Questions Relating to

Transboundary Harm and War Crimes

(Federal State of Abravanel/Republic of Rathanka)

RECORD

2016 University of Cebu College of Law Moot Court Competition

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NOTIFICATION DATED 10 FEBRUARY 2016, ADDRESSED TO THE MINISTER OF
FOREIGN AFFAIRS OF THE FEDERAL STATE OF ABRAVANEL AND THE MINISTER
OF FOREIGN AFFAIRS OF THE REPUBLIC OF RATHANKA

The Hague, 10 February 2016.

On behalf of the Special International Tribunal, and in accordance with Article 26 of the Rules
of Court, I have the honor to acknowledge receipt of the joint notification dated 05 February
2016. I have the further honor to inform you that the case of Questions Relating to
Transboundary Harm and War Crimes has been entered as 2016 General List No. 924. The
written proceedings shall consist of memorials to be submitted to the Court by 11 March 2016.
Oral proceedings are scheduled for 19–20 March 2016.

/s/
Registrar Special International Tribunal

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JOINT NOTIFICATION, DATED 19 JUNE 2015, ADDRESSED TO THE REGISTRAR OF
THE COURT

The Hague, 05 February 2016.

On behalf of the Federal State of Abravanel and the Republic of Rathanka, and in accordance
with Article 40, paragraph 1, of the Statute of the Special International Tribunal, we have the
honor to transmit to you an original copy of the English texts of the Special Agreement Between
the Federal State of Abravanel and the Republic of Rathanka for Submission to the Special
International Tribunal of Differences Between Them Concerning Questions Relating to
Transboundary Harm and War Crimes, signed at Prague, Czech Republic, on 10 February 2016.

For the Federal State of Abravanel: For the Republic of Rathanka:

/s/ /s/
Ariana Venti Miles Cyprus
Minister of Foreign Affairs Minister of Foreign Affairs

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SPECIAL AGREEMENT BETWEEN THE FEDERAL STATE OF ABRAVANEL AND THE
REPUBLIC OF RATHANKA FOR SUBMISSION TO THE SPECIAL INTERNATIONAL
TRIBUNAL OF DIFFERENCES BETWEEN THEM CONCERNING QUESTIONS
RELATING TO TRANSBOUNDARY HARM AND WAR CRIMES

The Federal State of Abravanel and the Republic of Rathanka,

Recalling that the Federal State of Abravanel and the Republic of Rathanka are Members of the
United Nations and that the Charter of the United Nations calls on Members to settle
international disputes by peaceful means,

Observing that the operation of Meightois Mining and Co. resulted in great loss and material
damage,

Recognizing that differences have arisen concerning the responsibility of such event,

Noting that the Federal States of Abravanel and the Republic of Rathanka have been unable to
settle their differences through negotiation,

Desiring that theSpecial International Tribunal , hereinafter referred to as “the Court,” consider
these differences,

Desiring further to define the issues to be submitted to the Court,

Have agreed as follows:

Article I

The Federal State of Abravanel and the Republic of Rathanka, hereinafter referred to as “the
Parties,” shall submit the questions contained in Annex A of this Special Agreement to the Court
pursuant to Article 40, paragraph 1, of the Statute of the International Court of Justice.

Article II

1. The Parties shall request the Court to decide this matter on the basis of the rules and principles
of general international law, as well as any applicable treaties.

2. The Parties also shall request the Court to decide this matter based on the Agreed Statement of
Facts, attached as Annex A-E, which is an integral part of this Agreement.

3. The Parties also shall request the Court to determine the legal consequences, including the
rights and obligations of the Parties, arising from any judgment on the questions presented in this
matter.

Article III

1. The proceedings shall consist of written pleadings and oral arguments.

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2. The written pleadings shall consist of memorials to be submitted simultaneously to the Court
by the Parties.

3. No changes may be made to any written pleading once it has been submitted to Moot Court
Board.

Article IV

1. The Parties shall accept the Judgment of the Court as final and binding upon them and shall
execute it in its entirety and in good faith.

2. Immediately after the transmission of the Judgment, the Parties shall enter into negotiations on
the modalities for its execution.

3. If the Parties are unable to reach agreement within six months, either Party may request the
Court to render an additional Judgment to determine the modalities for executing its Judgment.

Article V

This Special Agreement shall enter into force upon signature.

DONE at Prague, Czech Republic, on 10 February 2016, in two copies, each in the English
language, and each being equally authentic.

For the Federal State of Abravanel: For the Republic of Rathanka:

/s/ /s/
Ariana Venti Miles Cyprus
Minister of Foreign Affairs Minister of Foreign Affairs

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 Annex A

1. The Federal States of Abravanel (“Abravanel”) and the Republic of Rathanka (“Rathanka”)
are both landlocked states located in the continent of Karacan. Abravanel is located on the
eastern side of the continent while Rathanka is on the western side. Separating the two states is
the Appala Mountain Range and Mishka Forest (“Appala”)1.

2. Abravanel is a developing country with a population of approximately 10,000,000 people.

The country has a land area of 90,000 sq. km. It has a GDP of USD 37 billion. Its economy is
largely based on agriculture and ecotourism.

3. Rathanka is a developed state with a population of 8,000,000 people and a land area of 75,000
sq.km. It has a GDP of USD 700 billion. Its economy is largely based on industrial
manufacturing and energy production. It has one of the largest reserves of natural gas and coal.
The exact tonnage of the reserves is kept secret by the government but it is known that there are
over 1,200 mines and refineries in Rathanka. It is the world’s 9th largest exporter of natural gas
and the 5th largest exporter of coal.

4. Abravanel and Rathanka are Members of the United Nations and are Parties to the Statute of
the International Court of Justice.

5. Abravanel and Rathanka are Parties to the Vienna Convention on the Law of Treaties.

6. Abravanel and Rathanka are Parties to the International Covenant on Civil and Political Rights
and its protocols.

7. Abravanel and Rathanka are Parties to the International Covenant on Economic Social and
Cultural Rights and its protocols.

8. Abravanel and Rathanka are Parties to the Geneva Conventions and its protocols.

9. Abravanel and Rathanka are Parties to the Rome Statute of the International Criminal Court.

10. Abravanel and Rathanka are Parties to the Convention on Biological Diversity (CBD).

11. High-level representatives from Abravanel and Rathanka attended and fully participated in
the 1972 United Nations Conference on the Human Environment at Stockholm; the 1992 United
Nations Conference on Environment and Development at Rio de Janeiro; the 2002 World
Summit on Sustainable Development at Johannesburg; and the 2012 Rio+20 Conference at Rio
de Janeiro.

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The Appala Mountain Range and the Mishka Forest are geographically part of the Greater Appala Area. For
purposes of this Record, the term “Appala” shall refer to the Greater Appala Area encompassing both the mountain
range proper and the Mishka Forest.

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12. Abravanel and Rathanka are Parties to the 1949 Territorial Agreement between Rathanka and
Abravanel (TARA). The TARA is a boundary treaty between the two states covering the Greater
Appala Area.

13. The Greater Appala Area runs roughly 560 km from north to south. It is 15 km wide at its
narrowest points and 100 km wide at its widest points. It has a total area of roughly 13,000 sq.
km. The mountain range is covered by dense forests. In the northern reaches of the mountain
range lies the large Mishka Forest with an area of 4,000 sq. km. The mountains and forests are
home to nearly 300 species of birds and several endemic species of brown bear, chamois and
deer. Hundreds of rivers run from the eastern heights of the Appala mountains down to the
western forests.

14. The border between Abravanel and Rathanka runs unevenly across the length of the forest
and mountain range. Roughly two-thirds of the area of the mountain range and four-fifths of the
area of the Mishka Forest lie within the sovereign territory of Rathanka.

15. Appala is home to a minority group called the Abreans. The southern mountains of Appala
are home to roughly 200,000 Abreans in hundreds of small communities scattered throughout the
many plateaus and valleys of the mountain range. The Abreans maintain a largely rural lifestyle
and sustain themselves through farming and husbandry. They are culturally and ethnically
related to Rathankans but they do not acknowledge the political authority of either state or the
borders set by TARA.

16. In 1970 the Rathankan Parliament granted Abreans political autonomy over areas of the
Appala that belong to Rathanka. Since then, the Rathankan government has maintained peaceful
relations with the Abreans. In recent years, the Rathankan government has even embarked on
several ambitious projects to help the Abreans govern themselves.

17. Among these projects is a security aid program which authorizes the Rathanka Security
Forces (RSF) to provide Abreans with military aid. Since 2005, the Rathankan military has
provided Abreans with weapons and training. Training exercises include both combat (e.g.
guerilla warfare) and non-combat techniques (e.g. search and rescue, police work). The Abrean
trainees, while not formally part of the RSF, are nominally under the command of the Rathankan
military representative in the Greater Appala Area. Currently, this position is held by Gen.
Baldon Estenzicof the 5th Infantry Division of the RSF.

18. In contrast, the Abravanel government has consistently pressed its claim to the areas of
Appala that belong to it. It has always insisted that the Abreans’ occupation of Appala is a
violation of its sovereign rights. From 1960 to 2000, radical Abreans known as the Appala
Liberation Front fought a bloody guerilla war against the government of Abravanel. Hostilities
ended in 2000 with the signing of an armistice between Abrean war leaders and the President of
Abravanel.

19. In 2004, private researchers discovered large deposits of recoverable coal reserves in the
Abravanel side of Appala. It was estimated that as much 13,000,000,000 tonnes of Lignite and
9,000,000 tonnes of Anthracite may be recovered. However, due to a lack of financial and

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technical capability, the government of Abravanel was not immediately able to act on the
discovery.

20. In 2010, Ali Ramadi was chosen as the new Prime Minister of Abravanel. As part of his
plans to strengthen the economy of Abravanel, he embarked on a project to explore and recover
the large coal reserves in Appala. Lacking the financial and technical capability to carry out the
exploration and recovery on its own, the government of Abravanel initiated negotiations with the
government of Rathanka regarding the possibility of joint exploration and recovery of the coal
reserves in the Abravanel side of Appala. After a series of talks between PM Ramadi and
President Ralf Vidic of Rathanka, the two states agreed to a set of amendments to the TARA
called the Agreement Governing Coal Exploration and Recovery in the Greater Appala Area or
the “Coal Protocol”. Immediately after the conclusion of the Coal Protocol, the Parliament of
Abravanel and the Senate of Rathanka accepted the amendments and ratified the Coal Protocol.

21. Pursuant to the terms of the Coal Protocol, Rathanka agreed to provide Abravanel with
technological and administrative help to carry out the exploration and recovery operations of the
coal reserves in Appala. Help provided by Rathanka included transferring technology and
equipment, providing administrative, technical and scientific experts, and conducting training for
Abravanel personnel. Rathanka also provided technology and facilities to ensure environmental
and health safety. The States also embarked on a joint project to construct a segregated waste
disposal system for the mining refinery. Abravanel, for its part, agreed to grant Rathanka a thirty
percent share of any resources recovered from the mining operation.

22. In 2013, Abravanel established a coal mine and processing refinery on its side of the border
in the northern area of the Appala Mountain Range a few kilometers east of the Mishka Forest.
The coal mine and refinery is registered under the company name Meightois Mining Co. (MMC)
a company incorporated under Abravanel law and owned and operated by the Abravanel
government.

23. Following the establishment of the coal mine and refinery, forest rangers working for the
Abravanel government erected wire fences delineating the areas of the Mishka Forest and
Appala mountains which belong to Abravanel. Guards were posted to ensure that no MMC
worker mistakenly crosses into Rathankan territory.

24. Following the establishment of the mine and refinery, the Abravanel Green Movement
(AGM), a non-government organization of lawyers, scientists and academics, protested against
the MMC. The AGM is a well-respected organization that is recognized as a partner by the
United Nations Environment Programme (UNEP). In December 2014, roughly a year after the
coal extraction commenced, AGM), produced “The Coal Me Maybe” - a documentary on the
operations of MMC and its harmful effects on the environment and the health of residents in
nearby communities. The documentary, which was broadcasted in both Abravanel and
Rathanka, showed that the MMC employed mountain top mining (MTM) to expose and recover
coal seams in the Appala Mountains.

25. The documentary showed that the mining operations led to massive deforestation and soil
erosion. Several hectares of the Mishka Forest and of other smaller forests within the mountain

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range were destroyed. Moreover, seepage of chemicals and waste disposal system of the mine
and refinery contaminated nearby rivers. It was found that the sewage system could not handle
the capacity of the mine and refinery. The documentary also showed that blasting operations in
the mine and industrial processing in the refinery caused severe air pollution.

26. As a result of the environmental damage, thousands of birds and animals living in the
Greater Appala Area were killed. The deaths were attributed to the loss of habitat and feeding
and breeding grounds following the deforestation. The contamination of the rivers also resulted
in large fish kills.

27. Moreover, data showed that residents of the Greater Appala Area were exposed to health
risks from the activities of the mine and refinery. Data presented by in the documentary showed
that from 2013 to 2015 there was a twenty percent increase of respiratory diseases and lung
cancer among the people living near border. Rivers were contaminated with mercury. The
contamination of the rivers also deprived local communities of clean drinking water resulting in
high incidents of diarrhea and cholera, including some incidents of minamata disease.

28. Following the broadcast of the documentary, the UNEP published a report affirming the
findings of AGM. The report also showed that the deforestation affected a 300 sq. km. area on
the eastern side of Mishka Forest within Abravanel territory.

29. The Government of Abravanel held a press conference in response to the AGM documentary
and the UNEP report. In a statement, PM Ramadi said:

“The Meightois mining operation is a breakthrough project for the economic

resurgence of Abravanel. A few years ago, Abravanel was on the brink of
bankruptcy. Now, thanks to the mining operation, Abravanel has experienced
unprecedented economic growth. Without the project, we cannot fund the welfare
programs that our people desperately need. Without the project, thousands of jobs
in Abravanel’s mining and transport industry will be lost. Without the energy
provided by the coal from the mine, the country’s industries will stall. Without the
project the people of Abravanel will suffer.

We understand the concern of Abravanel Green Movement and the United

Nations Environment Programme and we thank them for their diligence. My
government promises to immediately enact the necessary laws and initiatives to
ensure that any further health and environmental concerns are mitigated.
Moreover, our government has already sought the help of the United States for the
purpose of gaining access to technology for reforestation and environmental
clean-up.”

30. Unhappy with the response of the Abravanel government, civil society organizations in
Rathanka led by the People’s Movement of Rathanka (PMOR) staged a protest to call for the
closure of the mine and refinery. They claimed that operation of the mine and refinery violated

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the Appala Mountain Range Treaty and called for the Government of Rathanka to act on the
matter.

31. In response to the reaction of the Rathankans, the Government of Rathanka sent a diplomatic
note on 12 August 2015 to the Government of Abravanel:

The Embassy of the Republic of Rathanka presents its compliments to the Government of
the Federal States of Abravanel and wishes to convey its concerns regarding operations
of the Meightois Mining Co. The Government of Rathanka is most grateful for the
continued relations with the Federal States of Abravanel in sharing their resources for
coal mining.

However, there is a growing concern among our citizens regarding the coal mining
operations, which included the cutting of trees in the Mishka Forest. The mining
operations threatens the health and livelihood of Rathankan citizens living near the
border.

We would like to request that MMC immediately halt its MTM operations as this is a
violation of the Sections 8 (a) and 8 (b) of the TARA, Principle 2 of the Rio Declaration
and Principle 21 of the Stockholm Declaration prohibiting the conduct of activities that
cause transboundary harm.

Moreover, the acts of MMC also violate Article 8 of the CBD, Principle 3 and Principle 4
of the Rio Declaration.

Finally, the acts of MMC violated the Rathankan citizens’ right to the highest attainable
standard of health, the right to a safe and healthy environment and the right to sustainable
development.

We request that your government take immediate action on this matter.

Should the Government of the Federal States of Abravanel fail to act on this matter, the
Government of the Republic of Rathanka shall be forced to exercise its right under
Article 20 of the TARA.

/s/
Leni Del Novo
Ambassador

32. Two days later, on August 14, 2015 the Government of Abravanel replied and forwarded
another diplomatic note:

The Embassy of the Federal State of Abravanel presents its compliments to the
Government of the Republic of Rathanka and has the honor to acknowledge receipt of the
diplomatic note dated 12 August 2015.

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 The Government of Abravanel shares the concern expressed by the Government of
Rathanka regarding the mining operations of Meightois Mining Co. We respectfully deny
the request for the cessation of MMC’s operations. MMC is essential to our economic
survival as a developing state.

Moreover, we note with respect that the Government of Rathanka has no right to
intervene in activities conducted by Abravanel within its own territory. The mining
operations and the cutting of the trees were conducted in and only affected areas of
Appala which are within the sovereign territory of Abravanel.

In any event, Abravanel did not violate its obligations under the TARA as it took diligent
efforts in ensuring that no transboundary harm would result from its mining operations.

We also respectfully remind the Government of Rathanka that it is a co-venturer and

beneficiary of the mining operations of MMC. As such, assuming without conceding that
there was transboundary harm caused by MMC, Rathanka shares in the responsibility for
such harm.

Finally, we deny the allegations that acts of MMC violated the Rathankan citizens’ right
to the highest attainable standard of health, the right to a safe and healthy environment
and the right to sustainable development.

Thank you for understanding.

/s/
Jeriko Manosca
Ambassador

33. Meanwhile, the first confirmed deaths of Rathankans were recorded in a farming village
close to the Mishka Forest. The cause of death was found to be complications arising from
cholera contracted from the contaminated rivers.

34. On August 20, 2015, an angry President Vidic appeared in a televised speech before the
international media. He declared, that pursuant to the rights granted under Article 20 of the
TARA, Rathanka is suspending all support it erstwhile provided to Abravanel under the Coal
Protocol and is withdrawing from further participation in the MMC.

35. He also issued an ultimatum against the Government of Abravanel – “Your mining
operations are killing Rathankans. Either you close down the MMC or we’ll close it down for
you!”

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36. Following the televised speech, on August 24, 2015 the Government of Rathanka sent a
diplomatic note to the Government of Abravanel informing the latter of its intent to exercise the
right under Article 20 of the TARA.

The Embassy of the Republic of Rathanka presents its compliments to the Government of
the Federal States of Abravanel and wishes to convey its decision to exercise the right
granted under Article 20 of the TARA.

Effective immediately, the Government of Rathanka is suspending its performance of its

obligations under the Coal Protocol. It is also withdrawing fully from any further
participation in the MMC.

/s/
Leni Del Novo
Ambassador

37. On August 26, 2015, the Government of Abravanel replied and forwarded another diplomatic
note:

The Embassy of the Federal State of Abravanel presents its compliments to the
Government of the Republic of Rathanka and has the honor to acknowledge receipt of the
diplomatic note dated 24 August 2015.

The Government of Abravanel questions the validity of Rathanka’s exercise of the right
under Article 20 of the TARA. Rathanka did not comply with requisites for the validity
of adopting a countermeasure.

/s/
Jeriko Manosca
Ambassador

38. Meanwhile, the Abreans in Appala who were most affected by the destruction caused by the
mining operation began arming themselves. Claiming that Abravanel’s mining operations pose a
grave threat to their homes and lives, a group of young Abreans who were trained under the RSF
security aid program hatched a plan to deal with the MMC.

39. On September 11, 2015, three hundred Abrean fighters descended on MMC and begin firing
unguided artillery at the MMC mine and refinery. One of the artillery shells hit a fuel storage
tank causing a massive explosion that razed the refinery. Fifty-five Abravan workers died and at
least two hundred were injured.

40. The Abravan military responded by sending several battalions of troops to Appala. The
Abravans Armed forces and Abreans clashed in villages close to the eastern edges of the Mishka
forest. The fighting lasted for two days but the Abravans eventually drove the Abreans back into

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the mountains. The battle left 44 Abravan soldiers dead with at least 30 injured. There were 25
confirmed civilian deaths and scores more injured. Thousands were forced to flee their homes.

41. PM Ramadi, speaking before the Abravanel Parliament condemned the attacks as “the work
of mad dogs with insane masters”. He vowed to take all necessary measures to ensure that the
sovereignty and national security of Abravanel will be preserved and that the perpetrators of the
MMC attack be held liable.

42. On 2 January 2016, the Government of Abravanel sent a diplomatic note to the Government
of Rathanka:

The Federal States of Abravanel is outraged by the malicious and despicable attack
against our sovereignty and national security carried out by Abreans trained by the RSF.
The Abrean trainees carried out an unprovoked attack against a civilian facility using
indiscriminate means and methods resulting in the deaths of Fifty-five Abravans and
causing injuries to two hundred others. These acts were grave violations of the Geneva
Convention and constitute war crimes for which they must be held liable.

We also demand that Rathanka immediately surrender to us Gen. Baldon Estenzic to face
trial for his crimes against our government and people. Estenzic was the de facto superior
exercising effective control over the Abrean trainees and is liable for the war crimes
committed by the latter.

/s/
Jeriko Manosca
Ambassador

43. On January 5, 2016, the Government of Rathanka forwarded its reply to the Government of
Abravanel:

The Republic of Rathanka is deeply saddened by the tragic incidents in September 2015.
We commiserate with the people of the Federal States of Abravanel.

Unfortunately, we are unable to comply with the demands made in the diplomatic note
dated January 2, 2016.

First, we do not believe that the Abrean trainees committed a war crime. The Geneva
Convention does not apply as the circumstances surrounding the incidents of last
September did not amount to an armed conflict within the meaning of treaty. The Abrean
trainees committed the common crimes of murder and destruction of property for which
they shall be tried under the domestic law of Rathanka.

Second, we also respectfully deny the liability imputed against Gen. Baldon Estenzic for
the acts of the Abrean trainees. He was not their military superior and did not exercise

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 effective control over them. Moreover, military officers of the RSF cannot be held liable
for the private acts of a group that did not act with the authority of our government.

/s/
Leni Del Novo
Ambassador

44. Under pressure from other states and international organizations, both Abravanel and
Rathanka agreed that the allegations of violations of international law be referred to a Special
International Tribunal (SIT). On February 6, 2013, the Security Council adopted Resolution
1280 which established the SIT.

45. Under the Statute of the SIT, the Tribunal has jurisdiction over cases cognizable before the
ICJ and ICC, and adopts by reference the relevant treaties thereof. The Tribunal is authorized to
rule on the issues submitted on the basis of treaty, customary international law, and generally
accepted principles of law.

46. The Federal State of Abravanel respectfully requests the Court to adjudge and declare that:

a) The Federal States of Abravanel did not violate its obligations under the TARA, the
Rio Declaration or the Stockholm Declaration to prevent transboundary harm.
Abravanel also did not violate the Rathankan citizens’ right to the highest attainable
standard of health, the right to a safe and healthy environment and the right to
sustainable development; and

b) Gen. Baldon Estenzic was criminally responsible as a military superior for the attack
carried out by the Abrean trainees. He committed a grave violation of the Geneva
Convention amounting to a war crime.

47. The Republic of Rathanka opposes the claims in the paragraph 24 and respectfully requests
the Court to declare that:

a) The Federal States of Abravanel violated the TARA, the Rio Declaration or the
Stockholm Declaration for failing to prevent transboundary harm. Abravanel also
violated the Rathankan citizens’ right to the highest attainable standard of health, the
right to a safe and healthy environment and the right to sustainable development; and

b) Gen. Baldon Estenzic was not criminally responsible as a military superior for the
attack carried out by the Abrean trainees. He did not commit a grave violation of the
Geneva Convention amounting to a war crime.

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 ANNEX B

Territorial Agreement between Rathanka and Abravanel (TARA)

Section 1. The Greater Appala Area and the natural resources therefrom are considered as shared
and protected resources belonging to both Abravanel and Rathanka.

xxx

Section 8. Prevention of Transboundary Harm from hazardous or potentially hazardous

activities.

The present section and subsections apply to activities not prohibited by international law
which involve a risk of causing significant transboundary harm through their physical
consequences.

a.) The State of origin shall take all appropriate measures to prevent significant
transboundary harm or at any event to minimize risk thereof.
b.) The State of origin shall take necessary legislative, administrative or other action to
ensure the prevention of significant transboundary harm or at any event to minimize
the risk thereof.

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Article 20. Adoption of countermeasures.

A state may, as a countermeasure to an internationally wrongful act, suspend its

compliance with the terms of this treaty or any of its Protocols provided the following requisites
concur:

a.) The act constituting countermeasure must be taken in response to a previous

intentional wrongful act of the other party and must be directed against that party.
b.) The injured state must have already called upon the party committing the wrongful
act to discontinue its wrongful conduct or to make reparation, but the request was
refused.
c.) The countermeasure must be commensurate with the injury suffered, taking into
account the rights in question.
d.) The adopted countermeasure must be reversible and its purpose is to induce the
offending party to comply with its obligations under international law.

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 ANNEX C

Map of the Continent of Karacan

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