STATEMENT OF FACTS

In 2013, the Alini Defense Forces (ADF) is headed by Gen. Hassan Amir.

Following decades of disenchantment against the Alini government, the Alin Liberation

Army (ALA), a self- proclaimed armed group, launched an attack against the police and security

forces on the southern part of Orkan and took control of a local administrative council.

As ALA expanded its control over several towns near Orkan, President Yousef Aflan, in

consultation with Gen. Amir, launched an offensive to neutralize ALA. A declaration of martial

law in areas controlled by ALA thereafter followed.

On June 13, 2013, a demonstration of residents was obstructed by ADF soldiers

following the directions of Gen. Hassan Amir that the manifestation be prohibited. He also

instructed to take any necessary measures to prevent it. At noon, the demonstration was

dispelled. However, about two hundred demonstrators succeeded in occupying the National

Technical College (NTC).

Around midnight following the demonstration, an ADF unit searched the NTC during

which several women were raped, as testified by one of the demonstrators. Moreover, two other

women testified that they were also raped by members of ADF in the detention facility

controlled by the Ministry of Security. Human Rights Protection, an international NGO, Al

Jazeera and BBC also reported incidents of sexual assaults committed by pro-government

militants during a subsequent search conducted a week after the demonstration.

Following international condemnation of the acts committed by ADF, the UN Security

Council adopted Resolution X which established the International Security Support Force (ISSF)

mandating it to take all necessary measures to protect civilians and civilian populated areas under

threat of attack and to maintain security in Alin. President Aflan expressed compliance with

Resolution X and implemented a ceasefire, consenting the deployment of ISSF in Alin. The

ceasefire was however breached leading to violent confrontations between PFU and ADF units.

On September 15, 2013, two ADF fighter jets attacked civilian areas near the ISSF

Compound. After the ISSF request for cessation of the attack was unheeded by Gen. Amir,

ISSF’s anti-aircraft machineguns fired at the fighter jets which discontinued the raid. This was

followed by the deployment of one hundred ADF militants which attacked the ISSF base using

heavy weaponry and rocket-propelled grenades while ISSF soldiers were preparing their dinner.

During the attack, Col. Adada was spotted outside the vicinity. After being blamed for the attack,

Pres. Aflan accused the ISSF of siding with the ALA.

After ADF expressed intension to expand the attacks to larger areas, Blin and Clin,

which contributed to the establishment of ISSF, bombed two major ADF air bases. President

Aflan denounced the attack. In yet another meeting where both Col. Adada and Gen. Amir were

present, the latter demanded that measures be taken to end the illegal occupation of the

international force.

On October 20, 2013, following an intense exchange of fire between ADF and ALA,

four vehicles containing twenty passengers, claiming to be civilians asked if they could be

sheltered in the ISSF station. When the vehicles were to be searched, the vehicles suddenly drove

at the ISSF members at full speed and opened fire. Dozens of grenades and explosives were

thrown at the buildings and personnel at the station, The surprise attack resulted to three deaths

and two injuries of ALA fighters and 10 deaths and 15 injuries of ISSF soldiers. The attackers

eventually admitted that they were ADF members. Gen. Amir denied having knowledge of the

attack contrary to the statement of one Imad Mousse with Al Jazeera that there attack was

coordinated and planned by ADF, and that he was personally greeted by Col. Adada for the

success of the operations.

The hostilities thereafter ended and Aziz Nur, the ALA leader, was elected as President

and Gen. Amir was no longer able to hold his post. On May 15, 2014, Alin referred the situation

in its territory from March to December 2013 to the ICC. On August 20, 2014, Gen. Amir was

surrendered by Alin to the ICC pursuant to the request of the Court.