Request for relief

The Netherlands requests the Tribunal to adjudge and declare that:

The Russian Federation:

a) In boarding, investigating, inspecting, arresting, detaining and seizing

the Arctic Sunrise without the prior consent of the Kingdom of The
Netherlands, breached its obligations to the Kingdom of the Netherlands,
in its own right, in the exercise of its right to protect a ship flying its flag,
and as a non injured State with a legal interest, in regard to the freedom of
navigation as provided by Articles 58.1 and 87.1(a) UNCLOS, and under
customary international law.

b) In boarding, investigating, inspecting, arresting, detaining and seizing

the Arctic Sunrise without the prior consent of the Kingdom of The
Netherlands,breached its obligations to the Kingdom of the Netherlands,
in regard to the exercise of jurisdiction by a flag State as provided by
Articles 56.2 and 58 UNCLOS, and Part VII of the UNCLOS, and under
customary international law.

c) In boarding the Arctic Sunrise without the prior consent of the

Kingdom of the Netherlands to arrest and detain the persons on board the
ship, and initiating judicial proceedings against them, breached its
obligations to the Kingdom of the Netherlands, in its own right, in the
exercise of its right to diplomatic protection of its nationals, in the
exercise of its right to seek redress on behalf of the persons on board a
ship flying the flag of the Kingdom of the Netherlands, irrespective of
their nationality, and as a non-injured State with a legal interest, in regard
to the right to liberty and security of the persons on board a ship and their
right to leave the territory and maritime areas under the jurisdiction of a
coastal State as provided by Articles 9 and 12.2 ICCPR, and customary
international law.

In applying national legislation related to artificial islands, installations

and structures in the exclusive economic zone vis-a-vis the Netherlands,
including ships flying its flag, extending the breadth of safety zones
around artificial islands, installations and structures in its exclusive
economic zone beyond the extent allowed under the UNCLOS, breached
its obligations to the Kingdom of the Netherlands:in its own right, in the
exercise of its right to protect a ship flying its flag, in regard to freedom
of protest at sea as provided by Articles 56.2, 58.1, and 60.4 UNCLOS,
and Part VII of the UNCLOS, and under customary