- 18 (j) Assure to all residents of Crimea within its jurisdiction effective protection and
remedies against acts of racial discrimination.
(k) Adopt immediate and effective measures in the fields of teaching, education,
culture and information, with a view to combating prejudices which lead to racial
discrimination against the Crimean Tatar and Ukrainian communities in Crimea.
(l) Pay Ukraine financial compensation, in its own right and as parens patriae for its
citizens, for the harm Ukraine has suffered as a result of Russia’s violations of the
CERD, including the harm suffered by victims as a result of the
Russian Federation’s violations of CERD Articles 2, 4, 5, 6 and 7, with such
compensation to be quantified in a separate phase of these proceedings.”
20. In the Preliminary Objections, the following submissions were presented on behalf of the
Government of the Russian Federation:
“In view of the foregoing, the Russian Federation requests the Court to adjudge
and declare that it lacks jurisdiction over the claims brought against the
Russian Federation by Ukraine by its Application of 16 January 2017 and/or that
Ukraine’s claims are inadmissible.”
21. In the Written Statement of its Observations and Submissions on the Preliminary
Objections, the following submissions were presented on behalf of the Government of Ukraine:
“For the reasons set out in this Written Statement, Ukraine respectfully requests
that the Court:
(a) Dismiss the Preliminary Objections submitted by the Russian Federation in its
submission dated 12 September 2018;
(b) Adjudge and declare that it has jurisdiction to hear the claims in the Application
submitted by Ukraine, dated 16 January 2017 and that such claims are admissible;
and
(c) Proceed to hear those claims on the merits.”
22. At the oral proceedings on the preliminary objections, the following submissions were
presented by the Parties:
On behalf of the Government of the Russian Federation,
at the hearing of 6 June 2019:
“Having regard to the arguments set out in the Preliminary Objections of the
Russian Federation and during the oral proceedings, the Russian Federation requests
the Court to adjudge and declare that it lacks jurisdiction over the claims brought
against the Russian Federation by Ukraine by its Application of 16 January 2017
and/or that Ukraine’s claims are inadmissible.”