Condensed Facts

Pertinent facts: For much of Arista’s history, its economy was based on small-scale mining and ecotourism. The coasts of the low-lying regions of Prah’sa and Parhul are known for their beaches while the mountainous region of Pintana is known as a spelunking haven where explorers can venture into caves, both natural and man-made, and tunnels which were once hideouts for Vinthi rebels during the Yvesolian occupation. The highest point in Pintana Island is Mt. Pamfall at 19,341 feet above sea level which has been home to the Vinthi people since the 1850.A small percentage of the population of Vinthi people originally lived in the lowlying regions of Prah’sa and Parhul but because of the Yvesolian occupation, they were forced to live in the mountains of Pintana. Arista is home to 3,000,000 people. About 50% of the population lives on less than $1 a day. The average annual gross domestic product of Arista is around $5 billion dollars. The capital of Arista is Prah’sa. Prah’sa and Parhul host 80% of the Aristan’s population The Federal States of Ravar has a population of approximately 8,000,000 people. About 10% of the population lives on less than $1 a day. The average yearly gross domestic product of Ravar is around $5 trillion dollars. Ravar has two alternate seasons: summer during the months of October to March and rainy during April to September. Since the beginning of the 21st century and due to the advent of climate change, the summer season becomes significantly longer than the rainy season. In the 1960s, Ravarian geologists discovered significant reserves of anthracite coal within the mountains of Pintana. However, at that time, it was not technologically feasible to exploit these deposits. 6. Between 1970 and 1973, Arista and Ravar engaged in extensive negotiation on the demarcation of their territorial claims in the Khu’Tan Mountain Range, resulting in a treaty dated 30 March 1976. The Khu’Tan Mountain Range Treaty of 1976 was hailed by both sides as a historic achievement, which allowed Arista and Ravar to protect vital natural resources within the Khu’Tan Mountain Range. The “whereas” clauses of the Treaty do provide, however, that “a key shared objective” of the parties to the Treaty was “to balance, and insofar as possible, to promote, the interests of the State Parties in respect of exploration, exploitation, and protection of this mountain range area of great importance to them both.” Both parties ratified the Khu’Tan Mountain Range Treaty in 1977. A year after, the Ravarian House of Representatives enacted the “Mining Act of 1978” which requires mining licensees to obtain periodic environmental reports on any mining or mining-related activity conducted in the Khu’Tan Mountain Range. In January 2000, the Aristan government entered into a mining-project agreement with TRATVIA INDUSTRIES INC. (hereinafter “Tratvia”), a newly established and licensed Ravarian mining company owned by Adair Vishna. Vishna was a member of the Ravarian House of Representatives for nine years (1989-1998). Vishna formerly headed the House Committee on Environmental Protection. After the approval of the environmental impact report by the Aristan Ministry on Environment (AME), it took two months for Tratvia to establish itself in the mountains of Pintana and begin the mining activities. The contract provides that Tratvia will provide the necessary technology and services for any mining and mining-related activity. All profits will be divided equally between the

governments of Arista and Ravar. Tratvia will be paid a reasonable compensation for its services. Tratvia used a type of surface mining called “strip-mining.” In 2004, the International League for Sustainable Advocacy (ILSA), an independent antimining advocacy group based in Rhat’sa, published a report that despite the successes of the mining project in Arista, significant environmental impact will occur in about six years or upon the completion of the extraction process. Tratvia ignored this report. In mid-April, a fire broke out in the Tratvia facility. It took two full days to quench the fire. Investigations by Ravarian police revealed that the fire was caused by excessive heat and a sudden upsurge in temperature in the Tratvia facility. The fire and the debris from the burnt coal caused the air to thicken and soon, employees of the Tratvia facility were laid off after several of them developed lung problems. Dust accumulated like a fog over the mountains and the wind from the east drove the dust over to the Aristan border. In a few months, the circumstances became too unbearable for the inhabitants of Mt. Pamfall. The infants were getting sickly and their well water became contaminated. Around 750 Vinthis, majority of whom were employed in industries in Prah’sa and Parhul and are living in the lower regions of the mountains, descended from the mountains and settled in the regions of Prah’sa. However, another 1,000 Vinthis, consisting mostly of former rebels and their families refused to settle in the region of Prah’sa and Parhul because they prefer the life in the mountains. Instead, they attempted to cross the border over to Ravar through the lower mountains of Khu’Tan. Their attempts proved unsuccessful. They were detained by Ravarian immigration authorities and brought to the Yumarian Refugee Center (YRC) under the Ravarian Bureau of Immigration. In early 2012, a severe bronchial infection spread throughout the refugee center that it became necessary to quarantine the area for two weeks. Around 77 Vinthis, mostly children below 10 years old and women, died. Around 50 others developed complications. The Aristan government immediately sent medical personnel to assist in the treatment of the disease. In response to this, Vinthi leaders engaged in negotiation with the immigration authorities to provide for better living conditions in the center. The Vinthi leaders contended that the children and the women are not used to living in cramped up living spaces. They also argued that the YRC resembles a detention facility as the same was formerly used as a minimum security prison. The Vinthis also complained about inadequate food and water and lack of access to medical services. Psychologists also determined that the quarantine had a negative impact on the psychiatric health of the detainees. The immigration authorities dismissed such averments. In response to this, Vinthi leaders engaged in negotiation with the immigration authorities to provide for better living conditions in the center. The Vinthi leaders contended that the children and the women are not used to living in cramped up living spaces. They also argued that the YRC resembles a detention facility as the same was formerly used as a minimum security prison. The Vinthis also complained about inadequate food and water and lack of access to medical services. Psychologists also determined that the quarantine had a negative impact on the psychiatric health of the detainees. The immigration authorities dismissed such averments.

the Ravarians, specifically those in Yumar, feared that they will contract the infection from the Vinthi people. Petitions for the ouster and transfer of the Vinthis were submitted by lobbyists before the House of Representatives. Classes were suspended and offices were closed. Due to these outcries, the Government of Ravaria forged a written deal with the Zoivel, a nearby archipelago whose facilities were suited to the needs of the Vinthi people. A number of international human rights non-governmental organizations vigorously protested the proposed transfer. One of these NGOs, Immigration Law Society (ILS), published a report declaring in part: The ILS is concerned with the transfer of the refugees from YRC to a nation, which has, at best, a dubious track record on human rights. This decision should not veer us away from the omission by Ravarian authorities to improve their facilities for the Vinthis. Shifting the burden to the Kingdom of Zoivel will only worsen the condition of the lives of the refugees. The Kingdom of Zoivel is a state-party to the International Convention on Civil and Political Rights. It used to be a haven for international refugees until a civil war broke out in 1985. Since then, human rights violations became rampant in Zoivel and prosecution thereof became scarce. Nevertheless, the facilities for refugees were wellpreserved. The queen, in her State of the Kingdom address, promised to invest funds to combat and prosecute human rights violations in Zoivel. The capital of Zoivel is the head office of the only World Health Organization Center for Disease Control (WHO-CDC) facility in Andhal. The Aristan government objected in the strongest terms the transfer of the Vinthi people to the Kingdom of Zoivel. President Sabda issued a public statement: “Our government urges the Ravarian government to cut the deal with the government of Zoivel as to the proposed transfer of the Vinthis to Zoivel. Their plight is caused by the negligence of the Ravarian government in the mountains of Khu’Tan. And it is their responsibility to provide the Vinthi migrants with decent living facilities and to supply them with their basic needs. To transfer the Vinthis to Zoivel is a violation of international law..” The head of the Bureau of Foreign Affairs of Ravar, responded in a declaration, saying: “The arrival of the Vinthis in Ravarian territory is an infringement of our immigration laws. The government has the absolute jurisdiction to deal with these illegal aliens. In fact, their arrival posed a grave danger to the health and well-being of our nationals. Any action to be taken by our government is purely domestic matter and needs no interference from any state.” Arista and Ravar became members of the United Nations in 1947. Both signed and ratified the International Convention on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the Vienna Convention on the Law of Treaties, the Convention Relating to the Status of Refugees, and the Protocol Relating to the Status of Refugees. Both states also signed and ratified the Stockholm Declaration, the United Nations Framework Convention on Climate Change and the 1979 Convention on Long-range Transboundary Air Pollution. The Federal States of Ravar requests the Court to adjudge and declare that: (1) Ravar’s conduct with respect to the mining project complied in all respects with its obligations under international law and the terms of the Khu’Tan Mountain Range Treaty; (2) Ravar has not violated international law in its treatment of the migrants from Arista, and that the Vinthi people

are being treated in accordance with the obligations of Ravar under international law and their proposed transfer to Zoivel is legal. The Republic of Arista requests the Court to adjudge and declare that: (1) Ravar’s acts and omissions with respect to the conduct of the mining project violated international law; (2) Ravar’s failure to process the migrants, its treatment of the detained Vinthi people and the proposed transfer to Zoivel, violated international law