Good afternoon Mr. President, Your Excellencies.

My name is _______and I am an
agent for the Applicant, The Federal Republic of Agnostica. I will be joined by my co-
applicant,__________for our submissions on the issue of the secession and
subsequent annexation of East Agnostica.

I will discuss the first two submissions: the illegality of Reverentias encouragement
of East Agnostican referendum and the unlawful secession and subsequent
annexation of East Agnostica. While the two other issues concerning the termination
of the Marthite Convention and the removal of the software at the Marthite
extraction facilities will be discussed by my coapplicant.

Mr. President, Your Excellencies, The Federal State of Agnosticas case against the
State of Reverentia is a result of the gross violation of the principle of equality
among States and we will discuss the grounds to this claim in each of our
submissions.

Our first submission contends that Reverentias encouragement of the East

Agnostican referendum violated Agnosticas territorial integrity, the principle of non-
intervention and the United Nations Charter.

The principle of territorial integrity is based on the principle of non-

interference in the internal affairs of states, and by establishing status quo
serves for maintenance of stability and peace in the relations among states.
Moreover, the United Nations Charter specifically protects a States territorial
integrity, and prohibits the use of force.

As a duty, every State must abstain and prevent its agents and subjects from any
act which contains a violation of another State's independence or territorial and
personal supremacy is correlative to the respective right of the other State.

Indeed, the principle of territorial integrity protects the sovereign state against all
sorts of violations of its territory. It renders illegal acts of direct physical effect in the
territory of another state as well as sovereign acts that one state carries out on the
territory of another state.

Reverentias passing of Crisis Resolution interfered with Agnosticas political affairs.

First of all, it confirmed the validty of East Agnosticas Referendum. By confirming
ones referendum, it obviously has an interest in the outcome of the secession as it
can be seen in the facts.

Secondly, its extension of diplomatic recognition to an independent state in the

territory of East Agnostica. After the Referendum, Reverentia immidiately
recognized the East Agnostica as a State. More States followed. Reverentia
prematuredly recognized East Agnostica as a State, since the requisites for
statehood is not present in this case.
 and lastly, Reverentia ordered its agents to take all measures necessary to ensure
the security and integrity of that state. Stationing its troops at the border,
Reverentia was preparing for the imminent secession of East Agnostica, and in the
event of rejecting the referendum, it readied its military for rescuing the Agnorevs.
That defense is i, however.

Therefore, by giving its support for the referendum, Reverentia violated its duty to
respect the inviolability of every State and to positively protect the territorial
composition of States, in particular the territorial integrity of Agnostica.

Its defense that their State is only after the preservation of the peace in their state
in the event that violence in East Agnostica will spill over in Reverentia and to offer
aid to those fleeing the violence in East Agnostica is of no moment. To believe in
this defense will be tantamount to blind appreciation of the sequence of events. The
timing of the sending of troops reveals the real intention of the government of
Reverentia. The government of Reverentia sent military troops along the borders
after the denunciation of the resolution they adopted in support of the impending
referendum in East Agnostica and after the orders of the Agnostican government to
put necessary measures to block the referendum.

Despite their declaration that Reverentia has no territorial ambition over East
Agnostica through a diplomatic note, it contradicted its declaration. Had it been
after the preservation of peace and offering aid to fleeing Agnorevs only, it would be
logical for it to send its military troops at the onset and during the height of the
demonstrations in East Agnostica and not after. Therefore, the mere presence of
Reverentian military forces is a form of intimidation, a clear support to the
referendum and therefore constitutes threat as enunciated in the case of Nicaragua
vs US. The Reverentian government violated the principle of non-intervention by
supporting the secession movement in East Agnostica and by intervening in the
domestic affairs of another state. The totality of the acts of the State of Reverentia
since the adoption of the resolution supporting the referendum to secede redounds
to its intervention in the domestic affairs of Agnostica. According to Oppenheim, the
prohibition against intervention is corollary to the right of every state to
sovereignty, territorial integrity and political independence. Therefore states are
duty-bound to not intervene with the domestic affairs of another state. Reverentia,
by manifesting its support to the secessionist movement through the resolution
which was strengthened by sending its military troops to the borders, intervened
with the domestic affairs of Agnostica. Reverentia has no legal basis to intervene
with the domestic affairs of Agnostica. Agnostica is a recognized independent state
and as such should be afforded independence in the conduct of its domestic affairs.
Reverentia thereby violated the rights of Agnostica to sovereignty, territorial
integrity and political independence. The recognition afforded by the Reverentian
government to East Agnostica as a sovereign state is another violation of the
principle of non-intervention. In international law, it is premature recognition of a
claim to statehood which is expressly prohibited as written by Borchard in his book
Recognition and Non-recognition. The result of the referendum was not recognized
by the Agnostican government. Hence, the recognition despite the presence of a
controversy surrounding the claim to statehood is considered premature
recognition. Therefore, this constituted intervention of the domestic affairs of
Agnostica. Our second submission is that the purported secession and subsequent
annexation of East Agnostica are illegal and without effect andthe applicant
maintains that East Agnostica remains a part of Agnostica. Legal maxims elucidate
that no legal rights may arise from illegal situations. The Federal State of Agnostica
welcomed the Agnorevs with open arms and afforded them with the same privileges
like those which native Agnosticans enjoy. When they elected to remain in East
Agnostica, they elected to become Agnosticans. However, Agnorevs do not fall
under the definition of people because they do not encompass the whole population
of the State. They are a minority and as such do not have the right to external self-
determination. The referendum was conducted only in East Agnostica, thus is not
reflective of the voice of the people of the entire Federal State of Agnostica.
Therefore, the secession was illegal. Further, remedial secession is also not
available to the Agnorevs. The Agnorevs were given the right to internal self-
determination and such is manifest by the fact that they were given the freedom to
call themselves Agnorevs. They were given the right to exercise their ethnicity, their
religion, language, culture and economic freedom. However, the call for
independence is a matter of decision that relies only in the federal government.
Further, the right to external selfdetermination only arises when internal self-
determination is denied. Thus, Agnorevs right to external self-determination was
not a remedy available to them. There was no large scale human rights violation
against Agnorevs for the right of remedial secession to arise. The presence of
military forces in East Agnostica is a valid exercise of police powers and an act of
self-preservation for the state is duty-bound to maintain the peace and protect its
nationals from the acts of aggression within its territory. The passing of the Marthite
Act, is also a valid exercise of the states police powers as it is duty-bound to
perform its moral obligation to supply Marthite not just in Agnostica but more
importantly to the whole world. The enactment was only a result of the shortage of
Marthite due to the sabotage that was created by Reverentia and not as means to
cause oppression towards the Agnorevs. Further, the long-standing grievances of
Agnorevs have proper venue in different parts of the government. The Agnorevs are
represented in the provincial state of East Agnostica as well as in the Parliament.
Therefore, the requirements for remedial secession to arise are not met in the case
of the Agnorevs. The secession of East Agnostica was conducted with the aid of
Reverentia, hence, it is illegal. The threat of Reverentia to use force in supporting
the referendum to secede by the resolution they adopted and the deployment of
military forces tendered the secession illegal. A third state, in this case Reverentia,
encouraging secession is a violation of international law according to a UN Security
Council resolution. The applicant submits that Reverentias annexation of East
Agnostica violates international law. First, the annexation is illegal under
international law which states that no territorial acquisition resulting from threat or
use of force shall be recognized as legal. In this case, Reverentia used threat or use
of force in encouraging the secession of East Agnostica. Therefore, the secession is
illegal which in effect makes the annexation illegal. Second, Agnorev Peoples
Parliament as a result of the referendum has no legal capacity nor personality to
enter into international relations with the State of Reverentia as East Agnostica has
not achieved the full status of being a state. Thus, the annexation has no binding
force and produces no legal effect. Therefore, the annexation is also null and void.
Third, the annexation is a violation of international law as it disregards the principle
of uti possidetis. The delineation made by Credera between Agnostica and
Reverentia must be respected as upheld and applied by the ICJ in post-colonial
disputes like the present case. Hence, the secession and annexation are not in
conformity with international law and therefore is illegal. The honorable bench, East
Agnosticas annexation is a deprivation of the Agnostican right to their property.
East Agnostica rightfully belongs to the Agnosticans and not just to Agnorevs alone.
To rule in favor of the annexation will be a precedent that will create worldwide
territorial instability and injustice resulting from massive illegal secessions and
annexations. Thank you.