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ICJ: Conclusions by Nicaragua
1 May 2012 -  ICJ: Nicaragua v. Colombia (Hearings): Reading of the final submissions of Nicaragua, on 1 May 2012, by the Agent of Nicaragua, H.E. Mr. Carlos José Argüello Gómez.
CIJ: audiences Nicaragua c. Colombie: lecture des conclusions du Nicaragua par l’agent du Nicaragua, S. Exc. M. Carlos José Argüello Gómez, le 1er mai 2012.”
Script of Nicaragua's final arguments:
Speaker: H.E. Mr. Carlos José Argüello Gómez, Ambassador of Nicaragua to the Kingdom of the Netherlands, Agent of Nicaragua in the proceedings:
"In accordance with Article 60 of the Rules of Court and having regard to the pleadings, written and oral, the Republic of Nicaragua,
I. May it please the Court to adjudge and declare that:
(1) The Republic of Nicaragua has sovereignty over all maritime features off her Caribbean coast not proven to be part of the “San Andrés Archipelago” and in particular the following cays: the Cayos de Albuquerque; the Cayos del Este Sudeste; the Cay of Roncador; North Cay, Southwest Cay and any other cays on the bank of Serrana; East cay, Beacon Cay and any other cays on the bank of Serranilla; and Low Cay and any other cays on the bank of Bajo Nuevo.
(2) If the Court were to find that there are features on the bank of Quitasueño that qualify as islands under international law, the Court is requested to find that sovereignty over such features rests with Nicaragua.
(3) The appropriate form of delimitation, within the geographical and legal framework constituted by the mainland coasts of Nicaragua and Colombia, is a continental shelf boundary dividing by equal parts the overlapping entitlements to a continental shelf of both Parties.
(4) The islands of San Andrés and Providencia (and Santa Catalina) be enclaved and accorded a maritime entitlement of 12 nautical miles, this being the appropriate equitable solution justified by the geographical and legal framework.
(5) The equitable solution for any cay, that might be found to be Colombian, is to delimit a maritime boundary by drawing a 3­nautical­mile enclave around them.
II. Further, the Court is requested to adjudge and declare that:
Colombia is not acting in accordance with her obligations under international law by stopping and otherwise hindering Nicaragua from accessing and disposing of her natural resources to the east of the 82nd meridian."