No. 652/2009 to them. In this regard, they submitted that their rights have been violated through the application of the Anti-Terrorism Proclamation No. 652/2009, which defines the act of terrorism so broadly that they could not have reasonably foreseen whether their protest against the government constituted terrorism acts. 146. The Complainants submitted that not only is the Anti-Terrorism Proclamation No. 652/2009 so vague and broad on so many aspects, including in that it did not allow the Complainants adequate forewarning on what constitutes a crime, but that it is designed in a way that allows the Respondent State to persecute its peaceful critics. 147. Relying on the principle of legality and limitation under the African Charter, the Complainants submitted that the Respondent State had violated their rights by "prosecuring" [SIC] them under the provisions of the Anti-Terrorism Law which are: too vague and overboard that they proscribe legitimate acts of protest and activism. In this regard, the Complainants submitted that whereas they were threatened, tortured and arbitrarily detained on trumped up charges of criminal conspiracy in terrorist acts under the Anti-Terrorism Proclamation No. 652/2009 their persecution is legitimatized under this law because of its faulty design providing legal vagueness and ambiguity that allows the Respondent State to prosecute activists, protestors, journalist, bloggers and political opposition leaders as terrorists. 148. According to the Complainants, the definition of "terrorism or terrorist" in the AntiTerrorism Proclamation No. 652/2009 is wanting and overboard in many ways. In this regard the Complainants submitted that given the broad brush with which the crime is defined it can inherently be and has been used to punish any political dissidents and civic activists including the Complainants. 149. The Complainants implored the Commission in its consideration of whether the Complainants' incarceration was prescribed by an adequately precise law. And they also implored the Commission to consider the fact that the Commission and almost all other international human rights mechanisms have decided that this law ought to be amended to comply with human rights standards. 150. The Complainants also implored the Commission to take next logical step and decide that the Anti-Terrorism Proclamation No. 652/2009 definitions under Article 3(4), (6) and 5(1) do not comply with the Commission's requirements that limitations of rights ought to be prescribed by adequately precise law. They also implored the Commission to make recommendations contained in the "Reliefs Sought" section of their submission in order to make the law compliant with regional and international standards. Alleged violation of Freedom of Religion (Article 8 of the African Charter) 151. After making lengthy submissions on the alleged violation of Article 8 of the African Charter the Complainants concluded that the Respondent State had violated the forum intemum, which is the internal right of the freedom to choose one's religion, and to be free from coercion in that the Government had forced over 18,000 Mt~o proselytization classes by the Abhash sect and by its declaration of non-abaSh-sect~ ~ ~~--l<>~~ illegal. And that the Respondent State had also violated the freedo of choice and 0"') , freedom from coercion by establishing the Abhash sect (a vaguely de ::!r d "t:ra9itiOna~ ""~~-~ Ethiopian Islam") as the official religion of Ethiopia. According to the Bmpfainan~sthe ~ ;.,\\ imposition or/ and prohibition of any religion or sect by the Respo nt Sta~teyYJl$ J J .. i ",'" "> II L .... 'Fl,,-" '<. // ~L. Q~I'/ 0.... .q"~I( \ ..v.'" ~ '~ ('Iv OllfMf E' '0'- •