11. The Complainants claim that although all the Dergue officials were collectively charged with the crime of Genocide, they raised an objection through their defence lawyers that the charge filed by the Prosecution did not clearly stipulate which cases fall under Genocide and which ones fall under crime against humanity, however, the court proceeded without making a ruling on the issue. They submit that to their dismay, they later learnt that most of those indicted had all been convicted and sentenced to rigorous prison terms, including capital punishment for the crime of Genocide. Those sentenced to death are waiting for the decision of the Head of State whether they would be pardoned or executed. 12. They allege that Genocide has an international definition, and by adding illegal and clandestine political parties and organizations to the list of protected entities under the Genocide Convention, the Ethiopian courts have created a new crime of genocide by analogy. The Complainants submit that the Ethiopian courts by creating crimes by analogy have not only deviated from the international Genocide Convention to which Ethiopia is a party, but also Article 9 of the Constitution of Ethiopia, which stipulates that all the laws of the land must be interpreted in conformity with international conventions, treaties and agreements. 13. They averred that when trial commenced, they had requested for an impartial and international tribunal to be set up to investigate the allegations but the Respondent State refused. The judges were mostly fresh University graduates, civil servants and ex-combatants from the new regime. Regarding the right to be represented by legal counsel, Complainants submit that the Court ordered legal practitioners to represent them in the subsequent trials, and that they did not have the chance to make a choice of counsel, but had to contend with the legal counsels assigned them by the State. 14. It is also alleged that the lawyers assigned to the detainees did not have the right to decline the order of the State to take up the cases, even if they indicated that they were not interested and/or that they did not have the expertise in defending cases dealing with the crimes of genocide and crimes against humanity. The lawyers were allegedly underpaid for the work, with no incentives and many of them are said to have given up going to Court to defend the detainees, consequently leaving many of the detainees virtually without legal counsel. 15. They submit that the detainees fall under the following categories:  Those that have been sentenced from, rigorous imprisonment up to death; 3

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