Respondent State's submissions on the Merits 193. The Respondent State in the main begun its submissions by making what appears to be a preliminary objection that the Complainants' allegations should be dismissed for failure to comply with the Commission's Ruling on admissibility. Complainants' allegation of violations under Article 1of the African Charter 194. The Respondent State submitted that the alleged violations of Article 1 of the African Charter lacks merit on two grounds. Firstly, the Respondent State submitted that the Complainants' arguments on the principle of legality can be boiled down to the supposition that the Anti-Terrorism Proclamation No. 652/2009 did not "allow [Mr. Abubaker et all.} adequate forwarding on what constitutes a crime." According to the Respondent State the Complainants arguments did not hold water under scrutiny. 195. The Respondent State then quotes, Article 3 of the Anti-Terrorism Proclamation No. 652/2009. According to the Respondent, specific to Article 3(6) thereof the provision of the law clearly requires that mens rea and actus rei must be met, hardly leaving any room for vagueness or overbreadth. And according to the Respondent State the Complainants' arguments must fail because none of the Defendants were charged and convicted under Article 3(6) of the Anti-Terrorism Proclamation No. 652/2009. 196. On the Complainant's argument that the Anti-Terrorism Proclamation No. 652/2009's provision regarding damage to property being equally overboard, the Respondent State submitted that it does not believe it should engage in a philosophical debate on this issue, because again, none of the Complainants in this case were charged or convicted for property damage under the Anti-Terrorism Proclamation No. 652/2009. 197. In responding to the Complainants' submissions on the principle on legality which includes assertions of vagueness or overbreadth of the crime of rendering support to terrorism under Article 3(5) of the Anti-Terrorism Proclamation No. 652/2009 the Respondent State submitted that the charges of vagueness and overbreadth are equally unsupported when viewed against the specificity of the mens rea and actus rei required under the law. 198. According to the Respondent State, none of the Complainants were charged under Article 5 of the Anti-Terrorism Proclamation No. 652/2009. In this regard the Respondent State requests the Commission to dismiss this and other arguments that are in irrelevant to the facts of this case. 199. The Respondent State submitted that, contrary to the submission by the Complainants, the evidence presented at the trial proved beyond reasonable doubt inter alia that Mr. Abubaker et al. incited crowds through their repeated calls for violence and Jihad against the Government. That they were not exercising their right to free speech, assembly and religion. 200. Secondly, the Respondent State submitted that the Complainants submissions that the Anti-Terrorism Proclamation No. 652/2009 contravenes the African Charter and International Standards are without merit. ~ . I;'I'····'O~ 201. According to the Respondent State, the Complainants in this case are n ~~~rt of the ~ civil society; they are instead individuals who incited others to take u ~ms agains;J z . «, ("l ~ ., o~""\ .f" ;).'~ 0>0 (.) 1L ~ :.. ~ " J' I}; !<.,"JQ 0'}'rj :5'$/ _ V ~,r 0", 4~'RIC,,\1"l~ I (>to ,:f~, ",¢< .'/ o\rMf E' {'(... '-- .