survival of all children including Ms.

Shunzette’s 5-year old daughter

As to the first point,

 Liberty of movement is an indispensable condition for the free development of a person. It is the very factor
which helped man to survive and evolve himself into what he is today
 The freedom of movement assumes great importance during emergencies
 The International Covenant on Civil and Political Rights (ICCPR), a key international human rights treaty
which provides a range of protections for civil and political rights obligates countries that have ratified the
treaty to protect and preserve basic human rights, among which is the FREEDOM OF MOVEMENT
 As stated in Article 12 of ICCPR, the freedom of movement includes the freedom to leave any country,
including his own.
 Also, General comment No. 27 on freedom of movement states that everyone (including aliens) lawfully
within the territory of a State enjoys the right to move freely and to choose his or her place of residence and
any restrictions on his or her rights guaranteed by the ICCPR, as well as any treatment different from that
accorded to nationals, have to be justified.
 although this right has been recognized as a fundamental one, Article 12 paragraph 3 of the same
convention states that this right may still be curtailed but only for exceptional circumstances such as to
protect national security, public order, or public health as well as the rights and freedoms of others. (To be
permissible, the conditions upon which the restriction is founded should be specific and consistent with the
principles of necessity and proportionality , meaning the restrictive measures must be appropriate to achieve
their protective function; they must be the least intrusive instrument amongst those which might achieve the
desired result and they must be proportionate to the interest to be protected.)
 In this case, your excellency, there is no evidence which would show that the Government of Recho placed
a restriction on the movement of all its nationals and sojourners, nor is there proof that it specifically limited
Ms. Shunzette’s right by a lawful order from its local court for being a threat to public safety or health. Thus,
it follows that Ms. Shunzette’s act of departing from Recho was never restricted, such that she can validly
exercise her right to movement for whatever purpose it may serve and for any period of time, more so if
such was justifiable, say to protect her from any possible impairment in her health security from which she
was exposed considering the proximity of Recho from Megoose.
 in the respondent's submitted memorial, on page 2 of its pleadings, Recho claimed that it did not stop Ms.
Shunzette from leaving the country, however, when Recho subsequently upheld the validity of her dismissal,
it appears that it is in effect punishing her for exercising such right to which she is rightfully entitled
 Based on the foregoing, we submit that Recho’s act of dismissing Ms. Shunzette, an Armis national from
work, as a punishment for her absence, defeated the principle of freedom to leave any country which is a
right guaranteed under the ICCPR.