STATEMENT OF FACTS

BACKGROUND AND GEOGRAPHY

The Federation of the Clans of the Atan (herein after referred as Atania) and the Kingdom

of Rahad (herein after referred as Rahad) are neighboring States that occupy two-thirds and

one-third of the Nomad Coast respectively. The nomad coast is bound to north by the great

garnet desert and otherwise by(no by) surrounded by the Emerald Ocean. Rahad is a

constitutional Monarchy with largest exporter of natural gas whereas Atan is a republic

federation with major source of revenue being tourism and grain exports.

The Greater Inata Aquifer (herein after referred as Aquifer)

being the largest underground source of fresh water in the nomad coast. In the report

published by the Rahadi Ministry it was concluded that the Aquifer covered more than

274,000 Sq. Km. Within nomad coast out of which 65% was located in Rahad and 35% in

Atania.

The Kin Canyon Complex (herein after referred as The Complex), a group of three canyons

located between the border of Atania and Rahad. Canyons constituting the complex are

located at the deepest part of greater wadi system. TAmong(correct it) any historic sites

within the complex and great interet(interest) to archaeologist and attraction(try to change the

sentence as the usage of conjunction isnt proper) to tourist were a walled fortress named the

stronghold and a free standing butte named Sunrise Mesa . The two of three canyons were

in Atania and the third canyon and Sunrise Mesa are(were) in Rahad. These are a rich source

of archaeological treasures since Neolithic era. In 1994, the world heritage committee had

listed the complex as a mixed heritage site.

The history of both the nation traces its root from Atan. In 500 CE, Teppa, a warrior of clan

Kin had defended the invader Ifan from invading the canyon. In his victory, she raised Ruby

Sipar, a ceremonial laden with jewels and declared peace. The kin honoured his victory by

establishing the Sisters of the Sun an order of women dedicated to protect and preserve

cultures of the Kin. They continued to serve as social and cultural leaders within Kin Society

and mediators in local dispute. For century, the original ruby sipar was believed to be lost

forever. In an excavation by Dr.Gena Lorges, an archaeologist, the original ruby sipar

featuring more than 100 precious gems surrounded by rubies which was later on its

authenticity was confirmed, Since then it was placed on public display.

UNILATERAL APPROACH BY RAHAD-THE SAVALI PIPLELINE

On abundant shortage of water and in honor(either use british English or American English

throughout, so honour, if it is british English) of World Water Day on 22 nd March, 1993;

Rahad promised to make every reasonable effort to preserve shared fresh water resources of

the nomad coast and to ensure equitable use. Due to prevalent drought conditions in the

region, Queen Teresa made a televised appearance setting out her plan to address the water

crisis in Rahad. She directed their Government funded organization, the Inata Logistic and

Scientific Association (ILSA) to study the feasibility of tapping the Aquifer to meet

Rahads domestic needs. The report in 2003 concluded that Rahad would need 1.2 km 3 of

water every day to establish self-sufficiency and such a rate of extraction would deplete the

aquifers extractable water in approximately 30 years and the depletion of aquifer could harm

the structural integrity of canyon complex. President Vhen had expressed serious concerns

about the unilateral approach and the potential dangers it might lead to.
The savali pipeline plan was prepared by the Bureau of Interior to connect 30 pump wells in

rahad to be connected by a pipeline system. The plan was put forth before the World heritage

committee and it strongly urged Rahad to implement plans, policies and proposals potentially

affecting the complex and to implement the plan without affecting the complex. The pipeline

project was completed on 20th Feb, 2016 and pumping began, out of which 70% was used for

agriculture, 22% was used by the natural gas industry and the remaining 8% went to a variety

of other uses.

COLLAPSE OF KING CANYON

Due to persistent use of water by the Savali pipeline, it had an adverse effect on Atan. It led to

drying of wells, springs and small streams causing permanent lowering of water table in the

region and loss of US $300 Million annually in the loss of food and other agricultural

products. Moreover it caused clear structural degradation of the canyons and the strong

withhold. President Vhen sent a communiqu requesting to add the complex on the List of

World Heritage in Danger which was accepted by the committee.

WRAP ACT AND THE CATASTROPHE

Coerced with loss of farmable land due to absence of water seepage from the Aquifer,

enacted the WRAP (Water Resources Allocation Program) ACT, 2012. It mandated farming

operations to purchase licences to use water but it gave exemptions to farmers who sold more

than US$ 75,000 worth of crop. It empowered the Bureau of Agriculture to punish for failure

to obtain license and for use of over quota under the Atanian Criminal Code. In an

investigation it was noted that 80% of Kin households used water in excess of quota. The

Dept. Of justice prosecuted two farmers and it sent flyers on this warning. The law was

amended through which the govt. was empowered to cut off water supply as of which the

water was cut off to the majority of the farms.

presidents residence and went on an hunger strike. Within two weeks, over 5,000 sisters of

the sun, kins and their supported(supporters) congregated in the strike. President condemned

such strike and called it to be a seditious protest. He also declared ruby sipar to be banned

and ordered for confiscation of the pedants(pendants). The armed police was deployed to

bring the unrest under control. The protesters were arrested and charged with disturbing

peace and sipar pedants(pendants) were seized, worn by the sister. On a peaceful protest by

the kins, Atanian police arrested 100 sisters of the sun and 900 kin demonstrators. In order to

ensure protection to the Ruby Sipar, Carlo Dugo stole it from vault and fled to Rahad.

REFUGEE INFLUX TO RAHAD

Pursuant to the fear of arrest and of starvation, 100,000 kin had crossed in to Rahad, it

enacted the Kin Humanitarian Assistance Act (KHAA) to provide refugee status to the

Sisters of the Sun on a preferential basis to Sisters of the Sun and other kin on a case to case

basis. Due to extensive influx of refugees, Rahad enacted the Border Protection Act, in

achieving three major objectives of negotiating the cessation of massive emigration, to devise

a plan for safe relocation and to claim financial assistance from Atania. Rahads Ambassador

to Atania submitted a detail(detailed) expenses incurred which was dismissed by the Atanian

Govt.

On failure to resolve the dispute, the parties submit the

present dispute concerning all the issues set out in the Special Agreement to the International

Court of Justice.