The International courts of arbitration are respectfully requested to declare that:-
1. the only basis for Barotseland becoming part of Zambia on its Independence was the Barotseland Agreement of 1964;
2. This Agreement has ceased to have effect, having been breached and repeatedly and finally repudiated by the Government of Zambia which abrogation and repudiation have been accepted by the Barotse National Council;
3. the situation has reverted to that which applied immediately before the Agreement was signed and Barotseland has in law reverted to being a ‘British Protectorate’, quite separate from Zambia, alternatively has become a free and self-governing nation state entitled to run its own affairs according to the will of its people and institutions;
4. Any continued governance, exercise of authority or occupation of Barotseland or any part thereof by Zambia is unlawful and must cease.
CONSEQUENTIAL …show more content…
FINANCIAL RELIEF That Zambia is ordered to make financial reparations to Barotseland:
1. by rendering to Barotseland a complete account of its dealings with the contents of its Treasury and all of its other assets, including but not limited to its mines and minerals and the revenue there-from, by repaying the sum shown by such account to be owing plus interest thereon at the bank borrowing rate as fixed from time to time by the Bank of England for sterling from the date of Independence of the Republic of Zambia to the date of payment;
2. for the loss due to the failure of the Zambian Government to provide financial support to Barotseland or to treat it fairly and equitably as against the remaining parts of Zambia in an amount to be calculated and fixed.
INTERIM