- 35 87. Ukraine argues that, while it is obliged to refer to the Russian Federation’s “intervention” in Crimea in describing the alleged campaign of racial discrimination against the Crimean Tatar and Ukrainian communities in Crimea, neither the substance of Ukraine’s claims, nor the relief requested, concern the status of Crimea. 88. According to Ukraine, its claims under CERD fall squarely within the definition of “racial discrimination” under Article 1, paragraph 1, of the Convention. Ukraine alleges that the Russian Federation has implemented a “policy of discrimination in political and civil affairs” and a “campaign of cultural erasure” against Crimean Tatars and ethnic Ukrainians in Crimea. The Applicant claims that the Russian Federation has impaired the civil and political rights of the Crimean Tatar and Ukrainian communities in Crimea by a series of targeted murders and acts of torture; forced disappearances and abductions; arbitrary searches and detentions; the imposition of Russian citizenship on the residents of Crimea; and the ban on the Mejlis. The Applicant also claims that the Russian Federation has impaired the economic, social and cultural rights of these communities, by imposing restrictions on Crimean Tatar and Ukrainian media outlets; the degradation of their cultural heritage; the suppression of culturally significant gatherings of these communities; and the suppression of minority rights relating to education, and in particular restrictions placed on education in the Crimean Tatar and Ukrainian languages. It is the Applicant’s position that these measures were principally aimed against the ethnic groups of Crimean Tatar and Ukrainian communities in Crimea and had the “purpose and/or effect” of disproportionately affecting these communities less favourably than other ethnic groups in Crimea. Accordingly, Ukraine maintains that these measures amount to racial discrimination within the meaning of Article 1, paragraph 1, of CERD. 89. Ukraine argues that its Memorial shows, “on an article-by-article basis”, that the Russian Federation’s conduct has resulted in nullifying or limiting the rights and freedoms of the Crimean Tatar and Ukrainian communities protected under Articles 2, paragraph (1) (a) and (b), 4, 5 (a) to (e), 6 and 7, of CERD. Ukraine thus asserts that its claims relate to an aspect of the dispute which concerns the interpretation or application of CERD. 90. Moreover, Ukraine argues that freedom from deportation from one’s country by an “occupying State” is a human right or fundamental freedom, the denial of which on a racial or ethnic basis constitutes a breach of CERD. Ukraine further argues that the denial of the right to return to one’s country either by the territorial sovereign or by an “occupying State” also constitutes a breach of CERD. Ukraine also emphasizes that, considering Article 1, paragraph 3, of CERD, citizenship laws passed by States parties to the Convention may constitute a breach of CERD if they “discriminate against any particular nationality”. In this regard, Ukraine maintains that the law granting Russian citizenship to citizens of Ukraine and to stateless persons resident in Crimea, together with the Russian Federation’s enforcement of this law, disproportionately and adversely affects Crimean Tatars and ethnic Ukrainians in Crimea. Ukraine disputes the Russian Federation’s assertion that these measures fall outside of CERD by virtue of paragraphs 2 and 3 of Article 1.