negative consequences for the family of the First Complainant. The Complainants further submit that the breakup of the protest in the park and the manner of its execution cannot be justified by any pressing need to protect national security, the safety, health, ethics, rights and freedoms of others. Finally, they contend that the incommunicado detention constituted psychological trauma which also constitutes a breach of Article 18. Respondent State’s Submission on the Merits 112. The Respondents State submits that because of the historic and continuing relationship and agreements between Sudan and Egypt, Sudanese nationals enjoy the right of entry into Egyptian territory with any identification document without hindrance, and that as such, the presence of Sudanese in Egypt is based on the agreements, particularly the latest one of 04 April 2004 and not on asylum in its legal and international definition. 113. The Respondent State submits that despite these special agreements, under the UNHCR agreement to which Egypt is a party, UNHCR examines applications in accordance with its standard practice, and thus that some Sudanese nationals have obtained yellow cards (indicating their status as asylum seekers) and blue cards (indicating their refugee status) and are entitled to the treatment specified for these categories under the UNHCR agreement. However, the State avers that “the vast majority of Sudanese nationals, estimated between 2 and 5 million residing in Egypt, are neither refugees nor asylum seekers.” 114. The State further avers that “the UNHCR has ascertained that a huge number of the Sudanese asylum seekers are ineligible for refugee status because the requisite criteria for such status were unfulfilled,” mainly because they were rather seen to be economic migrants. The Respondent State alleges that the Sudanese nationals vehemently rejected the decisions of the UNHCR and demanded that closed cases be reopened and that they be granted refugee status in countries like the United States, Australia and Canada. According to the Respondent State, the Sudanese nationals harassed the UNHCR staff on a daily basis on their way in and out of the premises. 115. The Respondent State alleges that the matter escalated into a continued sit-in protest in the park opposite the UNHCR office building, and that the number 28

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