I. SUMMARY OF ARGUMENT 

1. This arbitration presents issues of vital importance to the Sudanese people and the broader international community.  These issues concern the rule of law in contemporary affairs and the Ngok Dinka people’s right to their historic homeland of the Abyei Area.  

2. First, this arbitration concerns the finality of decisions made by the Abyei Boundaries Commission (“ABC”) – a hand-picked body of pre-eminent experts in Sudanese and African history, culture, law and politics.  After implementing a specifically tailored fact finding and dispute resolution procedure, collaboratively developed by the parties themselves, the Commission’s Experts rendered a unanimous and carefully reasoned Report.  Despite its undertakings that the Commission’s Report would be “final and binding” and entitled to “immediate effect,” the GoS has subsequently refused to comply with the ABC’s decision.