INTERNATIONAL COURT OF JUSTICE
INTERNATIONAL COURT OF JUSTICE
ALLEGATIONS OF GENOCIDE UNDER THE CONVENTION
ON THE PREVENTION AND PUNISHMENT OF THE CRIME OF
GENOCIDE (UKRAINE V. RUSSIAN FEDERATION)
ALLEGATIONS OF GENOCIDE UNDER THE CONVENTION
ON THE PREVENTION AND PUNISHMENT OF THE CRIME OF
GENOCIDE (UKRAINE V. RUSSIAN FEDERATION)
DECLARATION OF INTERVENTION OF THE
REPUBLIC OF BULGARIA
DECLARATION OF INTERVENTION OF THE
REPUBLIC OF BULGARIA
PURSUANT TO ARTICLE 63 OF THE STATUTE OF THE
INTERNATIONAL COURT OF JUSTICE
PURSUANT TO ARTICLE 63 OF THE STATUTE OF THE
INTERNATIONAL COURT OF JUSTICE
2 August 2024
2 August 2024
I. LETTER FROM THE AMBASSADOR OF THE REPUBLIC OF BULGARIA TO
THE KINGDOM OF THE NETHERLANDS TO THE REGISTRAR OF THE
INTERNATIONAL COURT OF JUSTICE, H.E. MR. PHILIPPE GAUTIER
I. LETTER FROM THE AMBASSADOR OF THE REPUBLIC OF BULGARIA TO
THE KINGDOM OF THE NETHERLANDS TO THE REGISTRAR OF THE
INTERNATIONAL COURT OF JUSTICE, H.E. MR. PHILIPPE GAUTIER
Excellency,
Excellency,
I have the honour to attach a Declaration by the Republic of Bulgaria of its intervention
pursuant to Article 63, paragraph 2, of the Statute of the Court in the merits phase of the case
concerning Allegations of Genocide under the Convention on the Prevention and Punishment
of the Crime of Genocide (Ukraine v. Russian Federation).
I have the honour to attach a Declaration by the Republic of Bulgaria of its intervention
pursuant to Article 63, paragraph 2, of the Statute of the Court in the merits phase of the case
concerning Allegations of Genocide under the Convention on the Prevention and Punishment
of the Crime of Genocide (Ukraine v. Russian Federation).
I also attach an instrument signed by the Minister for Foreign Affairs appointing the Agent and
I also attach an instrument signed by the Minister for Foreign Affairs appointing the Agent and
Co-Agents of the Republic of Bulgaria for the purposes of these proceedings. I certify that the
signature on the Declaration is that of the appointed Agent, Mr. Danail Chakarov.
Co-Agents of the Republic of Bulgaria for the purposes of these proceedings. I certify that the
signature on the Declaration is that of the appointed Agent, Mr. Danail Chakarov.
Please be informed that the Republic of Bulgaria is prepared to take a common approach with
other intervening States, which have deposited an identical or essentially comparable statement
of intervention, for the next phases of the proceedings, should the Court deem such common
approach useful for the good and expedient administration of justice.
Please be informed that the Republic of Bulgaria is prepared to take a common approach with
other intervening States, which have deposited an identical or essentially comparable statement
of intervention, for the next phases of the proceedings, should the Court deem such common
approach useful for the good and expedient administration of justice.
Finally, I have the further honour to advise that the address for service to which all
communications concerning these proceedings should be sent is that of this Embassy.
Finally, I have the further honour to advise that the address for service to which all
communications concerning these proceedings should be sent is that of this Embassy.
Emil Kishmerov
Charge d'affaires ad interim of the Embassy of the Republic of Bulgaria
to the Kingdom of the Netherlands
Emil Kishmerov
Charge d'affaires ad interim of the Embassy of the Republic of Bulgaria
to the Kingdom of the Netherlands
II. APPOINTMENT OF AGENT AND CO-AGENTS
II. APPOINTMENT OF AGENT AND CO-AGENTS
THE MINISTER OF FOREIGN AFFAIRS
THE MINISTER OF FOREIGN AFFAIRS
OF
OF
THE REPUBLIC OF BULGARIA
THE REPUBLIC OF BULGARIA
For the purposes of intervention pursuant to Article 63 of the Statute of the Court at the merits
stage in the present case before the International Court of Justice, Allegations of Genocide
under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v.
Russian Federation), I hereby appoint Mr. Danail Chakarov, Director of the International
Law Directorate, Ministry of Foreign Affairs, as Agent for the Republic of Bulgaria and His
For the purposes of intervention pursuant to Article 63 of the Statute of the Court at the merits
stage in the present case before the International Court of Justice, Allegations of Genocide
under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v.
Russian Federation), I hereby appoint Mr. Danail Chakarov, Director of the International
Law Directorate, Ministry of Foreign Affairs, as Agent for the Republic of Bulgaria and His
Excellency Konstantin Dimitrov, Ambassador Extraordinary and Plenipotentiary of the
Republic of Bulgaria to the Kingdom of the Netherlands, and Ms. Tzvety Romanska,
Excellency Konstantin Dimitrov, Ambassador Extraordinary and Plenipotentiary of the
Republic of Bulgaria to the Kingdom of the Netherlands, and Ms. Tzvety Romanska,
Counsellor, International Law Directorate, Ministry of Foreign Affairs as Co-Agents for the
Republic of Bulgaria.
Counsellor, International Law Directorate, Ministry of Foreign Affairs as Co-Agents for the
Republic of Bulgaria.
With the present letter, the appointment of agent and co-agent with letter, dated IO November
2022, is withdrawn.
With the present letter, the appointment of agent and co-agent with letter, dated IO November
2022, is withdrawn.
Sofia~July 2024
Sofia~July 2024
Dimitar GLA VCHEV
Minister of Foreign Affairs
Dimitar GLA VCHEV
Minister of Foreign Affairs
III. DECLARATION OF INTERVENTION OF THE REPUBLIC OF BULGARIA
III. DECLARATION OF INTERVENTION OF THE REPUBLIC OF BULGARIA
To the Registrar of the International Court of Justice, the undersigned being duly authorized
by the Republic of Bulgaria:
To the Registrar of the International Court of Justice, the undersigned being duly authorized
by the Republic of Bulgaria:
1. On behalf of the Republic of Bulgaria, I have the honour to submit to the Court a
Declaration of Intervention pursuant to Article 63, paragraph 2 of the Statute of the
International Court of Justice ("Statute") in the merits stage of the case concerning
1. On behalf of the Republic of Bulgaria, I have the honour to submit to the Court a
Declaration of Intervention pursuant to Article 63, paragraph 2 of the Statute of the
International Court of Justice ("Statute") in the merits stage of the case concerning
Allegations of Genocide under the Convention on the Prevention and Punishment of the
Crime of Genocide (Ukraine v. Russian Federation).
Allegations of Genocide under the Convention on the Prevention and Punishment of the
Crime of Genocide (Ukraine v. Russian Federation).
2.
2. Article 82, paragraph 5 of the Rules of the Court provides that a declaration of a State's
desire to avail itself of the right of intervention conferred upon it by Article 63 of the
Statute
Article 82, paragraph 5 of the Rules of the Court provides that a declaration of a State's
desire to avail itself of the right of intervention conferred upon it by Article 63 of the
Statute
"shall specify the case and the convention to which it relates and shall contain:
"shall specify the case and the convention to which it relates and shall contain:
(a) particulars of the basis on which the declarant State considers itself a party to the
convention;
(a) particulars of the basis on which the declarant State considers itself a party to the
convention;
(b) identification of the particular provisions of the convention the construction of which
it considers to be in question;
(b) identification of the particular provisions of the convention the construction of which
it considers to be in question;
( c) a statement of the construction of those provisions for which it contends;
( c) a statement of the construction of those provisions for which it contends;
(d) a list of documents in support, which documents shall be attached."
(d) a list of documents in support, which documents shall be attached."
3.
3. All those requirements are addressed in sequence below, after some preliminary
observations.
All those requirements are addressed in sequence below, after some preliminary
observations.
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PRELIMINARY OBSERVATIONS
4. On 26 February 2022, Ukraine instituted proceedings against the Russian Federation in
a dispute concerning the interpretation, application or fulfilment of the Convention on
the Prevention and Punishment of Genocide (the "Genocide Convention" or
PRELIMINARY OBSERVATIONS
4. On 26 February 2022, Ukraine instituted proceedings against the Russian Federation in
a dispute concerning the interpretation, application or fulfilment of the Convention on
the Prevention and Punishment of Genocide (the "Genocide Convention" or
·Convention").
·Convention").
5.
5.
In paras. 4-12 of its Application instituting proceedings, Ukraine contends that there is a
dispute between Ukraine and the Russian Federation within the meaning of Article IX
relating to the interpretation, application or fulfilment of the Genocide Convention.
In paras. 4-12 of its Application instituting proceedings, Ukraine contends that there is a
dispute between Ukraine and the Russian Federation within the meaning of Article IX
relating to the interpretation, application or fulfilment of the Genocide Convention.
6. On substance, Ukraine claims that the use of force by the Russian Federation in or against
Ukraine since 24 February 2022 on the basis of alleged genocide, as well as the
recognition that preceded the military operation, is incompatible with the Convention,
quoting Articles I-III thereof (paras. 26-29 of the Application).
6. On substance, Ukraine claims that the use of force by the Russian Federation in or against
Ukraine since 24 February 2022 on the basis of alleged genocide, as well as the
recognition that preceded the military operation, is incompatible with the Convention,
quoting Articles I-III thereof (paras. 26-29 of the Application).
7. Following a request for provisional measures from Ukraine, the Court ordered on 16
March 2022 that:
7. Following a request for provisional measures from Ukraine, the Court ordered on 16
March 2022 that:
(1) the Russian Federation shall immediately suspend the military operation that it
commenced on 24 February 2022 in the territory of Ukraine;
(1) the Russian Federation shall immediately suspend the military operation that it
commenced on 24 February 2022 in the territory of Ukraine;
(2) The Russian Federation shall ensure that any military or irregular armed units which
may be directed or supported by it, as well as any organizations and persons which
may be subject to its control or direction, take no steps in furtherance of the military
operations referred to in point (1) above; and
(2) The Russian Federation shall ensure that any military or irregular armed units which
may be directed or supported by it, as well as any organizations and persons which
may be subject to its control or direction, take no steps in furtherance of the military
operations referred to in point (1) above; and
(3) Both Parties shall refrain from any action which might aggravate or extend the
dispute before the Court or make it more difficult to resolve.
(3) Both Parties shall refrain from any action which might aggravate or extend the
dispute before the Court or make it more difficult to resolve.
8. As of the date of this Declaration, Russia has failed to comply with that Order, has
intensified and expanded its military operations on the territory of Ukraine and has thus
aggravated the dispute pending before the Court.
8. As of the date of this Declaration, Russia has failed to comply with that Order, has
intensified and expanded its military operations on the territory of Ukraine and has thus
aggravated the dispute pending before the Court.
9. On 30 March 2022, as contemplated by Article 63, paragraph 1, of the Statute of the
9. On 30 March 2022, as contemplated by Article 63, paragraph 1, of the Statute of the
Court, the Registrar duly notified the Republic of Bulgaria as a party to the Genocide
Convention that by Ukraine's application the Genocide Convention "is invoked both as
a basis for the Court's jurisdiction and the substantive basis of [Ukraine's] claims on the
merits". The registrar also noted that:
Court, the Registrar duly notified the Republic of Bulgaria as a party to the Genocide
Convention that by Ukraine's application the Genocide Convention "is invoked both as
a basis for the Court's jurisdiction and the substantive basis of [Ukraine's] claims on the
merits". The registrar also noted that:
"[Ukraine] seeks to found the Court's jurisdiction on the compromissory clause
contained in Article IX of the Genocide Convention, asks the Court to declare that it has
not committed a genocide as defined in Articles II and III of the Convention, and raises
questions concerning the scope of the duty to prevent and punish genocide under Article
"[Ukraine] seeks to found the Court's jurisdiction on the compromissory clause
contained in Article IX of the Genocide Convention, asks the Court to declare that it has
not committed a genocide as defined in Articles II and III of the Convention, and raises
questions concerning the scope of the duty to prevent and punish genocide under Article
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I of the Convention. It therefore appears that the construction of [the Genocide
Convention] will be in question in this case"'.
I of the Convention.
therefore appears that the construction of [the Genocide
Convention] will be in question in this case"'.
It
10. Between 21 July 2022 and 15 December 2022, 33 States (including the Republic of
Bulgaria) filed declarations of intervention under Article 63, paragraph 2, of the Statute
of the Court. By an Order dated 5 June 2023, the Court decided that the declarations of
intervention under Article 63 of the Statute submitted by 32 States were admissible at the
preliminary objections stage of the proceedings in so far as they concerned the
construction of Article IX and other provisions of the Genocide Convention that are
relevant for the determination of the jurisdiction of the Court.
10. Between 21 July 2022 and 15 December 2022, 33 States (including the Republic of
Bulgaria) filed declarations of intervention under Article 63, paragraph 2, of the Statute
of the Court. By an Order dated 5 June 2023, the Court decided that the declarations of
intervention under Article 63 of the Statute submitted by 32 States were admissible at the
preliminary objections stage of the proceedings in so far as they concerned the
construction of Article IX and other provisions of the Genocide Convention that are
relevant for the determination of the jurisdiction of the Court.
11. In the Judgment rendered on 2 February 2024, the Court concluded that it has jurisdiction,
on the basis of Article IX of the Genocide Convention, to entertain submission (b) in
paragraph 178 of the Memorial of Ukraine, whereby Ukraine requests the Court to
11. In the Judgment rendered on 2 February 2024, the Court concluded that it has jurisdiction,
on the basis of Article IX of the Genocide Convention, to entertain submission (b) in
paragraph 178 of the Memorial of Ukraine, whereby Ukraine requests the Court to
"[a}judge and declare that there is no credible evidence that Ukraine is responsible for
committing genocide in violation of the Genocide Convention in the Donetsk and
Luhansk oblasts of Ukraine", and that this submission is admissible.
2
"[a}judge and declare that there is no credible evidence that Ukraine is responsible for
committing genocide in violation of the Genocide Convention in the Donetsk and
Luhansk oblasts of Ukraine", and that this submission is admissible.
2
12. By the present Declaration, the Republic of Bulgaria avails itself of the right to intervene
in the merits stage conferred upon it by Article 63, paragraph 2, of the Statute. This Court
has recognized that Article 63 confers a "right" of intervention
3.
12. By the present Declaration, the Republic of Bulgaria avails itself of the right to intervene
in the merits stage conferred upon it by Article 63, paragraph 2, of the Statute. This Court
has recognized that Article 63 confers a "right" of intervention
The Court has also
underlined that an intervention "is limited to submitting observations on the construction
of the convention in question and does not allow the intervener, which does not become
a party to the proceedings, to deal with any other aspect of the case before the Court; and
whereas such intervention cannot affect the equality of the Parties to the dispute"."
3.
The Court has also
underlined that an intervention "is limited to submitting observations on the construction
of the convention in question and does not allow the intervener, which does not become
a party to the proceedings, to deal with any other aspect of the case before the Court; and
whereas such intervention cannot affect the equality of the Parties to the dispute"."
It
13.
13. It is the understanding of the Republic of Bulgaria that the Genocide Convention is of
utmost importance to prevent and punish genocide. The prohibition against genocide is
a jus cogens norm in international law. The rights and obligations enshrined by the
Convention are owed to the international community as a whole (rights and obligations
is the understanding of the Republic of Bulgaria that the Genocide Convention is of
utmost importance to prevent and punish genocide. The prohibition against genocide is
a jus cogens norm in international law. The rights and obligations enshrined by the
Convention are owed to the international community as a whole (rights and obligations
erga omnes partes). As a Contracting Party, the Republic of Bulgaria has an interest in
the construction that might be placed by the Court on the relevant provisions of the
erga omnes partes). As a Contracting Party, the Republic of Bulgaria has an interest in
the construction that might be placed by the Court on the relevant provisions of the
1
1
Letter from the Registrar of the Court of30 March 2022- see Annex A.
Letter from the Registrar of the Court of30 March 2022- see Annex A.
Allegations of genocide under the Convention on the Prevention and Punishment of the Crime of Genocide
Allegations of genocide under the Convention on the Prevention and Punishment of the Crime of Genocide
(Ukraine v. Russian Federation: 32 States intervening), Preliminary Objections, Judgement of2 February 2024.
(Ukraine v. Russian Federation: 32 States intervening), Preliminary Objections, Judgement of2 February 2024.
3
Haya de la Torre (Colombia v.
Peru), Judgment, I.C.J. Reports 1951, p. 76; Continental Shelf (Tunisia/Libyan
Arab Jamahiriya), Application for Pennission to Intervene, Judgment, I.C.J. Reports 1981, p. 13, para. 2 I.
3
Haya de la Torre (Colombia v. Peru), Judgment, I.C.J. Reports 1951, p. 76; Continental Shelf (Tunisia/Libyan
Arab Jamahiriya), Application for Pennission to Intervene, Judgment, I.C.J. Reports 1981, p. 13, para. 2 I.
'Whaling in the Antarctic (Australia v. Japan), Declaration of Intervention of New Zealand, Order of 6 February
2013, I.C.J. Reports 2013, p. 3, at p. 9, para. 18.
'Whaling in the Antarctic (Australia v. Japan), Declaration of Intervention of New Zealand, Order of 6 February
2013, I.C.J. Reports 2013, p. 3, at p. 9, para. 18.
5
5
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 111, paras. I 61-
162.
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 111, paras. I 61-
162.
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6
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
Myanmar), Provisional Measures, Order of 23 January 2020,
LC.J.
Myanmar), Provisional Measures, Order of 23 January 2020, LC.J. Reports 2020, p. 3 with further references;
Reports 2020, p. 3 with further references;
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
Myanmar), Judgment of 22 July 2022, para. 107.
Myanmar), Judgment of 22 July 2022, para. 107.
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3
Convention and wishes to observe the consistent interpretation, application and
fulfilment of the Convention among all Contracting Parties.
Convention and wishes to observe the consistent interpretation, application and
fulfilment of the Convention among all Contracting Parties.
14. The Republic of Bulgaria does not seek to become a party to the Proceedings. Bulgaria
hereby confirms that, by availing itself of its right to intervene under Article 63, it accepts
that the construction to be given by the Court's judgement in the case will be equally
binding upon it.
14. The Republic of Bulgaria does not seek to become a party to the Proceedings. Bulgaria
hereby confirms that, by availing itself of its right to intervene under Article 63, it
accepts
that the construction to be given by the Court's judgement in the case will be equally
binding upon it.
15. Consistent with the restricted scope for interventions under Article 63 of the Statute, the
Republic of Bulgaria will present its interpretation of the relevant Articles of the
Genocide Convention in line with customary rules of interpretation as reflected in
Articles 31-33 of the Vienna Convention on the Law of Treaties'.
15. Consistent with the restricted scope for interventions under Article 63 of the Statute, the
Republic of Bulgaria will present its interpretation of the relevant Articles of the
Genocide Convention in line with customary rules of interpretation as reflected in
Articles 31-33 of the Vienna Convention on the Law of Treaties'.
16.
16. In its intervention of 18 November 2022, the Republic of Bulgaria had focused solely on
Article IX of the Convention relating to the jurisdiction of the Court. On 18 June 2024
the Registrar provided some procedural information regarding the filing of a new
declaration of intervention at the merits stage of the present case.
The present
intervention will deal with Article I and Article II of the Convention for the merits of the
case.
8
In its intervention of 18 November 2022, the Republic of Bulgaria had focused solely on
Article IX of the Convention relating to the jurisdiction of the Court. On 18 June 2024
the Registrar provided some procedural information regarding the filing of a new
declaration of intervention at the merits stage of the present case.
8
The present
intervention will deal with Article I and Article II of the Convention for the merits of the
case.
17. The Republic of Bulgaria also wishes to assure the Court that the intervention was filed
"as soon as possible and no later than the date fixed for the opening of the oral
proceedings" as stipulated in Article 82 of the Rules of the Court. It requests to be
provided with copies of the Parties' pleadings, as well as any annexed documents, in line
with Article 86, paragraph I, of the Rules of the Court. It further informs the Court that
it is willing to assist the Court in grouping its intervention together with similar
interventions from other states for future stages of the proceedings, if the Court deems
such a move useful in the interest ofan expedient administration of justice.
17. The Republic of Bulgaria also wishes to assure the Court that the intervention was filed
"as soon as possible and no later than the date fixed for the opening of the oral
proceedings" as stipulated in Article 82 of the Rules of the Court. It
requests to be
provided with copies of the Parties' pleadings, as well as any annexed documents, in line
with Article 86, paragraph I, of the Rules of the Court. It
further informs the Court that
it is willing to assist the Court in grouping its intervention together with similar
interventions from other states for future stages of the proceedings, if the Court deems
such a move useful in the interest ofan expedient administration of justice.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Th e Gambia v.
Myanmar), Judgment of 22 July 2022, p. 37, para. 87: "The Court will have recourse to the rules of customary
Myanmar), Judgment of 22 July 2022, p. 37, para. 87: "The Court will have recourse to the rules of customary
international law on treaty interpretation as reflected in Articles 31 to 33 of the Vienna Convention on the law
international law on treaty interpretation as reflected in Articles 31 to 33 of the Vienna Convention on the law
of Treaties of 23 May 1969"; see also Application of the International Convention on the Elimination of All Forms
of Racial Discrimination (Qatar v. United Arab Emirates), Preliminary Objections, Judgment of 4 February 2021,
p. 28, para. 75 with further references.
of Treaties of 23 May 1969"; see also Application of the International Convention on the Elimination of All Forms
of Racial Discrimination (Qatar v. United Arab Emirates), Preliminary Objections, Judgment of 4 February 2021,
p. 28, para. 75 with further references.
8
8
Letter from the Registrar of the Court of 18 June 2024 - see Annex B.
Letter from the Registrar of the Court of 18 June 2024 - see Annex B.
4
4
BASIS ON WHICH THE REPUBLIC OF BULGARIA IS PARTY TO THE
CONVENTION
BASIS ON WHICH THE REPUBLIC OF BULGARIA IS PARTY TO THE
CONVENTION
18. The Republic of Bulgaria acceded to the Convention and deposited its instrument of
accession in accordance with Article XI, paragraph 4 of the Convention on 21 July 1950°.
In accordance with Article XIII, the Convention entered into force for the Republic of
Bulgaria on 12 January 1951. Upon accession, the Republic of Bulgaria made two
reservations, respectively regarding article IX and regarding article XII. The reservation
regarding article IX was withdrawn on 24 June 1992.
18. The Republic of Bulgaria acceded to the Convention and deposited its instrument of
accession in accordance with Article XI, paragraph 4 of the Convention on 21 July 1950°.
In accordance with Article XIII, the Convention entered into force for the Republic of
Bulgaria on 12 January 1951. Upon accession, the Republic of Bulgaria made two
reservations, respectively regarding article IX and regarding article XII. The reservation
regarding article IX was withdrawn on 24 June 1992.
See Annex C.
See Annex C.
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PROVISIONS OF THE CONVENTION IN QUESTION
PROVISIONS OF THE CONVENTION IN QUESTION
I 9. The Republic of Bulgaria wishes to share with the Court its interpretation of Articles I
and II of the Convention, which it considers relevant for the merits of the case.
I 9. The Republic of Bulgaria wishes to share with the Court its interpretation of Articles I
and II of the Convention, which it considers relevant for the merits of the case.
20. Article I of the Convention reads as follows:
20. Article I of the Convention reads as follows:
"The Contracting Parties confirm that genocide, whether committed in time of peace or
in time of war, is a crime under international law which they undertake to prevent and to
punish."
"The Contracting Parties confirm that genocide, whether committed in time of peace or
in time of war, is a crime under international law which they undertake to prevent and to
punish."
21. Under Article I, all States Parties to the Genocide Convention are obliged to prevent and
punish genocide. As the Court has already emphasised, the Republic of Bulgaria recalls
that in fulfilling their duty to prevent genocide, Contracting Parties must act within the
limits permitted by international law". The application and interpretation of treaties in
good faith is a rule of customary international law, reflected in Articles 26 and 31 of the
Vienna Convention on the Law of Treaties. As the Court has observed, the principle of
21. Under Article I, all States Parties to the Genocide Convention are obliged to prevent and
punish genocide. As the Court has already emphasised, the Republic of Bulgaria recalls
that in fulfilling their duty to prevent genocide, Contracting Parties must act within the
limits permitted by international law". The application and interpretation of treaties in
good faith is a rule of customary international law, reflected in Articles 26 and 31 of the
Vienna Convention on the Law of Treaties. As the Court has observed, the principle of
good faith "obliges the Parties to apply [a treaty] in a reasonable way and in such a
manner that its purpose can be realized"'
Good faith interpretation thus operates as a
safeguard against misuse of the Convention. It
is incompatible with the above-mentioned
principle for a Contracting Party to carry out an assessment of the occurrence of genocide
abusively. As "one of the basic principles governing the creation and performance of
legal obligations", good faith is also directly linked to the "trust and confidence [that] are
inherent in international co-operation
1•
good faith "obliges the Parties to apply [a treaty] in a reasonable way and in such a
manner that its purpose can be realized"'
1•
Good faith interpretation thus operates as a
safeguard against misuse of the Convention. It is incompatible with the above-mentioned
principle for a Contracting Party to carry out an assessment of the occurrence of genocide
abusively. As "one of the basic principles governing the creation and performance of
legal obligations", good faith is also directly linked to the "trust and confidence [that] are
inherent in international co-operation
22. In the Republic of Bulgaria's view, the notion of "undertake to prevent" implies that each
State Party must assess whether a genocide or a serious risk of genocide exists prior to
qualifying a situation as genocide and (possibly) taking action pursuant to Article !
13
.
22. In the Republic of Bulgaria's view, the notion of "undertake to prevent" implies that each
State Party must assess whether a genocide or a serious risk of genocide exists prior to
qualifying a situation as genocide and (possibly) taking action pursuant to Article !
13.
Such an assessment must be justified by substantial evidence "that is fully conclusive"
14
•
Such an assessment must be justified by substantial evidence "that is fully conclusive"
14•
23. Importantly, the UN Human Rights Council called upon all States, "in order to deter
future occurrences of genocide, to cooperate, including through the United Nations
system, in strengthening appropriate collaboration between existing mechanisms that
contribute to the early detection and prevention of massive, serious and systematic
23. Importantly, the UN Human Rights Council called upon all States, "in order to deter
future occurrences of genocide, to cooperate, including through the United Nations
system, in strengthening appropriate collaboration between existing mechanisms that
contribute to the early detection and prevention of massive, serious and systematic
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
Case Concerning Application of the Convention on the Prevention and
Punishment
Crime
of the
of Genocide
(Bosnia and Herzegovina v.
Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 221, para. 430;
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 221, para. 430;
A/legal ions of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide
A/legal ions of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide
(Ukraine v. Russian Federation), Order of 16 March 2022, I.CJ. Reports 2022, p.211, para. 57.
(Ukraine v. Russian Federation), Order of 16 March 2022, I.CJ. Reports 2022, p.211, para. 57.
Gab~ikovo-Nagymaros Project (Hungary/Slovakia), Judgment, I.C.J. Reports 1997, p. 7, at p. 79, para. 142.
Gab~ikovo-Nagymaros Project (Hungary/Slovakia), Judgment, I.C.J. Reports 1997, p. 7, at p. 79, para. 142.
Nuclear Tests (Australia v. France), I.C.J. Reports I 974, p. 253 p. I9, at p. 268, para. 142.
Nuclear Tests (Australia v. France), I.C.J. Reports I 974, p. 253 p. I9, at p. 268, para. 142.
3
3 Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
Case Concerning Application of the Convention on the Prevention and
Punishment
of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at pp. 221-222, paras.
430-431.
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at pp. 221-222, paras.
430-431.
14
14
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 90, para. 209.
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 90, para. 209.
6
6
violations of human rights that, if not halted, could lead to genocide".' It therefore
constitutes good practice to rely on the results of independent investigations under UN
auspices! before qualifying a situation as genocide.
violations of human rights that, if not halted, could lead to genocide".' It therefore
constitutes good practice to rely on the results of independent investigations under UN
auspices! before qualifying a situation as genocide.
24. The correct construction of Article I is hence that a State is under a due diligence
obligation to gather such evidence from independent sources, where they exist, before
alleging that another State party of the Genocide Convention has committed genocide.
24. The correct construction of Article I is hence that a State is under a due diligence
obligation to gather such evidence from independent sources, where they exist, before
alleging that another State party of the Genocide Convention has committed genocide.
25. Concerning the burden of proof, it is for the party which alleges a fact in support of its
claims to prove the existence of that fact'. This principle is not an absolute one, however,
since the determination of the burden of proof is in reality dependent on the subject
matter and the nature of the dispute brought before the Court; it varies according to the
type of facts which it is necessary to establish for the purposes of the decision of the
case.
18
25. Concerning the burden of proof, it is for the party which alleges a fact in support of its
claims to prove the existence of that fact'. This principle is not an absolute one, however,
since the determination of the burden of proof is in reality dependent on the subject
matter and the nature of the dispute brought before the Court; it varies according to the
type of facts which it is necessary to establish for the purposes of the decision of the
case.
18
26. In particular, the Court has recognized that there may be circumstances in which the
Applicant cannot be required to prove a negative fact, which it is asserting.
26.
19
In particular, the Court has recognized that there may be circumstances in which the
Applicant cannot be required to prove a negative fact, which it is asserting.
19
27. Against that background, the Republic of Bulgaria wishes to explain that it is for the State
Party bringing a case against another State Party for a false allegation of genocide used
as a basis to justify preventive action to provide prima facie evidence that its action did
not fall under the definition of genocide as laid down in Article IL In turn, the respondent
State asserting that its allegation was well-founded to justify its preventive action must
provide conclusive evidence in support since this attempted justification involves charges
of exceptional gravity." After adversarial scrutiny, it would then be for the Court to
evaluate all the evidence presented by the two Parties so as to reach its own conclusions.
21
27. Against that background, the Republic of Bulgaria wishes to explain that it is for the State
Party bringing a case against another State Party for a false allegation of genocide used
as a basis to justify preventive action to provide prima facie evidence that its action did
not fall under the definition of genocide as laid down in Article IL In turn, the respondent
State asserting that its allegation was well-founded to justify its preventive action must
provide conclusive evidence in support since this attempted justification involves charges
of exceptional gravity." After adversarial scrutiny, it would then be for the Court to
evaluate all the evidence presented by the two Parties so as to reach its own conclusions.
21
28. Article II of the Convention reads:
28. Article II of the Convention reads:
"In the present Convention, genocide means any of the following acts committed with
"In the present Convention, genocide means any of the following acts committed with
I5
I5 UN Human Rights Council, Resolution 43/29: Prevention of Genocide (29 June 2020), UN Doc
UN Human Rights Council, Resolution 43/29: Prevention of Genocide (29 June 2020), UN Doc
A/HRC/RES/43/29, para. 11.
A/HRC/RES/43/29, para. 11.
16
16
See for example the reliance of The Gambia on the reports of the Independent International Fact-Finding
See for example the reliance of The Gambia on the reports of the Independent International Fact-Finding
Mission on Myanmar established by the UN Human Rights Council before bringing a case to the Court; for details
see Application of the Convention on the Prevention and
Punishment
Crime
Mission on Myanmar established by the UN Human Rights Council before bringing a case to the Court; for details
see Application of the Convention on the Prevention and Punishment of the Crime of Genocide (The Gambia v.
of the
of Genocide (Th e Gambia v.
Myanmar), Judgment of22 July 2022, at pp. 25-27, paras. 65-69.
Myanmar), Judgment of22 July 2022, at pp. 25-27, paras. 65-69.
Pulp Mills on the River Uruguay (Argentina v. Uruguay), LC.J. Reports 2010 (1), Judgment, p. 14, at p. 7I,
Pulp Mills on the River Uruguay (Argentina v. Uruguay), LC.J. Reports 2010 (1), Judgment, p. 14, at p. 7I,
para. 162.
para. 162.
18
18
Ahmadou Sadio Diallo (Republic of Guinea v. Democratic Republic of the Congo), Merits, Judgment,
Ahmadou Sadio Diallo (Republic of Guinea v. Democratic Republic of the Congo), Merits, Judgment,
I.C.J. Reports 2010 (1I), p. 639, at p. 660, para. 54.
I.C.J. Reports 2010 (1I), p. 639, at p. 660, para. 54.
" Ahmadou Sadio Diallo (Republic of Guinea v. Democratic Republic of the Congo), Merits, Judgment,
I.C.J. Reports 2010 (II), p. 639, at p. 660, para. 55.
" Ahmadou Sadio Diallo (Republic of Guinea v. Democratic Republic of the Congo), Merits, Judgment,
I.C.J. Reports 2010 (II), p. 639, at p. 660, para. 55.
2
° Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
2
° Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 90, para. 209.
On the notion of"charges of exceptional gravity" see also G. M. Famelli, Consistency in the ICJ's Approach to
the Standard of Proof: An Appraisal of the Court's Flexibility, in: The Law and Practice of International Courts
and Tribunals, 21:1(2022), pp. 98-121, at 107-111.
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 90, para. 209.
On the notion of"charges of exceptional gravity" see also G. M. Famelli, Consistency in the ICJ's Approach to
the Standard of Proof: An Appraisal of the Court's Flexibility, in: The Law and Practice of International Courts
and Tribunals, 21:1(2022), pp. 98-121, at 107-111.
!
! 4hmadou Sadio Diallo (Republic of Guinea v. Democratic Republic of the Congo), Merits, Judgment,
4hmadou Sadio Diallo (Republic of Guinea
v.
Democratic Republic of the Congo), Merits, Judgment,
I.C.J. Reports 2010 (II), p. 639, at p. 660, para. 56.
I.C.J. Reports 2010 (II), p. 639, at p. 660, para. 56.
7
7
intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as
such:
(a) Killing members of the group;
(b) Causing serious bodily or mental harm to members of the group;
(c) Deliberately inflicting on the group conditions of life calculated to bring about its
physical destruction in whole or in part;
( d) Imposing measures intended to prevent births within the group;
(e) Forcibly transferring children of the group to another group."
intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as
such:
(a) Killing members of the group;
(b) Causing serious bodily or mental harm to members of the group;
(c) Deliberately inflicting on the group conditions of life calculated to bring about its
physical destruction in whole or in part;
( d) Imposing measures intended to prevent births within the group;
(e) Forcibly transferring children of the group to another group."
29. Article II of the Convention deals with the definition of genocide. The Republic of
Bulgaria contends that the elements of genocide are already well-established in the case
law of the Court and supports the current interpretation.
29. Article II of the Convention deals with the definition of genocide. The Republic of
Bulgaria contends that the elements of genocide are already well-established in the case
law of the Court and supports the current interpretation.
30. In particular, in order for an action to be qualified as "genocide", there is a requirement
to establish both genocidal action (actus reus) and a (specific) genocidal intent (mens
rea) next to the mental elements present in the acts listed in Article II.
The Genocide
Convention is designed to prevent the physical or biological destruction of all or part of
a protected group. When assessing the existence of genocide, the ICTY has considered
the detrimental long-term consequences the actions in question have for the physical
survival of the group, as well as the residual possibility that the group can reconstitute
itself, endorsing a quantitative and qualitative element for the actus reus.
22
30. In particular, in order for an action to be qualified as "genocide", there is a requirement
to establish both genocidal action (actus reus) and a (specific) genocidal intent (mens
rea) next to the mental elements present in the acts listed in Article II.
22
The Genocide
Convention is designed to prevent the physical or biological destruction of all or part of
a protected group. When assessing the existence of genocide, the ICTY has considered
the detrimental long-term consequences the actions in question have for the physical
survival of the group, as well as the residual possibility that the group can reconstitute
itself, endorsing a quantitative and qualitative element for the actus reus.
31. Article II provides that genocide may only occur if the relevant act is committed "with
intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as
such". This element is the "essential characteristic of genocide, which distinguishes it
from other serious crimes".
24
is to be distinguished from other motives or reasons the
perpetrator may have.
It
31. Article II provides that genocide may only occur if the relevant act is committed "with
intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as
such". This element is the "essential characteristic of genocide, which distinguishes it
from other serious crimes".
24
is not enough that the members of the group are targeted because
they belong to that group, that is because the perpetrator has a discriminatory intent.
It
It is to be distinguished from other motives or reasons the
perpetrator may have. It is not enough that the members of the group are targeted because
they belong to that group, that is because the perpetrator has a discriminatory intent.
32. In turn, the occurrence of civilian casualties during the course of armed conflict is not
per se evidence of genocidal action or genocidal intent.
32.
In turn, the occurrence of civilian casualties during the course of armed conflict is not
per se evidence of genocidal action or genocidal intent.
33. Where direct evidence for specific intent is absent, the Court has determined that "in
order to infer the existence of dolus specialis from a pattern of conduct, it is necessary
and sufficient that this is the only inference that could reasonably be drawn from the acts
33. Where direct evidence for specific intent is absent, the Court has determined that "in
order to infer the existence of dolus specialis from a pattern of conduct, it is necessary
and sufficient that this is the only inference that could reasonably be drawn from the acts
Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
Case Concerning Application of the Convention on the Prevention and
Punishment
Crime
of the
of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at pp. 121-122,
paras. 186-189.
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at pp. 121-122,
paras. 186-189.
23
23 prosecutor v Radislav Krstic (Judgement in Sentencing Appeals), IT-98-33-A, International Criminal Tribunal
for the former Yugoslavia (ICTY), 19 April 2004, paras. 24-31.
' Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Croatia v. Serbia),
Judgement, ICJ Reports 2015, p. 3, at p.62, para. 132.
prosecutor v Radislav Krstic (Judgement in Sentencing Appeals), IT-98-33-A, International Criminal Tribunal
for the former Yugoslavia (ICTY), 19 April 2004, paras. 24-31.
' Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Croatia v. Serbia),
Judgement, ICJ Reports 2015, p. 3, at p.62, para. 132.
2'
Case Concerning Application of the Convention on the
Prevention
2' Case Concerning Application of the Convention on the Prevention and Punishment of the Crime of Genocide
Punishment
and
of the Crime of Genocide
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at pp. 121-122,
paras. 187, 189.
(Bosnia and Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at pp. 121-122,
paras. 187, 189.
8
8
in question".
26
Article II contains an exhaustive list of the acts constituting a genocidal
action, all of which "are by their nature conscious, intentional or volitional acts".
in question".
26
Article II contains an exhaustive list of the acts constituting a genocidal
action, all of which "are by their nature conscious, intentional or volitional acts".
34. Claims involving charges of exceptional gravity must be proved by evidence that is fully
conclusive. The Court requires that it be fully convinced that allegations made in the
proceedings, that the crime of genocide or the other acts enumerated in Article III have
been committed, have been clearly established. The same standard applies to the proof
of attribution for such acts.
28
34. Claims involving charges of exceptional gravity must be proved by evidence that is fully
conclusive. The Court requires that it be fully convinced that allegations made in the
proceedings, that the crime of genocide or the other acts enumerated in Article III have
been committed, have been clearly established. The same standard applies to the proof
of attribution for such acts.
28
26
26
Application of the Convention on the Prevention and Punishment of the Crime a/Genocide (Croatia v.
Serbia),
Application of the Convention on the Prevention and Punishment of the Crime a/Genocide (Croatia v. Serbia),
Judgment, I.C.J. Reports 2015, p. 3, at p. 67, para. 148.
Judgment, I.C.J. Reports 2015, p. 3, at p. 67, para. 148.
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and
Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 121, para. I 86.
Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43, at p. 121, para. I 86.
28
28 Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and
Herzegovina v.
Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at p. 129, para. 209.
Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007 (I), p. 43, at p. 129, para. 209.
9
9
DOCUMENTS IN SUPPORT OF THE DECLARATION
DOCUMENTS IN SUPPORT OF THE DECLARATION
35. The following is a list of the documents in support of this Declaration, which documents
are attached hereto:
35. The following is a list of the documents in support of this Declaration, which documents
are attached hereto:
(a) Annex A- Letter from the Registrar of the International Court of Justice sent pursuant
to Article 63, paragraph I of the Statute;
(a) Annex A- Letter from the Registrar of the International Court of Justice sent pursuant
to Article 63, paragraph I of the Statute;
(b) Annex B -Letter from the Registrar of the International Court ofJustice, dated 18 June
2024;
(b) Annex B -Letter from the Registrar of the International Court ofJustice, dated 18 June
2024;
( c) Annex C - Copy of the Instrument of accession by the Republic of Bulgaria to the
Genocide Convention and copy of the Communication of the withdrawal of the
reservation under Article IX.
( c) Annex C - Copy of the Instrument of accession by the Republic of Bulgaria to the
Genocide Convention and copy of the Communication of the withdrawal of the
reservation under Article IX.
10
10
CONCLUSION
CONCLUSION
36. On the basis of the information set out above, the Republic of Bulgaria avails itself on
the right conferred upon it by Article 63, paragraph 2 of the Statute to intervene as a non
party in the proceedings brought by Ukraine against the Russian Federation in this case.
36. On the basis of the information set out above, the Republic of Bulgaria avails itself on
the right conferred upon it by Article 63, paragraph 2 of the Statute to intervene as a non
party in the proceedings brought by Ukraine against the Russian Federation in this case.
37. The Republic of Bulgaria has appointed the undersigned as Agent for the purposes of this
Declaration. The Registrar of the Court may channel all communication at the following
address:
37. The Republic of Bulgaria has appointed the undersigned as Agent for the purposes of this
Declaration. The Registrar of the Court may channel all communication at the following
address:
Embassy of the Republic of Bulgaria in The Netherlands
The Hague, Duinroosweg 9, 2597 KJ, Den Haag
Embassy of the Republic of Bulgaria in The Netherlands
The Hague, Duinroosweg 9, 2597 KJ, Den Haag
Respectfully submitted,
Respectfully submitted,
Agent of the Republic of Bulgaria
Agent of the Republic of Bulgaria
11
11
CERTIFICATION
CERTIFICATION
I certify that the documents attached by way of Annexes to this Declaration are true
copies of the originals thereof.
I certify that the documents attached by way of Annexes to this Declaration are true
copies of the originals thereof.
•
Danail Chakarov
•
Danail Chakarov
Agent of the Republic of Bulgaria
Agent of the Republic of Bulgaria
12
12
156413
&
COUR INTERNATIONALE
INTERNATIONAL COURT
DE JUSTICE. OF JUSTICE
COUR INTERNATIONALE -
INTERNATIONAL COURT
DE
JUSTICE.
OF JUSTICE
156413
30 March 2022
30 March 2022
I have the honour to refer to my letter (No. 156253) dated 2 March 2022 informing your
I have the honour to refer to my letter (No. 156253) dated 2 March 2022 informing your
Government that, on 26 February 2022, Ukraine filed in the Registry of the Court an Application
instituting proceedings against the Republic of the Russian Federation in the case concerning
Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of
Genocide (Ukraine v. Russian Federation). A copy of the Application was appended to that letter.
The text of the Application is also available on the website of the Court (www.icj-cij.org).
Government that, on 26 February 2022, Ukraine filed in the Registry of the Court an Application
instituting proceedings against the Republic of the Russian Federation in the case concerning
Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of
Genocide (Ukraine v. Russian Federation). A copy of the Application was appended to that letter.
The text of the Application is also available on the website of the Court (www.icj-cij.org)
Article 63, paragraph I, of the Statute of the Court provides that:
Article 63, paragraph I, of the Statute of the Court provides that:
[ w ]hen ever the construction of a convention to which States other than those concerned
in the case are parties is in question, the Registrar shall notify all such States forthwith".
[ w ]hen ever the construction of a convention to which States other than those concerned
in the case are parties is in question, the Registrar shall notify all such States forthwith".
Further, under Article 43, paragraph I, of the Rules of Court:
Further, under Article 43, paragraph I, of the Rules of Court:
"Whenever the construction of a convention to which States other than those
"Whenever the construction of a convention to which States other than those
concerned in the case are parties may be in question within the meaning of Article 63,
paragraph I, of the Statute, the Court shall consider what directions shall be given to the
Registrar in the matter."
concerned in the case are parties may be in question within the meaning of Article 63,
paragraph I, of the Statute, the Court shall consider what directions shall be given to the
Registrar in the matter."
On the instructions of the Court, given in accordance with the said provision of the Rules of
On the instructions of the Court, given in accordance with the said provision of the Rules of
Court, I have the honour to notify your Government of the foll owing.
Court, I have the honour to notify your Government of the following.
In the above-mentioned Application, the 1948 Convention on the Prevention and Punishment
In the above-mentioned Application, the 1948 Convention on the Prevention and Punishment
of the Crime of Genocide (hereinafter the "Genocide Convention") is invoked both as a basis of the
Court's jurisdiction and as a substantive basis of the Applicant's claims on the merits. In particular,
the Applicant seeks to found the Court's jurisdiction on the compromissory clause contained in
Article IX of the Genocide Convention, asks the Court to declare that it has not committed a genocide
as defined in Articles II and Ill of the Convention, and raises questions concerning the scope of the
duty to prevent and punish genocide under Article I of the Convention. It therefore appears that the
construction of this instrument will be in question in the case.
of the Crime of Genocide (hereinafter the "Genocide Convention") is invoked both as a basis of the
Court's jurisdiction and as a substantive basis of the Applicant's claims on the merits. In particular,
the Applicant seeks to found the Court's jurisdiction on the compromissory clause contained in
Article IX of the Genocide Convention, asks the Court to declare that it has not committed a genocide
as defined in Articles II and III of the Convention, and raises questions concerning the scope of the
duty to prevent and punish genocide under Article I of the Convention. It therefore appears that the
construction of this instrument will be in question in the case.
.I.
.I.
[Letter to the States parties to the Genocide Convention
(except Ukraine and the Russian Federation)]
[Letter to the States parties to the Genocide Convention
(except Ukraine and the Russian Federation)]
Palais de la Paix, Carnegieplein 2
Peace Palace, Carnegieplein 2
Palais de la Paix, Carnegieplein 2
Peace Palace, Carnegieplein 2
2517KJ La Haye - Pays-Bas
2517KJ The Hague - Netherlands
2517KJ La Haye - Pays-Bas
2517KJ The Hague - Netherlands
Tel~phone: +31 (0) 70 302 23 23 -Facsimile : +31 (0) 70 364 99 28
Tel~phone: +31 (0) 70 302 23 23 - Facsimile : +31 (0) 70 364 99 28
Telephone:+) I (0)70 302 23 23-Telefax: +31(0) 70 364 99 28
Telephone: +31 (0) 70 302 23 23-Telefax: +31 (0)70 364 99 28
Site Intemet: www.icj-cij.o rg
Site Intemet : www.icj-cij.org
Website: www.icj-cij. org
Website: www.icj-cij.org
COUR INTERNATIONALE
DE JUSTICE
INTERNATIONAL COUR.T
OF JUSTICE
COUR INTERNATIONALE
DE JUSTICE
INTERNATIONAL COURT
OF JUSTICE
Your country is included in the list of parties to the Genocide Convention. The present letter
should accordingly be regarded as the notification contemplated by Article 63, paragraph I, of the
Statute. l would add that this notification in no way prejudges any question of the possible application
of Article 63, paragraph 2, of the Statute, which the Court may later be called upon to determine in
this case.
Your country is included in the list of parties to the Genocide Convention. The present letter
should accordingly be regarded as the notification contemplated by Article 63, paragraph I, of the
Statute. I would add that this notification in no way prejudges any question of the possible application
of Article 63, paragraph 2, of the Statute, which the Court may later be called upon to determine in
this case.
Accept, Excellency, the assurances ofmy highest consideration.
Accept, Excellency, the assurances ofmy highest consideration.
Philippe Gautier
Registrar
Philippe Gautier
Registrar
-2
- 2
COUR INTERNATIONALE [l tr
By email onlv
COUR INTERNATIONALE [l tr
DE JUSTICE
INTERNATIONAL COURT
OF JUSTICE
DE JUSTICE
INTERNATIONAL COURT
OF JUSTICE
By email onlv
162412
18 June 2024
162412
18 June 2024
Madam,
Madam,
With reference to the case concerning Allegalions of Genocide under the Convention on the
Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation), I have the
honour to recall that by its Order dated 5 June 2023, the Court decided that the declarations of
intervention under Article 63 of the Statute submitted by 32 States (Australia, Austria, Belgium,
Bulgaria, Canada and the Netherlands (jointly), Croatia, Cyprus, Czechia, Denmark, Estonia,
Finland, France, Germany, Greece, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg,
Malta, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and
the United Kingdom) were admissible at the preliminary objections stage of the proceedings in so
far as they concerned the construction of Article
and other provisions of the Genocide Convention
that are relevant for the determination of the jurisdiction of the Court. The Court further decided that
the declaration of intervention under Article 63 of the Statute submitted by the United States was
inadmissible in so far as it concerned the preliminary objections stage of the proceedings. I also recall
that by its Judgment dated 2 February 2024, the Court found that it had jurisdiction, on the basis of
Article IX of the Genocide Convention, to entertain submission (b) at paragraph 178 of the Memorial
of Ukraine, whereby Ukraine requested the Court to "[a]djudge and declare that there is no credible
evidence that Ukraine is responsible for committing genocide in violation of the Genocide
Convention in the Donetsk and Luhansk oblasts of Ukraine", and that this submission was
admissible. In light of the fact that the case has now proceeded to the merits, I have the honour to
inform you of the following.
IX
With reference to the case concerning Allegalions of Genocide under the Convention on the
Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation), I have the
honour to recall that by its Order dated 5 June 2023, the Court decided that the declarations of
intervention under Article 63 of the Statute submitted by 32 States (Australia, Austria, Belgium,
Bulgaria, Canada and the Netherlands (jointly), Croatia, Cyprus, Czechia, Denmark, Estonia,
Finland, France, Germany, Greece, Ireland, Italy, Latvia, Liechtenstein, Lithuania, Luxembourg,
Malta, New Zealand, Norway, Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden and
the United Kingdom) were admissible at the preliminary objections stage of the proceedings in so
far as they concerned the construction of Article IX and other provisions of the Genocide Convention
that are relevant for the determination of the jurisdiction of the Court. The Court further decided that
the declaration of intervention under Article 63 of the Statute submitted by the United States was
inadmissible in so far as it concerned the preliminary objections stage of the proceedings. I also recall
that by its Judgment dated 2 February 2024, the Court found that it had jurisdiction, on the basis of
Article IX of the Genocide Convention, to entertain submission (b) at paragraph 178 of the Memorial
of Ukraine, whereby Ukraine requested the Court to "[a]djudge and declare that there is no credible
evidence that Ukraine is responsible for committing genocide in violation of the Genocide
Convention in the Donetsk and Luhansk oblasts of Ukraine", and that this submission was
admissible. In light of the fact that the case has now proceeded to the merits, I have the honour to
inform you of the following.
.I .
.I.
Ms Dimana Dramova
Agent of the Republic of Bulgaria
before the International Court of Justice
Embassy of the Republic of Bulgaria
The Hague
Ms Dimana Dramova
Agent of the Republic of Bulgaria
before the International Court of Justice
Embassy of the Republic of Bulgaria
The Hague
cc: His Excellency
Mr Konstantin Dimitrov
cc: His Excellency
Mr Konstantin Dimitrov
Co-Agent of the Republic of Bulgaria
before the International Court of Justice
Embassy of the Republic of Bulgaria
The Hague
Co-Agent of the Republic of Bulgaria
before the International Court of Justice
Embassy of the Republic of Bulgaria
The Hague
Email: [email protected]
[email protected]
Margarita. VELEY [email protected]
[email protected]
Email: [email protected]
[email protected]
Margarita. VELEY [email protected]
[email protected]
Palais de la Paix, Carnegieplein 2
2517KJ La Haye - Pays-Bas
Peace Palace, Carnegieplein 2
2517KJ The Hague - Netherlands
Palais de la Paix, Carnegieplein 2
2517KJ La Haye - Pays-Bas
Peace Palace, Carnegieplein 2
2517KJ The Hague - Netherlands
+
Telephone: +31 (0) 70 302 23 23 - Facsimile: +31(0) 70 364 99 28
Telephone:
31 (0) 70 302 23 23 - Facsimile: +31(0) 70 364 99 28
Telephone. +31 (0) 70 302 23 23 - Telefax. +31 (0) 70 364 99 28
Telephone. +31 (0) 70 302 23 23 - Telefax. +31 (0) 70 364 99 28
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COUR INTERNATIONALE
DE JUSTICE
INTERNATIONAL COURT
COUR INTERNATIONALE
DE JUSTICE
INTERNATIONAL COURT
OF JUSTICE
OF JUSTICE
States which sought to intervene at the preliminary objections stage and at the merits stage are
invited to indicate, by 2 August 2024, whether they maintain their declarations of intervention.
If deemed necessary, they may adjust by the same date their declarations of intervention in light
of the Judgment of2 February 2024.
States which sought to intervene at the preliminary objections stage and at the merits stage are
invited to indicate, by 2 August 2024, whether they maintain their declarations of intervention.
If deemed necessary, they may adjust by the same date their declarations of intervention in light
of the Judgment of2 February 2024.
States which only sought to intervene at the preliminary objections stage, but which now wish to
intervene at the merits stage should file a new declaration of intervention by 2 August 2024.
States which only sought to intervene at the preliminary objections stage, but which now wish to
intervene at the merits stage should file a new declaration of intervention by 2 August 2024.
Pursuant to Article 83, paragraph I, of its Rules, the Court will then invite the Parties to file
written observations on the admissibility of the declarations of intervention at the merits stage.
If one of the Parties objects to the admissibility of the declarations of intervention, there will be
a further round of written observations, in accordance with Article 84, paragraph 2, of the Rules.
Thereafter, the Court will decide on the admissibility of the declarations of intervention at the
merits stage.
Pursuant to Article 83, paragraph I, of its Rules, the Court will then invite the Parties to file
written observations on the admissibility of the declarations of intervention at the merits stage.
If one of the Parties objects to the admissibility of the declarations of intervention, there will be
a further round of written observations, in accordance with Article 84, paragraph 2, of the Rules.
Thereafter, the Court will decide on the admissibility of the declarations of intervention at the
merits stage.
Accept, Madam, the assurances of my highest consideration.
Accept, Madam, the assurances of my highest consideration.
Philippe Gautier
Registrar
Philippe Gautier
Registrar
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INITIALS
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INITI
ALS
�n nc r�f ·r.-nt �- votre let::rc du
6 d,fo�1)re
".
Monsieur le Sectaire c~n'ra1,
.
•g
~ votre lettre du d~cenore
Dn me r~£ 'rent
19\9 et conforment au: dispositions de 1'Article XI
19\9 ot conforment aux dispositions de 1'Article XI
de la Convention pour la pr'vention et ls r~press1on
de la Convention pour ls pr'vention et ls r-press1on
du crie de ~enoclo,ouverte ~ ln signature ~ Paris
du crie de Genocide,ouverte ~ le signature ~ Paris
le 9 dcebre 190, !'ai 1'honour de ous fire par
le 9 dcebre 19\0,
'ai 1'honour de ous fire par
venir per 1e
pr/sente 1'instruont d'adhision de la
venir par 1e pr/sente l'instruont d'adhsion de la
pub iue Popi.ire de Dulgario,tvoc les risorvos
pub ique Popi.ire de Dulgaria,tvoc les servos
~
express.ot y
mention'os,
te Convention,
lnd±
express ot y mention'os, ~ lnd±te Convention,
Veillez er~or,l.onsiur le Socrts±re t~
Veuillez gr~or,onsir le Socrtcire gad
rl4les assurances e me hmute cons1d~ration.
al4les assurances <e nn hnnte cons1drat1on
..1nistre
..1nistre
tranr res
on
Excel.enco
.on50ur r7/,Y 1e,
Secr~tire {~neral de
4
on Excel.enco
onsiour ryve lie,
1'0rg.±sat1on
des liations Unies,
Secr~ta±re g~n~rel de 1'Orgaisat1on
des liations Uaios,
Jg JI?OS, Now-for?:,
U..·.%
LJ; JU0S, Now-fork,
U..·.%
LE' PRESIDIU
de
LE'
PRESIDIU
de
L' ASEL BLEE NA TION4LE
de la
L' ASEL
BLEE NA
TION4LE
de la
REPUBLIQUE POPULAIRE DE BULGARIE
REPUBLIQUE POPULAIRE DE BULGARIE
AYANT
VU ET EXALINE a Convention du 9 d~cembre
1948 pour la pr~vention et la r~pression du crime de
G~nocide,
AYANT VU ET EXALINE a Convention du 9 d~cembre
1948 pour la pr~vention et la r~pression du crime de
G~nocide,
CCNF IR.E son adh~sion ~ cette Convention avec les
rserves suivantes :
CCNF IR.E son adh~sion ~ cette Convention avec les
rserves suivantes :
I. Ence qui concerne l'rtig_le IX: La R~publique
Popuulaire de Bulgarie ne s'estime pas tenue par les
I.
Ence qui concerne l'rtig_le IX:
La R~publique
Popuulaire de Bulgarie ne s'estime pas tenue par les
dispositions de 2'Article
qui stipule quue les dif
'~rends entre les Prties contractantes relatifs d
'interpr~tation,l'application ou 'ez~cution de la
Convention seront sounis ~ 'ezamen de la Cor inter
nationale de Justice ~ la re~te d'une partie cu
dif~rend,et d~clare qu'en ce
qui concerne la cop
tence de la Couur en mati~re de di'f~rends relatifs ~
IX
dispositions de 2'Article IX qui stipule quue les dif
'~rends entre les Prties contractantes relatifs d
'interpr~tation,l'application ou 'ez~cution de la
Convention seront sounis ~
nationale de Justice ~ la re~te d'une partie cu
dif~rend,et d~clare qu'en ce qui concerne la cop
tence de la Couur en mati~re de di'f~rends relatifs ~
'ezamen de la Cor inter
'interpretation,l'application et 'ez~cuution de la
Convention, la R~publique Populaire de Bulgarie conti
'interpretation,l'application et 'ez~cuution de la
Convention, la R~publique Populaire de Bulgarie conti
nera ~ soutenir,comne elle l'a fait jus' ce our,
gue,dans chaque cas particulier, l'accord de tuutes
nera ~ soutenir,comne elle l'a fait jus' ce our,
gue,dans chaque cas particulier, l'accord de tuutes
les parties cu dir'~rend est n~cessaire pour quue la
Gour internationale de Justice puuisse ~tre saisie de
ce di~rend au fins de d~cision.
les parties cu dir'~rend est n~cessaire pour quue la
Gour internationale de Justice puuisse ~tre saisie de
ce di~rend au fins de d~cision.
2.Ence qui concerne l'rtigle III
La
2.Ence qui concerne l'rtigle III
La R~publiquue
R~publiquue
Populaire de Bulgarie d~clare qu'elle n'accepte pas
Populaire de Bulgarie d~clare qu'elle n'accepte pas
les termes de 'Article XII de la Convention
et estime qe totes les clauses de ladite
les termes de 'Article XII de la Convention
et est~me que totes les clauses de ladite
Convention devraient s'appliquer au territoires
non autonomes,y compris les territoires sous
tutelle.
Convention devraient s'appliquer aur territoires
non autonomes,y compris les territoires sous
tutelle.
\
\
ET DECLARE en ssurer I'application.
EN FOI DE QUI, a sign~ les pr~sentes et y a
ET DECLARE en assurer I'application.
EN FOI DE QUI, a sign~ les pr~sentes et y a
f'ait apposer le sceau de I'&tat.
fait apposer le sceau de I'tat.
DONE ~ Sofia, 1e 4l juillet de 1'an mil nef
cent cinquante.
DONE So'ia, 1e 4l juillet de 1'an mil nef
cent cinquuante.
LE PRESIDENT:
LE SECRTL.IRS :
LE PRESIDENT:
LE SECRETE.IRS :
44-wf,
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COMPULSORY JURISDICTION OF THE INTERNATIONAL COURT OF JUSTICE MADE
BY BULGARIA UPON RATIFICATION OF, OR ACCESSION TO, THE NINE UNITED
SIDE
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CA5
26 June 1992
Chief, Treaty Section, OLA
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INTERCOURT
THE HAGUE
MARGINS
MR. EDUARDO VALENCIA-OSPINA
•
SEE
SECRETARY-GENERAL
:
ASSISTANT
I
INSTRUCT
I
I
ON THE
I
:
REVERSE
HEREWITH YOU WILL FIND COPY OF A COMMUNICATION ON THE
SIDE
I
NINSCRIVEI
RIEN DANS
LES MARGE°
WITHDRAWAL OF THE RESPECTIVE RESERVATIONS CONCERNING THE
COMPULSORY JURISDICTION OF THE INTERNATIONAL COURT OF JUSTICE MADE
BY BULGARIA UPON RATIFICATION OF, OR ACCESSION TO, THE NINE UNITED
I
VOYEI
_5.
NATIONS CONVENTIONS INDICATED ON THE SAID COMMUNICATION.
BEST REGARDS.
AU VE5
.AST
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CA5 26 June 1992
Chief, Treaty Section, OLA
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(18-5)
The Secretary-General of the United Nations presents his
The Secretary-General of the United Nations presents his
compliments to the Permanent Representative of the Republic of
Bulgaria to the United Nations and has the honour to refer to
compliments to the Permanent Representative of the Republic of
Bulgaria to the United Nations and has the honour to refer to
the Permanent Representative's note No. 332 of 23 June 1992,
the Permanent Representative's note No. 332 of 23 June 1992,
constituting the notification of withdrawal of the reservations
constituting the notification of withdrawal of the reservations
by the Government of Bulgaria to the provisions relating to the
by the Government of Bulgaria to the provisions relating to the
International Court of Justice, as contained in the following
International Court of Justice, as contained in the following
treaties:
treaties:
(i) Convention on the Privileges and Immunities of
(i) Convention on the Privileges and Immunities of
the Specialized Agencies, approved by the
General Assembly of the United Nations on
the Specialized Agencies, approved by the
General Assembly of the United Nations on
21 November 1947 (Sections 24 and 32);
21 November 1947 (Sections 24 and 32);
(ii) Convention on the Prevention and Punishment
(ii) Convention on the Prevention and Punishment
of Crimes against Internationally Protected
of Crimes against Internationally Protected
Persons, including Diplomatic Agents, adopted
Persons, including Diplomatic Agents, adopted
by the General Assembly of the United Nations
by the General Assembly of the United Nations
on 14 December 1973 (Article 13, paragraph 1);
on 14 December 1973 (Article 13, paragraph l);
(iii) Convention on the Prevention and Punishment
(iii) Convention on the Prevention and Punishment
of the Crime of Genocide, adopted by the
General Assembly of the United Nations on
9 December 1948 (Article IX);
of the Crime of Genocide, adopted by the
General Assembly of the United Nations on
9 December 1948 (Article IX);
(iv) International Convention on the Elimination
of All Forms of Racial Discrimination,
opened for signature at New York on 7 March 1966
(iv) International Convention on the Elimination
of All Forms of Racial Discrimination,
opened for signature at New York on 7 March 1966
(Article 22);
(Article 22);
- 2
- 2
(v)
(v)
Convention on the Elimination of All Forms of
Discrimination Against Women, adopted by the
General Assembly of the United Nations on
Convention on the Elimination of All Forms of
Discrimination Against Women, adopted by the
General Assembly of the United Nations on
18 December 1979 (Article 29, paragraph 1);
18 December 1979 (Article 29, paragraph 1);
(vi) Convention against Torture and other Cruel,
(vi) Convention against Torture and other Cruel,
Inhuman or Degrading Treatment or Punishment,
Inhuman or Degrading Treatment or Punishment,
adopted by the General Assembly of the
United Nations on 10 December 1984 (Article 30,
paragraph l);
adopted by the General Assembly of the
United Nations on 10 December 1984 (Article 30,
paragraph l);
(vii) Convention for the Suppression of the Traffic
in Persons and of the Exploitation of the
(vii) Convention for the Suppression of the Traffic
in Persons and of the Exploitation of the
Prostitution of Others, opened for signature
Prostitution of Others, opened for signature
at Lake Success, New York, on 2l March 1950
at Lake Success, New York, on 2l March 1950
(Article 22);
(Article 22);
(viii) Convention on the Political Rights of Women,
(viii) Convention on the Political Rights of Women,
opened for signature at New York on 31 March
opened for signature at New York on 31 March
1953 (Article IX); and
1953 (Article IX); and
(ix)
International Convention Against the Taking of
Hostages, adopted by the General Assembly of the
United Nations on 17 December 1979 (Article 16,
paragraph 1).
(ix) International Convention Against the Taking of
Hostages, adopted by the General Assembly of the
United Nations on 17 December 1979 (Article 16,
paragraph 1).
The International Court of Justice was immediately
The International Court of Justice was immediately
advised. All States concerned are being informed accordingly.
advised. All States concerned are being informed accordingly.
22
S
eptember 1992
22 September 1992
PERMANENT MISSION
PERMANENT MISSION
OF THE FREPUBLIC OF BULGARIA
OF THE FREPUBLIC OF BULGARIA
TO THE UNITED NATIONS
TO THE UNITED NATIONS
1EAST BAT STREET
NEw YORK NY.10O26
1EAST BAT STREET
NEw YORK NY.10O26
(212) 737.4790
(212) 737.4790
33..
33..
The Permanent Representative of the Republic of
Bulgaria to the United Nations presents his compliments to the
The Permanent Representative of the Republic of
Bulgaria to the United Nations presents his compliments to the
Secretary-General of the United Nations and has the honor to
communicate that the Republic of Bulgaria has decided to
withdraw, pursuant to a Law enacted by the National Assembly on
May 5, 1992, its reservations concerning the compulsory
jurisdiction of the International Court of Justice, made upon the
ratification of, or accession by the Republic of Bulgaria to the
Secretary-General of the United Nations and has the honor to
communicate that the Republic of Bulgaria has decided to
withdraw, pursuant to a Law enacted by the National Assembly on
May 5, 1992, its reservations concerning the compulsory
jurisdiction of the International Court of Justice, made upon the
ratification of, or accession by the Republic of Bulgaria to the
following international treaties:
i
following international treaties:
1. Convention on the Prevention and Punishment of the
Crime of Genocide, adopted by the General Assembly on 9 December,
1948 (Article 9);
2. Convention for the Suppression of the Traffic in
i
1. Convention on the Prevention and Punishment of the
Crime of Genocide, adopted by the General Assembly on 9 December,
1948 (Article 9);
2. Convention for the Suppression of the Traffic in
Persons and of the Exploitation of the Prostitution of Others,
opened for signature at Lake Success, New York, on 21 March, 1950
(Article 22);
3, Convention on the Political Rights of Women, opened
for signature at New York on 31 March, 1953 (Article 9);
4. International Convention on the Elimination of All
Persons and of the Exploitation of the Prostitution of Others,
opened for signature at Lake Success, New York, on 21 March, 1950
(Article 22);
3, Convention on the Political Rights of Women, opened
for signature at New York on 31 March, 1953
(Article 9);
4. International Convention on the Elimination of All
Forms of Racial Discrimination, opened for signature at New York
Forms of Racial Discrimination, opened for signature at New York
on 7 March, 1966 (Article 22);
on 7 March, 1966 (Article 22);
5, Convention on the Elimination of All Forms of
5, Convention on the Elimination of All Forms of
Discrimination Against Women, adopted by the General Assembly of
the United Nations on 18 December, 1979 (Article 29, para 1);
Discrimination Against Women, adopted by the General Assembly of
the United Nations on 18 December, 1979 (Article 29, para 1);
6. Convention Against Torture and Other Cruel, Inhuman
6. Convention Against Torture and Other Cruel, Inhuman
or Degrading Treatment or Punishment, adopted by the General
Assembly of the United Nations on 10 December, 1984 (Article 30);
or Degrading Treatment or Punishment, adopted by the General
Assembly of the United Nations on 10 December, 1984 (Article 30);
11' '
' !
11'
'
'
H.E. Dr. Boutros Boutros-Ghali
H.E. Dr. Boutros Boutros-Ghali
!
Secretary-General
Secretary-General
United Nations
New York
United Nations
New York
•
•
7. Convention on the Prevention and Punishment of
7. Convention on the Prevention and Punishment of
Crimes Against Internationally Protected Persons, Including
Diplomatic Agents, adopted by the General Assembly of the United
Nations on 14 December, 1973 (Article 13, paral);
Crimes Against Internationally Protected Persons, Including
Diplomatic Agents, adopted by the General Assembly of the United
Nations on 14 December, 1973 (Article 13, paral);
8, International Convention Against the Taking of
Hostages, adopted by the General Assembly of the United Nations
on 17 December, 1979 (Article 16, para 1);
8, International Convention Against the Taking of
Hostages, adopted by the General Assembly of the United Nations
on 17 December, 1979 (Article 16, para 1);
9, Convention on the Privileges and Immunities of the
Specialized Agencies, approved by the General Assembly of the
United Nations on 21 November, 1947 (Sections 24 and 32).
9, Convention on the Privileges and Immunities of the
Specialized Agencies, approved by the General Assembly of the
United Nations on 21 November, 1947
(Sections 24 and 32).
The Permanent Representative of the Republic of
The Permanent Representative of the Republic of
Bulgaria to the United Nations avails himself of this opportunity
to renew to the Secretary-General the assurances of his highest
consideration. ( •
Bulgaria to the United Nations avails himself of this opportunity
to renew to the Secretary-General the assurances of his highest
consideration. ( •
New York City
June 23, 1992
New York City
June 23, 1992
Declaration of intervention of Bulgaria