall be a safe home all the
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6th Amity International Moot Court Competition, 2016

believers in Firos religion. The letter also stated that the college of red priests had conducted a
referendum on September 10, 2014 in the city of White Land where the people in majority have
given their assent to the formation of this new state. The State of Black Land publicly declined to
recognize the sovereignty of the city of White Land.
The US Representative to the United Nations replied at a press conference held in New York:
We have received the news of formation of a new state of White Land by the Firos community.
This attempt is a serious concern for the US and other members of the United Nations. I have
received formal consents of three other permanent members of the UN Security Council. We
unequivocally do not recognize the sovereignty of White Land.
The king of Black Land promulgated an ordinance declaring White Land to be an Unstable
Territory. Military and paramilitary forces of Black Land were placed on alert and took up
positions around White Land.
According to the Whiteland Independence Act, 2014 enacted on September 11, 2014 the
territorial limits of the new state extended to the villages around the city of White Land including
Mereen, Astopore, and Dorne.
The Republic of White land has notified ICC that it does not recognize the jurisdiction of the
ICC as it is not a signatory to the Rome Statute even if FIR-RA has agreed to be present in the
court voluntarily. However, the State of Black Land has specifically denied and rejected any
territorial claims made by White Land as a sovereign state. Further, FIR-RA has contended the
validity of inclusion of WITNESS Xs testimony as he has not disclosed his identity, and the
Office of the Prosecutor wishes to proceed with such a witness. FIR-RA contends that nondisclosure of identities of such witnesses is inconsistent with his right to fair and impartial trial.
The Pre-trial Chamber issued an order pursuant to Rule 58 (2) of the Rules of Procedure and
evidence to take up the matter of challenge to its jurisdiction and the request to exclude evidence
to the confirmation proceeding. The Pre-trial chamber is now holding a hearing to confirm the
charges on which the prosecutor wishes to seek a trial.
The hearing is to be held in the presence of the prosecutor, Mustafa and Rhaegar Targareyan, as
well as their counsels.
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Following two cases have been brought by the Prosecutor against the accused persons named
below:1. Prosecutor vs. Mustafa alias 40th FIR-RA
2. Prosecutor vs. Rhaegar Targareyan

1. Charges against General Mustafa:

Mustafa is charged with the following:

Crimes Against Humanity against civilians in Temple of Astopore during the evening
of September 12, 2014, under Article 7 (1)(a) of the Rome Statute;

2. Charges against Rhaegar Targareyan:

Rhaegar Targareyan is charged with the following:

The crime of Genocide against civilians in the Capital City during the morning of
February 10, 2014, under Article 6 (b) of the Rome Statute;

Crimes against Humanity against civilians in the Capital City under Article 7 (1) (i)
and Article 7 (1) (g)-6 of the Rome Statute.

The Court has decided to hear the issues simultaneously. The Counsels are required to submit
written memorials and present oral arguments separately for the two cases as per the charges
framed by the Prosecutor against each accused. The Counsels are further required to present
oral arguments separately and simultaneously during the trial process.
Other issues of relevance to the case:
1. The matter is to be presented before the Pre-Trial chamber of the International Criminal Court in
furtherance of Section V of Rules of Procedure and Evidence.
2. Both prosecution and defense counsel are to make arguments with respect to the applicability of
the charges provided in the "Elements of Crimes"(United Nations Doc. PCNICC/2000/1/Add.2
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3. Proceedings: The hearing takes place pursuant to Article 61 of the ICC Statute (confirmation of
charges). At this stage, the Prosecutor has to support each charge with sufficient evidence to
establish substantial grounds to believe that the person committed the crime charged. The
Accused may object to the charges and/or challenge the evidence presented by the
4. Jurisdiction and admissibility: Counsels may; if relevant, address any issue regarding the
admissibility of the case.
5. Counsels are expected to bring to the Court's attention relevant jurisprudence and other
documents. It may include judgments and opinions delivered by International Courts, various
International Criminal Tribunals and tribunals wherever relevant.
6. The State of Black Land is a party to the four Geneva Conventions of 12 August 1949, the 1977
Protocols Additional (Protocol I and II) to the Geneva Conventions of 1949, the 1998 Rome
Statute of the International Criminal Court, the 1984 UN Convention against Torture and other
Cruel, Inhuman or Degrading Treatment or Punishment (CAT).
7. Whiteland had during a press conference expressed willingness to be a part of the international
community. However, no treaties/ conventions have been signed by White Land yet, to that

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