Updated Compromis - Symbiosis Law SC

SYMBIOSIS LAW SCHOOL, PUNE - INTERNATIONAL CRIMINAL TRIAL ADVOCACY COMPETITION, 2016
SYMBIOSIS LAW SCHOOL,

PUNE - INTERNATIONAL
CRIMINAL TRIAL ADVOCACY
COMPETITION, 2016
March 18, 2016 - March 20, 2016
Compromis
1
TABLE OF CONTENTS
TABLE OF CONTENTS................................................................................ 2
COMPETITION COMPROMIS: ELEMENTARY FACTS......................... 3
MAP ................................................................................................................ 10
ANNEXURES (EVIDENCE EXCLUDING TESTIMONIES) ................. 11
PROSECUTORS WITNESSES ................................................................... 21
DEFENCE WITNESSES ............................................................................. 35
VICTIMS WITNESSES................................................................................ 43
COMPETITION COMPROMIS: ELEMENTARY FACTS
1. The Bay of Gandar was a crescent-shaped bay which marked the southern-end of the
continent of Gandar. The centre of the Bay contained the meeting point of two tectonic
plates, with the result that there were high mountains, both under the sea and on the land.
On the land-mass, the mountains had been largely uncrossable, which caused the
development of two ethnically distinct populations. The western side formed the country of
Crossford and the eastern side formed the country of Hambridge. The topography of the
continent of Gandar was such that shipping services through the Bay of Gandar was the only
way the Continent could have traded with the rest of the world.
2. Approximately 20 nautical miles off the southern tip of the western extreme of the Bay of
Gandar was Western Slade, and approximately 20 nautical miles off the southern tip of its
eastern extreme was Eastern Slade. The islands were approximately 100 nautical miles apart,
on the same latitude. The sea between them was notorious for its strong currents and
hazardous weather conditions, caused largely by the undersea mountains in the Bay. Each
island had a population of about 10 million people, and Western Slade was prominently
Crossfordian whereas Eastern Slade was prominently Hambridgian in ethnicity. Each was
independent, but the economy of Eastern Slade was integrated with the much larger
economy of Hambridge, and Western Slade was tied to Crossford in a similar fashion.
3. The ongoing movement of the tectonic plates led to the emergence of a new island
equidistant between Western and Eastern Slade, which international cartographers called
Central Slade. It was unpopulated, and uninhabitable because the nature of the tide surges in
stormy weather was such that it remained inundated. However, it was growing at a rate that
outran the increase in sea levels from climate change. A geological survey released sometime
in March 2011 had revealed that the mountain that was growing under the sea to form
Central Slade was likely to be the source of a significant supply of rare earth metals, of great
value in the modern economy. In addition, there was the prospect of claiming fishing rights
around the island.
4. The result of the geological survey was that by May 2011 small naval fleets of both Western
Slade and Eastern Slade were stationed around the Central Slade for a claim to be laid on the
new island by the respective countries. Each navy was seeking to build a permanent structure
there, seeking to present a claim of sovereignty in due course. Allegations were made that
each was trying to sabotage the efforts of the other, and within 2 weeks, both Crossford and
Hambridge sent ships to reinforce the efforts of Western Slade and Eastern Slade
respectively. Within the next 4 months, skirmishes occurred, and eventually the situation
deteriorated; diplomacy failed and Western Slade and Eastern Slade declared war on each
other. Crossford and Hambridge did not formally declare war, and indeed urged a diplomatic
solution; but they reflagged naval ships from their own navies as belonging to Western Slade
and Eastern Slade.
5. By September 2011, trade in the region was severely compromised by aggressive naval action
since the focus of the war was sea-based. Neither Western Slade nor Eastern Slade had any
military aircrafts. Both navies targeted ships in the Bay that were heading to the other island
or to the mainland on the basis that they might contain military equipment that would be
used in the war. However, the action taken was not to sink ships, but to board them, by
force if necessary, and commandeer them. On various occasions, crew were forced into liferafts and abandoned; on other occasions, the crew were taken with the ship into port and
placed into prisoner of war camps.
6. The policy as to placing the crew of ships into life-rafts soon proved to be controversial; on
the first three occasions that it was done, first by the Western Slade navy and then twice by
the Eastern Slade navy, the life-rafts were unable to deal with the adverse weather conditions
and most passengers drowned. Despite this, the Rear Admiral, in charge of the Western
Slade Navy, Conrad Drahy, directed that the crew of every second ship commandeered
should be cast adrift in life rafts, the aim of the policy being to cause merchant ships to avoid
journeys to Eastern Slade or Hambridge. By the end of the conflict, which lasted for some
three (3) years, some 80 crews had been treated in this way; however, only one lifeboat
survived. The total loss of life was 1476 people. Although propaganda claims were made to
the contrary, very few ships that were boarded and commandeered had anything other than
normal supplies on board. Further, some 1304 people were held in prisoner of war camps in
Western Slade, where they were treated in accordance with humanitarian standards.
7. The Western Slade Navy was also responsible for another significant incident. One natural
gas carrier ship was shadowed by a Western Slade naval vessel, but not boarded as an
Eastern Slade naval vessel was reported to be in the area. Instead, on the command of
Conrad Drahy, Captain Trevor Trenk in charge of a Special Forces Unit approached the
tanker under the cover of the night and placed onto its hull a sophisticated bomb which was
designed to explode once the tanker had docked and was unloading its contents. The bomb
did explode, and the resulting explosion and fire caused 57 deaths and significant property
damage. In addition, it led to the rupturing of numerous oil tanks in the same storage facility,
which polluted a significant portion of the coast of Eastern Slade and disrupted the fishing
industry there: it was estimated that it would take 5 years for sea life to become edible again.
The cause of the incident was not determined to be resultant of a bomb explosion. However,
in the aftermath of the war, upon investigation of the local authorities, the actions of Captain
Trenk and his men were revealed.
8. None of the ships, stopped by the Eastern Slade Navy, had any military supplies either.
However, they stopped putting crew into life rafts after the first two instances and instead
always took them to shore. Its prisoner of war camp was run by a private prison companyAstco, which had been contracted first by the government of Hambridge and then by the
government of Eastern Slade to operate all prison facilities in the respective countries, both
civilian and military. Astco was owned the Chief Minister of Hambridge, Andre Bouillon,
who was a fervent believer in the free market and also a fervent Hambridgian nationalist.
When involved in politics, Bouillon had secured the arrangements for the privatisation of
many governmental services, with the result that no state facilities existed for detention
purposes in either Hambridge or Eastern Slade. His company was awarded the prison
contracts for both jurisdictions shortly after he left office. However, in practice the
operations of the Astco prison facilities were not only overseen by the Astco officials but
also by the Eastern Slade Minister of Defence, Susan Wanchuk, who had been Bouillons
protg.
9. Bouillon had also called for Hambridge and Eastern Slade to develop significant military
forces and take control of the entire Bay of Gandar. His view was based on a view that
Crossfordians were a lesser race altogether whose role in life was limited to providing manual
labour. 285,000 captured people had been placed in Astco facilities, the vast majority being
of Crossfordian nationality or ethnicity. They were all subject to a regime of forced labour,
the Astco policy being that prison had to be cost-neutral, such that inmates had to provide
labour services that equated to the cost of their imprisonment. This cost included the capital
costs of the facilities and an agreed profit margin for Astco. The net effect of this was that
each prisoner had to work for 62 hours a week on a range of employment activities.
10. Wanchuk, on her part, made sure that she personally reviewed all details of the disciplinary
regime at the prison. In particular, for every hour not worked, a prisoner lost one meal; and
for every five hours lost, each prisoner was subject to corporal punishment, involving one
stroke of the cane or more depending on the situation. She also introduced a new rule
whereby prisoners were to impose corporal punishment on each other, with Astco guards
having the power to cane any prisoner who sought to use less than proper force when caning
another prisoner. Lethal force could be used against anyone who sought to resist.
11. By the end of the war, a total of 187000 prisoners had died; some 40,000 died as a result of
being shot by guards when they sought to resist disciplinary action or other orders, and the
rest simply succumbed to the consequences of the beatings, malnutrition and forced work.
12. The peace treaty that brought an end to the war was brought about when the ongoing
disruption of the economies of Crossford and Hambridge caused their populations to turn
against the policy supporting the war, as a result of which naval vessels that had been
reflagged as belonging to Western and Eastern Slade were returned to the Crossfordian and
Hambridgian navies. This Treaty was called- the Treaty of Lamos. In addition, the Bay of
Gandar Treaty was signed whereby it was agreed that Central Slade (and the entire
underground range of mountains) should be administered by a trustee arrangement whereby
Crossford and Hambridge each had 40% of the costs of revenues and Western Slade and
Eastern Slade each had 10% of the costs of revenues.
13. All countries had ratified the Rome Statute in the year 2004. As part of the peace treaty,
which Crossford and Hambridge also ratified, it was agreed that each side should select two
people (and only two people) whose involvement would be referred to the International
Criminal Court. The process of selection was carried out by a Standing Committee whose
members were appointed by each of the four countries. At the end of its deliberations, the
four people selected by the Standing Committee to stand trial in the International Criminal
Court were- Conrad Drahy, Trevor Trenk, Andre Bouillon and Susan Wanchuk.
14. The Pre-Trial Chamber of the International Criminal Court, on 26th February, 2013, accepted
that there were proper grounds for trial against each defendant on the charges as proposed
and thereby authorized the ICC Prosecutor to begin investigation into the situation at the
earliest. By August 2013, the ICC Prosecutor had initiated investigation and collection of
evidence. In advance of this determination, Drahy, Trenk and Bouillon went underground
and had not yet been located. But Wanchuk travelled to Hague in June 2015, and
surrendered herself for trial. In doing so, she expressly preserved her right to raise any
objections to the trial based on the process whereby she was selected for trial; in the
alternative her legal representatives also argued before the Pre-Trial Chamber that her Trial
be expedited. She was allowed bail in light of her conduct. The Prosecutor argued that the
wider interests of justice demanded that the trial be delayed until all defendants had been
brought before the court. Through a ruling delivered on 05th August, 2015 the Pre-Trial
Chamber decided that her Trial must begin. However, the same Chamber also made an
observation stating that absence of other accused could be detrimental to the Prosecutors
case. In a subsequent hearing conducted on 21st October, 2015 the Prosecutor laid before the
Court the final proposed charges against Wanchuk which were confirmed by the Pre-Trial
Chamber with no reservations. The final charges laid against Wanchuk upon which the Trial
shall initiate are:
Genocide, for the attack against Crossfordians under Article 6 and Article 25 (3)
(e) of the Rome Statute;
Crimes against humanity for inflicting severe physical or mental pain or suffering
upon the Crossfordian population under Article 7(1) (f) and Article 28(b) of the
Statute;
The War Crime of torture or inhuman treatment, under Article 8(2)(a)(ii) for
inflicting physical pain upon the prisoners and the persons protected under the
Geneva Convention of 1949 and Article 25(3) (b) of the Statute;
The War Crime of intentionally using starvation as a method of warfare against the
Crossfordians by depriving them of objects indispensable to their survival, including
wilfully impeding relief supplies as provided for under the Geneva Conventions
under Article 8 2(b) (xxv) and Article 25(3) (d) of the Rome Statute.
15. The Standing Committee had as part of its process, worked with detectives from the police
forces of Western Slade, Eastern Slade, Crossford and Hambridge. It had also worked with a
range of non-governmental organisations which had been established to support those killed in
or affected by the conduct of the war. These included the Astco Survivors Movement (ASM),
which represented those who were imprisoned in the prison facilities and survived and the
families of those imprisoned who had died. The ASM had decided that an oral history project
7
should be created to archive the experiences of its members; the process involved simply
recording unstructured accounts whereby people were asked simply to put on record what they
thought should be put on record for posterity. There was no questioning of the people recorded.
Staff working for the Standing Committee had watched the entire archive and selected extracts
had been brought to the attention of the Standing Committee. In addition, some of the people
who recorded material as part of this process had also given witness statements to the police
investigators; again, staff working for the Standing Committee had reviewed all the witness
statements, and some of them had been produced to the Standing Committee. The entire archive
created by the ASM and the complete collection of witness statements created by the various
police forces were made available to the International Criminal Court.
16. The ASM was led by Karl Graham, who was born in Crossford but had lived in Western Slade
since he was a child. He was an advocate by profession, and had been a passenger on a ship
travelling to Crossford from Western Slade in order to be admitted to the bar in Crossford. His
ship was captured and he had spent some 20 months in the Astco prison. He had suffered a
range of indignities there, and his weight had dropped from 75 kg to under 50 kg by the time the
war ended. He had operated as the de facto lawyer for those detained there, and had regularly
sought to raise complaints with staff and with Wanchuk about the events at the prison.
17. Karl Graham along with 50 other survivors seeks to be a victim seeking reparations. However,
for the purpose of the case, they have agreed to be represented by the same Legal
Representative.
18. The Trial Chamber has indicated that it will hear arguments on whether Karl Graham should be
a victim party, as well as on any other matter the parties wish to raise; and that this will be the
opening of the trial should the outcome of those arguments be that the trial proceeds.
NOTE:
For the purpose of the Trial of Susan Wanchuk, the Defence team shall have the
accused as a compulsory witness while the ICC Prosecutor shall have PW: 4 as a
compulsory witness.
The following questions must not be raised before the Trial Chamber: questions
pertaining to the Peace Treaty or the Bay of Gandar Treaty or incidental thereto;
questions pertaining to any circumstances prevalent during the post-war
transition period or incidental thereto; For purposes of above mentioned issues,
participants shall solely rely on the facts given in the Competition Compromis
under strict application of the principle of as is, there iswhatever where is.
Through their oral submissions, the parties in their respective roles are expected
to fully appreciate the procedure employed by the International Criminal Court.
MAP
10
ANNEXURES (EVIDENCE EXCLUDING TESTIMONIES)
ANNEXURE 1
THE MINISTRY OF DEFENCE

OFFICE OF THE UNDER-SECRETARY
FOR IMMEDIATE RELEASE
11th March, 2012
Sub:ORDER FROM THE DEPARTMENT OF INSTRUCTIONS, MINISTRY OF

DEFENCE, PROVINCIAL COUNCIL OF EASTERN SLADE
It is hereby directed to all out stationed Circuit-In-Charges onboard the Nautilus-A008,

that pursuant to the powers vested in Susan Wanchuk, Honourable Minister for Defence,
Provincial Council of Eastern Slade the following directions be secured against the inmates of
the inter-galactic prison facilities. These directions have been issued to secure full cooperation
of the inmates and to resist all anti-institution manoeuvres, to ensure efficient reformative
reconstruction of the otherwise uncivilized lifestyle of the inmates.
It is hereby directed that all prisoners be given equal opportunity to earn their wages
according to the following subscriptions:
That every prisoner be directed to work on-board the Nautilus-A008 for a minimum of
62 hours every week;
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[...]
That keeping in view the safety concerns of all, discipline be ensured at all times at the
facilities failing which:
Every prisoner be condemned to six (6) hours of fatigue duties for every act of nonobedience to the command of the Circuit-In-Charge;
[...]
Additional disciplinary measures to be incorporated:
1. That no individual prisoner be allowed to contact any family members;
2. That repeated requests by any such prisoners for grant of communication with such
members be dealt with by punitive measures, including but not limited to, measures such
as water-boarding, electrocution and/or induced debilitation;
[...]
Yours Sincerely,
On behalf of Susan Wanchuk,
Honourable Minister of Defence
Provincial Council of Eastern Slade
Lucas Podolski,
Under-Secretary,
Ministry of Defence,
12
ANNEXURE 2
The following is an email transcript, obtained by the Office of the Prosecutor, with the aid of
local authorities, during its investigation into the crimes committed by Susan Wanchuk.
Susan Wanchuk<susan.wanchuk@easternslade.es>
Jan 18, 2012
To: pa.mod@easternslade.es
Do that. Be sure to carry $10,000 before you visit that rascal with the speech. That should be
good to make him understand our speech in the context we want him to.
On Sun, Jan 17, 2012 at 10:40 AM, [Redacted]<pa.mod@easternslade.es> wrote:

I will get to it immediately.
From: Susan Wanchuk [susan.wanchuk@easternslade.es]

Sent: 14 January 2012 08:36 PM
To: [Redacted]<pa.mod@easternslade.es>
Subject: Re:
While our drafting team is working on such a policy, convey precisely these orders to the Prison
Authorities:
No meals for those who do not work. Every hour not worked equals one less meal. 50 hours
shall be the time for which these prisoners will work, in a week. There will be no regular timings
for working. The Prison Authorities can act as they wish. They have my permission. The
prisoners shall maintain the gardens and those without an arm shall keep the prison premises
clean and serve food. Get those mad ones to beat those who disobey my command. If they dont
hit them hard enough, our boys can take care of both, the mental screw-ups and the sane screwups. Let the women suffer. Put them in the Panopticon and make sure that all the CCTVs are
functioning perfectly. We do not want any sort of disobedience.
Ask the Guards to stand down.
I also expect you to prepare a speech. A really fiery one! Our intention is to crush those
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cockroaches in mass number and morale. Finally remember to get it approved by that Astco
Official. I will deliver the speech this weekend at my visit to the Hatir. We will then telecast this
to all TV channels in the country. This should do a good job. There is nothing more destructive
than an inspired soldier on ground. Lets pump our boys, make them hungry!
On Sun, Jan 12, 2012 at 08:40 PM, [Redacted]<pa.mod@easternslade.es> wrote:

Sure we can do that. What are your orders for me?
From: Susan Wanchuk [susan.wanchuk@easternslade.es]

Subject: Re:
We need to implement policies to wipe out that entire race. Our policies need
to be strict, unforgiving and should have a wide outreach. And finally good
execution of the same has to be ensured. A functional policy should take his
gaze away from the Chairperson-designate and reinstate my sphere of
influence on him.
On Sun, Jan 08, 2012 at 06:00 AM,

[Redacted]<pa.mod@easternslade.es> wrote:
Madam, what do you suggest should be done?
From: Susan Wanchuk

[susan.wanchuk@easternslade.es]
Subject: Re:
Very well! That seems settled. However, we have a new

problem to tackle now. The Ascto chairperson-designate has
been getting very close to Minister Bouillion and I cant let
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that happen. It needs to be checked and it needs to be

checked right now.
On Sun, Jan 04, 2012 at 11:40 AM,

[Redacted]<pa.mod@easternslade.es> wrote:
Dear Madam, we have as many as 200
new prisoners on the move from the
shores to Hatir. Astco has ensured that all
of them are incapacitated enough, so as to
ensure that our guards face no resistance.
From: Susan Wanchuk

[susan.wanchuk@easternslade.es]
To:
[Redacted]<pa.mod@easternslade.es>
Subject:
Kindly update me with the latest
developments from Hatir. How many new
prisoners do we welcome?
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ANNEXURE 3
Annexure 3 is a series of letters exchanged between a prisoner (deceased) and his friend
(untraceable) in the Eastern Slade. All the letters were recovered by local authorities and handed
over to the ICC Prosecutor.
Annexure 3.1
Dear [Redacted],
I hope you are keeping well. The Eastern Slade is no place for a prisoner to be. I hope the
Western Slade is not doing the same with the prisoners of the Eastern Slade; or maybe I hope so.
We are not given proper food. We are made to pay for the food we eat and we do not have
enough. There is no cleanliness and the blankets given to us are infested with bedbugs. Wait for
my return. Pray for us. Today on the 15th day of December, 2011 I write to you this letter
without any hope of survival.
With loads of love,
Ramsay
Annexure 3.2
Dear Ramsay,
I am keeping well. I had received your letter only on August 10, 2012. I find it a little suspicious
that the letter was not sealed. I am sending you a pack of your favourite chocolates and a few
cigarettes. I pray for your safe return. That is all I can promise you. God be with you.
With love,
[Redacted]
Annexure 3.3
Dear [Redacted],
As I feared, our enemies have not spared any part of our lives. Today is the 12 th day of January
2013 when I received your letter along with what was left of the original chocolates. I was
greeted with crumpled cigarettes and half eaten chocolates. My friend with these armies around
and such leadership, I doubt if there is any God in these strange lands.
With loads of love,
Ramsay
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ANNEXURE 4
The following Medical Report (MR) has been made by the Officials of the Health and Hygiene
Ministry, Provincial Council of Eastern Slade. The medical report depicts the condition of the
survivors onboard The Circumnavigator after it was intercepted by the peacekeeping forces upon
the signing of the Treaty of Lamos.
Class
(20 per
class)
Murine
Typhus
(Number of
cases)
Muscle
Diarrhoea
(Number of cases
caused by rats)
Aches /
Abdominal
Cramps
Bubonic
Plague(Number
of Cases |
Number of
Carriers
Class I
20
1|5
Class II
10
20
3|3
Class III
20
0|2
Class IV
20
4|5
Class V
12
20
0|0
16
41
100
8 | 15
Causes of Murine Typhus in all Classes- rodent infestation
Causes of DiarrhoeaClass IV : Allergy to food, acute anxiety

Class II: Bowel Cancer, IBS, Coeliac Disease
Class V: Diarrhoea as a symptom of Salmonella EntericaSerovarTyphimirium (S.
Typhimurium)
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Class III: Diarrhoea as a symptom of Leptospirosis (Leptospira)

Class I: Unhygienic conditions, stale food, anxiety
Cause of Muscle Aches and Abdominal Cramps in all Classes- various reasons
Cause of Bubonic Plague in all Classes- infected flea bite.
Chief Medical Examiner,

Ministry of Health and Hygiene,
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ANNEXURE 5
CHAIN OF COMMAND OVER PRISON FACILITIES OF EASTERN SLADE AND

HAMBRIDGE
This chain of command has been shared by the domestic investigation agencies of Hambridge
and Eastern Slade. It depicts the heirarchy of individuals concerned with regards to regulation of
affairs and control over all prison facilities with prisoners of wars.
CM.C
Eastern Slade
Minister of
Defence
ASCTO
CHAIRPERSON
CIRTUIT INCHARGE: I
CIRTUIT INCHARGE: II
CIRTUIT INCHARGE: III
PRISON
WARDEN
PRISON
WARDEN
PRISON
WARDEN
GUARD 3
GUARD 1
GUARD 1
GUARD 2
GUARD 2
GUARD 2
GUARD-1
GUARD 3
19
ANNEXURE 6
The Annexure is a voice recording submitted jointly by representatives of the Standing
Committee with expressed approval of the same taken from the Ascto Survivors Movement, to
the ICC Office of Prosecutor, extracted from the archives of the Standing Committee. The
recording is an account rendered by a female survivor in the after-math of the war that took
place from 2011-2013. The female survivor passed away in February 2015. Her account was
recorded when she was under observation and undergoing medical treatment at a State-run
rehabilitation centre.
ANNEXURE 7

recording is an account rendered by a soldier captured as a Prisoner of War. The soldier has
refused to testify in the ICC fearing his life and the safety of his family.
ANNEXURE 8

recording is that of a speech made by the accused to a gathering of soldiers on-board a naval
vessel. The same was recorded by a soldier and submitted to the ASM on the condition that his
identity be protected under all circumstances.
20
PROSECUTORS WITNESSES
INTERVIEWS CONDUCTED BY THE OFFICE OF PROSECUTOR (OCP) DURING

INVESTIGATIONS CONDUCTED IN EASTERN SLADE
***
21/10/2013
Location: Undisclosed
PW-1 (Confidential)
Name: Witness 1
Nationality: Eastern Slader
Age: 25 years
Occupation: Soldier
OCP: Are you wilfully, and of free mind, providing us with this information for purposes of the
Treaty of Lamos?
Witness 1: Yes, I am.
OCP: What is your occupation?
Witness1: I am a soldier. I patrol the shores of the Eastern Slade.
OCP: What is the information you choose to provide us?
Witness 1: I was patrolling the shore, one day and a body washed ashore.
OCP: Which shore are you referring to?
Witness 1: The North-Eastern shore.
OCP: Proceed
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Witness 1: I walked to the body to see whose it was. It was the body of the Midshipman
from The Pegasus, sailing from Oceania.
OCP: How do you know this?
Witness 1: A day before this incident, I heard the Coast Guard talk to my comrade that
The Pegasus had been taken by Eastern Slade, two days before that. As to him being a
Midshipman, his uniform said it all.
OCP: Alright, proceed.
Witness 1: I searched his body for any means of identification. You tend to do these
things when you have to spend hours looking at the same thing. I found a diary in his
inner-jackets inside pocket. It was drenched in water which made it soggy. The pages
got stuck together because of the wetness. I opened it to see what it had in it. The writing
was extremely distorted and smudged. There were, however, some words and sentences
that were still legible.
OCP: What were these words and sentences?
Witness 1: The words were sabotage, fire, prison and sarin. They appeared frequently.
Another page said, They were trying to extinguish the fire in the Life-raft. After all, the raft had to
stay afloat at sea. Another page said, My visual senses had not failed me. I saw [distorted
writing], the man [smudged] pour petrol on the floor of the raft. It reminded me
[smudges and distortions]. Ironically, it was what happened at Ashmore Reef, Australia in
2009.
OCP: Were you able to infer anything else? Anything about the reference to Ashmore Reef?
Witness 1: There were talks in the Eastern Slades Shore region that certain ships were
being converted into floating prisons. Other than that nothing! I did not understand
anything from that reference. There was a map of the Bay of Gandar, on the last page. It
had a red line drawn from Oceania to the Western Slade side of the Bay, which then lead
to the Eastern Slade.
OCP: Any other information that you can provide to us?
Witness 1: No, Sir.
22
15/05/2014
PW-2 (Confidential)
Name: Witness 2
Nationality: Portuguese
Age: 32 years
Occupation: Technician
Treaty of Lamos?
Witness2: I was a technician on The Circumnavigator.
Witness 2: I am one of the survivors of the only lifeboat to reach the shore. The crew of
The Circumnavigator was tortured and raped, Sir.
OCP: Tortured and raped by?
Witness 2: They had the flag of the Western Slade, Sir, but I think they were from the
Eastern Slade. Their accent was so different.
OCP: Alright, Witness 2. You may continue.
Witness 2: They converted our ship into some sort of a prison facility, Sir. We were
locked in the rooms of the ship and we were made to strictly obey their orders. They
were very cruel and I dont intend to recollect everything that they had done. Some of
the crew had gone insane because of the torture and jumped off the boat at the first
opportunity to escape. The soldiers shot down those who had jumped into the water.
When they felt that they were falling short of resources, they put us into lifeboats to sail
the violent waters. They destroyed 10 of the 11 lifeboats that were on the ship with
23
grenades. They packed all of us into the last lifeboat and filled it with diseased rats. The
boat was packed with people with broken or severed limbs.
OCP: There were not many blood stains on the floor of the boat, Witness. Did you not see the
photographs? How can you prove that a lot of people had severed and broken limbs?
Witness 2: I was there, Sir. I saw the condition of each of these people. There was an
instance when the sea water had come into the boat. We had to close the crack in the
hull and pour off all the water. It could be that it took the blood with it. The people were
left bruised and worse.
OCP: How do you know that the people left behind were tortured? Are you still receiving
information from The Circumnavigator?
Witness 2: No, Sir. It is a strong belief of mine. Besides, isnt it obvious?
OCP: Thank you for providing us with this Information, Witness 2.
24
05/01/2014
PW 3(Confidential)
Name: Witness 3
Nationality: German
Age: 29 years
Occupation: Geologist
Treaty of Lamos?
Witness3: I am a Geologist from Germany. I was on The NorthStellarwhich was sailing to
the Bay of Gandar to study the active tectonic movement beneath the Bay. The Ships
course was charted towards the Central Slade. The others on the ship were all scientists.
You see, a newly formed island provides an absolutely marvellous opportunity to study
the development of ecosystems. It helps us understand how life spread, in earlier times.
Its a brilliant-OCP: Alright, Witness 3. Thank you for the context. What is the incident that you want to tell
us?
Witness 3: We were sailing in International Waters, Sir. We could see an Eastern Slade
Ship at a distance of about 600 m away from ours. The Captain of our ship was trying to
get a closer look at their ship, with his binoculars. He was standing next to me and he
narrated to me everything he was seeing. He told me that there were people, in shackles,
who looked like death personified. He said that he saw a firing squad take aim at some
people. Before he told me anything, they began to fire their cannons towards our ship.
We were forced to turn around, in fear of our Ship sinking.
OCP: Are you sure it was at your ship?
Witness 3: Towards our ship, Sir, yes.
25
OCP: Anything else?

Witness 3: There were flashes like gunshots from the ship.
OCP: Thank you
26
14/04/2014
Location: ICC, Hague
PW-4 (Confidential)
Name: Witness 4
Age: 40 years
Occupation: Political Advisor
Treaty of Lamos?
Witness4: I am a Political Advisor from Eastern Slade.
OCP: What is your connection with Susan Wanchuk?
Witness 4: I was her former Personal Assistant. I was replaced by Wanchuks distant
relative.
OCP: What information can you provide us?
Witness 4: Enough information to restrict Wanchuks life to the prison! I was there
when Wanchuk administered the Jails. I was there when Wanchuk decided what orders
to give, what each guard must do, what should be the scene in the kitchen, what should
happen to which woman. I can go on, Sir.
OCP: Thats quite alright. Please, tell us about Wanchuks role in the management of the
prisons. Also, if possible, throw some light on her role in the war that took place between
Eastern Slade and the Western Slade.
Witness 4: She was directly administrating 5 prisons. Moreover, in her capacity as the
Defence Minister, most directions given to the various navy fleets emanated from her
office.
OCP: Please tell us the names of these prisons.
27
Witness 4: Most of these were in Eastern Slade. There was Vaztiil Prison, Blue Gate,
Panopticon, Hatir and Tefleka. They were all private prisons under the administration of
Wanchuk.
OCP: Alright. What happened in these jails? Tell us the entire story.
Witness 4: It was 3 years ago, when she received news that the prisoners of the Western
Slade-Eastern Slade conflict will be sent to these 5 prisons. She strongly believed in that
rump-fed Bouillion. His hatred for the Western Sladers had influenced her a lot. The
news caused her great joy. She was eager for the prisoners to come in. She even directed
that no prisoner would be offered more than 50 hours of work per week, thereby
guaranteeing that all prisoners were subjected to food deprivation corporal punishment
of increasing severity.
OCP: How can you back this up?
Witness 4: She discussed these with me. You have the records. [Attached as Annexure 2]
OCP: Continue.
Witness 4: She first laid down unreasonably strict rules for the prisoners. She made them
work for 50 hours a week. She ordered the Authorities not to provide meals to the
prisoner if they have not worked. Now, Sir, 50 hours of physical labour, a week, is a lot!
A lot of prisoners lost a lot of meals. What was more inhumane was that these 50 hours
couldve been at any time the Authorities wished. There were no stipulated work hours.
This order was given to all the prisons. The first of the prisoners were put in Hatir. Over
there, orders were given to make prisoners with no legs maintain gardens and those
without a hand were to clean the prison premises or serve food to the others. New
prisoners were brought to Blue Gate 5 days later. These were the soldiers of the Western
Slade, along with certain Government Officials. Blue Gate was ordered to impose
corporal punishment on them if they did not obey the orders. Those who did not hit
hard were in-turn beaten by others. Wanchuk took so much joy from this that she
imposed this rule in every prison. In Tefleka, where the mentally challenged prisoners
were taken, along with the usual prisoners, they were made to hit those who disobeyed
the rules. If the insane prisoners did not hit hard enough, they were hit.
OCP: Anything else?
Witness 4: Ofcourse, the Panopticon. This was a place which was so transparent that a
person standing on the ground floor could see the person on the fourth floor, clearly.
28
Adding to that, every cell had a CCTV camera. The women were not given their privacy
nor did they have any security. They were subject to carnal brutality. Wanchuk ordered
the guards to not do anything if a Western Slader was being subject to such acts. No
women in any of the prisons were supplied with proper amenities for maintaining basic
hygiene.
29
04/08/2014
Location: Undisclosed Military Base, Western Slade
PW 5(Confidential)
Name: Witness 5
Nationality: Western Slader
Age: 36 years
Occupation: Soldier
Treaty of Lamos?
Witness5: I am a Soldier of Western Slade.
Witness 5: Transportation of munitions
OCP: Could you elaborate, please?
Witness 5: Some of us prisoners were given the tasks of transporting provisions from
one facility to another. By facilities, I dont mean only prison facilities. Oncethis is my
truck, by the wayOnce, the Warden had loaded my truck with firing pins, suppressors
and rifle scopes, along with crates of food and alcohol.
OCP: How does this relate to Wanchuk?
Witness 5: She was in the prison when all of this had happened.
OCP: I see! Anything else?
Witness 5: No. Thats it!
OCP: Thank you!
30
04/08/2014
PW - 6 (Confidential)
Name: Witness 6
Occupation/Vocation: Guard (Former), Prison 21101993
Nature of Occupation/Vocation: Fulltime Government Employee
Age: 37 years
Nationality: Citizen of Hambridge
Treaty of Lamos?
Witness 6:Yes, I am.
OCP: In your profile submitted to the OCP, by your Government pursuant to the Treaty, it has
been mentioned that you were employed as a guard at an Astco run prison facility; is it true that
your tenure of employment in the same capacity was around 10 months?
Witness 6: Yes, I was stationed at Prison 21101993.
OCP: How would you describe the condition of the prison that you were employed to guard?
Witness 6: The condition was ok! I mean the prison did run very smoothly; there were
no hiccups.
OCP: Could you describe the daily routine followed by the guards to secure that there were no
hiccups?
Witness 6: Is this some kind of test you guys are running? Am I in trouble? I want my
lawyer. I want a lawyer; otherwise I am getting out of here.
OCP:We assure you Witness 1 that this is no test, nor are you under any kind of detention. We
will request you to continue cooperation with us. This interview shall end soon and if at any
point of time, the questions become too strenuous to you, we will be more than willing to take a
break. Now, assuming that you shall continue to cooperate, could you please tell us the methods
31
that were commonly used by your friends to check things should they go wrong in the prison
vicinity?
Witness 6: Look man, we did what our bosses told us to. The folks that came to the
prison were anyways all broken and retarded. Most did not trouble us much. The ones
that did, we shoved their heads in water-buckets.
OCP: Did you hit those who annoyed your superiors?
Witness 6: No, those folks were too frail to take our batons. Anyways man, I am a God
fearing man. Others guys may have done something like that [. . .] but me [. . .] no way I
was going to hit those chickens.
[...]
The interview could not proceed beyond this point as the witness refused to engage with
the OCP Representatives.
32
14/10/2014
PW- 7 (Confidential)
Name: Witness 7
Occupation/Vocation: Captain/In-Charge of The Scrambler
Nature of Occupation/Vocation: Private Employee Of Company Xx
Age: 43 years
Nationality: Protected
ADDITIONAL INFORMATION:WITNESS 2 was the captain of a private ship The

Scrambler. The company which owned The Scrambler often charted it as a carrier for transporting
heavy metal substances to be used for army purpose to any nation which could afford it. The
Captain had claimed to the local authorities that the ship contained metal pipes. To that effect he
procured the bill of lading before the authorities. The inventory list submitted to the ICC is as
follows:
IKEA Wireless cupboards x100 units
Intel Core i7 processors x100 cartons
Eastern Slade Chemical Company Pipettes x500 cartons
TransnistriaKvint Wine x10000 packed bottles.
Rolled Aluminium Sheets x500 units.
INTERVIEW
Treaty of Lamos?
Witness 7:Yes, I am.
Witness 7: I was the captain of my beloved ship The Scrambler.
33
OCP: You have stated in your statements for the purpose of your profile that your ship was
hijacked by the navy of Eastern Slade and that all individuals abroad were massacred, while you
managed to save yourself by jumping into the sea. Can you describe the circumstances leading to
this crime?
Witness 7: Yes, it was around 3 am that we were hurled into groups by some soldiers.
We were all rounded up as criminals and taken to the deck. This is where we were tied to
the post and blinded. It is difficult to say anything with certainty that may have happened
after that; however, I do remember one of the men taking directions from a female over
a satellite phone. I believe it was the accused. She must have ordered her men to kill my
people.
OCP: We understand your situation Witness; also you have emailed us an inventory list
depicting the items on board the ship you were the captain of; could you let us know the
significance of this list?
Witness 7: The list is what we adhere to on every stop we make in whatever country. We
crosscheck everything loaded or unloaded with the total amount mentioned in the
inventory list.
[. . .]
NOTE:
The questions asked by the Office of the Prosecutor were part of the
investigations carried out pursuant to the authorization of the same issued by the
Pre-Trial Chamber of the ICC on 26th February, 2013. The participants are
cautioned against the use of those same questions addressed by the Office of the
Prosecutor.
34
DEFENCE WITNESSES
Biography of the Accused
Name: Susan Wanchuk

Age: 54 years
Occupation: Minister of Defence
Susan Wanchuk was born in Mittraversiamo, Hambridge. Both of her parents worked as
investigative journalists and had been successful in various sting operations. In one of these
operations, they exposed the Western Slades plan to solve the problem that was caused by
increased immigration of the Maxi, into the Slade. Wanchuk went to Staklioner Public School,
for her primary and secondary education. Political Science and International Relations had
become her passion over the years.
At the age of 20, Wanchuk left for Crossford to pursue her passion. At Crossfords
prestigious Fordfront School of Arts, she had been exposed to Governmental Politics. She
began involving herself exceedingly in the local politics of Fordfront. Wanchuk soon became a
power to reckon with, in Fordfront, despite not being a part of any political party. Her support
implied a great possibility of victory. Being from Hambridge, she denied all offers to join
Crossfords political parties. By the age of 25, Susan Wanchuk was a known name in Crossford.
When Wanchuk was 28 years old, the Maxi issue began to cause great turmoil.
Fordfront had been wrought with brutal attacks against the Maxi. She spoke against the use of
brutal measures and proposed peaceful talks. However, a large part of Crossfords population
was prejudiced and enraged against the Maxi who were being given unreasonable benefits due
to International pressure and various refugee conventions.
While Wanchuk continued studies as a Doctorate Student at Fordfront School of Arts,
her parents involved themselves in a sting operation relating to the Maxi, in Crossford. Soon,
Fordfront turned into a bloodbath. The people of Crossford turned against the Maxi, in an
extremely violent manner. Not once, in these set of events, did the Government of Crossford try
to prevent such violence. Wanchuk was kidnapped to hamper her attempts to pacify the riots.
Wanchuk was tortured and abused by the kidnappers. After five days of painful torture,
35
Wanchuk found herself back in a conflict-torn Fordfront. Wanchuk left Fordfront to go back
home.
When Wanchuk reached Hambridge, she was told that her parents, who had been
investigating into the involvement of the Western Slade in the civil unrest prevalent in Fordfront,
were taken prisoners. A month later, she was told that her mother had passed away. Her father
had returned home without an eye and without sanity. These events instilled great hatred in her
against Crossford and the Western Slade.
In Hambridge, where she sought to continue in politics, she heard about a powerful man
named Boullion. She soon began to idolize him. Some newspaper reports suggest that their
common hatred for the Westerners developed into a strong bond. His power gave Wanchuk an
opportunity to enter the Government of the Eastern Slade. So, she changed her nationality from
being a Hambridgean to being an Eastern Slader. She was appointed to the post of the Defence
Minister of the Eastern Slade; a post that deemed to be very appropriate for her. Boullion also
gave Wanchuk the responsibility to look after his Astco prisons in Hambridge and the Eastern
Slade. However, according to some political commentators, in practice the management and
control of the prisons were shared by Wanchuk as well as Astco officials.
As Minister of Defence, she has ordered many attacks on Crossford ships sailing close to
the Eastern Slade. She has also employed a number of spies to seep into the Governments of
Crossford and the Western Slade, in order to place the Eastern Slade in a stronger position.
There are accusations of her contracting with militia of the Western Slade and Crossford to
disrupt peace and order in their country. Her role in the Astco prisons also gave rise to
controversy and conspiracy. Her bank accounts, on inspection by officials of Standing
Committee in January 2015, showed a total net amount of $40,000 and tangible property (both
movable as well as immovable) worth $7000.
She is accused of genocide, war crimes and crimes against humanity for her role in the
Astco prisons. Wanchuk, however, refutes all liability. She says that she was only administrating
the prisons but had no real authority over the prisons. She points fingers at the Astco Leadership
which had real authority over the prison. She also says that she was compelled to be remotecontrolled by Boullion, who had turned himself into someone whose orders she had to obey. She
refutes all liability and lays blame onto Boullion, whom she says is her superior.
36
PROFILE OF D:WITNESS #02 (CONFIDENTIAL)
Name: Witness #02

Occupation / Vocation: Midshipman
Nature of Occupation/ Vocation: Fulltime Government Employee
Age: 40 years
Nationality: Citizen of Eastern Slade
GENERAL DESCRIPTION: Witness #02 is a Naval Personnel working for a contingent of

navy officers who had taken over a cargo ship, which was sailing for the Eastern Slade, during
the dark of the night. On subsequent examination, the ship was identified as The Scrambler. It was
moving at a fast pace and it was intercepted to be approaching from the Western Slade. In the
statements given by him to the local police, he claims to have heard Wanchuk dictate to his boss
that only ships with weapons on-board should be taken care of. Subsequently, he claims to
have seen torpedoes stored in one of the cargo labelled restricted access. However, Witness #2 is
unable to provide proof of them being torpedoes. Psychological tests conducted by the same
local authorities, have shown that Witness #2 has high memory retention capabilities.
37
Name: Witness #03

Occupation/Vocation: Provisional In-Charge (Food / Water and Other Essential Supplies Related to the
Prison-Mess) For Prisons Managed By Astco
Nature of Occupation/Vocation: Manager Employed by Astco

Age: 29 years
GENERAL DESCRIPTION: Witness #03 is the Provisional In-Charge of food supplies and
nutritional supplements which are to be arranged for all prisons during the war. He has
submitted that he had instructed all kitchen In-Charges to cook 100 kg of rice, 80 kg of pulses
and 80 kg of vegetables a day to serve the prisoners, on orders from the Authorities. There was
no change in the quantities cooked once 420 new prisoners had been brought in, in the first few
days. He had received orders to cook an additional 30 kg of rice, 20 kg of pulses and 30 kg of
vegetables. He was also asked to make more food for the canteens.
38
NAME: Witness#04
Occupation/Vocation: Medical Expert in the Eastern Slade, Ministry of Defence.
NATURE OF Occupation/Vocation: Government Employee
Age: 30 years
Nationality: Citizen of Eastern Slade
GENERAL DESCRIPTION: Witness #04 is a Para-Medic travelling with the troops. He said
that on one particular day, the trucks had either broken down or run out of fuel and that they
had to walk back to their camps, from the shore, to the prisons. He said that the transport which
they had sent for had only arrived after walking 20 km, saving a walk of another 20 km. The
prisoners were made to walk, along with the troops and the medic as there was a possible threat
of tectonic movement in the sea. The company passed through various small villages. Their
provisions had run out 15 km after leaving the shore, despite having replenished them in the
villages they had walked through. Witness #10 attended to the wounds of certain prisoners and
had run out of material to treat the wounds of the other prisoners. One soldier named Billy
Martin succumbed to his injuries. Neither food nor water was provided when the transport had
arrived. The wounded were tended to, as soon as they had entered the transport vehicles.
39
Name: Witness #05

Occupation/Vocation: Clergy/Priest
Nature of Occupation/Vocation: Unpaid Spiritual Guide/Leader Working For The Church; Giving
Voluntary Service To The Old, Dying And The Destitute
Age: 48 years
Nationality: Citizen OfHambridge
GENERAL DESCRIPTION:Witness #05 is a Priest from the Eastern Slade, who visited the
prison once a month. He said that the prisoners were being treated according to the Will of the
Lord. He refused to explain what the phrase will of the lord meant. The prison had the books
of a religion widely followed in Hambridge and the Eastern Slade. There were very few,
extremely damaged copies of Religious books of the Western Slade and Crossford. The prisoners
would try and make do with these copies. They were not stopped from praying to their own
gods, in their own traditional ways. The Maxis from the Western Slade, whose religion expected
them to sing their prayers out loud, were in no way subjected to any form of cruelty even on
instances when they had prayed for disease and death to be bestowed upon Eastern Slade.
40
Name: Witness #06

Occupation/Vocation: Civil Engineer Working for the Ministry of Housing and Infrastructure,
Government of Hambridge
Nature of Occupation/Vocation: Government Contractor

Age: 45 years
GENERAL DESCRIPTION: Witness #06 is a family-friend of Andre Bouillon who had

made regular visits to the prison facilities. He used to meet Bouillon in the prison and both of
them would walk around the prison facilities, along with Susan Wanchuk. Witness #5 had been
hired as a Chief Engineer for Astco. In his regular visits, he used to check for any defects or
damages in the building. He would spend half an hour, examining the facilities, in the 2 hours
time that he would get there. He says that the prison never subjected the prisoners to more than
5 hours of work, a day. He spent a week in multiple prisons in the Eastern Slade and made
various observations like damaged heating system, leaking toilets, defective mattresses, absence
of proper fittings on the beds, obscene and vulgar murals on the shaking walls, and that the new
prison being built blocked out the light that entered a majority of the cells. He also noticed that
there were multiple canteens in the prisons, selling food at subsidized prices. He immediately
sent for technicians for making necessary repairs. He maintains that the real command, so far as
the prison conditions were concerned, was vested in Andre Bouillon.
41
NAME: Witness #07

OCCUPATION/VOCATION: Social Worker/Para-Legal
NATURE OF OCCUPATION/VOCATION: Contractor
AGE: 26 years
NATIONALITY: Citizen of Eastern Slade
GENERAL DESCRIPTION: Witness 07 Is a Legal Aid worker from the Slade Law Institute
who had visited the prison on Ixigus Day, a National holiday in Eastern Slade. The worker
submits that the rules applying to the prisoners were clearly laid down, in the form of placards
on the walls. They were also written in books which were given to the prisoners. The worker also
submits that she had spoken to a number of prisoners in a section of the prison. None of them
had said anything which would imply unreasonable work hours, unreasonable limitations on
food, mockery of religion or injury to the body. She also said that the women seemed to be
protected and in good health. The kitchen, she submits, has been producing abundant food
which catered to everybodys needs. Her father has been a lifelong employee of Astco. She
wrote a research paper based on the empirical study of prisons in Eastern Slade which spoke of
how well the prisons were maintained and how nothing much was needed to be done with them.
She wrote in her paper, Prison reforms are now only things of the past, from now on, for the people of the
country. The state of prisons in our country is so good that anybody who has an issue with it must be an alien or a
person of unsound mind. Security, privacy, food adequacy, sanitation one can say that our own homes are not as
good, at times.
42
VICTIMS WITNESSES
VW-1
Name: Witness 1
Nationality: XXXX
Age: 51 years
Occupation: Consultant/Advisor to the Standing Committee
SUBMISSIONS OF WITNESS 1 MADE TO THE STANDING COMMITTEE

VICTIM WITNESS 1: Some parts of what I am going to say are taken from the report
prepared by the Standing Committee. The submissions I will be making are with regards to the
prisons on land and the ships, the prisoners and their conditions. A total of 285,000 people were
put in Astco prison facilities in the years of the war. Of these, 2,50,000 people were of
Crossfordian Nationality or Ethnicity.
Now, the quarterly income from the prisons was $40 million. The profits derived from
this were $28 million. Investigations into the financial statements of the prisons showed an
increase in revenue by $9 million. The profits deriving from these $9 million were $7.6 million.
This hike had taken place once the Prisoners of War were brought in. It is possible that the extra
revenue earned could be due to the market forces of the economy. However, it doesnt rule out
the possibility that the extra could have been because of the prisoners. Now, the total revenue
during the war period, on an average, was $49 million. The total profits, on an average, were
$35.6 million. $14.5 million was the only expenditure, per quarter. Of this, $6 million was
transferred to various Bank Accounts. Some of these were accounts of people from whom Astco
had borrowed money. Some of it went into the stock market. Only $2 million was invested into
the maintenance and sanitation of the prison facilities and hygiene of the prisoners. Only an
additional $500,000, along with the former $1 million was invested in catering. The remaining $5
million had gone into payment to the employees and officials.
Special point of significance is the increase in personal wealth of Wanchuk and Boullion.
Their estimated wealth, based on their official salaries and other sources of income, should have
raised from $10,000 (based on tax returns of year 2010) to $15,000 in the year 2013 based on the
fact that during the war salaries of all working for the Government was reduced and was
43
sparingly released. However, when the Standing Committee officials went to inspect Wanchuks
accounts in December 2013, which were frozen under pressure from the international
community, we found a staggering increase of some 120% of her salary making her personal
fortune to the tune of some $2,000,000.
On investigation, it was found that someone from Astco has been transferring $2 million
of Astco profits into the accounts of certain Rear Admirals and Admirals. It has not been
ascertained as to who exactly the person is, but, it is obvious to the Committee that it is someone
with great influence. Only Boullion, Astco Prison Chiefs, Wanchuk and two to three others had
control over the finances. It is really hard to ascertain who the account belongs to.
At the end of the war, it was found that a total of 187,000 prisoners had died. Of this,
there were 170,000 prisoners who had been imprisoned after the war had started. Of this
170,000 a total of 40,000 prisoners had died from bullet wounds. Of the remaining 130,000
malnutrition and unhygienic conditions had taken another 20,000. Another 50,000 had died for
reasons whose post-mortem reports suggest are impact of blunt instruments in delicate parts of
the body. 50,000 had succumbed to the plague. 400 prisoners had committed suicide. The
remaining 99,600 are still being traced or under observation. These are reports from all prison
facilities, inland and on-water.
Before the war, Hambridge had a hundred ships at sea. After the war began, they
deployed another fifty ships. Out of these, contact has been lost with 20 ships and another 10 are
majorly suspected to be in the hands of the Westerners. Crossford had 150 ships at sea before
the war. This number reached 200 once the war began. On investigation, it was found that 30
ships were missing. 50 ships had been taken by the Easterners. Other countries which had their
ships sailing towards the Bay of Gandar have reported 6 missing ships.
A majority of the woman prisoners have reported rape committed against their own
selves, but refused to take names of those who committed the offence against them. The
prisoners have also reported sexual abuse, either of their own, or their cellmates. The majority of
prisoners were all Crossfordian/Western Slade prisoners, have reported 8-9 hours of work a day,
for 7 days. They refused to provide any more details.
The walls of the prison and certain rooms of the non-prison ships, where prisoners were
held, had long blood marks on the wall, indicating blood being splattered onto the walls on
impact. Broken teeth were recovered in some other cells.
Rats, mosquitoes and bedbugs were at large in the prison facilities.
44
50,000 families of prisoners have reported that their mails never reached the prisoner.
Several prisoners have made the same complaint. A majority of the prisoners also reported that
they werent allowed a legal counsel.
VW-2
Name: Witness 2
Nationality: Western Slade
Age: 43years
Occupation: Admiral in the Western Slade military.
DEPOSITION BEFORE STANDING COMMITTEE AND EXECUTIVE MEMBERS OF THE

ASM:
PHASE 1:I was a prisoner in one of the floating prisons. I was aboard my own ship, the ONS
Wraith, one of the finest ships in the country! It was the night of the 5th of November. A fleet of
6 boats, if I remember correctly, filled with those damned Easterners, sneaked their way to our
ship. About 50 Eastern Sladers boarded our ship and sabotaged our Communications Array.
Then, they captured our ship with the help of their Mothership from Hambridge, the CNS
Spirit. Once that happened, they rounded up all of my men at the centre of their ship. One of
them had that.uhsatellite phones with him. He contacted his Higher Command and
received orders which I could not hear. He then turned our ship into his own prison facility. He
said, This Wraith is now a vengeful Spirit. The next few days had been disastrous for us. They put
us in shackles and turned us into prisoners. Some of us had been put in the weapons room. They
mustve been bored or spotted by somebody else, or both. They placed some of my men right
next to the cannons and fired the cannons at somebody. The recoil of the cannon bashed their
brains out. Once our food supplies started to diminish, they docked the ship in their ports and
put us in prison facilities on land. There, me and whatever remained of my remaining men, spent
time till the end of the war. I reiterated the terms of the Geneva Conventions several times. I
insisted that my men wouldnt work if the terms are being violated. The prison authorities did
45
not pay heed. Every time I resisted, one of my men took a brutal beating. I finally gave in. This is
me, today. The ghosts of my past haunt me and I plan on resigning from my post as Admiral.
PHASE 2: The whole concept of a prison is violated if the living conditions are predominated
by coercion and an ever looming fear of being chopped. Because that is how war zones are
supposed to be, not prisons. In the time that I have spent there, scores of people were violated
in unimaginable ways such as using the technique of water boarding followed by electrocution.
Soldiers in particular were treated mercilessly. I shared my cell with a man. He was a trader from
the Balkan States. He told me that his life savings went in the making of one of the ships; a ship
with which he planned on securing a fortune for his family and future generations. After he was
captured, his ship was gifted by Wanchuk to Boullion, who in turn used to share it with all
Executive heads of Hambridge for State official purposes.
Our demand is very simple: True it is that we are very grateful to the ICC for helping us
get through the transition period from turbulence to peace, but our voices are largely unheard of
because what is not understood is, that when our ships along with everything else there is on the
ship is taken by a hostile enemy, what is taken is our investment, our life earnings, our present
livelihood and future source of livelihood. The ICC fails to appreciate the same. ASM has
decided that should the ICC allow us to bring our misfortunes before it, they will try to make the
Court understand our plight. I have full faith in the judges of the great Court.
46

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SYMBIOSIS LAW SCHOOL, PUNE - INTERNATIONAL CRIMINAL TRIAL ADVOCACY COMPETITION, 2016

SYMBIOSIS LAW SCHOOL,

March 18, 2016 - March 20, 2016

COMPETITION COMPROMIS: ELEMENTARY FACTS

ANNEXURES (EVIDENCE EXCLUDING TESTIMONIES)

THE MINISTRY OF DEFENCE

Sub:ORDER FROM THE DEPARTMENT OF INSTRUCTIONS, MINISTRY OF

It is hereby directed to all out stationed Circuit-In-Charges onboard the Nautilus-A008,

Jan 18, 2012

On Sun, Jan 17, 2012 at 10:40 AM, [Redacted]<pa.mod@easternslade.es> wrote:

From: Susan Wanchuk [susan.wanchuk@easternslade.es]

On Sun, Jan 12, 2012 at 08:40 PM, [Redacted]<pa.mod@easternslade.es> wrote:

From: Susan Wanchuk [susan.wanchuk@easternslade.es]

On Sun, Jan 08, 2012 at 06:00 AM,

From: Susan Wanchuk

Very well! That seems settled. However, we have a new

that happen. It needs to be checked and it needs to be

On Sun, Jan 04, 2012 at 11:40 AM,

From: Susan Wanchuk

Causes of Murine Typhus in all Classes- rodent infestation

Causes of DiarrhoeaClass IV : Allergy to food, acute anxiety

Class III: Diarrhoea as a symptom of Leptospirosis (Leptospira)

Cause of Bubonic Plague in all Classes- infected flea bite.

Chief Medical Examiner,

CHAIN OF COMMAND OVER PRISON FACILITIES OF EASTERN SLADE AND

CIRTUIT INCHARGE: III

The Annexure is a voice recording submitted jointly by representatives of the Standing

The Annexure is a voice recording submitted jointly by representatives of the Standing

INTERVIEWS CONDUCTED BY THE OFFICE OF PROSECUTOR (OCP) DURING

OCP: Anything else?

ADDITIONAL INFORMATION:WITNESS 2 was the captain of a private ship The

IKEA Wireless cupboards x100 units

Intel Core i7 processors x100 cartons

Eastern Slade Chemical Company Pipettes x500 cartons

TransnistriaKvint Wine x10000 packed bottles.

Rolled Aluminium Sheets x500 units.

Biography of the Accused

Name: Susan Wanchuk

PROFILE OF D:WITNESS #02 (CONFIDENTIAL)

Name: Witness #02

GENERAL DESCRIPTION: Witness #02 is a Naval Personnel working for a contingent of

PROFILE OF D:WITNESS #03 (CONFIDENTIAL)

Name: Witness #03

Nature of Occupation/Vocation: Manager Employed by Astco

PROFILE OF D:WITNESS #04 (CONFIDENTIAL)

PROFILE OF D:WITNESS #05 (CONFIDENTIAL)

Name: Witness #05

PROFILE OF D:WITNESS #06 (CONFIDENTIAL)

Name: Witness #06

Nature of Occupation/Vocation: Government Contractor

GENERAL DESCRIPTION: Witness #06 is a family-friend of Andre Bouillon who had

PROFILE OF D:WITNESS #07 (CONFIDENTIAL)

NAME: Witness #07

SUBMISSIONS OF WITNESS 1 MADE TO THE STANDING COMMITTEE

DEPOSITION BEFORE STANDING COMMITTEE AND EXECUTIVE MEMBERS OF THE

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