memorial

CONCLUSION AND PRAYER FOR RELIEFFor the foregoing reasons, Respondents respectfully request this Honourable Court to adjudge

and declare as follows:

(1) The incursion of Rafalean troops into the territory of DRT is in violation of JMSA

and is accordingly in violation of international law.

(2) The secession and subsequent annexation of the territory of DRT is in violation of

international law and Kingdom of Rafale is responsible for the same; and

(3) The actions of Azazel in changing the depicted borders of Azazel by introducing a

worm into the servers of MapMyRafale are in conformity with international law, or in

any case the wrongfulness of these actions are precluded under customary

international law.

Respectfully submitted,

Agents for Applicants

Contents

Statement of jurisdiction.......................................................................................................................4

QUESTIONS PRESENTED........................................................................................................................5

STATEMENT OF FACTS...........................................................................................................................6

SUMMARY OF PLEADINGS.....................................................................................................................7

A. Action of Azazel was in conformity of international law...........................................................8

PLEADINGS.........................................................................................................................................9

1. THE INCURSION OF THE RAFALEAN TROOPS INTO THE TERRITORY OF THE DRT IS IN VIOLATION OF THE JMSA AND IS ACCORDINGLY IN VIOLATION OF INTERNATIONAL LAW...............9

A. That the JMSA is a valid treaty under international law........................................................9

a. DRT is the lawful territory of the Republic of Azazel............................................................11

B. That the incursion of Rafalean troops into the territory of DRT amounts to aggression or use of force, and is accordingly violation of international law.....................................................12

2. THE SECESSION AND SUBSEQUENT ANNEXATION OF TERRITORY OF DRT IS IN VIOLATION OF THE INTERNATIONAL LAW AND THE KINGDOM OF RAFAL IS RESPONSIBLE FOR THE SAME...........15

A. That the secession of the DRT is not valid............................................................................15

B. That annexation of DRT by Kingdom of Rafale is in violation of international law...............17

3. THE ACTION OF AZAZEL IN CHANGING THE DEPICTED BORDERS OF AZAZEL BY INTRODUCING WORM INTO THE THE SERVERS OF MAPMYRAFALE ARE IN CONFORMITY WITH INTERNATIONAL LAW, OR IN ANY CASE THE WRONGNESS OF THESE ACTIONS ARE PRECLUDED UNDER CUSTOMARY INTERNATIONAL LA..........................................................................................................................20

A. Action of Rafale owned MMR Corp. is amounts to internationally wrongful act against Azazel...........................................................................................................................................20

B. It’s action is precluded under customary international law as a countermeasure..............21

CONCLUSION AND PRAYER FOR RELIEF...............................................................................................25

Index of authorities

Statement of jurisdictionThe Republic of Azazel and the Kingdom of Rafale have submitted the present dispute to this

Court by Special Agreement, sixteenth day of July in the year two thousand and

fourteen, pursuant to article 40(1) of the Court’s Statute. Both parties have agreed to the

contents of the Compromis submitted as part of the Special Agreement. All States parties to

this dispute have accepted the compulsory jurisdiction of the Court in accordance with article

36(2) of the Court’s Statute. All parties shall accept the judgment of this Court as final and

binding and shall execute it in good faith in its entirety.

QUESTIONS PRESENTED1. THE INCURSION OF THE RAFALEAN TROOPS INTO THE TERRITORY OF THE

DRT IS IN VIOLATION OF THE JMSA AND IS ACCORDINGLY IN VIOLATION OF INTERNATIONAL LAW?

2. THE SECESSION AND SUBSEQUENT ANNEXATION OF TERRITORY OF DRT IS IN VIOLATION OF THE INTERNATIONAL LAW AND THE KINGDOM OF RAFAL IS RESPONSIBLE FOR THE SAME?

3. THE ACTION OF AZAZEL IN CHANGING THE DEPICTED BORDERS OF AZAZEL BY INTRODUCING WORM INTO THE THE SERVERS OF MAPMYRAFALE ARE IN CONFORMITY WITH INTERNATIONAL LAW, OR IN ANY CASE THE WRONGNESS OF THESE ACTIONS ARE PRECLUDED UNDER CUSTOMARY INTERNATIONAL LAW?

STATEMENT OF FACTS1. Azazel, a country situated in Eurasia, is divided more or less in two parts, from north

to south, by the spine mountains. Shortly after WW II it was ravaged by a bitter civil

war resulting into its partition into Republic of Azazel and Kingdom of Rafale.

2. In 1993, certain geographical changed took place along the spine mountains taking

advantage of which the Azazelian Army marched ahead towards Rafale and captured

the territory which later came to be known as DRT. Under the global pressure, both

countries signed Joplin Memorandum of Security Assurance, according to which both

countries were required to keep their armies along what came to be known as Mary-

Kubis Line.

3. In 2010, Doodle Inc., a company incorporated in Azazel, depicted map of Azazel

showing Mary-Kubis line as their border. The issue was not taken very well by

Rafale, and it banned Doodle Inc. in its territory.

4. To capitalize the absence of Doodle Inc., MapMyRrafale, a state owned corporation

started its new product which depicted the border of Rafale along the Spine

Mountains.

5. In its protest of falsely depiction of the borders by MapMyRafale, Azazel introduced

worm into the servers of MapMyRafale and hacked it and defended its action as

countermeasure.

6. Meanwhile in 2012, the inhabitants of DRT started demanding secession of DRT

from Azazel, as result referendum of independence was held in DRT in which

majority of inhabitants of DRT ( 34% of of total voter) opted for independence.

7. Accordingly Azazelian army started to retreat back from DRT. Meanwhile,

PhunsukWangdu, leader of the DRT announced accession of DRT with Rafale.

SUMMARY OF PLEADINGS1. THE INCURSION OF THE RAFALEAN TROOPS INTO THE TERRITORY OF THE

DRT IS IN VIOLATION OF THE JMSA AND IS ACCORDINGLY IN VIOLATION OF

INTERNATIONAL LAW.

A. That the JMSA is a valid treaty under international law

a. Parties have capacity to enter into a treaty

b. It is an international agreement

c. It is subject to international law

B. DRT is the lawful territory of the Republic of Azazel

2. THE SECESSION AND SUBSEQUENT ANNEXATION OF TERRITORY OF DRT IS

IN VIOLATION OF THE INTERNATIONAL LAW AND THE KINGDOM OF RAFAL IS

RESPONSIBLE FOR THE SAME.

A. That the secession of the DRT is not valid

B. That annexation of DRT by Kingdom of Rafale is in violation of international law

3. THE ACTION OF AZAZEL IN CHANGING THE DEPICTED BORDERS OF

AZAZEL BY INTRODUCING WORM INTO THE THE SERVERS OF

MAPMYRAFALE ARE IN CONFORMITY WITH INTERNATIONAL LAW, OR

IN ANY CASE THE WRONGNESS OF THESE ACTIONS ARE PRECLUDED

UNDER CUSTOMARY INTERNATIONAL LAW.

A. Action of Azazel was in conformity of international law

a. Action of Rafale owned MapMyRafale Corp. amounts to internationally wrongful

act against Azazel

b. The act of Azazel in response is valid under customary international law as a

countermeasure.

i. it has observed all necessary procedural obligations of a lawful countermeasure

ii. countermeasure is in proportion with the injury suffered by Azazel

PLEADINGS

1. THE INCURSION OF THE RAFALEAN TROOPS INTO THE TERRITORY OF THE DRT IS IN VIOLATION OF THE JMSA AND IS ACCORDINGLY IN VIOLATION OF INTERNATIONAL LAW.

A. The JMSA is a valid treaty and has a binding effect under international law1. It is respectfully submitted that The Vienna Convention on Law of Treaties,

19691 defines a treaty as ‘an international agreement concluded between states in

written form and governed by the international law, whether embodied in a

single instrument or in two or more related instruments and whatever its

particular designation.2

2. It is respectfully submitted that therefore if any international agreement , made

between states and if it is creating binding obligation3 and governed by

international law then that agreement can be called as a treaty.

3. It is submitted that the term Agreement is wider as compared to treaty and also it

can be confirmed by Article 102 of UN Charter that refers “every treaty and

every international agreements’’.4Thus, all treaties are international agreement

but all international agreements are not the treaties.

4. It is submitted that an international agreement means an agreement intended to

be governed by the international law between two or more states of international

law possessing international personality and having capacity to enter into

treaties.5

5. Treaties may be made or concluded by the parties in virtually any mannerthey wish. There is no prescribed form or procedure, and how a treatyis formulated and by whom it is actually signed will depend upon theintention and agreement

1Hereinafter referred to as VCLT.2VCLT, Art. 2.3Fitzmaurice, ‘law and procedure’ Cambridge University Press, 1993 pp. 204-74MALCOLM N. SHAW, INTERNATIONAL LAW( Cambridge university press, sixth ed. 2008) at 9095M.Jones, Full Powers and Ratification, Cambridge, 1946. at pp. 96

of the states concerned. Treaties may be draftedas between states, or governments, or heads of states, or governmentaldepartments, whichever appears the most expedient6 a state is presumed to have given its consent to be bound by the treaty if it has been signed by the the head of the state.7 Moreover once consent is given to be bound by the treaty, it is presumed to have come into force.8

6. It is submitted that the agreement is subject to international law as both the

parties to the JSMA have agreed to be governed by the Charter of the United

Nations.9 both the parties to the agreement are independent and sovereign states10

and both have capacity to enter into a treaty. Thus, the JSMA is an international

treaty creating a legal relation between the parties to the insant cse.

7. A state may regard itself as having given its consent to the text of the treaty by

signature in defined circumstances noted by article 12, that is, where the treaty

provides that signature shall have that effect, or where it is otherwise established

that the negotiating states were agreed that signature should have that effect, or

where the intention of the state to give that effect to the signature appears from

the full powers of its representative or was expressed during the negotiations. so

here it can be concluded that JSMA is a treaty because both the head of the state

have signed the treaty11 and therefore, it has come into force.

8. It is submitted that a treaty has a legal basis and that basis is the presence of

common consent12 and both of the states have freely given their consent13 to be

bound by the terms of the treaty, and therefore the treaty does not suffer from

6Supra n. 4, Art.7,VCLT7Ibid., Art. 7 (2) (a); supra n. 9.8Supra n. 4, Art.24 (3).9Joplin Memorandum of Security Assurance, Art. 2.10 As both the parties are member of the United Nations, Compromis [33].11 Annexure I compromis12Reservations to the Convention on the Prevention and Punishment of the Crime of Genocide, [1951] I.C.J. Rep. 32.13Preamble of JMSA , also signature by the head of the states is evidence of their consent Vienna Convention of Law of Treaties, Art. 7(2) and Art. 11.

vice of prohibited means of entering into a treaty. Further it is given14 that both

parties signed treaties after six months of bilateral talks. thus can be concluded

that both the parties have sufficient time to enter into the agreement. and thus it

is strongly established that both the parties had given consent to the treaty before

signing the treaty.

a. That the Disputed Rafale Territory is the lawful territory of the Azazel

9. It is submitted that the acquisition of a territory by boundary treaties is an

accepted mode of acquisition of territory and it establishes an objective territorial

regime valid ergaomnes.15 Thus a territory may be legally acquired by a

Boundary treaty where a sovereign state has agreed to give a piece of its territory

to another state.16

10. It is submitted that by the time of conclusion of JMSA was signed, the Republic

of Azazel had already taken control over the Disputed Rafale Territory17 and

according to JMSA both states have expressly agreed to maintain their troops

only along the present borders which in the instant case is DRT..18

11. It is respectfully submitted that in order to determine the intention of the parties,

reliance can be placed on Article 31 and Article 32 of VCLT,1969. A treaty

should be interpreted in good faith19 and in accordance with the ordinary

meaning given to the terms of treaty in their context and in the light of its object

14 Para. 13 copmromis15 Supra 4, pp. 49616Ibid.17Hereafter referred as DRT.18Supra n. 13, Art. 3. 19 Art. 31, VCLT

and purpose.20 Ordinary meaning of a term of the treaty should be determined in

the light of itsobject and purpose.21

12. It is respectfully submitted that in the instant case, the object and purpose of the

JSMA treaty is to maintain peace and security at the present border and to

respect the independence and sovereignty of states concerned.22 Therefore it can

easily be inferred that under JMSA, Kingdom of Rafale intended to give the

captured territory to Republic of Azazel.

13. Further it is submitted that the passage of sovereignty by means of an agreement

is an established and recognised concept in the international law if the respective

parties to the respective agreement intends to do so. In the instant case Rafale

has transferred its sovereignty over DRT to Azazel by JMSA and it is legal as

international law recognises such a right

B. the incursion of Rafalean troops into the territory of DRT amounts to aggression or use of force, and therefore the act of rafalean troops is in violation of recognised international law.

14. It is submitted that the the sovereignty of states is the basis of international law

and it is the right ofevery sovereign state to conduct its affairs, internal as well as

external, without interference of any other state23.

15. It is submitted that the United Nations Charter provides that all members shall

refrain in their international relations from the threat or use of force against

the territorial integrity or political independence of any state, or in any other

20Supra n. 3, Art. 31.21Supra 4, pp.83922 Annexure 1 ,compromis23Nicaragua V. United States of America, [1986] I.C.J. Rep. 392.

manner inconsistent with the purposes of the United Nations.24 This principle

is also a pre-emptory norm not to be violated by states.Thus all countries have

duty and obligation to not to use force against soverignity and political

independence any other state.

16. It is submitted that the use of force would violate international law. Thus even

the Rafale’s claim is assumed to be valid, it has still violated the general

principles of international law.

17. It is submitted that the use of force cannot be justified on any ground except as

provided in the charter itself i.e. self-defence,25 participations in United Nation

enforcement action, or seemingly, in some cases of humanitarian intervention

with UN authorisation.26Therefore, it is clear that Kingdom of Rafale, by sending

the troops into the territory of the Azazel, has used the force and has thus

violated the territorial sovereignty of the Azazel, and it is therefore the violation

of the provisions of the charter of the United Nations.

18. It is further submitted that even if the claim of Rafale over Disputed Rafalean

Territory is accepted, then also Rafale will still be guilty of violating the

international law because use of force is against principles of international law.

24UN Charter, Art. 2(4); supra n. 3.25The UN Charter, Art. 51.26Supra n. 3, p. 893.

2. THE SECESSION AND SUBSEQUENT ANNEXATION OF TERRITORY OF DRT IS IN VIOLATION OF THE INTERNATIONAL LAW AND THE KINGDOM OF RAFAL IS RESPONSIBLE FOR THE SAME.

A. the secession of the Disputed rafalean territory is illegal19. It is submitted that the right of the people to self-determination is one of the

essential principles of international law.27 Article 1(2) of the International

Covenant on Economic, Social and Cultural Rights, 197028 states that right to

self-determination is the right of every person and it is the responsibility of the

state parties to the covenant to promote the realization of right to self-

determination in conformity with the UN Charter.29

20. It is submitted that in a case30 it was held by international court of justice that

the right to self-determination of peoples was held to be part of customary

international law. In yet another case, court recognised its essential binding

obligation character.31 In view of some writers, principle of self-determination is

also jus cogens.32

21. It is submitted that the republic of Azazel, is a party to the ICESCR without any

reservation,33 and therefore it is bound to ensure that every person in the

disputed rafalean territory enjoys the right of self-determination, and in

furtherance of that obligation Azazel conducted referendum in the DRT and

which resulted in people of DRT chosing independence.34

27 Supra 3. pp. 20528Hereafter referred as ICESCR.29International Covenant on Economic, Social and Cultural Rights 1970, Art.1(3).30Advisory Opinion on Legal Consequences for the states of continued presence of South Africa in Namibia, [1971] I.C.J. Rep. 31.31Supra n. 3.32Supra n.3 pp. 48333Compromis [33].34Compromis [27], [28].

22. It is submitted that International law donot contain either a right of unilateral

secession or the explicit denial of this right35 therefore, unilateral declaration of

independence or secession can be regarded as legal in limited circumstances i.e.

when the territory is subject to decolonialization, or parent state has given its

consent, or people of the territory are subject to flagrant violation of human

rights etc.36 It is further submitted that here in the instant case, people of DRT are

neither under a colonial rule nor had parent state Azazel completed its process of

secession, as the final decision of secession is yet to be taken by the house of

representative and people of DRT are not subjected to flagrant violation of

human rights.

23. It is submitted that Legality of secession is subject to pre emptory norms i.e.

secession must not have taken place against any of the the principles of

international law i.e. breach of territorial sovereignty and use of force. 37

24. It is submitted that in the instant case an unlawful secession in violation of pre-

emptory norms has took place because Rafale has violated jus cogens principles

of non-use of force and territorial sovereignty of a state under Article 2(4) of the

UN Charter. Also, since Azazel being a democratic state,therefore people of

DRT enjoys internal self-determination, and thus these people do not have any

right to secede fromrepublic of Azazel without the consent of azazel through its

House of Representative.

35Antonnio cassesse, principles of international relations pp. 62; Reference re Secession Qubec, [1998] 2 I.C.J. 217.36Ibid.;.37Kosovo case (Request for Advisory Opinion), [2010] I.C.J. Rep. 403.

B. The illegal annexation of DRT by Kingdom of Rafale is a violation of international law

25. It is further submitted that Annexation means a forceful acquisition of a piece of

territory of a state with the intention to retain it38. Thus the element of force is

essential to for any country or estate to annex and therefore annexation of a

territory is invalid.39 Since Force is being prohibited by the UN Charter40, the

annexation of a territory is therefore a violation of international law.41

26. It is further submitted that after the decision of Azazel to retreat its troops from

DRT and to secede DRT from Azazel,it was announced by PhunsukWngdu who

is the leader of free DRT movement along with the monarch of Rafale

announced that DRT would again join Rafale. Thereafter, Rafale sent its troops

to DRT which was still a lawful territory of Azazel.42

27. It is submitted that the act of Rafale in sending the troops to the territory of

republic of Azazel amounts to annexation through use of force and therefore it

violates the jus cogens43 and the principles of international law.44further, the act

of annexing the DRT by kingdom of rafale violates the territorial integrity of

Azazel, and this is against the principles of international customary law.45

28. It is submitted that Kingdom of Rafale, intervenen in the internal matters of a

state,thus it has violated the principle of non-intervention recoginsed in

38L. OPPENHEIM, OPPENHEIM’S INTERNATIONAL LAW, VOLUME 1, PEACE, PART 2 TO 4, 700 (R. Jennings & A. Watts eds., 9th edn. 2005).39It is contrary to UN Charter Art. 2(4).40Article 2(4) of UN Charter.41Supra n. 18.42Compromis [29].43Supra n. 3. pp 49544Threat or Use of force is prohibited under Article 2(4) of the UN Charter.45Under Article 2(4) of UN Charter.

international customary law and therefore has violated an international

customary law.

29. It is submitted that every state has a duty to avoid use of any forcible action that

deprives peoples referred in to the equal rights and self-determination of their

right to self-determination and freedom and independence, and by the act of use

of force and annexation of DRT, Rafale has violated the international law.

30. It is further submitted that, kingdom of Rafale, by an act annexation of DRT

violates the right to self-determination of the people of DRT as it is not allowing

them to freely choose their political and social status as given in the UN Charter,

ICCPR and ICESCR46. Thus it can be said that by denial of the right of the

people of DRT to enjoy right to self-determination, Rafale is violating the

principle of international law.47

3. THE ACTION OF AZAZEL IN CHANGING THE DEPICTED BORDERS OF AZAZEL BY INTRODUCING WORM INTO THE THE SERVERS OF MAPMYRAFALE ARE IN CONFORMITY WITH INTERNATIONAL LAW, OR IN ANY CASE THE WRONGNESS OF THESE ACTIONS ARE PRECLUDED UNDER CUSTOMARY INTERNATIONAL LAW.

A. The Act of MMR Corporation of kingdom of rafale is an internationally wrongful act against the republic of Azazel

46Ibid.47Supra n. 30, p.773-4.

31. It is submitted that both the parties to the JSMA, being the member of the United

Nations,48 have certain obligations of respecting the territorial integrity and

political independence of each other. It is further submitted that if a state does

any act which violates international obligation49, towards any other state, it will

be said to have committed an act recognised internationally to be a wrongful act

and it thus entails certain responsibility towards that state.50

32. It is submitted that an International wrongful act has been defined as any act or

omission attributable to states or other subjects of international law which

constitutes of breach of an international obligation. 51

33. Thus, there are two elements of international wrongful act, first that the conduct

in question must be attributable to the State under international law and

secondly,the conduct must constitute a breach of an international legal obligation

in force for that State at that time.52

34. It is submitted that States are obliged to take measures to prevent harm which

affects the interests of another states that can be caused by public or private

activities53 conducted within its jurisdiction or control.54

35. It is submitted that in the instant case the kingdom of Rafale is a member of the

United Nations55 so it owes an duty and an obligation as well to respect the

territorial integrity of the Azazel. This obligation is originated from the UN

Charter itself.

48Compromis [33].49Supra n. 3 pp 118.50 S.S.Wimbladon., [1922] P.C.I.J. Series A, No. 2,51Draft Articles on state Responsibility for Internationally Wrongful Acts 2001, 2 YILC 165 (1973) Art. 3; supra n.3.52United States Diplomatic and Consuler Staff in Tehren (United States of America v. Iran),[1980] I.C.J. Rep.4.53J.B. MOORIE, Alabama Claims, A DIGEST IN INTERNATIONAL LAW 7 (15069).54Pulp Mills on the River Uruguay (Argentina v. Uruguay) [2011] I.C.J. Rep. 18.55Compromis [33].

36. It is submitted that the action of MyMapRafale Corporation of kingdom of Rafale

in falsely depicting the map of Republic of Azazel, is in violation of the

obligation on the part of kingdom of Rafale to respect the territorial integrity of

Azazel. The MyMapRafale Corp. is a state owned corporation,56 thus it qualifies

to be an organ of the state of Rafale, and therefore its actions are attributable to the

kingdom of Rafale.57

B. The act of mymaprafale is a which is precluded under customary international law as a countermeasure to any act

37. It is respectfully submitted that the wrongfulness of an act of a State not in

conformity with an international obligation towards another State is precluded if

and to the extent that the act constitutes a countermeasure taken against the latter

State.58 And further it is submitted that the Countermeasure means an act of

unilateral enforcement which violates the rights of other states, and is justified

by the refusal of the state committing an internationally wrongful act, to honour

an obligation which arising under the rule of state responsibility.59 In other

words, it refers to any act which is non-violent act and which are illegal in

themselves, but they become legal when done by one state in response to the

commission of an previous illegal act by another state towards the former.60 this

justifies otherwise unlawful conduct taken in response to a previous international

wrongful act of another State and directed against that State.61

56Compromis [21].57Supra n. 3 pp 78358Draft Articles on Responsibility of States for Internationally Wrongful Acts 2001, Art. 22.59Supra n. .60OSCAR SCHACHTER, INTERNATIONAL LAW IN THEORY AND PRACTICE, 167 (Kluwer Law International, London, 1995).61Gabčíkovo-Nagymaros Project (Hungary v. Slovakia), [1997] I.C.J. Rep. 7.

38. It is further submitted that the countermeasures are lawful to the extent they that

they have been taken in accordance with certain substantial and procedural

conditions,62 like it must have been taken in response to a previous international

wrongful act of another state and must be directed against that state, he injured

state must have called upon the state committing the wrongful act to discontinue

its wrongful conduct or to make reparation for it, it must be aimed to induce the

wrongdoing state to comply with its obligations under international law it must

be reversible, and its effects must be in proportion with the wrong done.

39. It is submitted that a countermeasure is said to be in proportion with injury

suffered if it commensurates with initial wrong taking in account the gravity of

the internationally wrongful act and the rights in question. Proportionality of

ciountermeasure must be assessed by taking into account not only the purely

quantitative element of injury suffered, but also some qualitative factors such as

the and the seriousness of the breach importance of the interest protected by the

rule infringed.

40. It is submitted that in the instant case, all necessary substantive and procedural

conditions of a countermeasure should been fulfilled. It is to be taken as a

response to the earlier internationally wrongful act of Rafale which had, by

depicting false map, 63violated the territorial integrity of Azazel.

41. It is submitted that Azazel had also called upon Rafale to discontinue its

internationally wrongful activity,64 and countermeasure was not taken to punish

Rafale but to induce or compel it to abide by its international obligation of

respecting the territorial integrity of Azazel.

62Supra n.3. pp 12463Compromis [22].64Compromis [20].

42. It is further submitted that the action taken by Azazel to introduce worm into the

servers of MapMyWorld65 was not irreversible, as it can easily be taken back by

Azazel and it does not hamper the permanent infrastructure of MapMyWorld.

43. It isfurther submitted that the countermeasure was in proportion to the right

breached. The effect of the countermeasure is equivalent to the effect of injury

caused i.e. it has restored the position prior to time when wrong was done. Also,

it is related with same right in question i.e. territorial integrity of Azazel.

44. It isfurther submitted that it is clear that countermeasure taken by Azazel was in

conformity with the international customary law of countermeasure.

65Compromis [23].

CONCLUSION AND PRAYER FOR RELIEFFor the foregoing reasons, Respondents respectfully request this Honourable Court to adjudge

and declare as follows:

(4) The incursion of Rafalean troops into the territory of DRT is in violation of JMSA

and is accordingly in violation of international law.

(5) The secession and subsequent annexation of the territory of DRT is in violation of

international law and Kingdom of Rafale is responsible for the same; and

(6) The actions of Azazel in changing the depicted borders of Azazel by introducing a

worm into the servers of MapMyRafale are in conformity with international law, or in

any case the wrongfulness of these actions are precluded under customary

international law.

Respectfully submitted,

Agents for Applicants