303A

INTERNATIONAL COURT OF JUSTICE

AT THE PEACE PALACE,

THE HAGUE, THE NETHERLANDS

– 2025 –

The Case Concerning the Nagea Sea

THE UNION OF AMBROSIA

V.

THE REPUBLIC OF ROVINIA

Memorial for the Applicant

The 2025 Philip C. Jessup International Law Moot Court Competition

 TABLE OF CONTENTS

TABLE OF CONTENTS
INDEX OF AUTHORITIES
STATEMENT OF JURISDICTION
STATEMENT OF FACTS
SUMMARY OF PLEADINGS
PLEADINGS

1. The International Court of Justice has jurisdiction to hear this case under Article XXI of
the OCDP Charter

.........................................................................................................................................Page 11

2. The arrest and prosecution of Ms. Cross violated international law, including the rule on
immunity and jurisdiction

.........................................................................................................................................Page 15

3. The issuance of fishing licenses by Rovinia in the Triton Shoal violated Ambrosia’s
exclusive rights under international law

.........................................................................................................................................Page 18]

4. The seizure and sale of “The Falcon” violated Ambrosia’s sovereign immunity

.........................................................................................................................................Page 22

5. The recognition of the Transitional Council violated international law and constitutes
unlawful interference in Ambrosia’s domestic affairs

.........................................................................................................................................Page 28

IX. Prayers for Relief

...........................................................................................................................................Page 29

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 INDEX OF AUTHORITIES

Cases

1. Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States), ICJ

Reports 1986

2. Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening), ICJ Reports

2012

3. Arrest Warrant of 11 April 2000 (Democratic Republic of the Congo v. Belgium), ICJ Reports

2002

4. North Sea Continental Shelf Cases (Germany v. Denmark; Germany v. Netherlands), ICJ

Reports 1969

5. Avena and Other Mexican Nationals (Mexico v. United States), ICJ Reports 2004

6. Certain Questions of Mutual Assistance in Criminal Matters (Djibouti v. France), ICJ Reports

2008

7. Haya de la Torre (Colombia v. Peru), ICJ Reports 1951

8. Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory, ICJ

Reports 2004

9. Belgium v. Senegal, ICJ Reports 2012

10. Côte d’Ivoire (Ouattara Government Recognition Case)

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Statutory Provisions

1. Charter of the United Nations, Articles 2(1) and 2(4)

2. United Nations Convention on the Law of the Sea (UNCLOS), Articles 56, 74(3), and 83

3. United Nations Convention on Jurisdictional Immunities of States and Their Property

(UNCJISP), Articles 5, 6, 18, and 19

4. International Convention for the Protection of All Persons from Enforced Disappearance

(ICPPED), General Obligations

5. Vienna Convention on the Law of Treaties, Article 27

Principles and Doctrines

1. Principle of Non-Intervention in Domestic Affairs

2. Functional Immunity (Ratione Materiae)

3. Stimson Doctrine

Treaties and Agreements

1. Charter of the Organization for Cooperation and Development in the Paine (OCDP), Article

XXI

United Nations Resolutions

1. United Nations General Assembly Resolution 2625 (XXV), Declaration on Principles of

International Law concerning Friendly Relations and Cooperation among States

2. United Nations General Assembly Resolution 3314 (XXIX), Definition of Aggression

3
Other Authorities

1. Statements from Acting President Zavala and President Derey

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 STATEMENT OF JURISDICTION

The union of Ambrosia (“Ambrosia”) and the Republic of Rovinia (“Rovinia”) hereby submit

the present dispute to the International Court of Justice pursuant to Article 40(2) of the Statute of

the Court in accordance with the Statement of Agreed Facts for submission to the ICJ of the

disputes concerning the Naegea Sea and certain other matters, submitted to the Court on the 30th

day of August 2024. However, both States have not accepted the jurisdiction of this Court

pursuant to Article XXI of the Organization for Cooperation and Development in the Paine

(OCDP). While Rovinia accepts the Court’s jurisdiction over the fishing license dispute and the

aircraft seizure, it contests jurisdiction over the arrest and prosecution of Gertrude Cross.

STATEMENT OF FACTS

HISTORICAL AND GEOGRAPHICAL BACKGROUND

The Paine Peninsula was colonized by the Kingdom of Fretzi in the 17th century and later

divided into seven administrative units. Between 1920 and 1946, these units gained

independence as sovereign states with democratic systems. Ambrosia, the northernmost state, has

a land area of approximately 180,000 square kilometers, a population of 4 million, and a

coastline extending 910 kilometers along the Naegea Sea. Rovinia, the southernmost state, spans

900,000 square kilometers, has 10 million inhabitants, and its Naegae Sea coastline is 455

Kilometres long.

ECONOMIC AND ENVIRONMENTAL CONTEXT

The Naegea Sea is rich in tuna species, making fishing the backbone of the Peninsula’s

economy. Ambrosia's fishing industry accounts for 20% of its USD 120 billion GDP, while

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Rovinia’s fishing sector contributes 40% of its USD 240 billion GDP. All seven states legislated

exclusive fishing rights within their EEZs up to 200 nautical miles. However, climate change has

caused significant sea level rise, disproportionately affecting Ambrosia due to its low lying

geography.

ESTABLISHMENT OF ORGANIZATION FOR COOPERATION AND

DEVELOPMENT

In 2016, the seven Peninsula states formed the Organization for Cooperation and Development in

the Paine (OCDP) to promote law enforcement collaboration, sustainable resource management,

and climate adaptation. The inclusion of a compromissory clause in the OCDP Charter to resolve

disputes at the International Court of Justice (ICJ) sparked debate, especially on freezing

baselines and related issues.

AMBROSIA'S INTERNAL POLICIES

President Prosper Derey launched the “Implementing the Law for a Safer Ambrosia” (ILSA)

program in 2013 to combat drug trafficking, leading to increased arrests but later facing

allegations of human rights abuses. In 2015, Ambrosia adopted the Baseline Freezing Law to

address sea-level rise by fixing maritime boundaries. While supported by most Peninsula states,

Rovinia opposed this measure, claiming it violated international law.

ROVINIA'S ACTIONS AND REACTIONS

Rovinia refused to adopt baseline freezing legislation and actively opposed its regional

endorsement. In 2018, it began issuing fishing licenses for yellowfin tuna in disputed areas of the

Triton Shoal, which Ambrosia claimed fell within its EEZ under the Freezing Law. Rovinia also

recognized the Transitional Council during Ambrosia’s political crisis, further straining relations.

POLITICAL CRISIS IN AMBROSIA

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Following President Derey’s incapacitation in 2022, Vice-President Mary Zavala assumed the

role of Acting President but faced criticism for neglecting domestic issues, particularly after

Hurricane Luna. Amid growing protests and cabinet resignations, the Transitional Council, led

by Rooney Piretis, assumed control in March 2023, declaring Zavala's government illegitimate.

LEGAL AND DIPLOMATIC DISPUTES

In 2023, Rovinia seized and sold Ambrosia’s vice-presidential aircraft, "The Falcon," based on a

disputed waiver of immunity by the Transitional Council. In 2024, Rovinia arrested former

Ambrosian Minister Gertrude Cross for alleged human rights violations under ILSA, asserting

universal jurisdiction. These incidents escalated diplomatic tensions between the two countries.

PROCEEDINGS BEFORE THE INTERNATIONAL COURT OF JUSTICE

Ambrosia instituted proceedings at the ICJ, in July, 2024 alleging Rovinia violated international

law in four key areas: the recognition of the Transitional Council, the seizure and sale of "The

Falcon," the prosecution of Gertrude Cross, and fishing rights in the Triton Shoal. Rovinia

contested the Court's jurisdiction over the Cross case but accepted it for the other issues,

asserting its actions were lawful.

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 SUMMARY OF PLEADINGS

PLEADING I

The International Court of Justice (ICJ) has jurisdiction under Article XXI of the

OCDP Charter, which mandates compulsory jurisdiction over disputes of a legal

nature between Member States. This includes Ambrosia’s claims regarding state

immunity, sovereign rights under UNCLOS, and violations of international treaty

obligations. The arrest and prosecution of Ms. Cross raise significant legal questions,

including violations of functional immunity and improper assertions of universal

jurisdiction. These issues fall within the ICJ’s jurisdiction, as the continuing legal

consequences of Rovinia’s actions demand adjudication under international law.

PLEADINGS II

The arrest and prosecution of Ms. Cross violated international law, including the

principles of state immunity and jurisdiction. As a former minister acting in her

official capacity, Ms. Cross is entitled to functional immunity under international law

and the UNCJISP, which protects state officials from foreign prosecution for official

acts. Rovinia’s reliance on universal jurisdiction conflicts with its obligation under the

UNCJISP to respect immunity claims and refrain from prosecuting officials entitled to

such protections. Furthermore, Rovinia’s use of domestic law to justify its actions

violates international treaty obligations, which cannot be overridden by internal legal

provisions. These actions constitute a clear breach of international law.

PLEADINGS III

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Rovinia’s issuance of fishing licenses in the Triton Shoal violates Ambrosia’s

exclusive rights under international law, particularly under UNCLOS and the 2015

Freezing Law. Ambrosia’s sovereign rights over its EEZ, as guaranteed by Article 56

of UNCLOS, entitle it to regulate and manage natural resources within the Triton

Shoal. Rovinia’s actions disregard these rights and constitute an infringement on

Ambrosia’s sovereignty. The 2015 Freezing Law affirms Ambrosia’s authority over

its maritime zones, and Rovinia’s unilateral issuance of fishing licenses without

Ambrosia’s consent directly contravenes this law. Rovinia’s actions also breach

international norms under UNCLOS, which require states to cooperate and refrain

from unilateral actions in disputed maritime areas. By failing to adhere to regional

practices and the duty of cooperation, Rovinia has destabilized maritime relations,

undermined mutual respect, and hindered the potential for peaceful resolution of

maritime disputes. Its actions violate established legal norms and principles of good

faith, making them unlawful under international law.

PLEADINGS IV

The seizure and sale of “The Falcon” violated Ambrosia’s sovereign immunity,

contravening international law protections for state property. Under Articles 18 and 19

of the UNCJISP, Ambrosia is immune from pre- and post-judgment measures of

constraint, including the seizure and sale of state assets. Rovinia’s actions, executed

through its courts, disregarded these principles and unlawfully interfered with

Ambrosia’s sovereign property. Furthermore, the Transitional Council’s purported

waiver of immunity is invalid, as the Council lacked constitutional authority to act on

behalf of Ambrosia. Its unconstitutional usurpation of power undermined Ambrosia’s

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democratic integrity, rendering any actions taken by the Council, including the waiver

of immunity, null and void under international law.

PLEADINGS V

Rovinia’s recognition of Ambrosia’s Transitional Council violated international law

and constitutes unlawful interference in Ambrosia’s domestic affairs. Under

customary international law and the principles of sovereignty enshrined in Articles

2(1) and 2(4) of the UN Charter, a state’s choice of government is a domestic matter

free from external intervention. By recognizing the Transitional Council, Rovinia

undermined Ambrosia’s constitutional government, breaching the principle of non-

intervention. Rovinia’s actions also violate the Stimson Doctrine, which prohibits

recognition of unconstitutional governments. Despite the Transitional Council’s claim

of effective control, its unconstitutional assumption of power disqualifies it from

legitimate recognition under international law. Effective control alone does not confer

governmental status, as legitimacy must adhere to constitutional norms, which Acting

President Zavala upheld throughout the crisis. Furthermore, Rovinia’s recognition of

the Transitional Council was politically motivated to serve its interests, particularly to

validate the waiver of immunity for “The Falcon” and justify its seizure and sale.

These actions demonstrate bad faith and disregard for the principles of sovereignty

and non-intervention, violating Ambrosia’s rights under international law.

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 PLEADINGS

I. THE INTERNATIONAL COURT OF JUSTICE HAS JURISDICTION TO HEAR

THIS CASE UNDER ARTICLE XXI OF THE OCDP CHARTER
Jurisdiction is the bloodline of judicial process and the authority of a court to hear and determine
cases. In international law, jurisdiction ensures that disputes between states are adjudicated by a
competent and recognized authority. In the present matter, the International Court of Justice
holds jurisdiction to adjudicate the case under Article XXI of the OCDP Charter. Article XXI
establishes the compulsory jurisdiction of the Court over disputes of a legal nature between
Member States.

A. The ICJ’s Jurisdiction is Compulsory Under Article XXI of the OCDP Charter
Ambrosia’s dispute clearly falls within the compulsory jurisdiction of the International Court of
Justice (ICJ) under Article XXI of the OCDP Charter, which mandates that Member States
submit legal disputes of a juridical nature to the Court. This provision enforces the obligation of
states to submit disputes to the ICJ without the need for a special agreement.
1. Article XXI of the OCDP Charter Establishes the ICJ’s Compulsory Jurisdiction
Article XXI obligates Member States to submit disputes to the ICJ, reflecting the same
principle found in Article 36(2) of the ICJ Statute. This was confirmed in United States
v. Iran (1980),1 where the ICJ asserted that disputes under the Treaty of Amity were
subject to compulsory jurisdiction, even without specific consent for each individual
dispute. Thus, under Article XXI of the OCDP Charter, Ambrosia’s case falls within the
scope of disputes that must be submitted to the ICJ without further agreement.

2. Ambrosia’s Dispute Falls Within the Scope of the ICJ’s Jurisdiction

The dispute raised by Ambrosia involves state immunity and the interpretation of
UNCLOS, both of which are core matters of international law that fall within the ICJ’s
jurisdiction. In Germany v. Italy (2012)2, the ICJ affirmed its jurisdiction over disputes
concerning state immunity, establishing that such matters are within the Court’s authority
1 Case concerning the dispute between the United States and Iran regarding the seizure of the U.S. Embassy in
Tehran. International Court of Justice (ICJ), United States Diplomatic and Consular Staff in Tehran (United States v.
Iran), Judgment of 24 May 1980, ICJ Reports 1980, p. 3. URL: ICJ Case Law - United States v. Iran

11
 to adjudicate. In addition, the North Sea Continental Shelf Cases (1969)3 demonstrated
the ICJ’s competence in interpreting and applying international treaties, such as the 1958
Convention on the Continental Shelf, which is analogous to the interpretation of
UNCLOS in Ambrosia’s case.

Based on the foregoing, Ambrosia argues that the dispute falls within the ICJ’s
compulsory jurisdiction under Article XXI of the OCDP Charter, thereby obligating the
Court to hear the case in line with international legal standards.

B. The Arrest and Prosecution of Ms. Cross Fall Within the Court’s Jurisdiction
The arrest and prosecution of Ms. Cross fall squarely within the jurisdiction of the International
Court of Justice (ICJ). The continuous nature of these actions, compounded with their
international legal implications, requires the ICJ’s intervention to ensure compliance with
international legal standards and obligations.

1. The Continuing Legal Consequences of Ms. Cross’s Detention and Prosecution

Rovinia’s argument that the arrest and prosecution of Ms. Cross concern actions that
occurred prior to the enforcement of Article XXI is irrelevant. The detention and
prosecution of Ms. Cross, as well as the ongoing refusal to release her, continue to have
legal consequences, and thus fall under the ICJ’s jurisdiction in line with Article 36(1) of
the ICJ Statute. This principle is supported by the case Nicaragua v. United States
(1986),4 where the ICJ emphasized that the continuing nature of unlawful acts could be
grounds for jurisdiction, even if the initial actions occurred prior to the filing of the
dispute. The Court held that violations of international law could have ongoing
consequences, extending the jurisdictional reach of the ICJ. Similarly, in Avena and

2 Case involving Germany’s claim against Italy for violations of state immunity. International Court of Justice
(ICJ), Jurisdictional Immunities of the State (Germany v. Italy), Judgment of 3 February 2012, ICJ Reports 2012, p.
99. URL: ICJ Case Law - Germany v. Italy
3 Cases concerning the delimitation of the continental shelf in the North Sea between Germany, Denmark, and the
Netherlands. International Court of Justice (ICJ), North Sea Continental Shelf (Federal Republic of Germany v.
Denmark; Federal Republic of Germany v. Netherlands), Judgment of 20 February 1969, ICJ Reports 1969, p. 3.
URL: ICJ Case Law - North Sea Continental Shelf
4 Military and Paramilitary Activities in and Against Nicaragua (Nicaragua v. United States of America), Judgment
of 27 June 1986, ICJ Reports 1986, p. 14. URL: ICJ Case Law - Nicaragua v. United States

12
 Other Mexican Nationals (Mexico v. United States) (2004), 5 the Court ruled that
breaches of consular rights and ongoing detentions could lead to continuing violations,
establishing that jurisdiction extends to situations with continuing legal effects.

2. The International Legal Dimensions of the Allegations Against Ms. Cross

Despite Rovinia’s assertion of domestic jurisdiction, the allegations against Ms. Cross
raise significant violations of international law, particularly under the International
Convention for the Protection of All Persons from Enforced Disappearance
(ICPPED). Both Ambrosia and Rovinia are signatories to the ICPPED, which imposes
binding international obligations on the States Parties to prevent enforced disappearances
and provide legal remedies when such violations occur. The ICJ has held that disputes
involving the interpretation and application of international conventions fall within its
jurisdiction, as established in Belgium v. Senegal (2012).6 Similarly, in Bosnia and
Herzegovina v. Serbia and Montenegro (2007), the ICJ asserted its jurisdiction over
matters involving genocide, demonstrating that even if the alleged acts occurred within
the territory of a State, international obligations take precedence, and the ICJ is
empowered to hear such cases.

Based on the foregoing, Ambrosia argues that the arrest and prosecution of Ms. Cross fall
within the jurisdiction of the ICJ, as the continuing nature of these actions, along with
their international legal ramifications, require the Court’s involvement in ensuring
adherence to international law.

C. The ICJ Has the Competence to Determine Its Own Jurisdiction

The competence of the International Court of Justice (ICJ) to determine its own jurisdiction is a
foundational principle of international law. It ensures that the ICJ has the necessary authority to
interpret and apply jurisdictional provisions.
1. The ICJ’s Inherent Competence to Determine Its Own Jurisdiction

5 Avena and Other Mexican Nationals (Mexico v. United States of America), Judgment of 31 March 2004, ICJ
Reports 2004, p. 12. URL: ICJ Case Law - Avena and Other Mexican Nationals
6 Questions Relating to the Obligation to Prosecute or Extradite (Belgium v. Senegal), Judgment of 20 July 2012,
ICJ Reports 2012, p. 422. URL: ICJ Case Law - Belgium v. Senegal

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 The ICJ’s competence to determine its jurisdiction is explicitly enshrined in Article 36(6)
of the ICJ Statute, which states that the Court has the authority to decide whether it has
jurisdiction in a given case. This principle was reaffirmed in Monetary Gold Removed
from Rome in 1943 (Italy v. France, United Kingdom, and United States), 7 where the
ICJ emphasized its duty to assess its jurisdiction before proceeding to substantive issues
(ICJ Reports 1954, p. 19). Similarly, in the Nottebohm Case (Liechtenstein v.
Guatemala),8 the ICJ interpreted compromissory clauses to determine its jurisdiction,
solidifying its role as the arbiter of its jurisdictional scope (ICJ Reports 1953, p. 111).

In Legality of Use of Force (Serbia and Montenegro v. Belgium), 9 the Court reiterated
its inherent competence to determine whether a dispute meets the jurisdictional criteria
under relevant treaties and statutes (ICJ Reports 1999, p. 124). These cases collectively
demonstrate the ICJ’s unwavering adherence to its mandate under Article 36(6).

2. Rovinia’s Misinterpretation of Article XXI

Rovinia’s objections to the ICJ’s jurisdiction are based on a flawed interpretation of
Article XXI of the OCDP Charter. This provision, consistent with international legal
principles, mandates that disputes of a juridical nature between Member States be
referred to the ICJ. The ongoing detention and prosecution of Ms. Cross, which involve
allegations of violations under international law, as well as broader issues of state
immunity and sovereign rights, fall squarely within the scope of Article XXI.

The ICJ has previously addressed objections similar to Rovinia’s in Preliminary

Objections in Certain Iranian Assets (Islamic Republic of Iran v. United States of
America),10 where it upheld its jurisdiction by interpreting treaty provisions in light of
the overarching objectives of dispute resolution (ICJ Reports 2019, p. 7). Furthermore, in

7 Monetary Gold Removed from Rome in 1943 (Italy v. France, United Kingdom, and United States), Judgment of
15 June 1954, ICJ Reports 1954, p. 19. URL: ICJ Case Law - Monetary Gold Removed from Rome
8 Nottebohm Case (Liechtenstein v. Guatemala), Preliminary Objections, Judgment of 18 November 1953, ICJ
Reports 1953, p. 111. URL: ICJ Case Law - Nottebohm Case
9 Legality of Use of Force (Serbia and Montenegro v. Belgium), Provisional Measures, Order of 2 June 1999, ICJ
Reports 1999, p. 124. URL: ICJ Case Law - Legality of Use of Force
10 Certain Iranian Assets (Islamic Republic of Iran v. United States of America), Preliminary Objections, Judgment
of 13 February 2019, ICJ Reports 2019, p. 7. URL: ICJ Case Law - Certain Iranian Assets

14
 Case Concerning Armed Activities on the Territory of the Congo (Democratic
Republic of Congo v. Uganda),11 the ICJ rejected narrow jurisdictional interpretations,
emphasizing its role in resolving disputes involving international obligations (ICJ Reports
2005, p. 168).

Based on the foregoing, Ambrosia argues that the ICJ has the inherent authority to
determine its own jurisdiction, ensuring that all disputes are addressed in accordance with
international law.

D. The Arrest and Prosecution of Ms. Cross Raise Serious Questions of International Law,
Justifying the Court’s Jurisdiction
The arrest and prosecution of Ms. Cross present significant legal questions, particularly
concerning state immunity and universal jurisdiction. These issues necessitate the Court’s
intervention to ensure clarity and adherence to international law.
1. Functional Immunity of Ms. Cross
Ms. Cross, as a former Minister, is entitled to functional immunity for acts carried out in
her official capacity. Her arrest and prosecution disregard this principle, as established in
the Arrest Warrant Case (Democratic Republic of the Congo v. Belgium). 12 In this
case, the ICJ held that senior government officials enjoy immunity from foreign
prosecution for acts performed in their official capacity, even after leaving office. The
violation of this fundamental principle raises important legal issues, which fall firmly
within the Court’s jurisdiction.
2. The Boundaries of Universal Jurisdiction
Rovinia’s claim of universal jurisdiction to prosecute Ms. Cross must adhere to
international legal norms. In line with the Arrest Warrant Case, the ICJ reaffirmed that
universal jurisdiction cannot override the immunity of foreign state officials. In addition,
the Convention Against Torture (Article 5(2))13 makes clear that universal jurisdiction

11 Case Concerning Armed Activities on the Territory of the Congo (Democratic Republic of Congo v. Uganda),
Judgment of 19 December 2005, ICJ Reports 2005, p. 168. URL: ICJ Case Law - Armed Activities on the Territory
of the Congo
12 Arrest Warrant Case (Democratic Republic of the Congo v. Belgium), Judgment of 14 February 2002, ICJ
Reports 2002, p. 3. URL: ICJ Case Law - Arrest Warrant
13 Convention Against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, Article 5(2).
URL: UN Treaty - Convention Against Torture

15
 is secondary to the primary right of the territorial state, Ambrosia, to investigate and
prosecute crimes occurring within its territory. This creates an essential limitation that
must be respected. Therefore, Rovinia’s actions in asserting universal jurisdiction
challenge accepted principles of international law and should fall within the ICJ’s
purview.
3. The Court’s Jurisdiction Under Article XXI of the OCDP Charter
The arguments concerning jurisdiction highlight the Court’s clear authority to address
this matter under Article XXI of the OCDP Charter. The issues at hand concern essential
principles of international law, including state immunity and treaty obligations, which are
best resolved by the Court. The LaGrand Case (Germany v. United States of
America)14 demonstrated that the ICJ has the competence to intervene when violations of
international obligations affect the rights of nationals. The Court’s jurisdiction is
instrumental in resolving conflicts between member states and ensuring adherence to
international law.
4. Safeguarding National Rights through ICJ Intervention
Ambrosia has brought this case before the Court to protect the rights of its nationals,
including Ms. Cross. The ICJ’s intervention is necessary to address the legal questions
raised and to clarify essential international legal principles. As in Certain Questions of
Mutual Assistance in Criminal Matters (Djibouti v. France), 15 where the Court upheld
its authority to resolve disputes relating to international obligations, the ICJ can provide
critical guidance to resolve conflicts between states. Through this case, the Applicant
believes that the Court will clarify important legal principles and help safeguard national
rights in accordance with international law.

II. THE ARREST AND PROSECUTION OF MS. CROSS VIOLATED

INTERNATIONAL LAW, INCLUDING THE RULE ON IMMUNITY AND
JURISDICTION.

14 LaGrand Case (Germany v. United States of America), Judgment of 27 June 2001, ICJ Reports 2001, p. 466.
URL: ICJ Case Law - LaGrand
15 Certain Questions of Mutual Assistance in Criminal Matters (Djibouti v. France), Judgment of 4 June 2008, ICJ
Reports 2008, p. 177. URL: ICJ Case Law - Djibouti v. France

16
 Former ICJ Judge Awn Shawkat Al-Khasawneh defined immunity as "an exception
from the general rule that man is responsible legally and morally for his actions." 16This
principle is established under international law to safeguard the independence and
sovereignty of states. The arrest and prosecution of Ms. Cross constitute a flagrant
violation of the United Nations Convention on Jurisdictional Immunities of States and
their Property (UNCJISP).

A. Ms. Cross, a former minister acting in her official capacity, is entitled to immunity from
prosecution in Rovinian courts under international law

The principle of immunity for state officials, especially for acts carried out in an official
capacity, is a well-established tenet of international law. Ms. Cross, as a former minister,
is entitled to this immunity, and Rovinia must respect it in accordance with international
obligations.

1. Immunity under Article 5 of the UNCJISP

Article 5 of the United Nations Convention on Jurisdictional Immunities of States

and Their Property (UNCJISP) guarantees that a State enjoys immunity from the
jurisdiction of the courts of another State, covering both the State itself and its property.
This immunity extends to the agencies or instrumentalities of the State engaged in acts of
sovereign authority, as clarified under Article 2(b)(iii). In line with this, Ms. Cross, in
her official capacity, is entitled to the immunity protections under this provision. In the
case of Jurisdictional Immunities of the State (Germany v. Italy: Greece
Intervening),17 the ICJ emphasized that states, as well as their representatives, benefit
from jurisdictional immunity under customary international law and relevant treaties.

2. Functional Immunity for Official Acts

International law grants functional immunity (ratione materiae) to state officials for acts
performed in their official capacity, even after they leave office. This immunity ensures
that state officials are shielded from foreign jurisdiction for actions taken while fulfilling

16 Arrest Warrant Case (Democratic Republic of the Congo v. Belgium), Judgment of 14 February 2002, ICJ
Reports 2002, p. 3. URL: ICJ Case Law - Arrest Warrant
17 Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening), Judgment of 3 February 2012, ICJ
Reports 2012, p. 99. URL: ICJ Case Law - Jurisdictional Immunities

17
 their duties, irrespective of their current status. In the Arrest Warrant Case
(Democratic Republic of the Congo v. Belgium), 18 the ICJ reaffirmed that senior
officials, including ministers, enjoy immunity from prosecution for acts carried out in
their official capacity, even after leaving office.

Ms. Cross, having served as the head of the Ministry of Interior, is entitled to this
immunity due to the official nature of her role and the acts she undertook while serving in
office.

3. Ms. Cross’s Official Capacity and Immunity

Ms. Cross, as the former head of the Ministry of Interior, was acting in her official
capacity when the alleged crime of enforced disappearance occurred. As such, she is
entitled to immunity from prosecution in Rovinian courts, in accordance with
international law that protects state officials from foreign legal proceedings for acts
carried out in their official roles. This is consistent with the Congo v. Belgium case,
where the Court found that immunity is applicable even when the official acts involve
serious allegations, such as war crimes or crimes against humanity.

4. Duty to Notify and Respect for Immunity

International law requires that a State seeking to claim immunity for one of its officials
notify the authorities of the state where proceedings are being pursued. In Djibouti v.
France,19 the ICJ confirmed that such notification is necessary to allow the forum state to
respect the immunity claim. Ambrosia, in this case, has adhered to the legal obligation of
notifying Rovinia that Ms. Cross is entitled to immunity based on her official capacity. In
this instance, the ICJ’s decision in Djibouti v. France reinforces the necessity of formal
diplomatic notification for the invocation of immunity.

5. Ambrosia’s Notification and Demand for Release

Following Ms. Cross’s arrest, Ambrosia, through its Ambassador in Rovinia, informed
the relevant authorities on May 2, 2024, that Ms. Cross was an official at the time of the

18 Arrest Warrant Case (Democratic Republic of the Congo v. Belgium), Judgment of 14 February 2002, ICJ
Reports 2002, p. 3. URL: ICJ Case Law - Arrest Warrant
19 Djibouti v. France (Certain Questions of Mutual Assistance in Criminal Matters), Judgment of 4 June 2008, ICJ
Reports 2008, p. 177. URL: ICJ Case Law - Djibouti v. France

18
 alleged crime and entitled to immunity. Furthermore, President Prosper Derey’s formal
request for her release the following day further emphasizes the legal basis for Ms.
Cross’s immunity, yet Rovinia disregarded this request. Despite Rovinia’s defiance,
Ambrosia’s position remains legally sound and justified under international law, and this
claim of immunity is supported by the principles established in the Jurisdictional
Immunities of the State20 case.

B. Rovinia’s reliance on universal jurisdiction to arrest and prosecute Ms. Cross for alleged
enforced disappearances is inconsistent with its obligations under the UNCJISP.

Rovinia’s attempt to justify its actions based on universal jurisdiction conflicts with its binding
obligations under international law, particularly under the UNCJISP. The treaty mandates that
states respect immunity and refrain from exercising jurisdiction against officials of other states
when they are entitled to immunity.

1. Obligation to Respect Immunity under Article 6 of the UNCJISP

Article 6 of the UNCJISP imposes a clear obligation on states to respect state immunity
and refrain from exercising jurisdiction over officials who are entitled to immunity. This
principle has been upheld by international courts and tribunals in various rulings.

The relevant part of Article 6 provides:

“A State shall give effect to State immunity under Article 5 by refraining from
exercising jurisdiction in a proceeding before its court against another State, and to that
end, shall ensure that its courts determine on their own initiative that the immunity of
that other State under Article 5 is respected.”

This provision is central to the argument that Rovinia’s prosecution of Ms. Cross, a
former official acting in her capacity, is unlawful under international law. The ICJ case
Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening 21)

20 Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening), Judgment of 3 February
2012, ICJ Reports 2012, p. 99. URL: ICJ Case Law - Jurisdictional Immunities
21 Jurisdictional Immunities of the State (Germany v. Italy: Greece Intervening), Judgment of 3 February 2012, ICJ
Reports 2012, p. 99. URL: ICJ Case Law - Jurisdictional Immunities

19
 reinforced this obligation, noting that states must respect immunity claims even in cases
where universal jurisdiction is invoked.

2. Rovinia’s Disregard for the Provisions of the UNCJISP

Rovinia’s continued refusal to release Ms. Cross, despite her clear entitlement to
immunity, reflects an outright disregard for the provisions of the UNCJISP. The ICJ has
consistently emphasized that states must comply with international obligations and
cannot unilaterally override immunity protections based on domestic legal arguments. In
the Congo v. Belgium (Arrest Warrant Case), the Court highlighted that the immunity
of high-ranking state officials is absolute when it comes to official acts, even in the
context of universal jurisdiction claims. The Congo v. Belgium ruling explicitly stated
that universal jurisdiction cannot override state immunity for officials acting in an official
capacity.

3. Inadmissibility of Rovinia’s Reliance on Domestic Law as Justification

Rovinia’s invocation of its domestic law as a basis for disregarding international law is
expressly prohibited by international treaty law. Article 27 of the Vienna Convention on
the Law of Treaties (VCLT) stipulates that states cannot use their internal laws as a
justification for non-compliance with binding international obligations. It provides:

“A party may not invoke the provisions of its internal law as a justification for
failure to perform a treaty.”

This provision is crucial because it prevents states from using domestic laws as a defense
to evade international obligations. In Austria v. Italy,22 the ICJ emphasized that a state
cannot disregard its international obligations under customary international law or
treaties, including immunity provisions, by invoking domestic legal rules. The Court
made it clear that universal jurisdiction could not be invoked in a way that undermines
the immunity protections established under international law.

III. THE ISSUANCE OF FISHING LICENSES BY ROVINIA IN THE TRITON SHOAL

VIOLATED AMBROSIA’S EXCLUSIVE RIGHTS UNDER INTERNATIONAL LAW

22 Austria v. Italy (State Immunity), Judgment of 19 December 2014, ICJ Reports 2014, p. 100.
URL: ICJ Case Law - Austria v. Italy

20
 Ambrosia asserts that Rovinia’s issuance of fishing licenses in the Triton Shoal
contravenes its exclusive rights under international law. These rights, as defined by the
2015 Freezing Law and the United Nations Convention on the Law of the Sea
(UNCLOS), have been unjustifiably violated, infringing upon Ambrosia’s sovereign
rights over its Exclusive Economic Zone (EEZ), as articulated in the facts of the case.

A. The Legal Basis of Ambrosia’s Exclusive Rights

Ambrosia’s exclusive rights over its EEZ are grounded in well-established international
law, specifically the United Nations Convention on the Law of the Sea (UNCLOS).
Rovinia’s actions, disregarding Ambrosia’s sovereign authority, violate these rights and
must be recognized as unlawful.

Article 56 of the UNCLOS states that in the EEZ, the coastal state has sovereign rights
for the purpose of exploring, exploiting, conserving, and managing the natural resources,
whether living or non-living. Given that the Triton Shoal lies within Ambrosia’s EEZ,
Ambrosia possesses the exclusive authority to regulate activities, including fishing, in
this area. The International Court of Justice (ICJ) has consistently upheld this principle in
cases such as Fisheries Jurisdiction (United Kingdom v. Iceland), 23 where it was
established that a coastal state has exclusive jurisdiction over the regulation of fisheries
within its EEZ. Rovinia’s interference by issuing fishing licenses is a direct violation of
these sovereign rights.

Further, in the Nottebohm Case (Liechtenstein v. Guatemala), 24 the ICJ emphasized

the importance of good faith in honoring state rights under international law. Rovinia’s
unilateral issuance of fishing licenses, while knowing the Triton Shoal lies within
Ambrosia’s EEZ, demonstrates bad faith and an unlawful disregard for Ambrosia’s
rights. This conduct undermines the principle of mutual respect in international relations,
as set out in numerous ICJ rulings.

23 Fisheries Jurisdiction (United Kingdom v. Iceland), Judgment of 2 February 1974, ICJ Reports 1974, p. 3. URL:
ICJ Case Law - Fisheries Jurisdiction (United Kingdom v. Iceland)
24 Nottebohm Case (Liechtenstein v. Guatemala), Judgment of 6 April 1955, ICJ Reports 1955, p. 4. URL: ICJ
Case Law - Nottebohm Case (Liechtenstein v. Guatemala)

21
B. Violation of Sovereign Rights Under International Law
Rovinia’s actions are a direct infringement on Ambrosia’s rights, as defined under
UNCLOS and further confirmed by established case law. Such actions are unlawful and
undermine the fundamental principle that states must respect the sovereign rights of their
neighbors.

In the Barcelona Traction Case (Belgium v. Spain),25 the ICJ ruled that states must
refrain from acts that infringe upon the rights of other states when such rights are clearly
recognized by international law. Rovinia’s issuance of fishing licenses in Ambrosia’s
EEZ disregards Ambrosia’s exclusive sovereign rights, breaching both international law
and Ambrosia’s ability to manage its resources effectively. This breach undermines the
integrity of Ambrosia’s jurisdiction over the Triton Shoal, which is clearly within its
EEZ.

C. The Role of the 2015 Freezing Law

The 2015 Freezing Law is a crucial legal instrument that affirms Ambrosia’s control
over its EEZ. Rovinia’s actions, which conflict with this domestic law, further
demonstrate a blatant disregard for Ambrosia’s legitimate authority and international
obligations.

The 2015 Freezing Law states that no activity may take place in the Triton Shoal without
the prior authorization of the Ambrosian government. Rovinia’s actions, issuing fishing
licenses without Ambrosia’s consent, are a direct violation of this law and a breach of
Ambrosia’s exclusive rights under UNCLOS. The ICJ’s decision in Fisheries
Jurisdiction (United Kingdom v. Iceland) confirms that coastal states possess the
exclusive right to regulate fisheries within their EEZs, and any interference by a third
state constitutes an infringement on the sovereign rights of the coastal state. Rovinia’s
issuance of fishing licenses further compounds its violations, as it disregards both the
domestic legal framework of Ambrosia and its international rights under UNCLOS.

25 Barcelona Traction (Belgium v. Spain), Judgment of 5 February 1970, ICJ Reports 1970, p. 3. URL: ICJ Case
Law - Barcelona Traction (Belgium v. Spain)

22
D. Violation of Established International Norms and Regional Practices Concerning
Maritime Boundaries
Rovinia’s unilateral actions also breach the norms that govern maritime boundary
delimitations. UNCLOS and customary international law demand cooperation, mutual
respect, and fair agreements between states to ensure equitable solutions to maritime
disputes.

Articles 74 and 83 of UNCLOS require that states with adjacent coasts delimit their
EEZs and continental shelves through negotiations based on international law principles
aimed at achieving equitable solutions. In The North Sea Continental Shelf Cases
(Germany v. Denmark; Germany v. Netherlands), 26 the ICJ affirmed that states must
negotiate in good faith to establish maritime boundaries. Rovinia’s unilateral actions
violate this fundamental obligation by infringing on Ambrosia’s rights within its EEZ
without an agreement. This case underscores the requirement of cooperation in maritime
boundary delimitation, which Rovinia has disregarded in favor of unilateral action.

E. Violation of Norms on Provisional Arrangements Pending Delimitation

Rovinia’s actions are in direct violation of international norms governing provisional
arrangements in areas of maritime dispute. UNCLOS mandates that states refrain from
actions that would jeopardize or hinder the potential for a negotiated resolution.

Article 74(3) of UNCLOS mandates that states must refrain from activities that might
jeopardize or impede the reaching of a final agreement on maritime delimitation.
Rovinia’s issuance of fishing licenses in the disputed Triton Shoal undermines the
potential for an equitable resolution of the maritime boundary dispute. In Guyana v.
Suriname27, the arbitral tribunal emphasized that unilateral actions in disputed maritime
areas violate UNCLOS obligations to preserve the marine environment and maintain the

26 The North Sea Continental Shelf Cases (Germany v. Denmark; Germany v. Netherlands), Judgment of 20
February 1969, ICJ Reports 1969, p. 3. URL: ICJ Case Law - The North Sea Continental Shelf Cases (Germany v.
Denmark; Germany v. Netherlands)
27 Guyana v. Suriname, Award of 17 September 2007, PCA Case No. 2004-02. URL: PCA Case Law - Guyana v.
Suriname

23
 status quo. Rovinia’s actions in the Triton Shoal not only disrupt this balance but also
violate international norms designed to prevent such destabilizing conduct.

F. Breach of Regional Practices and Duty of Cooperation

Rovinia’s unilateral actions undermine established regional practices of cooperation,
disregarding the duty of states to collaborate in managing shared marine resources and
respecting each other’s sovereign rights.

The ICJ in the Land and Maritime Boundary between Cameroon and Nigeria
(Cameroon v. Nigeria: Equatorial Guinea Intervening)28 stressed the importance of
cooperation and mutual respect in maintaining peaceful and stable maritime relations.
Rovinia’s unilateral actions are a breach of both international law and the principles of
regional cooperation, as established in this case. The longstanding regional cooperation
between coastal states, which is essential for managing shared marine resources, has been
disrupted by Rovinia’s actions. The ICJ has consistently reinforced the duty of states to
engage in cooperative efforts to avoid destabilizing activities and to respect one another’s
sovereignty over maritime zones.

Rovinia’s issuance of fishing licenses in the Triton Shoal disrupts both Ambrosia’s
exclusive rights under international law and the established principles of regional
cooperation. These actions not only infringe on Ambrosia’s sovereignty but also
destabilize the legal framework governing maritime relations in the region, highlighting
the significance of mutual respect and negotiation in maritime governance.

In conclusion, Rovinia’s issuance of fishing licenses in the Triton Shoal represents a clear
violation of Ambrosia’s exclusive rights under international law, including UNCLOS, the
2015 Freezing Law, and established case law. These actions undermine the fundamental
principles of sovereignty, good faith, and regional cooperation, and must be condemned
under international legal norms.

28 Land and Maritime Boundary between Cameroon and Nigeria (Cameroon v. Nigeria: Equatorial Guinea
Intervening), Judgment of 10 October 2002, ICJ Reports 2002, p. 303. URL: ICJ Case Law - Land and Maritime
Boundary between Cameroon and Nigeria

24
IV. THE SEIZURE AND SALE OF “THE FALCON” VIOLATED AMBROSIA’S
SOVEREIGN IMMUNITY
The unlawful seizure and sale of “The Falcon” infringes upon Ambrosia’s rights as a
sovereign state, violating its immunity from judicial measures of constraint on state
property. The actions of the Rovinian court and the Transitional Council’s purported
waiver of immunity must be scrutinized under the clear principles of international law
protecting state sovereignty and property. Below are the pertinent arguments to support
this claim.

A. The Judicial Seizure and Sale of “The Falcon” Under Rovinian Court Orders Violated
Ambrosia’s Rights to Immunity for Its State Property

1. The Order for the Seizure and Sale of “The Falcon” Violated Ambrosia’s Immunity
from Pre-Judgment Measures of Constraint
Under international law, particularly Article 18 of the UNCJISP, Ambrosia is entitled to
immunity from pre-judgment measures, such as the seizure or arrest of state property. 29 The
actions of the Rovinian court in ordering the seizure and sale of “The Falcon” violate this
immunity and cannot be justified under any lawful exception.30
2. The Order for the Seizure and Sale of “The Falcon” Violated Ambrosia’s Immunity
from Post-Judgment Measures of Constraint
Similarly, Article 19 of the UNCJISP upholds that states are immune from post-judgment
measures of constraint, including attachment or execution against state property. The judicial
actions of the Rovinian court constitute a clear violation of Ambrosia’s rights, as no valid waiver
or exception was in place to authorize such an interference with its sovereign property.31

29 Article 18 United Nations Convention on Jurisdictional Immunities of States and Their Property
30 Paragraphs 41 and 54 of the STATEMENT OF AGREED FACTS, CASE CONCERNING THE NAEGEA
SEA
(Union of Ambrosia v. Republic of Rovinia)
31 Paragraph 54 of the STATEMENT OF AGREED FACTS, CASE CONCERNING THE NAEGEA SEA
(Union of Ambrosia v. Republic of Rovinia)

25
B. The Transitional Council’s Waiver of Immunity Is Invalid Under International Law, as
the Council Lacked Lawful Authority to Act on Behalf of Ambrosia

1. The Transitional Council Lacks Constitutional Authority to Waive Ambrosia’s Immunity

The Republic of Ambrosia’s Constitution dictates clear procedures for the assumption of office, 32
establishing the powers of an elected head of state and government, and provides for a fixed term
of office.33 The unconstitutional actions of the Transitional Council in usurping power 34 are in
direct violation of these provisions, thereby rendering any waiver of immunity by the
Transitional Council legally invalid.
2. The Transitional Council’s Actions Threaten the Democratic Integrity of Ambrosia
As an unconstitutional body, the Transitional Council has no rightful authority to make decisions
that affect the state’s sovereignty, including waiving the state’s immunity. This breach of
constitutional procedure undermines the fundamental principles of Ambrosia’s democratic
system, and as such, any purported waiver of immunity is not binding under international law.

V. THE RECOGNITION OF THE TRANSITIONAL COUNCIL VIOLATED

INTERNATIONAL LAW AND CONSTITUTES UNLAWFUL INTERFERENCE IN
AMBROSIA’S DOMESTIC AFFAIRS.

Rovinia's recognition of Ambrosia’s Transitional Council violated international law, as it

undermines the constitutional government of Ambrosia and breaches the principle of non
intervention in domestic law.

1. Customary International Law applies

a. Rovinian has interfered in domestic affairs.

The identity of a government is a domestic issue. It is an established international legal principle

that states possess the freedom to choose their political systems without external interference.
This principle is rooted in state sovereignty and non interference in internal affairs. It is

32 Paragraph 1 of the STATEMENT OF AGREED FACTS, CASE CONCERNING THE NAEGEA SEA
(Union of Ambrosia v. Republic of Rovinia)
33 Paragraphs 7 and 23 of the STATEMENT OF AGREED FACTS, CASE CONCERNING THE NAEGEA SEA
(Union of Ambrosia v. Republic of Rovinia)
34 Paragraph 38 of the STATEMENT OF AGREED FACTS, CASE CONCERNING THE NAEGEA SEA
(Union of Ambrosia v. Republic of Rovinia)

26
enshrined in Article 2(1) and 2(4) of the Charter of the United Nations. In Military and
Paramilitary Activities in and against Nicaragua (Nicaragua v. United States), the ICJ held that
any intervention that directly or indirectly influences a state's domestic structure or government
is prohibited under international law. Likewise, the decision in Haya de la Torre (Colombia v.
Peru) (1951) ICJ Rep 71, where the ICJ reiterated that the determination of governmental
legitimacy remains primarily within the competence of the sovereign state concerned.

Thus, Ambrosia’s right to determine its governmental structure has been undermined by the
recognition of the Transitional Council when Judge Timbre sought and adopted the advice from
the Foreign Minister of Rovinia to determine the standing of the TC to represent Ambosia in the
O' mander corp case.

b. Non-Recognition of Unconstitutional Governments

A foundational principle in international law is principle of Stimson Doctrine. It prohibits

recognition of governments established through unconstitutional means. In Côte d’Ivoire
(Ouattara Government Recognition), international actors reaffirmed the necessity of maintaining
constitutional legitimacy in the recognition of governments. Acting President Zavala's response
to the establishment of the TC in paragraph 40 discloses the illegitimacy and unconstitutionality
of the TC. Also, the president's (President Prosper Derey) speech in paragraph 56 further reveals
that the assumption of power by the Transitional Council is unconstitutional. Thus, Rovinia's
recognition of the TC clearly undermined the constitutional government of Ambosia.

c. Effective Control Alone Does Not Confer Governmental Status

There are specific criteria for governmental status. They include: claim to governmental status,
autonomy, constitutionality, effective control and other considerations. In respect to
effective control, one of the ways to assess effective control is that the exercise of public
authority must, at least where there is more than one claimant to governmental status in respect
of the same state, extend over a substantial majority of the territory and population of that state.
However, as a matter of present-day customary international law, an unconstitutional
government will not enjoy governmental status, even if it exercises effective control, as long as a
rival constitutional claimant to governmental status exists.

27
In Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory
(2004) ICJ Rep 136, para 88, the Court held that the mere existence of a de facto authority does
not negate the requirement of legality and adherence to constitutional norms.

In spite of the facts according to paragraph 47, 48 & 49 that the TC controlled all parts of
Ambosia and had majority support from the people, it doesn't eliminate the fact that TC achieved
control of Ambrosia through unlawful and unconstitutional means and the Acting President
Zavala assumed and remained in this office pursuant to the constitutional provisions of Ambrosia
as shown in paragraph 24. Therefore, The TC’s claim to effective governance does not hold
sway in this situation and Rovinian's recognition under these circumstances constitutes a
violation of international law.

2. Rovinia’s Recognition of the Transitional Council was politically motivated.

If the recognition of the Transitional Council was constitutional and met the other necessary
criteria for recognition, it will nevertheless not give Rovinian an upper hand in this case because
Rovinia's unilateral act of recognition was clearly based on the fact that it will be to their own
interest and gain that the TC is recognised to the end that the immunity to which the Falcon
airplane is waived and to give validation to the seizure and sale of the airplane.

28
 PRAYER FOR RELIEF

The Applicant, the Union of Ambrosia, respectfully requests the Court to adjudge and

declare that:

1. The International Court of Justice has jurisdiction to hear this case under

Article XXI of the OCDP Charter, and Rovinia is obligated to submit to the

Court’s authority in accordance with its international legal obligations.

2. Rovinia’s arrest and prosecution of Ms. Gertrude Cross violated international

law, including the principles of state immunity and jurisdiction, and Rovinia is

required to release Ms. Cross immediately and provide reparations for the harm

caused.

3. Rovinia’s issuance of fishing licenses in the Triton Shoal infringed Ambrosia’s

sovereign rights under international law, including the United Nations

Convention on the Law of the Sea, and Rovinia must cease all unlawful

activities in Ambrosia’s Exclusive Economic Zone.

4. Rovinia’s seizure and sale of the aircraft “The Falcon” violated Ambrosia’s

sovereign immunity, and Rovinia must provide reparations for this breach of

international law.

5. Rovinia’s recognition of the Transitional Council as the legitimate government

of Ambrosia constitutes unlawful interference in Ambrosia’s domestic affairs,

and Rovinia must revoke its recognition and refrain from future actions that

undermine Ambrosia’s sovereignty and constitutional order.

29
 Respectfully submitted,

AGENTS FOR THE APPLICANT

30