May it please the Hon’ble Court, we, the Agents represent the Republic of State of Tree Lovers

(“the Applicant”) in the case of COMPROMIS BETWEEN THE REPUBLIC OF STATE OF TREE
LOVERS (APPLICANT) AND THE STATE OF NOBLES (RESPONDENT) TO SUBMIT TO THE
INTERNATIONAL COURT OF JUSTICE THE DIFFERENCES BETWEEN THE STATES
CONCERNING DHANPURI AND VOLUNTEERS FOR JUSTICE.

With the due permission of the Hon’ble Court, the Agents for the Applicants would like to
address the Hon’ble Court as Your Excellency and Mister President.

Much obliged, Mister President.

Mister President, the agent seeks permission to state a statement of facts and
statement of jurisdiction before proceeding to the main arguments.

Facts-
The State of Tree Lovers, formed in 1967 following its independence from the Disintegrated
Kingdom, emerged from a tumultuous partition process with the neighboring State of Nobles.
Despite being the result of a negotiated settlement, tensions between the two states persisted,
exacerbated by religious and political differences. Initially, the partition scheme aimed to create
two independent states based on religious demographics: the State of Noble for Sun
Worshippers and the State of Tree Lovers for the Tree Lovers community. However, the
Province of Rampur, where both communities coexisted harmoniously, opted to remain part of
the secular State of Nobles, leading to discontent among some Tree Lovers. In the aftermath of
independence, the State of Tree Lovers faced internal strife and external challenges. The
formation of political parties with differing ideologies further complicated matters. The defeat in
the war with the State of Nobles in 1973, as per the Treaty of Nobelpuri, imposed significant
concessions and reparations on Tree Lovers.

Political changes ensued, with the Pan Treaty Lovers assuming power and prioritizing defense,
leading to the establishment of the Intelligence for Revenge unit. Tensions between Tree Lovers
and Sun Worshippers in Rampur escalated, prompting allegations of treachery and the
formation of Rampur for Tree Lovers. The situation deteriorated with the alleged involvement of
the State of Tree Lovers in supporting unrest in Rampur, culminating in riots and further distrust
between the two states. The Volunteer for Justice attacks in Dhanpuri in 2011 prompted missile
strikes from the State of Nobles, escalating the conflict. International intervention through the
United Nations Security Council called for a ceasefire and recommended a pacific settlement
through the International Court of Justice. These events highlight the complex and challenging
journey of the State of Tree Lovers in its quest for stability and peaceful coexistence with its
neighbors.

Moving forward to the Statement of Jurisdiction- The THE REPUBLIC OF STATE OF TREE
LOVERS AND THE STATE OF NOBLES have brought their case before this Court by
notification of the Special Agreement as provided for by Article 40(1) of the Statute of the
International Court of Justice. The Court has jurisdiction over the case pursuant to Article 36(2)
of the said Statute.

The Agent now proceeds to the first main argument of the instant case, my lordships, This is a
clear case of INVALID AND BASELESS ACCUSATIONS AGAINST THE APPLICANT- STATE
OF TREE LOVERS.
I appear before this esteemed International Court of Justice today on behalf of the State of Tree
Lovers to present arguments in defense of our position. At the heart of this case lies the
question of whether the actions of the Volunteers for Justice can be attributed to the State of
Tree Lovers. We submit that they cannot, and I will elucidate upon our arguments forthwith.

The fundamental principle of state responsibility under customary international law, as codified
in the International Law Commission's Articles on State Responsibility (2001), dictates that a
state can only be held responsible for actions it has directed, ordered, or endorsed. The attack
perpetrated by the Volunteers for Justice was not orchestrated or sanctioned by the State of
Tree Lovers, thus absolving the state of any responsibility under international law.

Absence of Direct Involvement: The State of Tree Lovers did not provide direct support or
resources for the attack on Dhanpuri. While individuals from Tree Lovers may have been
involved, their actions were not authorized or supported by the state. No evidence exists to
suggest that the state allocated funds, weapons, or logistical support to the perpetrators. The
Volunteers for Justice acted independently, without any direct control or authorization from the
State of Tree Lovers. Their actions cannot be imputed to the state merely on the basis of their
nationality. The absence of official directives or authorizations from the government of Tree
Lovers further underscores this point. Case Law: Nicaragua v. United States of America (1986):
This case established the principle that a state can only be held responsible for actions it has
directed, ordered, or endorsed. The ICJ ruled that the United States could not invoke self-
defense to justify its support for Contra rebels in Nicaragua, as the actions were not attributable
to the US government.

Violation of International Law: The attack, while regrettable, does not constitute a breach of
international law by the State of Tree Lovers. The state consistently pursued peaceful means to
resolve conflicts, as evidenced by its efforts to seek a pacific settlement through this august
Court. Case concerning Armed Activities on the Territory of the Congo (Democratic Republic of
the Congo v. Uganda) (2005): This case emphasized the importance of peaceful settlement of
disputes and respect for the territorial integrity and political independence of states.

Human Rights Obligations: The State of Tree Lovers is duty-bound to protect the human rights
of its citizens, including their right to life and security. In the face of escalating tensions and
violence, the state took measures to safeguard its citizens, including seeking assistance from
the international community and pursuing a peaceful resolution through this Court.
Preventing Further Violence: The call for assistance by Kimma, the religious leader, was a
legitimate response to perceived threats to the safety of Tree Lovers in the State of Nobles. It
was aimed at preventing further violence and protecting the rights of Tree Lovers who felt
endangered.

Non-Violent Intentions: The State of Tree Lovers, through its representative Samir,
unequivocally rejected violence and military training offered by the Volunteers for Justice. This
demonstrates the state's commitment to resolving disputes peacefully and within the framework
of international law. Armed Activities on the Territory of the Congo (Democratic Republic of the
Congo v. Uganda) (2005)- This case held that Uganda could not be held responsible for the
actions of rebel groups operating on Congolese territory, as Uganda did not exercise effective
control over those groups. Similarly, the State of Tree Lovers cannot be held responsible for the
actions of non-state actors over which it does not exercise control.

Argument 3: Treaty Obligations and the Principle of Pacifism

Ceasefire and Resolution: The State of Tree Lovers promptly sought a ceasefire and pursued a
peaceful resolution through the United Nations Security Council and this Court. This aligns with
its obligations under international law to resolve disputes peacefully, as enshrined in the United
Nations Charter. Article 2(4) prohibits the threat or use of force against the territorial integrity or
political independence of any state. This emphasizes the sovereignty of states and the
necessity of refraining from interfering in the internal affairs of other states.

International Treaties: Both states are parties to the United Nations Charter, which emphasizes
the peaceful settlement of disputes and prohibits the threat or use of force against the territorial
integrity or political independence of any state. The Treaty of Nobelpuri (1973) further
underscores the commitment of the parties to peaceful dispute resolution.

With respect to the aforementioned arguments, your Excellency, the Agent on behalf of the
Applicants- State of Tree Lovers, we request that this Court finds the acts of Volunteers for
Justice as not attributable to the State of Tree Lovers, and thus there is no violation of any
general or customary international by it. The state acted in accordance with its obligations under
international law to protect its citizens and seek a peaceful resolution to the conflict. Any liability
for the attack rests solely with the individuals involved. And as a matter of fact it is the State of
Nobels that have violated human rights, international laws, treaties and conventions.