TABLE 4 – TAN, SANTOS, LUGTU APRIL 18, 2018

PLEADING FOR THE APPLICANT

HUMANITY FIRST (HF)
I. RIGHT TO LIFE
St. Priyah and Miyah (PM) violated the right to life of Martinez, del Junko, and, awaiting
execution, Moto, in contravention of the principle under the Raccoons Convention that
everyone’s right to life shall be protected by law.1 The imposition of the death penalty has
contradicted the duty of PM, under the international law principle of pacta sunt servanda, their
responsibilities to uphold the precepts of international law laid out in the treaties and
conventions, of which they are evidently and unconditionally signatories thereof.
II. RIGHT TO FREEDOM AGAINST TORTURE
In regard to del Junko, he was subjected to cruel practices and interrogation, which clearly
contravenes the Raccoons Convention, under which declares that no one shall be subjected to
torture or to inhuman or degrading treatment or punishment. 2 Also, PM is a signatory to the
International Covenant on Civil and Political Rights, which direct that no one shall be subjected
to torture or to cruel, inhuman or degrading treatment or punishment. In particular, no one shall
be subjected without his free consent to medical or scientific experimentation.3
III. RIGHT TO FAMILY
In regard to the marriage of Diaz and Martinez, PM has violated the sanctity of the family, as laid
out in Raccoons Convention that everyone has the right to respect for his private and family life,
his home and his correspondence.4 PM’s direct refusal to acknowledge the marital bonds of Diaz
and Martinez, under the customary traditions of the Sokotah religion, undermines the state’s duty
to respect the autonomy and integrity of the family.
IV. LEGAL STANDING
HF, a local NGO with observer status in the Raccoons human rights system, has locus standi to
sue with respect to various human rights violations, as the Raccoons Human Rights Court
(RHRC) entitles relevant Non Governmental organizations (NGOs) with observer status before
the Commission, and individuals to institute cases directly before it, in accordance as well with
rule on the state party’s declaration of the competence of the Court to acknowledge such cases.5

1 Raccoons Human Rights Convention (Raccoons Convention – European Convention on Human Rights of 1985),
Article 2, Right to life
2 Raccoons Convention, Article 3, Prohibition of torture.
3 International Covenant on Civil and Political Rights, Article 7.
4 Raccoons Convention, Article 8, 1. Right to respect for private and family life.
5 Protocol of the RHRC (Protocol to the African Charter on Human and Peoples' Rights on the Establishment of the
African Court on Human and Peoples' Rights), Article 5(3) Access to the Court, and Article 36 (4) Ratification.
TABLE 4 – TAN, SANTOS, LUGTU APRIL 18, 2018

V. ADMISSIBILITY
HF offers that its case must be admitted as per the rules of the Convention on the acceptance of
cases, which expressly states that any person or group of persons, or any nongovernmental entity
legally recognized in one or more member states of the organization, may lodge petitions with
the Commission containing denunciations or complaints of violation of this Convention by a
State Party. 6 Given that HF is a relevant and recognized organization before the Court, the
application is entirely admissible.
VI. MERITS AND REPARATION
a. Merits
HF has standing and personality before this Court, and its application is admissible before the
standards of the Court.
PM has violated international law treaties, of which it is signatories to, namely the Raccoons
Convention, and the International Covenant on Civil and Political Rights.
PM’s imposition of the death penalty infringes on the fundamental human rights of its people,
which is upheld under international law.
b. Prayer
HF respectfully requests this Honorable Court to adjudge and declare that:
1. That PM be sanctioned and for neglecting their duties and responsibilities before the
international community.
2. That PM be ordered to pardon or commute the sentence of Moto, in view of the fact that their
imposition of the death sentence as the penalty is an arbitrary depravation of life and contravenes
the generally accepted principles of international law.
3. That a probe or investigative body be commissioned to investigate further human rights
violations in PM and Nehiko, in relation to child marriages and human trafficking.
4. That an award be granted for the Applicant for the violation of human rights.

Respectfully submitted,
AGENTS FOR HUMANITY FIRST

6 Raccoons Convention on Admissibility Requirements (American Convention on Human Rights), Article 44.