STATEMENT OF FACTS

1. The Republic of Winterfell which is the third largest country in terms of area
and is the second most densely populated country in the world with the fourth
fastest growing economy and has a quasi – federal structure with 25 states and
5 centrally administered units. One of its state called as Nihel which is rich in
natural resources is located in south west corner of Winterfell and is sharing its
western territorial border with Republic of Croatia. The border had remained
largely porous as the river had been largely used for trade and commerce
between the local people and the Nihel people had language and customs that
has made them culturally distinguishable. However, the Nihel people have
managed to preserve their distinct culture all throughout, and they voluntarily
decided to be part of Winterfell when it attained independence from the
colonial rule.

2. But before independence, the Balian armed forces repeatedly committed several
grave human rights violations on the Croatian people and then in 1990, the
Croatian rebel groups started violent protest against the Balian administration.
Thus, Balian armed forces retaliated with heavy use of force, compelling
hundreds of thousands of Croatian to flee across the border into Nihel in
Winterfell.

3. After few months, over a million of Croatian entered Nihel illegally through the
river Nihel, as that part of the border did not contain any fencing or barbed
wires. As some of the refugees were taken to the temporary camps, most of
them mingled with the local population and start making their own settlements
and some of them also migrated to other neighbouring states.
4. So the government verbally assured them that this is only a temporary situation
and Croatians will return to their homeland once the situation is resolved when
the local population expressed its concerns about the immigrants but In
November 1990, a violent large scale movement led by Croatian rebel group
erupted against the Balian administration which is popularly known as United
 against Oppression. However in January 1999, the Balian armed forces were
defeated and Croatia declared its independence.
5. Although Croatia became an independent nation but the migration in Nihel
continued and local administration faced difficulty in distinguishing Croatians
from the citizens of Winterfell as both had similar features and languages and
also obtained land and employment in Nihel and other neighbouring states on
the basis of some forged and fabricated documents showing them as citizens of
Winterfell. After dialogues between the two countries, the Republic of Croatia
stated that they are willing to take back those persons living in Winterfell, who
have valid proof to show that they are Croatian citizens.
6. Several local organisations in Nihel, led by the Nihel Youth United started
protesting against the government of Winterfell and Nihel in December 1998,
alleging that the governments are deliberately not taking effective measures to
detect and deport the immigrants as most of them had managed to get their
names on to the voters list.