The Purgation State: Detailed National Factbook [READ ONLY]

[Purgatio]

Under-Class (~14-16% of all Purgation households)

The final social class below even the powerless 'lower-class' which is dependent upon, and vulnerable to, the economic decisions undertaken by the ruling 'upper-class' of capital investors who control and command their labour, is the under-class of enslaved Dysfonctionnel being forced to work against their will in the country's over 49,000 'liquidation facilities', as part of an ongoing genocidal project currently being perpetrated against the Dysfonctionnel for their ostensibly perverse, disordered, and parasitical genotypes, to be exterminated and eradicated, slowly and gradually, through the technique of so-called 'liquidation through labour'. Such persons make up the so-called 'under-class' of the stratified PNL Purgation society because they are not merely powerless and dependent like the Purgation 'lower-class' of wage-labourers, but are reduced to being mere assets to generate capital income for the financial capital-owning 'upper-class', as accrued through privatised 'concession contracts' and des profits à prendre financial products structured as derivatives linked or pegged to the profits earned out of these brutal 'liquidation facilities' of Dysfonctionnel slave labourers toiling away, the victims of a genocidal exterminatory project forming the foundational basis of the dominant wealth and power of the present Purgation ruling class.

The presence of the Dysfonctionnel plays a critical role in maintaining and upholding the present social structure of PNL Purgatio. The most obvious sense in which this is true is, of course, economic. The Dysfonctionnel are slave labourers being slowly worked to death against their will for the profit of the owners and operators of the country's 'liquidation facilities', be they the PICOS organisation or private for-profit concessionaires. As the Dysfonctionnel constitute roughly 14-16% of the Purgation population, and with the total number of Dysfonctionnel languishing and suffering within Purgation 'liquidation facilities' ranging from between 338.33 million and 380.65 million slave workers, the annual profits from the Purgation 'liquidation facilities' are enormous and easily run into tens of trillions of Élites annually, constituting an enormously fruitful and profitable resource presently being exploited by the Purgation ruling class. The Dysfonctionnel are thus the main source of the upper class's economic power and the indispensable reason for the unusual and supranormal productivity of their financial capital and the profitabilty of their investments, and consequently, they (or, more accurately, their forced labour) confer upon the PNL oligarchical clique the critical resources needed to keep the PNL one-party regime in power and to efficaciously maintain their control over the rest of Purgation society.

In addition to the direct profits garnered by the slave labour of the Dysfonctionnel, there are also the indirect economic benefits which are conferred upon the Purgation upper-class (and, to a lesser extent, upon the 'mass affluent' middle-class as well). First of all, the present system of 'concession contracts' over the country's many 'liquidation facilities' represents a key source of revenue for the Purgation government, which would otherwise have to be paid for through tax rate increases or cuts to public spending. Due to the trillions of Élites earned every year from regular payments made to the Purgation Ministry of Commerce and International Trade by private concessionaires under these 'concession contracts' (as well as the additional sums earned from auctioning off these long-term 'concession contracts' at closed yet highly-competitive auctions), the PNL government can afford to keep taxes low, with a top personal income tax rate of only 10.9% (with an average household tax bill of just 9.4%), a low corporate tax rate of 6.4%, and no taxes at all on almost all forms of capital income or capital asset-ownership (i.e., no capital gains tax, no dividends tax, or interest income tax, no stamp duties or financial transactions taxes, no inheritance or estate taxes, no gift taxes, no property tax, etc.), with the bulk of fiscal revenues being generated from 'concession contract' payments, fines levied on a whole host of minor offences, and various other forms of mostly regressive taxation (value-added taxes, sales taxes, excise taxes, 'sin taxes' on various vices, import duties, payroll taxes, etc.), amounting to a tax structure that severely favours wealthy capital owners and, consequently, confers a massive benefit to the capital-owning upper-class and, to a lesser extent, the 'mass affluent' middle-class with a sizeable amount of investible financial capital as well, which is critical to enable the PNL regime to retain the support of the Purgation upper-class and middle-class, which were, and remain to this day, the core support base of the current PNL party. This tax structure can only be maintained, however, through the current system of 'concession contract' payments, otherwise the PNL regime would either be forced to raise taxes on the wealthy and the middle-class (thereby alienating all of their supporters) or, alternatively, cut spending in the most important and hefty sectors of government outlays and expenditures, which are, of course, the Purgation military, law enforcement, secret police, and other national security agencies, in other words, all the critical State organs which enable the PNL regime to maintain its repressive power and to inflict State violence (or the threat thereof) upon potential dissidents and opponents, with either option clearly amounting to policy choices which would hurt and undermine the stability of the PNL's current grip on power.

This is not the only indirect economic benefit conferred by the slave labour of the Dysfonctionnel. Another effect of the present system of privatised 'concession contracts' is that it vastly improves the bargaining power of corporations at the expense of the lower-class of wage-labourers who are dependent upon these companies for paid employment, since the forced labour of the Dysfonctionnel amounts to a form of cheap competition which depresses the wages of the lowest-paid workers in the Purgation State whilst vastly increasing the disposability and replaceability of menial, laborious, or unskilled labour, rendering most low-income workers in the country extremely dispensable to their employers, to the extent that their labour can be replaced by, or substituted with, the more easily and directly exploitable slave labour of the Dysfonctionnel in 'liquidation facilities'. This starkly unequal bargaining position keeps the cost of labour low, for both enslaved and unenslaved labour alike, ensuring that the PNL regime will always retain the support of the Purgation business community, local and foreign corporations, and by extension, the support of the upper-class and (to a lesser extent) the middle-class, who have together reaped the financial benefits and rentier profits accrued from their financial capital investments into these companies. In this way, the presence of the Dysfonctionnel slave labourers represents yet another tool in the arsenal of the Purgation ruling class of capital owners to further control the lower-class and keep Purgation wage-labourers in an evermore vulnerable and dependent position.

In addition to these more obvious direct and indirect economic benefits, however, the Dysfonctionnel play an even more important role in preserving the present stratified social order of the PNL-ruled Purgation State by keeping the Purgation lower-classes under control, in a variety of ways. First, the presence of the Dysfonctionnel serves a crucial deterrent to potential dissidents or other aspects of the Purgation populace - especially the economically deprived Purgation 'lower-class' - against engaging in any riotous or disorderly behaviour that could threaten the stability of the present Purgation regime, as any such conduct, if caught by the nation's highly militarised and empowered police forces, could result in genetic re-classification, condemned to a terrible fate of extermination via 'liquidation through labour' or being worked to death. Consequently, the present treatment of the Dysfonctionnel is not only a eugenical measure, but also functions as a form of de facto social control on a broader level. Second, the Dysfonctionnel serve as a convenient scapegoat for the present PNL regime and propagandist PNL-aligned media outlets to blame the country's various social and economic problems on. Given the prevailing PNL regime's propagandist narrative that demonises the Dysfonctionnel as 'genetically disordered', a biologically pathological and perverse force tending towards 'parasitical' traits and behaviours, nearly every economic or social problem assailing the Purgation people is generally attributed by the PNL regime and PNL-aligned media outlets to either foreign nations (said to be dominated by, and under the boot-heel of, their own local Dysfonctionnel run amok) or the un-arrested, un-discovered, and un-liquidated Dysfonctionnel within Purgation borders (be it illegal immigrants who crossed the border irregularly, or Dysfonctionnel infants and new-borns harboured from the medical authorities from birth, or runaway Dysfonctionnel who escaped from police custody, or Dysfonctionnel who have yet to be discovered as such and re-classified, or Dysfonctionnel insurgent fighters and militants in the ongoing GEM resistance or terrorist movement (depending on one's perspective), or Dysfonctionnel who have staged successful slave revolts who broke out of their 'liquidation facilities' and fled to the outskirts of the country, etc., etc.), there are no shortage of foreign and local Dysfonctionnel who can be blamed for practically any problem or trouble assailing the PNL regime in some way. Economic downturns or recessions can be blamed on the Dysfonctionnel for committing property crimes that sap the nation's economic productivity, and for perpetrating drug crimes and organised crimes which are a 'parasitical' leech on the nation's total productive output. Rising unemployment can be blamed on illegal immigrants crossing the border irregularly and 'moonlighting' in secret without the knowledge of the authorities. Worsening inflation can be blamed on the Dysfonctionnel for burdening social services and inflating government outlays and expenditures by abusing the country's highly-limited social services through welfare fraud and the indolence of dependency upon various social services (such as temporary jobseeker assistance, healthcare subsidies, or educational grants and scholarships). Sporadic terrorist attacks by the GEM insurgency movement are always framed by PNL-aligned media outlets as proof of the broader pathological and perverse tendencies of the Dysfonctionnel as a whole, by virtue of their genomes, and the same tactic is employed for any inner-city riots of poor, low-income Purgation youth (especially in deprived neighbourhoods), such violent and disruptive incidents are always seized upon and weaponised by the Purgation media and the authorities to paint the entire Dysfonctionnel community as a pathologically 'parasitical' force that burdens the rest of the Purgation populace and whose mere existence serves to drain the lifeblood and productivity of the Purgation national people's community at the expense of the regular 'genetically healthy' Sain, the implicit (or sometimes explicit) suggestion being simply that if the Dysfonctionnel did not exist at all, the Purgation people would be much safer, happier, and more economically prosperous overall. By virtue of such a narrative, practically every social or economic problem troubling the Purgation people can be blamed, in some way or another, on the existence of such Dysfonctionnel persons, both within and without, with the PNL regime no longer being framed as the cause of the country's ills, but the solution, a benign force that is attempting to do their best to control and suppress the genetically 'parasitical' disposition and tendencies of a 'genetically disordered' internal sub-group which is the true source and origin of the nation's woes.

Finally, the existence of the Dysfonctionnel allows the PNL regime and the ruling class to push for an alternative identity for the lower-classes to accept and embrace, in contradistinction to either a class-based identity (i.e., a member of the lower-class identifying as part of a broader oppressed, persecuted, and marginalised 'lower-class') or an anti-government political identity (e.g., as a liberal or pro-democracy activist opposed to the present autocratic structure of the PNL one-party regime), by cultivating a new national identity of the 'genetically healthy' Purgation national community, filled with an inherently and biologically superior populace by virtue of decades of proper eugenic policies and genetic selection, keeping a proper check upon (and actively suppressing, through State action) the degenerative and dysgenic effects of the 'disordered' elements of the national gene-pool which would be the avowed inevitable result of allowing the Dysfonctionnel to run wild and breed and procreate freely amongst the Purgation populace, spreading their perverse genes, contaminating and polluting healthy blood-lines, and consequently perpetuating and exacerbating their 'parasitical' traits and tendencies at the expense of the health and vitality of the Purgation community. This narrative provides the Purgation people with an alternative identity to embrace, a racial-genetic identity rooted in ultranationalism, populist elitism, and a sense of both personal and communal superiority, allowing an ordinary Sain citizen of Purgatio to feel superior to both foreigners and foreign nations and peoples (i.e., as part of a eugenic and genetically 'superior' gene-pool in contradistinction to foreign population groups whose genetic health has 'degraded' and declined over time due to the unchecked dysgenic tendencies of their Dysfonctionnel) as well as the local Dysfonctionnel who are said to be inherently, biologically, and naturally inferior to the ordinary Sain Purgations, the latter of whom are naturally inclined by virtue of their genes towards healthy, productive, and contributive traits and tendencies (as opposed to the naturally parasitical tendencies of the Dysfonctionnel). This is a very psychologically attractive narrative for many ordinary Purgations to embrace, since it is inherently flattering and panders to the normal human psychological and emotional tendency to want to embrace a worldview that is more ego-boosting and self-validating, being consistent with a more pleasing and edifying self-image or self-perception overall. This alternative national and racial-genetic identity - viz., as a member of a 'genetically healthy' national community and as a Purgation Génétiquement Sain - clearly works in the favour of the present PNL regime, since it encourages all Purgations to self-identify with the ruling class and the existing PNL government, as being 'on the same side' or the 'same team', forming part of a broader unified national community of 'genetically healthy' Purgations with a common racial-genetic interest, who must unite, show solidarity, and stand together as one against both the internal and external Dysfonctionnel of the world at large, to preserve their own 'genetic health' and natural biologically-ingrained productivity.

Consequently, it is no exaggeration to state that the existence of the under-class of Dysfonctionnel is crucial to keeping the PNL regime in power, not only because of the economic benefits to the PNL elite from enslaving and exploiting the Dysfonctionnel slave labourers being worked to death in an ongoing genocidal 'liquidation through labour' campaign, but the additional social and political benefits as well in reinforcing PNL propaganda and its organs and methods of social control. In short, the PNL regime needs the Dysfonctionnel to survive and to remain relevant as a political force within Purgation society. This is why, more than three decades later, the PNL one-party regime clings onto its slave labour economy of privatised 'concession contracts' over Purgation 'liquidation facilities', even in the midst of changing social and economic trends such as globalisation, deindustrialisation, technological innovations, and automated labour, because of the essential and indispensable role that the continuing exploitation of the Dysfonctionnel plays in propping up the ruling PNL government. Even as the Dysfonctionnel grow increasingly riotous and rebellious, with 'slave revolts' and 'slave rebellions' increasing in frequency every year and with more and more Dysfonctionnel slave labourers attempting to stage risky revolts and violent takeovers of 'liquidation facilities', endangering and slaughtering corporate handlers, concessionaire taskmasters and factory floor supervisors, and PICOS troopers and guards alike, and the fiscal cost to the PNL government of guarding such 'liquidation facilities' and keeping the Dysfonctionnel sufficiently deterred and under control continues to climb, nevertheless, the PNL regime simply cannot afford to abandon its present 'rentier-genocidal' economic model, and in that sense, it can perhaps be said that the Purgation ruling class is somewhat trapped by, and shackled to, the very same social and economic structure that it has created and established to maintain and preserve its own power.

[Purgatio]

Legal System and Due Processes in the Purgation Jurisdiction

Ultimate Rule of Recognition (Le Principe du Chef)

Every coherent legal system has an ultimate highest constitutional norm (or set of norms) from which the validity and legitimacy of every other rule, norm, and principle of law within that jurisdiction flows. This is the 'ultimate rule of recognition', so called because it is the highest norm by which the validity and correctness of every other legal norm in that order may be acknowledged and 'recognised' as so valid. It is the ultimate, original, and primary root of the binding legal force of every other norm generated by, and flowing from, that 'ultimate rule of recognition', forming an internally coherent and cohesive 'hierarchy of norms' with that 'ultimate rule of recognition' being the highest norm occupying the apex position at the very top of that normative hierarchy, thereby binding together the jurisdiction as one unified and harmonious constitutional order.

Back when the Purgation State was still La République de la Purgatio or the Republic of Purgatio (1823-1988), that 'highest constitutional norm' or 'ultimate rule of recognition' was simply Purgatio's written constitution. However, when the Purgation National Congress (PNC) repealed that constitution with the passage of Le Loi sur le Rétablissement de l'Unité Nationale et l'Intégrité Politique du Royaume on 27 August 1988 (often referred to as the "Constitution Repeal Act" for short), crossing the necessary two-thirds supermajority for constitutional amendments by a vote of 644-216, without any written or textual replacement therefor, it left open a legal lacuna or vacuum to be filled and clarified as to what the new 'ultimate rule of recognition' in the Purgation constitutional order now was, once the prior 'ultimate rule of recognition' had been vacated and abrogated. The Supreme Court of Cassation answered that question with its unanimous judgment rendered on 20 September 1988 in the case of In the Matter of the Reference of the Ministry of Justice No. 74 of 1988 [1988] 6 RJRP 5744 (often abbreviated as "Re Ministry of Justice No. 74/1988"), which held that the new 'highest constitutional norm' of the Purgation legal order was Le Principe du Chef (i.e., the so-called 'leader principle').

La Dame Juge de la Cour Suprême Cateline d'Évreux, who authored the unanimous opinion in Re Ministry of Justice No. 74/1988, justified and explained the basis for the Supreme Court of Cassation's finding that Le Principe du Chef was the 'highest constitutional norm' that determined the correctness of every other inferior legal norm in the Purgation jurisdiction and which conferred validity upon every legal rule and principle therein. First, the Supreme Court of Cassation adopted the reasoning that "repeal equals reversion". In the words of La Dame Juge Cateline d'Évreux, "[t]o repeal is to revert to a prior state of affairs which existed before the doing of the legal act being repealed and the previous effectuation of which is now nullified and cancelled and, by extension, accordingly, the prior legal state of affairs which was previously said to be properly abrogated by the enactment of that legal act can now be said to be restored and re-established as a result. If a legal act is validly enacted which cancels a man's proprietary right or nullifies his estate, and that legal act is repealed, the logical consequence must be the restoration of that right which was cancelled or that estate which was nullified, that being the necessary reversal of that which was previously intended to be enacted. Otherwise, that repeal would be of no real effect. No law-making body which intentionally enacts a legal act, in seeking to put into effect a specific legal instrument or document, should lightly be taken to have done so in vain and taken such pains to achieve a purposeless nullity. Ut res magis valeat quam pereat - it is better for a thing to have effect than to be made void. If the prior state of affairs cancelled and nullified by the repealed legal act were deemed to stand notwithstanding the repeal, the necessary consequence is to reduce the act of repeal into redundancy, inutility, and ineffectual vanity. That is an unacceptable result for any intentionally implemented legal act intended to effectuate a consequential change and a particular normative impact that is to be ascertained. Consequently, it stands to reason that, as the prior written Constitution, in its enactment, had imposed cognisable limitations upon the various powers of the Souverain, as the embodiment of the Purgation State, whatever formal title he may be said to have held or by whatsoever name he may have been so called at given periods of our constitutional history, to govern as such as a limitless Souverain, through the creation and establishment of textual limitations accompanying the conferrals of delimited and demarcated norm-making powers coupled with other expressed and specified restrictions and prohibitions upon the manners of the varied exercises of such powers, it follows that the repeal of such cognisable limitations must be taken to have been intended to revert back to that prior state of the absolute, unrestricted, and unlimited powers once enjoyed in the body of the Souverain as the State himself and the source of all law and governance within and throughout our Royaume. In the same way as the repeal of an expropriation must be taken to have been intended to restore and re-confer that which was expropriated, as such, the repeal of the Constitution's textual limitations and restrictions likewise restored and re-conferred back upon the Souverain his prior legal status as an unlimited Souverain who is the physical personification of the State herself and as the tangible expression and materialisation of all her sovereign powers over law-making and governance made into flesh and blood. That is the result which necessarily flows from the principle that 'repeal equals reversion'" (see, Re Ministry of Justice No. 74/1988 at [47]).

Second, the Supreme Court of Cassation reasoned that that result was further shored up and reinforced by the principled approach that "to repeal is to seek to implement a cognisable and identifiable legislative volte-face which stands to be discovered". In the words of La Dame Juge Cateline d'Évreux, "a repeal is a legislative volte-face, it is a legal about-turn or contraposition that seeks the reversal and inversion of that legal act which has been repealed. Where that contrary or inverse position can be identified with clarity and without ambiguity, in the absence of any indication to the contrary, it ought to be taken that the intent behind the repeal was to achieve that contraposition or inverse outcome by way of the tergiversation of repeal. To repeal the criminalisation of an act is to seek the legalisation of that act. To repeal the reduction of an excise tax is to seek an increase of that excise tax to a prior, higher rate that was levied. And to repeal the conferral or award of a governmental contract or the erection of a public works development or construction project is to seek to nullify the award of that contract or the establishment of that developmental project. In such cases, the identification of the so-called 'inverse' result, so as to discover the original intent behind the purposefully enacted volte-face, can be described with particularity and recognised without great difficulty as a matter of common-sense. Sometimes, however, the contours and modalities of that volte-face are comparatively difficult to establish and cannot be pinpointed by a mere prima facie examination of the act being repealed. Nevertheless, the underlying principle remains that a repeal is a legislative volte-face which stands to be discovered, and the ultimate aim and objective remains the same, that is, identifying the contraposition or inverse outcome of the legal act being repealed in order to implement the intended volte-face into practical effect. Here, the act being repealed is a written Constitution, which transformed this constitutional order from a previous absolute monarchy into a republican order, governed under a textually and constitutionally limited order, in which the sovereign powers which had previously been vested into a singular person and body - Le Saint-Roi - were divided and broken up into a mass of differing institutions and persons - the President, the Prime Minister, the Cabinet of Ministers, the Purgation National Congress (PNC), the Supreme Court of Cassation, provincial and cantonal legislatures, and so forth - such that these organs and bodies, together, combined, cumulatively wield the sovereign and regulatory powers of governance and norm-creation which, hitherto the implementation of that written instrument, had been vested solely and singularly in one person alone who was the State made flesh, thereby transforming a unified Souverain into a divided Souverain. That being the legal consequence of the act now under repeal, the identifiable legislative volte-face can now be recognised and discovered without difficulty and as a matter of common-sense - namely, that the volte-face intended to be enacted here was simply a re-unification of the divided Souverain and the re-consolidation of these powers into the body of a singular individual once more, in whose person the sovereign State of our Royaume finds her physical manifestation and her one and only fleshly external materialisation" (see, Re Ministry of Justice No. 74/1988 at [52]).

Third, the Supreme Court of Cassation cited the Second Reading speech of La Première Legislatrice du Congrès National, Jeanne-Emmanuelle de la Fayette, who moved the Constitution Repeal Act on 22 August 1988, which it referenced as an "interpretative aid to divine the true legislative intent behind the enactment thereof and the purpose sought to be effectuated by the various implementations therein". The judgment of Re Ministry of Justice No. 74/1988 quoted, in particular, the words of La Première Legislatrice dated 22 August 1988, wherein she stated that, "[t]hrough this momentous measure, Madame la Présidente, we shall, in one fell stroke, finally put a definitive end to the divisive, fractious, chaotic model of factional partisan politics which has engulfed this nation, held her people back, and arrested her development in a permanent state of political paralysis, all in the name of servicing the ideological agenda of upholding a so-called 'constitutional style of government'. That chaotic, disordered, and dysfunctional state of affairs cannot be permitted to continue, the ship of state must be set right, and this time, for good. The people of our nation cry out for no less. Indeed, the actions of this government just this year, in tackling criminality, organised syndicates, gangsterism, hooliganism, restoring our streets and public spaces to a state of peace, safety, and harmony, have gone a long way towards showing the people of this great nation what real leadership can achieve without the burdens and strains of a so-called 'divided government', and more importantly, what this country has lost and squandered away in the past few decades - no, the past century - by stubbornly clinging onto her old, bloated, confused, disordered, and dysfunctional 'constitutional compact', like it is some sacrosanct, inviolable object of worship, but no longer. At long last, we shall liberate our people from the chains and shackles of the gridlock and dysfunction of fractious, factional, partisan, class-based so-called 'law'. From now on, true law, good law, just law, the only law, shall flow from the unified, cohesive, integral, undivided Souverain - and from the will of that Souverain alone. No longer shall we all be held hostage to the endless chaos and the disorganised, interminable confusion of narrow-minded, capricious, dispersed, and disaggregated petty and squabbling law-makers, to the whims and fancies of party, class, and bastard law, to the small-minded rivalries of these laws of lies. What was once fractured and divided shall be made whole once more. This nation, our people, our eternal Royaume, shall be re-united and re-integrated into a singular, coherent, harmonised whole. Unity under our undivided Souverain shall mean principled integrity and normative harmony for all. That, Madame la Présidente, is, and shall be, true law made flesh, now and forevermore."

Commenting on the above excerpt of her Second Reading speech, La Dame Juge Cateline d'Évreux reasoned that, "it is trite law that, in the course of the exercise of statutory construction and legislative interpretation, courts of law may have recourse to secondary materials, up to and including, inter alia, records of Congressional legislative debates in Les Documents Officiels des Débats Parlementaires du Congrès National (or Déparle Dugrès for short), as a constructive and interpretative aid to divine the underlying will and justificatory intent of the Legislature, where the interpreting body deems it 'necessary and beneficial to have in its aid the historical background of the enactment' or where the 'secondary materials sought to be invoked in aid are fairly regarded as useful and necessary to clarify ambiguities, put to rest uncertainties, illuminate obscurities, or otherwise disclose the public policy ill or mischief sought to be redressed and rectified by the relevant instrument to be applied' (see, e.g., The Secretary of State for the Royal Treasury's Chambers c. La Duchesse d'Aujaislin [1917] 4 RJRP 1129 at [118]-[119]; Eugénie de la Beauharnaise c. The Office of the Prime Minister [1938] 7 RJRP 6299 at [43]-[47]; and, La Société de Confiserie des Aromates c. The Inspectorate-General of the National Administration for Food and Beverage Safety [1952] 1 RJRP 185 at [72]-[75]). Here, as the text of the Constitution Repeal Act, by reference to its express wording alone, only provides for the wholesale repeal of what was once this jurisdiction's highest governing constitutional framework, without explicit replacement or expressed substitution of any other written constitutional norms in exchange therefor, it lies to this court to discern and decipher the true, underlying intent of the Legislature in the enactment of that repeal, with helpful reference to such secondary materials as the Déparle Dugrès records of the legislative debates that led up to the passage of that Act, including the Second Reading speech of La Première Legislatrice as she moved that legislation on the 22^nd of August, in the Year of 1988. Mesdames et mes Seigneurs, it is clear, in my view, from the abovementioned excerpt (see, at [56] above) that the speech delivered by La Première Legislatrice in moving that legislation further reinforces and provides additional support for the aforementioned analysis (see, at [47] and [52] above) that the true, underlying intent behind the passage of the Constitution Repeal Act was, ultimately, to consolidate all the sovereign powers of governance and regulation of our Royaume under a singular individual who would be the one and only head of our jurisdiction and sole source of all law, to avoid the divisiveness, fractiousness, and discordant disharmony of multiple warring, squabbling sources of law promulgating competing rules and norms, in which gridlock, friction, and strife cast a long shadow of confusion, uncertainty, and unpredictability over numerous areas of legal and regulatory life in this hitherto chaotic and dismembered constitutional order. Normative disintegration and principled segmentation was to be reversed through the top-down harmonisation of the Purgation legal jurisdiction by unifying and consolidating all sovereign law-making and norm-generating powers under the body and within the personage of a singular Souverain, who would be the sole and ultimate primary source of all law from thereon. All law would then flow, solely and exclusively, from the physical and material embodiment of the sovereign Purgation State - viz., Le Souverain (ou La Souveraine aussi), replacing the confusion and disorder of normative fragmentation arising from splintered and disaggregated sources of law with an integrated, cohesive, harmonised source of law flowing from a singular ultimate source, thereby structurally guaranteeing the normative homogeneity and the principled unity and integrity of a truly harmonised and integrated constitutional order" (see, Re Ministry of Justice No. 74/1988 at [57]).

Fourthly, and finally, the Supreme Court of Cassation cited the principle of "contextual interpretation", to support its approach of referencing extraneous legal instruments enacted by the Purgation National Congress (PNC) which, in its view, constituted the "relevant history, context, and background" to "confirm the true meaning of that legislation through an overall divining of its underlying purpose via a context-sensitive teleological approach to construction". Once again, quoting the unanimous majority opinion authored by La Dame Juge Cateline d'Évreux, she noted that, "in my view, it is also notable, and not at all a mere coincidence or pure happenstance, that, indeed, shortly before the Constitution Repeal Act was given its First Reading on 22 August 1988, the Legislature had, on 18 August 1988, enacted Legislative Motion (LM) No. 51 of 1988 (or LM-51 for short), which purported to exercise the Legislature's constitutional power to appoint a successor to the outgoing President Pierre de Craon who resigned from that post on that same day, to hold that office in the interregnum between periodic presidential election cycles. LM-51, however, exercised that power to appoint the then-Prime Minister Chalon-Arlay de la Fayette as the interregnum successor to the presidential office, and purported also to confer upon him the title of Magnificus Dominus, in reflection of the first-ever unification of the separate offices of the President (then-head of state) and the Prime Minister (then-head of government) into one single person, wielding the lawful and constitutional powers of both from thereon. There is a clear and obvious connection between the unification of the offices of President and Prime Minister into the Magnificus Dominus, in LM-51, and the moving of the First Reading of the Constitution Repeal Act just four days later. Mesdames et mes Seigneurs, while I acknowledge that an enactment within a separate piece of legislation cannot generally be taken to not override or nullify a contrary provision in a different legislative instrument, nevertheless, in the spirit of the contextual interpretation of legislative acts, it cannot be ignored that the Legislature is a singular body and organ of persons, and where possible, it should be presumed that that organ does not legislate in an insular vacuum and seeks not to undermine its own policy objects or undercut and invalidate the very ends it seeks to accomplish. Where possible, all the legislative instruments of the Legislature ought to be viewed as an integral and coherent whole, and unless the express wording of individual provision renders such an outcome impossible, provisions in one instrument ought not to lightly be construed to contradict the provisions in another. This proposition of law is as trite as it is most uncontroversial (see, e.g., La Société des Feuillants c. The Purgation Medical Association [1967] 4 RJRP 5110 at [27]-[29] and In re L (Guardianship of an Infant) (Compulsory Vaccination) [1970] 2 RJRP 2878 at [37]-[39] and [45]). The canon of noscitur a sociis does not, in my view, rest upon such a thin and malnourished bed that it cannot be understood to apply, albeit with the necessary variations and modifications, between provisions found in different legislations as opposed to merely between provisions found within the same legislation, especially and particularly where there is a propinquity of time and space between the two legislative acts at issue, and a consequential similarity of the historical background and context thereof. The unification of the offices of President and Prime Minister into the new office of the Magnificus Dominus, shortly before the Legislature proceeded to repeal the prior written constitution of this jurisdiction altogether, must be viewed together and not in isolation, confirming the view that, indeed, the underlying rationale and the justificatory intent undergirding the passage of the Constitution Repeal Act was the further unification and consolidation of various sovereign law-making powers scattered and fragmented across a divided constitutional order into a singular, unified source of law from thereon, with both instruments thereby complementing one another in service of a common objective. This is confirmed, as well, with reference to the long title of the Constitution Repeal Act - Le Loi sur le Rétablissement de l'Unité Nationale et l'Intégrité Politique du Royaume - and the preamble to that legislation, which, inter alia, describes that legislation as "An Act to provide for the immediate and necessary restoration of National Unity and Political Integrity of our one and only sovereign Royaume for the strengthening of the polity and the construction of a revitalised and reinvigorated national community reincarnated through a common will marching onwards towards one unified and ever-harmonious object". Such titles and pre-titles are, of course, merely preambulatory in nature and carry no legal effect, by themselves. Nevertheless, they provide the necessary context which shapes and frames what the executory portions of the legislation must be understood to say and to mean. Le chapeau décore la tête comme la coiffure encadre le visage. In the spirit of contextual interpretation, such preceding words and events cannot be isolated from the executory and repealing provisions of the Act itself, for they constitute the relevant history, context, and background, and so confirm the true meaning of that legislation through an overall divining of its underlying purpose via a context-specific teleological approach to construction" (see, Re Ministry of Justice No. 74/1988 at [61]).

Consequently, the Supreme Court of Cassation relied upon the foregoing four justifications to reach the ratiocination that the new 'highest constitutional norm' governing the Purgation legal order was Le Principe du Chef (or the 'leader principle'), which it described as such: "The legislative intent animating that Law must reasonably be construed as such, to establish in substitution for Purgatio's prior codified constitution this new ultimate constitutional rule of le principe du chef, that is, that the leader's will must be said to enjoy a position of normative precedence and primacy over any other written or unwritten laws and all governmental actions and conduct, for the normative validity of all norms or rules in this constitutional order must from thenceforth ultimately be derived and divined from, and necessarily found and identified in, that same will, when the emergence of any such norms have been traced all the way back to their original, historical primary root, thereby emanating in common from the will of a unified, cohesive, singular, integrated Souverain" (see, Re Ministry of Justice No. 74/1988 at [63]). In short, the will of the Chef, the Souverain, who in the Purgation constitutional order is the Magnificus Dominus Chalon-Arlay de la Fayette, is the ultimate and final source of the validity of all legal norms, rules, and principles having binding force within the new constitutional order of the Purgation State. Every legal act is valid insofar as it flows, properly and correctly, from the will of the Magnificus Dominus, and a purported legal act is consequentially invalid insofar as it fails to be attributable, ultimately, to the will of the Magnificus Dominus. Where the fundamental source and origin of the validity of all Purgation legal acts was once a written codified constitution, the determinations and desires of a single human Souverain, and his one unified, integrated, and cohesive will, had arisen to take its former place (see, Re Ministry of Justice No. 74/1988 at [65]-[67] and [69]).

The decision in Re Ministry of Justice No. 74/1988 at [75]-[78] also sought to explain and justify the social value of the constitutional principle of Le Principe du Chef based on a rationale of "efficient social organisation and effective mass mobilisation towards the attainment of common benefits and fruitful collective ends requiring coordinated community action". It was explained that the "social force of any stable legal and/or constitutional order rests upon a capacity for the structuring and harmonisation of the acts and conduct of the subject-community", and that "such harmonisation can only take place where a central nexus or focal point exists which the subjects can harmonise their conduct in reference thereto, forming the essential node around which the community stands to be corralled, rallied, and regulated towards a common end". The Supreme Court of Cassation would explain that "such harmonisation becomes fraught with difficulty and altogether fettered and burdened where the social coordination is thrown into confusion and uncertainty because of an absence of clarity as to what, or who, that central coordinative nexus even is, to begin with", which it described as the "necessary and inevitable result of a deliberate division, decentralisation, and disintegration of the sources of valid, legitimate power and authority amongst varied bodies, deputies, and agents of the Sovereign State and her imperii police powers, which can only tend towards a disordered and dysfunctional state of affairs in which regulatory harmonisation is thrown into doubt and disarray under a regime of normative fracturing, fragmentation, and disaggregation overall". Consequently, it reasoned that the "underlying value and benefit of the new ultimate constitutional norm, recognised from hereon by this Judiciary by virtue of common law rationalisation and the binding ratiocination of this decision's divining of the Legislature's true will, in the enactment of the examined Act that is at issue, can be said to be the rectification of the prior state of normative disintegration and fragmentation in favour of the clarity, certainty, and integrity of establishing with decisive and definitive effect a secure and stable source of all law and rightness found throughout a single, unified, integrated jurisdictional regime, at the centre of which lies, not a fragmented and fractured set of bickering, discordant, divided, disharmonious organs and deputies, but a singular Chef, a superintending Directeur, charged from thereon with the harmonised organisation and coordination of the subject-community as a whole, speaking with one voice, promulgating with one will".

Since the rendering of that decision by the Supreme Court of Cassation, a variety of interesting legal issues have emerged as to the proper application of Le Principe du Chef as a matter of legal practice. It is clearly good law, from at least a theoretical perspective, that the will of the Souverain, that is the Magnificus Dominus, represents the ultimate and original primary source of the legitimacy and validity of all other norms in the Purgation jurisdiction, forming the apex of the entire 'hierarchy of norms' that bind all laws and rules of the Purgation legal order into a singular, integrated constitutional regime. However, in certain circumstances, questions can arise as to the proper identification and interpretation as to what that will is, and what it provides for in a specific or particular case. This is best illustrated with examples. One preliminary issue which can emerge pertains to the question of what acts of the Magnificus Dominus may be cited or referenced as an expression of his will, in his capacity as a Souverain, to engage the application of Le Principe du Chef. This was the issue which arose in the case of Madeleine Turpin et alia c. Le Commandant en Chef de l'Ordre pour la Purification de la Purgatio et alius [1994] 7 RJRP 4137 (often abbreviated as "Turpin c. Purification Order"). That case concerned a class-action lawsuit filed by 287 plaintiffs against the Commandant en Chef of the Purification Order and the High Inquisitor of PICOS for the common law torts of assault and battery in relation to injuries which were alleged to have been sustained by the 287 Dysfonctionnel victims at the hands of various PICOS troopers and Purification Order paramilitary soldiers during the infamous 1991 pograms of La Semaine de la Grande Revanche. The first and second defendants invoked the common law defence of 'lawful authority', namely that the PICOS troopers and Purification Order soldiers had acted within the scope of their lawful authority to exercise their police powers to contain Dysfonctionnel disruption and other such unruly and disorderly conduct from that community, based on the broad legislative mandate conferred by the Legislature in their enactment of the "Law for the Restoration of the Public Square and the Efficacious Redress of Dysfonctionnel Vandalism and Agitation" back in 20 June 1990 (often referred to as the "Enabling of Anti-Dysfonctionnel Exclusion Act" for short).

The plaintiffs, however, argued that the 1990 Enabling of Anti-Dysfonctionnel Exclusion Act could not be read so broadly as to encompass the mass and uncontrolled beatings, lynchings, and even molestations and sexual assaults inflicted upon Dysfonctionnel victims during the chaos and pandemonium of La Semaine de la Grande Revanche, which they alleged was of an indiscriminate and, in any event, wholly disproportionate character. In any event, the plaintiffs submitted that the common law defence of 'lawful authority' was not available to the defendants because it was their case that the Magnificus Dominus had never authorised the pogroms and lynchings, and had in fact publicly condemned the violence on a number of occasions. The plaintiffs therefore took out a striking-out application in respect of the defendants' pleaded defence of 'lawful authority'. It was in this context that the Supreme Court of Cassation had to consider the question of how the constitutional principle of Le Principe du Chef stood to be applied to public statements of the Magnificus Dominus in newspaper and magazine interviews or in live televised interviews to the press. The majority judgment was authored by Le Lord Président de la Cour Suprême Romain de Saint-Aulaire, in which he considered whether the application of Le Principe du Chef was engaged in respect of eleven (11) press statements of the Magnificus Dominus, delivered back in 1991, in which he had expressed condemnation and/or regret for the mass violence inflicted in La Semaine de la Grande Revanche, and further expressed that the attacks had not occurred with his authorisation or permission.

In the words of Le Lord Président Romain de Saint-Aulaire, "it is the contention of the plaintiffs herein that as the Magnificus Dominus is undoubtedly and incontrovertibly the highest authority of our land, his will must therefore take precedence over the will of his agents and ministers, including that of the High Inquisitor and Commandant en Chef and their various officers, with their acts now forming the subject-matter of the present litigation. That is certainly true. It is also argued by the plaintiffs that Le Principe du Chef dictates that the will of the Magnificus Dominus, as said to have been clearly expressed in the 1991 Representations and relied upon by the plaintiffs in this case, not only enjoys the force of binding law, but that law also occupies the apex position of the 'hierarchy of norms' of this jurisdiction, and consequently overrides any other inferior norms or acts emanating from any other public authority herein. They rely upon the ratio decidendi of this court's unanimous judgment in In the Matter of the Reference of the Ministry of Justice No. 74 of 1988 [1988] 6 RJRP 5744 ("Re Ministry of Justice No. 74/1988") in support of this proposition of law. Although I certainly agree that the ultimate highest constitutional principle governing this jurisdiction is, fundamentally, that the laws that emanate from the prescriptive or legislative will of the Magnificus Dominus confers ultimate validity upon all other norms and rules within this legal order, I disagree with the plaintiffs that the 1991 Representations can be said to fall within the proper scope and ambit of application of the constitutional norm of Le Principe du Chef. As such, the proper contours and modalities of that constitutional principle ought, in my view, to be properly clarified in this case. It is clear that Le Principe du Chef rests upon the animating rationale of, inter alia, a normative recognition of the critical importance of having a clearly and unambiguously designated 'final decision-maker' with the last word or final say to uncontroversially settle any outstanding prescriptive disputes as to the contents and/or validity of norms now emanating from a centralised as opposed to decentralised source, in the interest of proper social harmonisation and efficient coordination of the community's conduct. That being the case, however, it would not serve the animating rationale of the constitutional principle of Le Principe du Chef - and, in fact, would contravene and frustrate the justificatory spirit thereof through the exacerbation of the prescriptive legal uncertainty and confusion that that principle had been intended to prevent and resolve - to interpret that principle's scope of application in an overtly wide and overbroad fashion to encompass any and all acts and representations of the Magnificus Dominus, in whatsoever capacity or contexts those acts or conduct were expressed or performed or otherwise came to be seen or heard by the general public. It is the view of this court, therefore, that for a statement or conduct of the Magnificus Dominus to fall within the ambit of application of Le Principe du Chef, two essential ingredients must be satisfactorily made out - first, the act must have been performed qua Souverain or in his capacity as the Sovereign of the Purgation State, it must have been done in an officious or governmental capacity as opposed to a purely private or individual capacity, in other words, constituting an actum iure imperii as opposed to an actum iure gestionis; and, second, even if the act was performed in a public or governmental capacity, it must have been performed with the requisite animus praecipiendi or with the intention to prescribe a legal norm, rule, or principle which was intended to bind, in other words, to govern a particular set of circumstances, to have a certain contemplated legislative or regulatory effect, as determined on an objective construction of the reasonable intent behind the act in question. In other words, mere facultative or precatory remarks, or brief commentaries that are expressed in passing, which are more correctly construed or understood as mere recommendations or delivered in an advisory capacity only, or are expressions of comments, remarks, observations, or personal opinions alone, would not satisfy the requisite test of an act performed by the Magnificus Dominus with the necessary animus praecipiendi so as to attract the application of the constitutional norm of Le Principe du Chef" (see, Turpin c. Purification Order at [31]).

Accordingly, it was held by the majority opinion that, on the specific facts of Turpin c. Purification Order, the first ingredient of an act performed qua Souverain was satisfied in respect of the 1991 Representations as the press statements or interviews were delivered as a result of his occupation of the office of Magnificus Dominus (the concurring opinion departed from this view), but the second ingredient of an act performed with the necessary animus praecipiendi was not satisfied as the 1991 Representations were, on a proper and reasonable construction thereof, provided in an opining or consultative capacity and had merely been intended to express the view and opinion of the Magnificus Dominus as to the 1991 pogroms and incidents of violence but without laying down or promulgating any particular legal norm, rule, or principle therein which would serve to bind or govern any particular circumstances or scenarios (the concurring opinion agreed with this view) (see, Turpin c. Purification Order at [49] and [52]-[54]). Consequently, the 1991 Representations were not governed by the constitutional norm of Le Principe du Chef, as they did not constitute the expression of the legislative or prescriptive will of the Magnificus Dominus, such as to constitute a superior norm that would enjoy precedence or priority over all other legislative or executive acts of all other public authorities, including, inter alia, the High Inquisitor of PICOS or the Commandant en Chef of the Purification Order (see, Turpin c. Purification Order at [57] and [61]).

Another issue which would arise in respect of the constitutional norm of Le Principe du Chef is how that principle stands to be applied when the Purgation Judiciary is confronted with different legal acts of the Magnificus Dominus which appear to prescribe contrary effects or militate in opposite directions. Guidance on this issue may be derived from the landmark Supreme Court of Cassation case of De Magnificus Dominus (sur l'application de The Saint Helaire's Society of Charity for the Afflicted and Destitute) c. High Inquisitor of the Purgation National League (PNL) Inquisitorial Committee for Order and Security [2002] 2 RJRP 994 (often abbreviated as "St. Helaire's Society c. High Inquisitor"), which was an administrative challenge filed by the applicant charity, which was a Catholic healthcare provider that sought declaratory relief that the recent PICOS Order No. 344 of 1999 ("PO 344/1999") which provided for the mandatory abortion of Dysfonctionnel foetuses, the mandatory euthanasia of Dysfonctionnel newborns, and the mandatory sterilisation of persons who had conceived more than three Dysfonctionnel foetuses or newborns in their lifetime, was unlawful and unconstitutional because it was said to contradict the will of the Magnificus Dominus for it contravened the provisions of the PNC's Legislative Motion (LM) No. 76 of 1993 ("LM-76"), which received the assenting signature of the Magnificus Dominus back in 1 May 1993, and which had provided, inter alia, for the eventual but incremental release of all Dysfonctionnel prisoners into segregated Dysfonctionnel-only neighbourhoods or 'ghettos', heavily policed and surveilled, as an alternative to their wholesale detention or even extermination, representing a long-term compromise solution to the identified social problem of the Génétiquement Dysfonctionnel community. The applicant argued that since PO 344/1999, issued by the respondent High Inquisitor of PICOS, called for the reproductive or biological genocide of the Dysfonctionnel as a whole, it contravened the clear terms of LM-76, and by extension, the expressed will of the Magnificus Dominus, rendering PO 344/1999 unconstitutional under the established highest constitutional norm of Le Principe du Chef. On that basis, the applicant sought declaratory relief invalidating PO 344/1999 as unconstitutional and sought a prohibitory injunction to restrain the respondent from enforcing or implementing any of its provisions. The respondent High Inquisitor, however, pointed out that shortly after her promulgation of PO 344/1999, the Magnificus Dominus issued Executive Order (EO) No. 312 of 1999 ("EO 312/1999") on 25 September 1999, which ratified the terms of PO 344/1999 in their entirety. Consequently, applying the constitutional norm of Le Principe du Chef, the expressed will of the Magnificus Dominus was that PO 344/1999 was valid, as opposed to invalid.

Thus, in St. Helaire's Society c. High Inquisitor, the Supreme Court of Cassation had to determine how the constitutional rule of Le Principe du Chef stood to be applied in the face of seemingly contrary or incompatible emanations of the will of the Magnificus Dominus, with the majority opinion being authored by La Dame Juge de la Cour Suprême Ludivine de Bauffremont in that case. It was held that the principle of Le Principe du Chef was to be governed by a 'canon of harmonious interpretation', which La Dame Juge Ludivine de Bauffremont explained as such, "it is clear that as Le Principe du Chef provides that the sovereign police and regulatory powers of the political person and entity of the Purgation State is now to be unified and consolidated within a singular integrated Souverain, for the purposes of clarity, certainty, and predictability, with an eye towards more efficient social harmonisation and coordination, it follows that the Souverain, that is the Magnificus Dominus, must consequently be taken to speak with one voice; he is taken to express a singular will with an overarching integrated and consistent political project or ideological design emanating from a singular and coherent Souverain. Following this constructive canon of harmonious interpretation, where a legislative act emanating directly from the Magnificus Dominus is capable of more than one reasonable interpretations of the meaning inhered therein, the interpretation which coheres with another legislative act also emanating directly from the Magnificus Dominus ought to be preferred over a contrary interpretation that is repugnant to, or contradictory with, one or more other legislative acts also emanating directly from the Magnificus Dominus. This follows logically from the proposition that the Magnificus Dominus is a singular Souverain and therefore must be taken to speak with a singular voice as well. Hence, where the broad and general terms of LM-76, which received the ratification of the Magnificus Dominus on 1 May 1993, may be capable of several differing constructions, this court will favour the constructions which support the aims and objects of EO 312/1999, promulgated by the Magnificus Dominus on 25 September 1999, over and above those constructions which, whilst reasonable and plausible when the legislative act of LM-76 is considered in a state of stranded insularity and clinical isolation, becomes improbable and implausible when considered against the wider contextual background of all the sovereign legislative acts emanating from the Souverain, considered holistically as one whole coherent enmeshed network of expressed designs and desires which, in accordance with the constitutional norm of Le Principe du Chef, collectively combine to constitute a singular, harmonious, unified, and integrated will of the Souverain, and which now stands to be divined and deciphered accordingly" (see, St. Helaire's Society c. High Inquisitor at [39]).

Applying the "constructive canon of harmonious interpretation" to the facts of St. Helaire's Society c. High Inquisitor, it was thus held in that case by La Dame Juge Ludivine de Bauffremont, for the majority of the Supreme Court of Cassation (with the concurring opinion departing from this view), that LM-76 was capable of two differing interpretations, which the majority opinion termed the "Unqualified Interpretation", on the one hand, and the "Qualified Interpretation", on the other. Under the former "Unqualified Interpretation", the project for the erection of ghettoised and segregated Dysfonctionnel-only residential neighbourhoods had been intended by the Legislature and the Magnificus Dominus as a programme to be implemented in a blanket and absolute sense, irrespective of any change or alteration in prevailing circumstances, unless LM-76 came to be expressly repealed, contradicted, or abrogated by a subsequent legislative act. Under the latter "Qualified Interpretation", however, LM-76 had been designed with a particular set of circumstances in mind - namely, that the civil war being waged by the PAF against the GEM insurgency in the Districts of Villehardouin and Lusignan was still ongoing at that time, and LM-76 had been designed as a permanent long-term solution tailored to the then-prevailing circumstances in which the Dysfonctionnel population in the other peacetime Districts had been interned in concentration camps with no established plan for the dealing therewith or disposition thereof - and LM-76 had not been intended to apply if those conditions or circumstances ceased to exist, either due to the end of the GEM insurgency in the outlying Districts or the implementation of a new political project for the extermination of the Dysfonctionnel through the project of 'liquidation through labour' (see, St. Helaire's Society c. High Inquisitor at [55]-[57] and [59]). It was the view of the majority opinion that both interpretations constituted reasonable constructions of LM-76, with the former "Unqualified Interpretation" being the most reasonable construction based on a consideration of the text of LM-76 alone, but with the "Qualified Interpretation" being the more reasonable construction when considered against the legislative object and purpose of LM-76, as demonstrated with relevant references to the PNC legislative debates recorded in the Déparle Dugrès records (see, St. Helaire's Society c. High Inquisitor at [49]-[50] and [52]) (see also, St. Helaire's Society c. High Inquisitor at [68]-[71], in which the concurring opinion departed from this view and found that only the Unqualified Interpretation was a reasonable construction of LM-76 as the Qualified Interpretation could not be reconciled with the text and wording of LM-76).

Consequently, since the Unqualified Interpretation was irreconcilable with the expressed will of the Magnificus Dominus in the subsequent EO 312/1999 (which ratified the High Inquisitor's PO 344/1999), whereas the Qualified Interpretation was compatible with that expressed will, under the principle of effecting a 'harmonious interpretation' of the singular and unified will of the Souverain, the Qualified Interpretation was to be preferred over the Unqualified Interpretation, with the result that PO 344/1999 was neither unconstitutional nor incompatible with the Magnificus Dominus having signed and ratified the PNC's LM-76 (see, St. Helaire's Society c. High Inquisitor at [61]).

Additionally, another important principle clarified by the Supreme Court of Cassation in St. Helaire's Society c. High Inquisitor (which the majority opinion and the concurring opinion both agreed on) was the application of the so-called alter ego rule respecting determinations of the legislative or prescriptive acts which engage the application of Le Principe du Chef. The alter ego rule is often referred to as the Baillairgé doctrine, named after the Supreme Court's earlier decision of Antonin Baillairgé c. Commissioner of the Purgation Police Force (PPF) [1927] 3 RJRP 1006, which held that where a legislative instrument conferred a power which had to be exercised by a particular governmental office-holder (in that case, it was the PPF Commissioner, that was conferred the power to sign and issue the lettres de saisies at issue), it was not a violation of the non-delegation principle of delegata potestas non potest delegari (i.e., a delegated power may not itself be further delegated to another) for the PPF Commissioner's principal private secretary to sign and issue the lettre de saisie which had to be signed by the PPF Commissioner. Under the Baillairgé doctrine, where a servant of the public official does an act, not in their own capacity, or even as a separable deputy or agent of the public official, but as an alter ego or living surrogate of that public official, their act is deemed to be the act of the public official where they were conducting themselves as the mere emanation or living embodiment of that governmental minister.

Prior to the case of St. Helaire's Society c. High Inquisitor, the Supreme Court of Cassation had never received an opportunity to clarify whether the Baillairgé doctrine could also apply to the highest constitutional norm of Le Principe du Chef. It was accorded such an opportunity in St. Helaire's Society c. High Inquisitor due to the submission of the applicant society that Le Principe du Chef could not be said to apply where the Chef de Cabinet of the High Office of the Magnificus Dominus had appended his signature onto EO 312/1999 and then proceeded to issue and publish that instrument, all on the behalf of the Magnificus Dominus (as opposed to LM-76 which had received the personal assenting signature of the Magnificus Dominus himself). On that point, La Dame Juge Ludivine de Bauffremont, writing for the majority opinion (with which the concurring opinion agreed on this issue), made short shrift of that submission, reasoning that "[t]o even suggest that the Magnificus Dominus must personally have signed the Executive Order at issue for Le Principe du Chef to come into play is a nonsense. It was certainly never intimated or implied by this court in its prior decision of In the Matter of the Reference of the Ministry of Justice No. 74 of 1988 [1988] 6 RJRP 5744 ("Re Ministry of Justice No. 74/1988") that this highest constitutional norm was to be understood based upon a miserly and stingy examination of purely technical formalities alone as opposed to the undertaking of a more sensible and substantive analysis of the heart and essence of what was done. Here, Le Chef de Cabinet of the governmental department helmed by the Magnificus Dominus penned his signature to EO 312/1999 not in his own individual capacity, nor even as an independent representative and agent of the Magnificus Dominus, but purely in his capacity as an alter ego thereof. In that moment, he was a pure instrumentality of the Magnificus Dominus, a living expression and material embodiment of the office of the Magnificus Dominus (in contradistinction to the natural person who happens to be in occupation of the said office which is best viewed as a pure juridical construct of our legal and constitutional order), his acts were thus entirely an emanation of that office as a particular materialisation of the officious personage and constitutional personality of the Magnificus Dominus. From the signing of the order, to the delivery and issuance thereof, until its publication in Le Journal Officiel, there was no separation in law whatsoever between the personage of Le Chef de Cabinet, on the one hand, and the High Office of the Magnificus Dominus, which Le Chef de Cabinet doth indeed personify in law and in fact, on the other - his acts were the Souverain's acts, his mind was the Souverain's mind, and consequently, his powers were also all of powers of the Souverain as well" (see, St. Helaire's Society c. High Inquisitor at [26]).

While in St. Helaire's Society c. High Inquisitor, the majority in that case was willing and able to effectuate a 'harmonious construction' to reconcile the interpreted meanings of two differing legislative acts, both emanating from the Magnificus Dominus, in order to interpret those two acts in conformity with one another, it still left open the question of the approach to be undertaken if such a 'harmonious construction' was not reasonably possible or properly open to the Judiciary to effect (c.f., the concurring opinion in St. Helaire's Society c. High Inquisitor had found the two legislative acts there to be clearly incompatible with one another, and therefore did go on to consider that particular issue, but their reasoning on that point could not constitute the holding or ratio decidendi of that judgment). This jurisprudential lacuna was filled in the case of Bruvielle Développements, S.A. c. La Duchesse de Poisson [2004] 4 RJRP 3365 (often abbreviated as "Bruvielle Développements"). In that case, the claimant was a real estate construction company which owned prime commercial and residential land in the inner city areas of central Poisson (the provincial capital city of the northeastern District of Amboise), on which it intended to develop a series of luxury rental condominiums. During the midst of that real estate construction and development project, the Magnificus Dominus, who had been 'restored' to his position as an absolute monarch and Le Grand Roi de la Purgatio, enacted a royal edict on 31 July 2000 (Édit Royal No. 11 of 2000 or "ER 11/2000" for short), which purported to effectuate a 'restoration of seigneurial rights and privileges' said to have been hijacked and wrongfully usurped by the revolutionaries in the wake of the liberal Purgation Revolution of 1823, including by restoring pre-1823 'feudal titles' over demesnes and manorial land tenures previously held by various aristocratic estates (which had not been tenanted out or sub-enfeoffed to any vassals or peasants). Under the authority of ER 11/2000, 168,000 acres of prime real estate in central Poisson was seized and expropriated by the Crown Restoration Commission from the claimant company in December 2000, without market compensation, and 'returned' to their 'rightful owner', Madame Sylvie de Charlet-Vérac (née de Vérac), who was the Duchess of Poisson and who, in that capacity, asserted her legal claim to all lands held within the Duchy of Poisson prior to the Purgation Revolution's abolition of all feudal aristocratic and seigneurial privileges. La Duchesse de Poisson halted the real estate construction and development project and tore down all the half-constructed buildings on these lands to erect a holiday or vacation home for her and her family to rest and relax in during the weekends and public holidays, surrounded by gardens, ponds, lakes, without any other residential or commercial buildings that could serve to disturb the peace, quiet, and tranquility of the intended getaway mansion.

The claimant company instituted a civil action for the torts of trespass to land, trespass to chattels, conversion, and negligent damage to property, against the defendant Duchess, for her seizure of the claimant's lands and her halting of their development project and intentional destruction of the already constructed buildings. The claimant argued that ER 11/2000 could not stand because it contradicted an earlier legislative act - the Land Registration Act of 1928 ("LRA 1928") - enacted by the PNC under the Republic of Purgatio on 3 May 1928, which provided for a Torrens registration system for the registration of estates and interests in land, and which further provided, inter alia, that estates in land registered under the Land Registry would constitute indefeasible proof of title and generate an irrebuttable presumption in law that the registered proprietor of the estate was also the true owner of the said estate in law. The claimant provided proof that it had become the registered proprietor of the fee simple estate over the relevant lands in 1999, having purchased the estate in a registered transaction from the previous registered proprietor of that estate. It argued that, for the purposes of the tort of trespass to land, its status as the registered proprietor meant that the claimant company, and not the defendant Duchess, had the right to the exclusive possession of the lands. Moreover, it further argued that the 1928 Act was covered by the constitutional doctrine of Le Principe du Chef, notwithstanding that its passage had predated the rise of the office of the Magnificus Dominus (which arose from the unification of the offices of President and Prime Minister in August 1988), because the legislative or prescriptive powers of the President and Congress, combined and considered together, had been the constitutional predecessor-in-title to the now-unified sovereign legislative and prescriptive powers possessed by the singular office of the Magnificus Dominus, qua Souverain.

[Purgatio]

The Supreme Court of Cassation unanimously found in favour of the respondent-defendant Duchess and against the petitioner-claimant company, with that unanimous decision being authored by Le Lord Juge de la Cour Suprême Maxence Cartier (who had also authored the concurring opinion in St. Helaire's Society c. High Inquisitor, and as such, the unanimous opinion in Bruvielle Développements largely adopted the approach of that concurrence towards the resolution of conflicting norms both covered by the constitutional principle of Le Principe du Chef which cannot be reconciled with one another). Le Lord Juge Maxence Cartier agreed with the claimant company that Le Principe du Chef could apply to primary legislation enacted prior to the rise of the High Office of the Magnificus Dominus, "indeed, for if it were otherwise, much chaos and disruption would afflict the present constitutional order if all these prior enacted laws and acts suddenly lost their binding force in one fell swoop overnight. The question is whether the pre-1988 law was enacted in such a fashion that it possesses an equivalent constitutional status as a legal act directly promulgated by the Magnificus Dominus, qua Souverain, such that the constitutional norm of Le Principe du Chef may justly and fairly be said to apply, mutatis mutandis, to the enactment of that prior law. The test for this is whether the pre-1988 constitutional actors, when their various powers are combined together, and considered as one unified whole, stands in a similar or analogous position to that of the Magnificus Dominus today, as the supreme leader of this jurisdiction - in other words, was the legislation enacted by a constitutional organ or organs which, considered together, may fairly and reasonably be regarded as having so prescribed that law qua Chef, and not qua Vicarius. Here, the LRA 1928 was clearly enacted qua Chef and not qua Vicarius. It was not a piece of secondary or subsidiary legislation, enacted by a Minister acting under a delegated power derived from a primary piece of legislation, such as an Act of Congress. Rather, the LRA 1928 was itself an Act of Congress, having been validly enacted under the old pre-1988 constitutional order, viz., through a simple majority vote of the Congressional legislators, and receiving the assenting signature of the elected President. Neither Congress nor the President, acting alone, stood in any analogous position to the Magnificus Dominus today, who, of course, is undoubtedly the physical embodiment, tangible expression, and singular living personification of the entirety of the sovereignty of the Purgation State, as recognised in the principle of Le Principe du Chef, and as was acknowledged by this court in our seminal decision of In the Matter of the Reference of the Ministry of Justice No. 74 of 1988 [1988] 6 RJRP 5744 ("Re Ministry of Justice No. 74/1988") at [63]-[65]. However, Congress and President, considered together, as one integrated whole, had possessed the sovereign law-making powers which have now been agglomerated and unified into the singular personage and entity of the High Office of the Magnificus Dominus. In that sense, the constitutional sovereignty of the pre-1988 'President-in-Congress' may fairly be regarded as the predecessor-in-title of the constitutional sovereignty enjoyed in the office and body of the post-1988 Magnificus Dominus. Laws enacted by the 'President-in-Congress' are thus enacted qua Chef in much the same way as Executive Orders promulgated by the Magnificus Dominus are likewise enacted by him and his office qua Souverain. There is hence little merit to the view of the respondent here that the constitutional principle of Le Principe du Chef cannot be said to apply to the LRA 1928 simply because it was not promulgated by the Magnificus Dominus, having predated the creation of his office. Indeed, that constitutional norm never rested upon such a thin Procrustean bed as that. It suffices that LRA 1928 had been properly enacted by organs and bodies which, together, possessed the combined constitutional powers which cumulatively constituted the predecessor-in-title to the sovereign powers now collectively and singularly imbued in the unified personage and office of the Magnificus Dominus, acting and legislating qua Chef" (see, Bruvielle Développements at [30]).

Having determined that both the LRA 1928 and ER 11/2000 were equally covered by the principle of Le Principe du Chef, the next question was how to resolve the seeming normative conflict between the substantive rules of these differing legislative acts. Le Lord Juge Maxence Cartier agreed with the petitioner-claimant company that it was impossible to effectuate a 'harmonious interpretation' of the two legislative acts under the approach laid down in the court's previous decision of St. Helaire's Society c. High Inquisitor, such that the two legislative acts were, on any reasonable construction, clearly in a position of being in an irreconcilable normative conflict with one another (see, Bruvielle Développements at [32]-[33] and [36]). As held in that unanimous opinion, "[t]o my mind, it is quite clear that, in such circumstances, where on an objective interpretation of two legal acts, both of equal standing, emanating from the sovereign will of the Magnificus Dominus, qua Souverain, there is indeed an irresolvable normative conflict in the substantive contents thereof, one must turn to seminal constructive canons and rules respecting the resolution of such 'conflicts of norms', as was explained in the concurring opinion appended in St. Helaire's Society c. High Inquisitor at [74]-[75] and [78], viz., that where the substantive contents of two or more norms or rules of law appear to collide in an irreconcilable conflict, one should adopt the priority or precedence, as between those two legal rules, that would preserve, as far as possible, the binding legal effect of each, reducing neither rule to a position of mere surplusage, for a pronouncer or promulgator of norms shall not be taken to have legislated in vain. Without proposing to canvass such conflict rules in any exhaustive fashion, it is clear, to my mind, that two such conflict rules bear the greatest significance and relevance to the facts of the present case - first, lex specialis derogat legi generali (the specific derogates from the general); and, second, lex posterior derogat legi priori (the subsequent derogates from the antecedent). Both of these maxims reasonably follow from the same underlying fundamental rule running in common between the undergirding rationale of both, namely, the overriding need to avoid reducing either conflicting rule to a relegated position of being mere surplusage and nothing more. For a specific contrary norm to derogate from a general norm preserves the effect of the former whilst maintaining the effect of the latter in all other scenarios and circumstances save only for the more narrowly delimited circumstances in which the former governs, whereas if the general contrary norm were to derogate from a specific norm, the natural consequence would be to deprive the specific norm of any further legal effect. Much in a similar vein, for a subsequent contrary norm to derogate from an antecedent norm preserves the prospective legal effect of the former whilst leaving unmolested the valid juridical effect of the latter in the interregnum, but if the antecedent norm were held to override the subsequent norm, then the subsequent norm is bereft of any juridical effect or quality, be it prospective or, certainly, retrospective. Consequently, in order to reduce neither conflicting norm to a position of mere surplusage, it follows quite logically and inevitably from that proposition that the specific must be held to derogate from the general, and likewise, it is the subsequent that also derogates from the antecedent" (see, Bruvielle Développements at [47]).

Thus, applying the 'conflict of norms' maxim of lex specialis derogat legi generali, it was held that the rule of the indefeasible title of the registered proprietor laid down in the legislative schema of the LRA 1928 represented the legi generali that was of wide and general application to all registered estates and interests in land, more broadly, whereas the rule of restitutio ad integrum which provided for the restoration of pre-Revolution feudal titles in unenfeoffed or non-subinfeudated landed estates and holdings to the aristocratic estates which had formerly held onto those seigneurial interests was the lex specialis which provided for a contrary outcome only in respect of those precisely and narrowly delimited circumstances, in which the opposite outcome would follow, viz., the unregistered feudal seigneurial interests of such aristocratic estates would prevail over the registered title of the registered proprietor in that estate in land which would be indefeasible in all other circumstances save for that scenario alone (see, Bruvielle Développements at [54]-[55] and [64(a)]). Likewise, applying the 'conflict of norms' maxim of lex posterior derogat legi priori, since the LRA 1928 was enacted back in May 1928 whereas ER 11/2000 was promulgated by Le Grand Roi Chalon-Arlay de la Fayette in July 2000, it was quite clear that the subsequent rule in ER 11/2000 would prevail over any contrary rule contained in the antecedent LRA 1928 (see, Bruvielle Développements at [58]-[59] and [64(b)]). Hence, the restored feudal titles and re-constituted seigneurial interests of the respondent-defendant Duchess were held to prevail over the registered estate in land that was owned by the petitioner-claimant real estate development company prior to the December 2000 expropriations.

However, a note of caution that should be observed here is that the Supreme Court of Cassation has often warned against the blind and unthinking application of these 'conflict of norms' maxims as laid down in, inter alia, Bruvielle Développements, where it is clear that the result that would be obtained from the application of such maxims is improper and inappropriate under the particular circumstances at hand. In other words, the maxims in Bruvielle Développements are merely guidelines to be taken into due consideration as opposed to fixed and immutable rules to be rigidly applied irrespective of the given factual matrix that is actually in question in a specific case. The Supreme Court of Cassation decision in Burghers & Khessel's Constructions and Engineering Designs Company c. Suheira Financial Holdings Group [2015] 11 RJRP 10081 (often abbreviated as "Burghers & Khessel's") is rather instructive on this issue. That case concerned an aborted highway construction project which then carried knock-on implications upon a cross-border financing agreement in which a financial conglomerate from the Tatsumako Federation had agreed to loan monies to an Animirian construction company to fund the operating costs of a highway construction project under a concession contract awarded by the Animirian federal government to that Animirian construction company in the border region of Lilian-en-Alagnon. After the Second Cleansing War of 2006-2009, the PAF occupied the Lilian-en-Alagnon border region and remained in such occupation after the war's end, when the territory was formally annexed by the Purgation State. Following an extensive EDP discussion on the subject, the Magnificus Dominus ordered the wholesale depopulation of the Lilian-en-Alagnon border region in Executive Order (EO) No. 421 of 2009 ("EO 421/2009") in order to make way for PAF military bases and extensive defensive fortifications in the border territories adjacent to Purgatio's hostile neighbours of Animiria and Stulitia. EO 421/2009 included a clause which, inter alia, provided that any prior construction contracts entered into in respect of the affected border territories were to be treated as wholly frustrated in law due to a supervening event, that being the depopulation ordered in EO 421/2009, and were hence no longer liable to be performed or enforced.

Due to that depopulation, and the Animirian government's loss of effective control over the territory of Lilian-en-Alagnon, the highway construction project could not be performed. The respondent finance company invoked the arbitration dispute-resolution clause in its finance agreement with the petitioner construction company to sue the latter for approximately US$58.778 million in compensatory damages, arguing that on a proper construction of the contract, the omission to complete the highway construction project was a defaulting event which entitled the respondent to call in the entirety of the loaned monies, with interest, from the petitioner. Pursuant to the terms of the dispute-resolution clause, the arbitration was seated in Havelkdaag, the capital city of the Visserien Vrijstaat, administered by the Havelkdaag Chamber of Commerce (HCC) governed by HCC Arbitration Rules. The HCC Tribunal found in favour of the respondent company and ordered the petitioner company to pay roughly US$20.023 million in damages to the respondent in an award published in 2013.

The respondent then attempted to enforce that 2013 arbitral award against the assets of the applicant held in a number of jurisdictions including, inter alia, that situated in Purgatio, relying upon the Congressional legislation known as the Recognition and Enforcement of Foreign Arbitral Awards Act of 1959 ("REFAA 1959"), which provided a mechanism for foreign arbitration awards to be registered and enforced as a Purgation court order, provided that the award was rendered in a foreign State which, like the Purgation State, had also ratified the International Convention on the Recognition and Enforcement of Foreign Awards in Arbitrations and were in fact enforcing arbitral awards rendered in Purgatio in compliance with their treaty obligations (such qualifying States were listed in the Schedule to the REFAA 1959 and can be amended and updated by the Foreign Secretary by way of statutory instruments, which list of qualifying States included the Visserien Vrijstaat). However, the petitioner relied on EO 421/2009 to argue that the enforcement of the 2013 arbitral award would, in effect, amount to the enforcement of the financing agreement over the aborted highway construction project in Lilian-en-Alagnon which, for all practical intents and purposes, would violate the prohibition contained in EO 421/2009. The petitioner construction company initially prevailed on this point before the Vindicatory Equities Division (VED) of the Purgation Court of First Instance (or La Cour de Première Instance de la Purgatio) but the respondent finance company then prevailed when the Purgation Court of Final Appeals (or La Cour d'Appels Finaux de la Purgatio) later reversed that decision in its favour upon its appeal thereto.

The petitioner sought a reversal of that decision before the Supreme Court of Cassation, which chose to hear the matter en banc, producing a splintered judgment in Burghers & Khessel's, dismissing the petitioner's 'petition for cassation' by a very narrow 7-6 majority (with three Justices agreeing with the plurality opinion, four Justices agreeing with the concurring opinion, and six Justices agreeing with the dissenting opinion). The plurality opinion, authored by La Dame Présidente de la Cour Suprême Clothilde d'Hénin-Liétard d'Alsace, is often regarded as the controlling opinion by nearly all jurists, practitioners, and academics, being in the majority of the en banc court on all legal and factual findings and thereby regarded as expressing the ratiocination or ratio decidendi of the Burghers & Khessel's judgment. First, the plurality opinion held (and with which the dissenting opinion agreed but the concurring opinion departed from) that the provisions of EO 421/2009 were to be reasonably interpreted as prohibiting the enforcement of the 2013 arbitral award, for its wording provided that construction contracts in respect of the newly occupied border territories, including Lilian-en-Alagnon, were to be regarded as frustrated on account of the depopulation ordered therein, and crucially and more importantly, EO 421/2009 explicitly prohibited any legal actions from being instituted that would enforce the terms and obligations of such construction contracts. In the view of the plurality, the most reasonable construction of such a provision is that the EDP and the Magnificus Dominus sought to address the consequential effects of its depopulation project by preventing the enforcement of various construction projects in the border regions that would be incompatible with that depopulation and therefore could not be performed, and correspondingly, to prevent companies from being sued for damages or equitable reliefs for failing to perform their construction project obligations that would conflict with or frustrate the depopulation of the border regions. In the words of La Dame Présidente Clothilde d'Hénin-Liétard d'Alsace, writing for the plurality of the court, "I would favour the adoption of an effet utile interpretation or an effective construction of Art 16(2) of EO 421/2009 and its provisions respecting the Order's consequential effects upon pre-existing contracts in relation to the affected regions, based upon a teleological reading thereof. To draw a distinction between a direct legal action for breach of contract, in an attempt to obtain, inter alia, an order for common law damages for breach of contract, or equitable reliefs such as an order for specific performance or injunctions that would serve to compel or pressure a contracting party into compliance with the said contract, on the one hand, and an award of damages resulting from international commercial arbitration arising directly out of claims and disputes in connection with, or resulting from, that same construction project, would not only be overly technical and unduly formalistic and artificial in its analysis, but more importantly, from the perspective of the underlying spirit and rationale of EO 421/2009, it is indeed a distinction without a difference. In either event, one contracting party seeks to enforce the terms of the construction contract against the other contracting party through, inter alia, the obtaining of damages in compensation for the performance debts arising out of the stipulations and obligations of that contract, which are owed and owing thereunder, thereby enforcing or restoring the integrity of the contractual obligations therewithin. An attempt to enforce the terms of a contract remains such an attempted enforcement irrespective of whether the chosen mechanism of enforcement is a common law award of damages before a Purgation court of law or an arbitral award of damages before an independent arbitration tribunal in a foreign seat. Hence, for the purposes of EO 421/2009, both such attempts are equally covered by the prohibition contained in Art 16(2) thereof" (see, Burghers & Khessel's at [81]).

In adopting such an interpretation of EO 421/2009, the plurality opinion went on to find that this necessarily meant that EO 421/2009 came into a clear normative conflict with REFAA 1959, since the former prohibited the enforcement of the 2013 arbitral award and the damages awarded therein, whereas the latter required the enforcement of that award given that it resulted from an arbitral process seated in a jurisdiction listed in the Schedule thereof (viz., the Visserien Vrijstaat), which could not be reconciled through a 'harmonious construction' of the two legislative acts (see, Burghers & Khessel's at [86]-[87]). Moreover, it was held that both pieces of legislation constituted primary legislation of equal standing and value under the constitutional norm of Le Principe du Chef, as EO 421/2009 was promulgated directly by the Magnificus Dominus whereas (and following the reasoning in Bruvielle Développements that primary legislation predating the existence of the High Office of the Magnificus Dominus remained equally covered by the principle of Le Principe du Chef) the REFAA 1959 had been enacted by the PNC as Congressional legislation which was then signed into law by the elected President (see, Burghers & Khessel's at [89]-[90] and [92]). The question, therefore, was how that identified normative conflict between two legislative acts engaging the application of Le Principe du Chef stood to be resolved on the facts of that case.

The plurality opinion acknowledged that a strict application of the 'conflict of norms' maxims in Bruvielle Développements (i.e., the maxims of lex specialis derogat legi generali and lex posterior derogat legi priori) would carry the effect of EO 421/2009 taking priority or precedence over the REFAA 1959, since the prohibition on the enforcement of construction contracts over the border regions is the lex specialis applying only in that specific set of circumstances whereas the legi generali is the wider and broader requirement to enforce qualifying foreign arbitral awards more generally. Likewise, EO 421/2009 was promulgated into law half a century after the enactment of REFAA 1959, making the former the lex posterior while the latter is the legi priori (see, Burghers & Khessel's at [95] and [98]).

However, the plurality opinion warned against blindly and uncritically applying the 'conflict of norms' maxims identified in Bruvielle Développements and other similar cases, for in the words of La Dame Présidente Clothilde d'Hénin-Liétard d'Alsace in that case, "[o]ne should never forget or ignore that such maxims of conflict resolution and canons of legislative construction are guidelines of reason and not rules of black-letter law. They are tools devised by the courts as interpretative aids lending assistance to judges and tribunals in their undertaking of an analytical inquiry into the correct meaning of a particular legal act. As tools and aids, however, they are always subject to the overriding exercise of discretion of the decision-maker, to promote and advance the underlying inquiry in all cases, which is to correctly effect an objective construction of the relevant legal acts based on a reasonable reading of the underlying object and purpose thereof. It is the advancement of that underlying legislative object which is the true rule of law that binds all courts and tribunals in our vindication of the rule of law, with such maxims as that identified in Bruvielle Développements serving as instruments providing guidance and assistance in pursuit of that overriding objective - in other words, it must never be forgotten that, at the end of the day, they are mere slaves to the courts and not mistresses thereof, maidservants and not our masters. Slavish unthinking adherence to such 'conflicts of norms' maxims and canons of construction can, in fact, produce results contrary to a reasonable or sensible construction of the will of the legislating Souverain where the derived outcome is clearly inapposite and wholly infelicitous when viewed against the context and background of the actual legislative schema that stands to be construed and the underlying legislative intent that needs to be divined and deciphered therein; and, in my humble view, the factual matrix presented here constitutes such a case" (see, Burghers & Khessel's at [104]).

The plurality opinion held (with which the concurring opinion agreed and the dissenting opinion departed from) that the general rule for the enforcement of qualifying foreign arbitral awards in REFAA 1959 trumped the narrower prohibition on the enforcement of construction contracts over the Lilian-en-Alagnon region in EO 421/2009 based on the circumstances of the case. It reasoned that where the entire legislative raison d'être of a legislative scheme of general application was to govern and apply to even future legislative acts, it should not lightly be held, in the absence of express wording to the contrary, that a subsequent incompatible legislative act serves to derogate from the former legal regime, especially where the effect of such an approach, when taken to its logical conclusion in every case, would be to rob and deprive the former programme of its intended object and purpose by wholly undercutting or undermining its ability to govern and regulate future legal acts that are subsequently prescribed (see, Burghers & Khessel's at [106] and [109]-[111]). The plurality opinion was persuaded that the REFAA 1959 had been so intended by the 'President-in-Congress' to have such a legislative effect. It noted that the REFAA 1959 made clear in its long title and pre-title that the object and purpose of that legislation had been to put into effect the Purgation State's international treaty obligations under the relevant 1959 Convention, which strongly militated against any construction that would rob the REFAA 1959 of its intended effect of ensuring the Purgation State remained in compliance with the 1959 Convention and guarding against any defaults upon the stipulations thereunder. It was clear also, in the view of the plurality opinion, that the REFAA 1959 had been intended to apply even where the defaulting act that resulted in a qualifying foreign arbitral award had been performed by a public authority (such as an awarding ministry or department that granted a concession contract to a private actor with an agreement to arbitrate contained in a dispute-resolution clause therein), pointing to various provisions such as Section 26 of REFAA 1959 which clarified that a public authority could not resist the enforcement of an arbitral award against it on the basis of, inter alia, the common law doctrine of qualified immunity or by invoking the fact that that public authority's actions were authorised or even mandated by legislation or otherwise performed under any lawful power, duty, obligation, or authority. Finally, the plurality opinion cited statements in the Second Reading speech of Le Premier Législateur delivered in respect of REFAA 1959 and contained in the Déparl Dugrès official records, which indicated that the Legislature had intended for REFAA 1959 to apply even in public-private or investor-state arbitral disputes in which the underlying dispute was the result of the adoption of primary or secondary legislation which conflicted with the stipulations provided for under commercial transactions with any public bodies or governmental agencies containing such arbitration clauses, in the interest of providing certainty, security, and confidence to foreign investors and overseas businesses (see, Burghers & Khessel's at [113], [115]-[116], [119], [125]-[128]).

The plurality of the court acknowledged, however, that the factual matrix in Burghers & Khessel's did not concern an investor-state dispute but rather the enforcement of a financing agreement between two private foreign parties. Nevertheless, in its view, these were relevant considerations demonstrating the contextual background behind the enactment of REFAA 1959 and the legislative object and purpose behind the adoption thereof. It demonstrated that the REFAA 1959 had been intended to provide the certainty and predictability of the reliable enforcement of qualifying foreign arbitral awards even where such awards and the damages awarded therein had been the result of requirements laid down in subsequent legislation postdating the implementation of REFAA 1959. Therefore, the adoption of the approach that EO 421/2009 derogated from REFAA 1959 and prevented the enforcement of the 2013 arbitral award - despite the enforcement of that award being required under the 1959 Convention which REFAA 1959 had been intended to implement and effectuate into Purgation law - would, if taken to its logical conclusion, rob the legislative scheme in REFAA 1959 of its intended effect, which had been contemplated by the Legislature at the time as a programme that would regulate and govern even future and subsequent legal acts, in order to, inter alia, ensure that the Purgation State did not default upon its international treaty obligations in the 1959 Convention, and thereby providing the necessary assurance of such due guarantees of protection to potential foreign investors and suppliers of international capital. Consequently, it was held that the requirements of REFAA 1959 would take precedence and primacy over the contrary provision in EO 421/2009, with the effect that the respondent finance company was entitled to the enforcement of the 2013 arbitral award and the award of damages in its favour which was to be payable to it by the appellant construction company. In the now-famous words of La Dame Présidente Clothilde d'Hénin-Liétard d'Alsace, writing for the plurality of the court, "[t]he objective in all instances, in the application of the highest constitutional norm of Le Principe du Chef, is to divine the underlying notional reasonable intentions of the prescribing Souverain by effectuating a teleological interpretation of all of the legal acts emanating from the personage and will of the Souverain, qua Chef, to determine and ascertain, in the round, what the reasonably intended effect would be in the given factual matrix. To put it very simply, when faced with two conflicting pieces of legislation tugging in opposite directions and contrary effects, the question to be asked is always this - based on all of the external circumstances and indicators, would an objective reasonable person situated in the position of the Souverain have intended for the former conflicting legislation to prevail over the latter, or vice versa? All maxims and canons of construction are but tools and aids assisting in the judge's determination of the correct answer to that essential question, but in any event, the core conceptual character of that fundamental inquiry still remains exactly the same in all such cases, and thus stands to be answered holistically, in the round, in a rational and common-sensical manner overall" (see, Burghers & Khessel's at [131]).

[Purgatio]

Sources of Law (Primary and Secondary Legislation) and Branches of Government

All legal acts enacted within the Purgation constitutional order may be broadly differentiated into two categories - primary and secondary legislation - based largely on the source they emanate from and the governmental body or organ which enacts them into law. The significance of that distinction is that it determines the hierarchical value of the legal act, for primary legislation will always enjoy precedence over secondary legislation in the event of a conflict between the two.

In the case of De Magnificus Dominus (sur l'application de Léonie Delphine Cordonnier) c. Attorney-General [2022] 2 RJRP 1109 (often abbreviated as "Léonie Cordonnier"), the Supreme Court of Cassation summarised and reiterated the essential difference between primary and secondary legislation for the purposes of Purgation constitutional and administrative law. In a nutshell, considered from the foundational principle of Le Principe du Chef (i.e., the 'leader principle'), primary legislation is a legal act emanating directly from the will of the Magnificus Dominus, qua Souverain, whereas secondary legislation is any other legal act emanating indirectly from the will of the Magnificus Dominus, often being promulgated by a secondary source acting under a delegated authority that is ultimately traceable back to the original will of the Magnificus Dominus (see, Léonie Cordonnier at [17] and [19]). The Supreme Court of Cassation articulated that since, under the constitutional norm of Le Principe du Chef, the validity and binding force of all legal norms within the Purgation legal order stems, ultimately, from the will of the Souverain, qua Chef, meaning that all legal acts and norms owe their legal force and effectiveness to the enacted will of the Magnificus Dominus who is the Souverain of the Purgation State, it follows from there that, in the event of a conflict between primary legislation and secondary legislation, the former will trump the latter, being a more direct legal act with a more immediate and proximate relationship to the Magnificus Dominus, and thereby more likely to be truly reflective of his sovereign legislative and prescriptive will. From there, the Supreme Court of Cassation reiterated the 'conflict of norms' maxim of lex superior derogat legi inferiori - higher legal norms will derogate from lesser legal norms - as the basis for the so-called ultra vires doctrine, the idea that secondary legislation is always liable to be challenged before courts of law for their alleged illegality or unlawfulness, on the basis of an alleged conflict with any primary legislation.

The facts of Léonie Cordonnier concerned a respondent subjected to a 'genetic re-classification' proceeding before a TECON tribunal. The 'complaint' seeking a re-classification of the re-classification respondent's registered genetic typology from Génétiquement Sain to Génétiquement Dysfonctionnel had been filed by the PICOS secret police organisation, after evidence emerged that the re-classification respondent had carried on an illegal sexual relationship with a Dysfonctionnel male in contravention of EO 41/1990 (amended in EO 305/1990), which criminalised all marriage, procreation, and sexual relations between the Sain and the Dysfonctionnel. After the PICOS 'complaint' was instituted against the re-classification respondent, the two other 'stakeholders' in the process, the PIGC and Home Office, expressed their support for the re-classification. The final decision, however, as to whether a 're-classification action' is to be instituted lay not in the hands of any of the three 'stakeholders' (viz., PICOS, PIGC, and the Home Office), but in the hands of the Attorney-General and the Attorney-General's Office (AGO), which would decide whether or not to institute the action or decline to do so. The AGO issued public guidelines, policy directives and circulars intended to provide guidance to AGO state counsel as well as members of the public more generally as to how the AGO would exercise its discretion to determine whether it would institute, or decline to institute, a 'genetic re-classification action'. In respect of EO 41/1990 offences, the AGO had promulgated Attorney-General's Office (AGO) Circular No. 358 of 2019 (Amended Version No. 19) ("AGO CN 358/2019"), which divided EO 41/1990 offences into 'three bands' of severity, based on a number of aggravating and mitigating factors, indicating that 'Band 1' offences would usually result in a 're-classification action' being instituted, whereas 'Band 3' offences would usually result in the AGO state counsel declining to institute the 're-classification action', whilst for 'Band 2' offences there would be no 'starting point' in favour or against the bringing of the 're-classification action', with that decision depending upon the AGO state counsel's exercise of discretion based on the factors listed in AGO CN 358/2019.

In Léonie Cordonnier, the AGO state counsel assigned to the re-classification respondent's case took the view that the case fell within the 'Band 2' category under AGO CN 358/2019, and exercised her discretion in favour of instituting a 're-classification action', providing a detailed list of reasons for her decision in a written letter of representation to the re-classification respondent's legal representatives. However, the re-classification respondent disagreed with that expressed view, and submitted that her case actually fell within the 'Band 3' category of offences, such that the presumptive starting position prescribed under AGO CN 358/2019 was that the AGO would decline to bring a 're-classification action', absenting any special circumstances or compelling reasons for so doing. Hence, she instituted an administrative challenge seeking the judicial review of the AGO's decision to institute that 're-classification action' against herself, on the basis that it contravened the terms of AGO CN 358/2019, and sought a prerogative order restraining or staying the TECON re-classification proceedings.

When the case of Léonie Cordonnier eventually went all the way up to the Supreme Court of Cassation on a 'petition for cassation', that court then took the opportunity to clarify in its reasoning (whilst reiterating trite law already found in prior cases) that, in any action for judicial review or any legal challenge brought under administrative or constitutional law, the first step in the inquiry is that the judge has to determine the legal status of the public administrative act that is under review, and whether that act was performed under the colour of authority of law found in legislation that constituted 'primary legislation' or that constituted 'secondary legislation' instead. In the court's view, the significance of that dichotomous taxonomical classification is that it determines whether the underlying legislation from which the act emanates or is implemented is even open to challenge to begin with. Primary legislation which emanates directly from the will of the Magnificus Dominus himself cannot be challenged for illegality or unconstitutionality because, under the constitutional norm of Le Principe du Chef, such laws emanate directly from the will of the Souverain which is the highest law of the land. In contrast, secondary legislation, which emanates indirectly from the will of the Magnificus Dominus, such as where a public official prescribes a legal act under a delegated law-making power (whether that delegation or conferral of power(s) is derived from primary or from secondary legislation or is to be implied from an act of appointment by the Magnificus Dominus or otherwise) is always open to being challenged for being ultra vires and therefore illegal, on the basis of an alleged incompatibility with any primary legislation, based on the 'conflict of norms' maxim of lex superior derogat legi inferiori (see, Léonie Cordonnier at [17]-[19] and [22]).

If the respondent's administrative act which is under review is one that flows directly from primary legislation, the validity of the underlying primary legislation is not, in itself, open to challenge. Therefore, the applicant must show that the administrative act is illegal or invalid based on its non-conformity with the legal, substantive, or procedural requirements found in the primary legislation itself, and on a proper construction thereof. However, where the respondent's administrative act that is impugned and under challenge is one that flows from an ostensible authority or putative power conferred in secondary legislation, the applicant now has far more grounds available to him or her to satisfactorily make out their desired legal challenge. The applicant could seek to challenge the administrative act itself on the grounds of an alleged non-conformity with the legal, substantive, or procedural requirements found in the secondary legislation from which the administrative act flows, or a non-conformity with any primary legislation that flows directly from the will of the Magnificus Dominus and therefore makes up the collective corpus of higher or superior norms of the Purgation jurisdiction from which the administrative act and underlying secondary legislation may not derogate. The applicant could also succeed by challenging the legality of the secondary legislation itself, under the ultra vires doctrine, by showing that the relevant provision in the secondary legislation that conferred the power upon the administrative body in the first place actually conflicts with the requirements or norms of any primary legislation, and is therefore invalid on that ground. The applicant may also succeed in his or her challenge by urging the judge to adopt a reading or construction of the secondary legislation that effectively prohibits the respondent administrative body from exercising the power conferred therein in the exact manner and fashion that it was so exercised by the respondent, under the substantive canon of construction known as the 'constitutional avoidance canon' - i.e., that where two or more reasonable constructions of a legislative provision are available to the judge, the judge should prefer interpretations that preserve the legality of the legislation over interpretations which would have the effect of rendering the legislation illegal, invalid, and/or unconstitutional. That constructive canon is based on the reasonable and common-sensical notion that the law-maker, in enacting the legislation in question, would presumably have intended and preferred for that legislation to have a valid effect as opposed to being invalidated and, consequently, rendered wholly ineffectual as a result. Hence, if one possible interpretation of a piece of secondary legislation would conflict with primary legislation (rendering it unlawful for being ultra vires) whereas another possible interpretation of that secondary legislation would conform with primary legislation (rendering it lawful for being intra vires), it follows from the 'constitutional avoidance canon' that the judge should generally lean in favour of the latter interpretation over the former one. If the lawful intra vires interpretation is a narrower construction of the power-conferring provision in the secondary legislation, it could carry the effect of excluding the respondent administrative body's exercise of their putative powers in the actual manner that it did so, thus rendering the impugned administrative act unlawful and ultra vires as a result. All of these various options would have the same ultimate effect of allowing the applicant to challenge the validity of the impugned administrative act of the respondent administrative body but simply through differing legal argumentative routes (see, Léonie Cordonnier at [24]-[25], [28], [30]-[31], [35]-[36], and [38(a)]).

Common examples of primary legislation in the Purgation constitutional order include the following (see, Léonie Cordonnier at [38(b)] and [41]):

• Legislation enacted by the Purgation National Congress (PNC) and signed into law with the assenting signature of the Magnificus Dominus;
• Executive Orders (EOs) promulgated by the Magnificus Dominus, with or without a formal consultative meeting with the Executive Directorate of Purgatio (EDP);
• Royal edicts promulgated by Le Grand Roi de la Purgatio, either alone and personally or through his body of representative royal advisors under his officially constituted Le Conseil d'État du Roi;
• Policy-making directives, departmental guidelines, and inter-ministerial circulars issued by the Magnificus Dominus governing the operations and activities of the High Office of the Magnificus Dominus (HOMD), which handles all official, personal, and administrative affairs of the Magnificus Dominus arising within his capacity as the head of government, including the resolution of jurisdictional conflicts between various ministries and governmental departments, monitoring or supervising the activities of EDP Ministers, Secretaries of State, and other governmental Heads of Departments in terms of the overall broader policy direction of their respective ministries and departments, coordinating efforts between governmental departments and agencies through common harmonised standards and overarching policy objectives (organised through EDP Cabinet meetings), handling complaints against governmental officials, considering investigatory reports by governmental ombudsman upon such complaints, addressing and redressing citizen petitions, handling internal PNL party matters including issues concerning party discipline; and,
• Any legal act or instrument of executive appointment effected by the Magnificus Dominus, howsoever effected, including appointments to the PNC, EDP, the Supreme Court of Cassation, Directors-General of the cantonal Districts, and Governors of the Occupied Territories (amongst other such executive appointments).

The types and varieties of secondary legislation, on the other hand, are far too diverse and numerous to list out in full or in any exhaustive fashion. However, following the constitutional principle of Le Principe du Chef, where the foregoing acts constitute 'primary legislation' because they are directly implemented, enacted, or promulgated by the Souverain of the Purgation State (and thereby regarded as a direct manifestation or effectuation of his sovereign will), secondary legislation would consist of any legal act which flows or emanates from any of the foregoing pieces of primary legislation, such as, inter alia, the following (see, Léonie Cordonnier at [38(c)] and [44]):

• Any subsidiary legislation or statutory instrument implemented into law by any policy-making official (such as a Minister or Secretary of State of a public body or governmental department, whether sitting on the EDP or otherwise) conferred upon such official in PNC legislation;
• Any regulatory act implemented or enacted by any regulatory body or enforcement agency established in an EO (whether promulgated by the Magnificus Dominus personally or during or following an EDP Cabinet meeting);
• Any subsidiary or secondary EO implemented not by the Magnificus Dominus but is instead promulgated by any one of his Ministers, Secretaries of State, or Heads of Department sitting on the EDP, acting within the scope of their executive appointment thereto, such as a PICOS Order (PO) implemented by the High Inquisitor of PICOS (a particularly prominent example of such legislation would be PO 344/1999 or Le Décret pour la Solution Finale which provides, inter alia, for the mandatory abortion of Dysfonctionnel foetuses and the mandatory euthanasia of Dysfonctionnel newborns);
• Any common law rules created and laid down by judicial officers in the Purgation Judiciary amounting to 'judge-made law', inclusive of common law rules (without any statutory codification or backing under any written law) concerning common law offences (assault, battery, sédition, l'obscénité, etc.), common law torts (libel, nuisance, scandale, dérogeance, etc.), and common law rules of property transfer (donatio mortis causa, inter vivos gifts, liens and easements, usufructs and sub-usufructs, etc.), acting under authority delegated by the Magnificus Dominus in the form of their individual judicial appointments;
• Any decisions, awards, or rulings handed down by any administrative tribunals, adjudicatory boards, or decision-making panels acting in a judicial or quasi-judicial capacity and established in any primary legislation (with the most famous example being the TECON-TECAT tribunal system which handles all 'genetic re-classification' proceedings and was established under primary legislation in the form of EO 26/2011, and is often referred to as the Special Tribunals Establishment Ordinance); and,
• Any acts of provincial or cantonal bodies, such as the regional legislatures and governments of the Occupied Territories as well as the local executive authorities operating in the seven provincial Districts making up the Purgation State's mainland, which operate under an authority delegated by the respective Directeurs-Généraux and/or Chefs des Zones, which in turn derive their powers from their appointment by the Magnificus Dominus as such.

Hence, in Léonie Cordonnier, it was held that the Attorney-General's representations in AGO CN 358/2019 clearly amounted to secondary and not primary legislation, the primary legislation was the appointment of the Attorney-General (Lucien Vannier) to that official position of executive authority, and the promulgation or issuance of AGO CN 358/2019 amounted to a derivative or secondary act the legal validity and effect of which was derived from, and ultimately traceable to, the primary legislation of the Magnificus Dominus appointing the Attorney-General and vesting in his personage the necessary powers and authorities to discharge the varied duties and responsibilities of that office, following the constitutional principle of Le Principe du Chef (see, Léonie Cordonnier at [50] and [65]-[67]). Since AGO CN 358/2019 held the status of secondary legislation, in order to invalidate the administrative act under challenge (the institution of re-classification proceedings against the applicant in that case), the applicant could mount a number of different arguments to succeed in her challenge. First, she could argue that the re-classification proceedings conflicted with the terms of AGO CN 358/2019, because her breach of EO 41/1990 ought to have been classified under 'Band 3' instead of the 'Band 2' category of offending, and was consequently unlawful and ultra vires (see, Léonie Cordonnier at [51(a)]). Second, she could argue that, insofar as the institution of the re-classification action against her was in conformity with AGO CN 358/2019 (i.e., that her case had been correctly regarded by the AGO state counsel as a case of 'Band 2' offending as opposed to 'Band 3' offending), that this would conflict with the object and purposes behind the genetic re-classification regime which the primary legislation of EO 26/2011 and the entire TECON-TECAT procedural mechanism erected by EO 26/2011 was intended to implement and effecuate, and to that extent, AGO CN 358/2019 was unlawful as it conflicted with higher law (see, Léonie Cordonnier at [51(b)]). Third, and finally, she could argue that, insofar as AGO CN 358/2019 was equivocal on its face, in terms of its written text, as to whether the starting point or presumptive position for a violation of the criminal prohibition in EO 41/1990, based on the precise factual matrix of her offending, was to institute a re-classification action, decline to so institute, or otherwise (i.e., no starting position either way), then AGO CN 358/2019 should be narrowly construed in favour of a construction that better accords with the underlying legislative object and purpose of various primary pieces of legislation, inclusive of EO 41/1990 (which, after being amended in EO 305/1990, created the offence criminalising sexual acts or relations between the Sain and the Dysfonctionnel) and EO 26/2011 (which established the TECON-TECAT tribunals and the entire procedural regime for genetic re-classification proceedings, from which the Attorney-General's delegated power to institute or decline to institute such re-classification actions may be found) (see, Léonie Cordonnier at [51(c)] and [53]-[55]). It should also be noted for completeness that, in the end (in terms of the eventual outcome of the case), each of these grounds of challenge submitted by the applicant failed to persuade the court, which found in favour of the respondent and declined to stay the institution of re-classification proceedings for being ultra vires or illegal, unlawful, and/or unconstitutional (see, Léonie Cordonnier at [69]-[70], [75], [77], [81], [84]-[87], and [88(d)]).

Nevertheless, that outcome of the litigation does not undermine the reasoning of the court in Léonie Cordonnier as to the relationship between primary and secondary legislation in the Purgation constitutional order, considered against the overriding constitutional principle of Le Principe du Chef and the relative proximity of a piece of legislation to the will of the Magnificus Dominus from which all valid and effective legal acts must, ultimately, emanate and originate. The facts of Léonie Cordonnier serve not only as a useful illustration of the relationship between primary and secondary legislation, and how one goes about classifying a legal act into either category and the implications of that classification, but it also demonstrates the interaction between the various branches of government and organs of governmental power, in their exercise of such powers. Appended below is an image of a very commonly used infographic in the curriculum of constitutional law tutorials for law students at the University of Savoy-Ducasse and the University of Pétrus, illustrating the relationship between various governmental bodies and organs and the legal and executive acts thereof, using the underlying facts of Léonie Cordonnier to illustrate the broader constitutional framework of the Purgation legal order.

At the very top of the hierarchy lies the Magnificus Dominus. Under the ultimate rule of recognition or highest constitutional norm of Le Principe du Chef, his sovereign prescriptive will, qua Souverain, represents the highest law or laws of the land. In the infographic, the Magnificus Dominus performs a number of acts which amount to primary legislation, the validity and effectiveness of which is therefore not open to constitutional or administrative challenge. First, he promulgates several Executive Orders (EOs). He promulgates EO 41/1990 (amended in EO 305/1990) which imposes a criminal prohibition upon sexual acts or sexual relations between Sain and Dysfonctionnel persons. He also promulgates EO 26/2011, which establishes the TECON-TECAT tribunal system, a procedural mechanism for the genetic re-classification of persons from Génétiquement Sain to Génétiquement Dysfonctionnel. Moreover, he makes appointments to the Executive Directorate of Purgatio (EDP), which impliedly confers necessary powers and authorities upon the appointees to carry out the duties and responsibilities of their executive offices. The EDP consists of twenty-seven (27) members in total, but for the purposes of the infographic, only five (5) are of relevance here - the High Inquisitor of PICOS (Geneviève de la Fayette), the Director of the PIGC (Marin de la Trémouille), the Home Secretary (Joslyn de Lussan), the Attorney-General (Lucien Vannier), and the Procureuse-Générale du Roi (Véronique d'Alsace). He also appoints judicial officers to the higher courts of the Purgation Judiciary (i.e., the ordinary courts of law), on the advice and recommendation of the Judicial Appointments Commission (JAC) (consisting of esteemed and highly experienced senior barristers and senior judges). All of these acts of promulgation and appointment carry the force of primary legislation. They are not open to constitutional or administrative challenge since they flow directly from the sovereign will of the Magnificus Dominus. All other legal acts in the above infographic may derive or trace their validity to at least one or more of these primary legal acts. Correspondingly, this also means that all other legal acts in the above infographic constitute secondary legislation, the validity or effectiveness of which may be legally challenged on the grounds of an incompatibility with, or contravention of, any primary legislation emanating directly from the implemented will of the Magnificus Dominus.

Any and all legal or law-making acts of the Attorney-General (AG), Lucien Vannier, would necessarily constitute secondary legislation by virtue of the fact that he is not the Magnificus Dominus. This includes the promulgation of AGO CN 358/2019, an executive instrument intended to have the force of law, meant to determine how AGO state counsel exercise their powers of discretion to institute, or decline to institute, genetic re-classification proceedings against any person before a validly-constituted TECON tribunal. The secondary or derivative power of the AG to promulgate and implement AGO CN 358/2019 must be found, by implication, in the primary legal act of his appointment as such by the Magnificus Dominus, considered together with the delegation or conferral of powers found in another piece of primary legislation, namely, EO 26/2011, which granted to the AG the sole and exclusive power to either institute, or decline to institute, actions for genetic re-classification before a validly-constituted TECON tribunal. In order for the provisions in AGO CN 358/2019 to be considered valid, they must conform with all primary legislation throughout the entirety of the Purgation legal order, flowing directly from the legislative will of the Souverain, including, inter alia, the AG's instrument of appointment as such, EO 26/2011, and EO 41/1990, amongst others. When an individual state counsel of the Attorney-General's Office (AGO) exercises the AG's powers under EO 26/2011, read with AGO CN 358/2019, to institute an action against La Femme Léonie Delphine Cordonnier to genetically re-classify her from Sain to Dysfonctionnel (exercising the AG's powers as the alter ego of the AG, under the Baillairgé doctrine), they are performing an executive act which likewise possesses the derivative status of secondary legislation (with the word 'legislation' here being used in the wider or broader sense to mean any act which carries any legal effect, whether generally, in relation to the entire subject-community or a class thereof, or directed specifically at an individual). That impugned act of institution, which was challenged by the applicant in Léonie Cordonnier, must therefore be intra vires and fall squarely within the confines of the secondary legislation under which it was performed (viz., AGO CN 358/2019), it must also conform to all primary legislation across the Purgation legal order, including EO 41/1990, EO 26/2011, and the AG's instrument of appointment (and confirmation thereof), all having been promulgated and enacted into law directly by the Magnificus Dominus.

The task of adjudicating or arbitrating that legal dispute between the applicant of that administrative challenge (La Femme Léonie Delphine Cordonnier) and the administrative challenge respondent (the AGO) falls to the ordinary courts of law, including the Executive Prerogatives Division (EPD) of the Purgation Court of First Instance (CFI), with a right of appeal to the Purgation Court of Final Appeals (CFA), followed by the presentation of a 'petition for cassation' to the highest court of the land, the Supreme Court of Cassation, with all judicial officers of all these ordinary courts of law (being superior courts of record) having been appointed by the Magnificus Dominus. Consequently, the judgments rendered by such courts (inclusive of the judgment in Léonie Cordonnier) would also hold the constitutional status of secondary legislation within the hierarchy of norms in the Purgation legal order (again, with 'legislation' being used here in the broader or wider sense of embracing any act of legal effect, including a legally binding determination of the contents of the legal relationship between particular disputants only), as the validity of its legally binding effect is ultimately traceable in an indirect fashion back to the sovereign will of the Magnificus Dominus, being a product of the delegated powers conferred upon these judicial officers by way of appointment by the Magnificus Dominus.

The same relationship holds true for every other legal act contained in the above infographic, including the myriad of secondary legal acts which were not under challenge or impugned in the administrative legal challenge in Léonie Cordonnier, but which made up the factual and procedural background of the legal dispute therein. For example, prior to the genetic re-classification action being instituted against La Femme Cordonnier in 2019 by the AGO, she had been criminally charged for having sexual relations with a Dysfonctionnel man in violation of the criminal prohibition in EO 41/1990 by a Crown Prosecutor (or un procureur du roi), having been brought before a cour de prises to be formally charged around the close of 2017 before being convicted at trial in 2018 by a trial judge sitting in the Criminal Justice Division (CJD) of the CFI. The executive act of the individual procureur du roi, in instituting criminal charges against a defendant and conducting a criminal prosecution against them in court, is an exercise of the powers of the Procureuse-Générale du Roi Véronique d'Alsace, who is a member of the EDP Cabinet and was appointed to that role with effect from 1 January 2011. Hence, that act of prosecution would be a secondary legal act, the validity of which is ultimately traceable to a piece of primary legislation, namely, the December 2010 instrument of appointment of La Procureuse-Générale du Roi de la Purgatio. Likewise, the trial judge of the CFI would have also been appointed to that position of power by the Magnificus Dominus, hence the conviction or acquittal of a criminal defendant would carry a derivative or secondary legal effect that is likewise traceable back to a piece of primary legislation in the form of the Magnificus Dominus having appointed the trial judge to that office. These secondary legal acts are thus all liable to be challenged, as a matter of administrative and/or constitutional law, for illegality or unlawfulness based on an ostensible contradiction with any norm or putative norm, express or implied, explicit or construed, found or identified in any piece of primary legislation in the Purgation legal order, pursuant to the constitutional rule of Le Principe du Chef.

The same is true for the other appointed members of the EDP Cabinet which are also involved in the TECON-TECAT genetic re-classification process, namely, the High Inquisitor of PICOS, Geneviève de la Fayette, the Director of the PIGC, Marin de la Trémouille, and the Secretary of State for the Department of Home Affairs (also known as the 'Secretary of State for the Home Office' or just the 'Home Secretary' for short), Joslyn de Lussan, all of whom were appointed to such positions on the EDP by the Magnificus Dominus and with such written instruments of appointment (or confirmation thereof) amounting to primary legal acts flowing directly from the sovereign will of the Magnificus Dominus, acting qua Souverain. Consequently, all internal policy-making guidelines, directives, or policy circulars promulgated by such EDP Ministers, intended to direct and determine how civil service administrative officers discharge their functions and exercise their discretionary powers within their respective governmental departments or ministries (similar to the Attorney-General's promulgation of AGO CN 358/2019) also bears the status of secondary legislation, with a legal effect and validity that is derivative off of the primary legal validity of acts flowing directly from the will of the Souverain, namely, their appointment to such positions or offices by the Magnificus Dominus himself. The same is true of any subsidiary legislation or executive act which is enacted by these EDP Ministers (either personally or through their civil servants acting as their personified alter egos under the Baillairgé doctrine) under any law-making or executive powers conferred upon them in any primary legislation. Hence, where EO 26/2011 conferred upon these three EDP Ministers the ius standi to institute a 'complaint' to the Attorney-General, seeking the genetic re-classification of any person from Sain to Dysfonctionnel, coupled with a right of the other two 'stakeholders' who did not file such a re-classification complaint to either file a statement of support for or opposition to such a proposed re-classification action before the AGO for the AG's consideration, and rights to appoint adjudicators to the three-member TECON tribunal (one from each of the three 'stakeholders') where the AGO agrees to institute such a re-classification action, any secondary legal acts effected by virtue of such delegated powers under EO 26/2011 likewise hold the subordinate status of secondary legislation within the Purgation constitutional order, with a legal validity that is derivative off of that of the primary legislation from which such powers are derived (viz., EO 26/2011). Hence, such executive acts are likewise liable to be challenged for being illegal or unlawful where they are exercised ultra vires or contrary to the terms of any relevant secondary legislation under which such acts were performed (such as policy-making circulars, directives, or guidances implemented by the relevant EDP Minister or Secretary) or such acts were otherwise incompatible with any legal norm, express or implied, holding the hierarchically superior status of being a primary legal rule or norm, pursuant to the highest overriding constitutional principle of Le Principe du Chef.

[Purgatio]

Unified Judicature, Judicial Hierarchy, and Common Law Interpretivism

The Purgation State follows a unitary as opposed to federal model of governance; thus, the entirety of the territory of the Purgation State constitutes a singular, coherent, normatively integrated legal jurisdiction, with all courts and tribunals within the Purgation State forming part of a singular Unified Judicature with an established judicial hierarchy of appeals and petitions for review. All disputes or controversies of law, falling within the jurisdiction of the Purgation State, are liable to be compulsorily adjudicated before the Unified Judicature of the Purgation State, with a binding settlement or resolution to be effected by a court or tribunal thereof. This section briefly outlines the present judicial hierarchy of the Unified Judicature, the original and appellate jurisdictions of different courts and tribunals thereof, and the system for appeals to a higher court against a lower court's determinations.

The highest court of the land is the Supreme Court of Cassation of Purgatio (La Cour Suprême de Cassation de la Purgatio) or just the 'Supreme Court' for short. It is the only judicial body that is not created by statute or legislation, with an existence which is inhered within the Purgation constitutional order itself. Prior to the abolition of the Republic of Purgatio's written constitution in 1988, the written constitution provided for the existence of the Supreme Court in Article 31, with Article 31(1) providing that "within this one and only Supreme Court of Cassation shall be vested the sole ultimate Judicial Power to interpret and adjudicate upon the correct meaning of all legal acts, norms, rules, or other principles of legal effect throughout the jurisdiction of this Republic, and to thereby determine any disputes thereon arising out of any and all live cases and controversies of law materialising within that jurisdiction". This conferral of "ultimate Judicial Power" means that the Supreme Court is given the final say and the last word on all matters of legal interpretation and construction throughout the Purgation legal order, and can pronounce a binding settlement as to the correct meaning and contents of legal norms and rules throughout that jurisdiction. Despite the repeal of that written constitution in 1988, the effect of Article 31(1) has been effectively preserved by way of the Magnificus Dominus incorporating that language into his written instruments of appointment, whenever a judicial officer is appointed to the Supreme Court, thereby maintaining the position that the Supreme Court retains an inherent and ultimate Judicial Power to interpret and adjudicate upon all legal questions arising from cases and controversies of law in the Purgation State.

All other judicial bodies in the Unified Judicature of the Purgation State are creatures of statute, and may only exercise the jurisdiction that is conferred upon them. All judicial bodies may be divided into four categories - (1) superior or plenary courts of law; (2) inferior or subordinate courts of law; (3) specialised subject-matter courts; and (4) administrative tribunals or decision-making bodies acting in a quasi-judicial capacity.

A superior or plenary court of law refers to an ordinary court of law with an unlimited subject-matter jurisdiction, meaning that, in theory, any legal case, irrespective of the subject-matter, area of law, or the value or complexity of the case, may be heard and determined by that court. Only three judicial bodies fit that description - the Supreme Court of Cassation of Purgatio (La Cour Suprême de Cassation de la Purgatio), the Court of Final Appeals (La Cour d'Appels Finaux), and the Court of First Instance (La Cour de Prèmiere Instance). All judicial officers to such courts are appointed directly by the Magnificus Dominus (but, by convention, only on the advice and recommendation of the Judicial Appointments Commission or JAC), hence their appointments hold the force of primary legislation, under the constitutional principle of Le Principe du Chef. It is this distinction which grants the superior or plenary courts of law the hierarchical power and authority to overrule or override legal norms pronounced by all other judicial bodies, whose judicial officers are appointed by other governmental ministries or departments acting on a delegated or derivative authority off of that of the Magnificus Dominus. Consequently, under the principle of Le Principe du Chef, the legal judgments pronounced by all other courts of law rank inferior and are hierarchically subordinated to the legal judgments pronounced by these superior or plenary courts of law, exercising either a supervisory or appellate function over these other judicial bodies. This is how the constitutional norm of Le Principe du Chef gives rise to a clear judicial hierarchy within the Unified Judicature of the Purgation State between superior and inferior courts of law.

Only the Court of First Instance is vested with any original jurisdiction (i.e., the power to hear, try, and then determine a case in the first-instance), whereas the Court of Final Appeals and Supreme Court may only exercise an appellate jurisdiction (i.e., the power to determine an appeal from a first-instance decision or judgment) but they possess no original jurisdiction in themselves. The Supreme Court of Judicature Act 1884 vests a plenary original jurisdiction in the Court of First Instance (CFI), giving the CFI the theoretical power to hear and try any and all civil and criminal legal disputes in the first-instance. In practice, however, the CFI only hears civil and criminal cases of particular importance in the first-instance. This outcome is arrived at in a negative rather than a positive fashion, by way of implied exclusion. As statutory legislation creates many other judicial bodies in the Unified Judicature of the Purgation State, and then positively vests original jurisdiction in these judicial bodies to adjudicate certain cases, judicial practice directions generally require litigants to submit their cases to the lower courts in the first-instance, and if such cases are submitted to the CFI, there are inter-judicial transfer mechanisms such that the CFI Registry will transfer that case down the judicial hierarchy to the appropriate court. Hence, in practice, the CFI only exercises its original jurisdiction in respect of legal cases where that original jurisdiction has not been vested in any other judicial body or administrative tribunal, and in all other cases, it only exercises its appellate jurisdiction to hear and determine appeals from the lower courts. As will be observed as other judicial bodies are discussed, the effective end-result of this system is that the CFI only handles civil and criminal cases of high-value and/or high-importance in the first-instance.

The next category of courts are the inferior or subordinate courts of law. These are defined as the courts of law with a general subject-matter jurisdiction over a broad variety of civil and criminal cases, but unlike the superior or plenary courts of law, their subject-matter jurisdiction is confined to certain defined limits. For civil cases, this limit generally takes the form of a maximum cap on the damages that a litigant may be seeking beyond which the case would exceed the jurisdiction of that court, and for criminal cases, this limit takes the form of a maximum limit on the maximum prescribed punishment for the criminal offence(s) disclosed in the charge instituted before that court, beyond which the prosecution would exceed the penal jurisdiction of that court. Based on that definition, there are only three inferior or subordinate courts of law in the Unified Judicature of the Purgation State, which are, in ascending order of importance and value (in terms of the cases they handle), as follows - the Courts of Seizures (Les Cours de Prises), the Courts of Partitions (Les Cours des Départements), and the Royal Court of Justice (La Cour Royale de Justice).

The Courts of Seizures are the ultimate 'courts of volume', handling the most number of cases out of all the other judicial bodies in the Purgation State, with over 12,000 court-houses scattered across the seven Districts of Purgatio handling more than 70 million civil and criminal cases every year. Under the Subordinate Courts Act 1966, the Courts of Seizures are vested with the civil jurisdiction to hear cases seeking civil damages of up to a maximum of $55,000 Élites (or where the rights or properties forming the subject-matter of the dispute have an estimated value of $55,000 Élites or less) and the criminal jurisdiction to hear and determine prosecutions involving charges for offences with a maximum prescribed punishment of 4 years' ordinary imprisonment or below or fine-only offences (with or without a prescribed limit to the quantum of the fine imposed) or offences (usually regulatory offences) where the prescribed punishments are limited to either a fine (with or without a prescribed quantitative limit) or an order prohibiting certain business or commercial activities from being undertaken within a period of time (with or without a prescribed limit to the duration thereof). In essence, the Courts of Seizures cannot hear any criminal case where at least one of the prosecuted offences has a prescribed punishment that is a term of ordinary imprisonment where the maximum limit exceeds 4 years, or that is eligible for any judicial lashing, punitive labour, or, of course, judicial execution. In practice, nearly all criminal cases will begin in the Courts of Seizures so that justices of the peace may handle preliminary matters, including the arraignment of the accused and the pre-trial production of an accused in detention, with the case being transferred to the appropriate court once the investigations are completed, the charges are finalised, and it is clear which court is the appropriate forum to hear the criminal trial or take the offender's guilty plea. This stands in stark contrast to the procedure in civil cases, however, where the plaintiff or claimant is instead expected to file their claim in the correct court at the very initiation of the proceedings, based on the damages being claimed or the reliefs being sought in their pleadings; hence, the plaintiff or claimant will control which court hears their action at the outset of the process, although an inter-judicial transfer mechanism can be triggered where it is clear and obvious that the plaintiff's valuation of subject-matter property or assessment of damages suffered is manifestly low or clearly excessive even at the pre-trial interlocutory stage.

The Courts of Partitions are likewise 'courts of volume', handling the second-most number of cases in the Unified Judicature, with over 1,500 court-houses divided across the 860 départements (which are the pre-1988 constituencies for the PNL Legislature) with roughly one or two courts per département handling approximately 5-10 million civil and criminal cases per year. Under the Subordinate Courts Act 1966, the Courts of Partitions are vested with the civil jurisdiction to hear cases seeking civil damages of up to $185,000 Élites (or where the rights or properties forming the subject-matter of the dispute have an estimated value of $185,000 Élites or less) and the criminal jurisdiction to hear and determine prosecutions involving charges for fine-only offences, offences with a maximum prescribed punishment of 12 years' ordinary imprisonment or below or offences which permit the imposition of judicial lashing with a prescribed maximum penalty of 10 lashes or below.

The court exercising an intermediate appellate jurisdiction over such courts is called the Royal Court of Justice (rennamed by the Ministry of Justice in October 1990 from the republican name of the Federal Court of Justice), established by the Federal Justice Act 1971. The Royal Court of Justice hears all civil and criminal appeals from the Courts of Seizures and the Courts of Partitions and also has an original civil jurisdiction to hear cases seeking civil damages of up to $315,000 Élites (or where the rights or properties forming the subject-matter of the dispute have an estimated value of $315,000 Élites or less) and the criminal jurisdiction to hear and determine prosecutions involving charges for fine-only offences, offences with a maximum prescribed punishment of 25 years' ordinary imprisonment or below, offences which permit the imposition of judicial lashing with a prescribed maximum penalty of 30 lashes or below, or offences with a prescribed punishment of 10 years' punitive labour or below. In each of the seven provincial capital cities of the seven Districts of the mainland Purgation State, there is one massive RCJ court-house building containing approximately 30-50 courtrooms therein, hearing civil and criminal trials for important civil and criminal cases barring the exceptionally serious or high-value ones which must be heard by the Court of First Instance in the first-instance hearing. In any given year, the RCJ hears approximately 700-900,000 civil and criminal cases in its original jurisdiction and between 1-2 million civil and criminal appeals.

By way of exclusion and necessary logical implication, this means that ordinary civil cases seeking damages of more than $315,000 Élites must be heard by the Court of First Instance, civil cases seeking reliefs in respect of rights or properties forming the subject-matter of the claim and the prayers sought whilst having an estimated valuation exceeding $315,000 Élites (e.g., litigation seeking a court order for possession of real property worth more than $315,000 Élites, a rei vindicatio legal action seeking possession of a piece of chattel or movable property worth more than $315,000 Élites, a breach of trust lawsuit seeking declaratory relief declaring that a bank account containing more than $315,000 Élites in monies is held on a constructive trust, etc.), as well as prosecutions for any offences with prescribed punishments exceeding the jurisdiction of the RCJ and the other courts below it, which includes fine-only offences, offences with a maximum prescribed punishment of above 25 years' ordinary imprisonment (including offences which prescribe life imprisonment as an eligible penalty, with or without the possibility of parole), offences which permit the imposition of judicial lashing with a prescribed maximum penalty exceeding 30 lashes, offences which impose a maximum prescribed punishment of over 10 years' punitive labour, and of course, offences for which capital punishment is an available penalty, including high treason, murder, rape, sexual assault by penetration, kidnapping, torture, aggravated robbery, aggravated maritime brigandage, and human trafficking, amongst other such offences. Moreover, civil and criminal appeals from the RCJ are also heard by the Court of First Instance. The only CFI court-house building in the entirety of the Purgation State is the large and ornate CFI building in the former capital city of Ravaliér. Hence, any litigants who wish to pursue their appeals all the way up to the Court of First Instance must be willing and able to travel to Ravaliér and appear in-person, wheresoever they may ordinarily reside throughout the Purgation State. As such, the CFI hears approximately 60-80,000 civil and criminal cases in its original jurisdiction and between 70-90,000 civil and criminal appeals from the RCJ every year. All criminal prosecutions and appeals are heard by the CFI's Criminal Justice Division (CJD), whereas most first-instance civil trials and civil appeals are heard by the Private Stipulations Division (PSD) where the dominant claim is founded in consensual contractual or quasi-contractual personal obligation, the Civil Delictual Division (CDD) where the dominant claim is founded in tortious or delictual liability, or the Vindicatory Equities Division (VED), which deals, inter alia, with cases featuring the vindication and determination of proprietary rights, be they legal, equitable, beneficial, or otherwise.

Having outlined the general structure of the inferior or subordinate courts of law with a broad and general civil and criminal subject-matter, the next category of courts to be considered are the 'specialised courts' with a more specific subject-matter expertise and more focussed area of law, of which there are three - first, the Courts of Family Affairs (Les Cours d'Affaires Familiales); second, the Courts of Mercantile Transactions (Les Cours d'Opérations Mercantile); and third, the Permanent Chamber of the Tribunal of International Commerce (La Chambre Permanente du Tribunal de Commerce Internationale).

The Courts of Family Affairs are a set of specialised family courts established by the Magnificus Dominus, on the recommendation of the Ministry of Justice, the Ministry of Health and Human Services, and the Department of Welfare, Work, and Pensions, which in a 2011 joint report advised the establishment of family-oriented courts with specialised training and expertise geared towards a reconciliatory and less adversarial approach towards family litigation. Hence, in Executive Order (EO) No. 68 of 2012 (also known as the "Familial Harmony in Litigation Decree"), which took effect by the close of 2014, the Courts of Family Affairs were established to hear a whole range of family-related legal disputes, including divorce and matrimonial litigation, litigation over the custody and care of children, applications for child maintenance, probate and inheritance disputes, civil cases involving domestic or family violence including applications for civil protective orders and household exclusion orders, establishments of legal curatorships in mental capacity disputes, cases involving the adoption of children or conferring parental orders for commissioning couples, child abuse or neglect cases where social service agencies seek various child protection or child removal orders against parents, and civil claims for amatory torts such as breaches of promises to marry, seduction, criminal conversation, alienation of affections, and wrongful loss of familial or matrimonial consortium, amongst other such cases. Additionally, the Familial Harmony in Litigation Decree established new divisions of the Court of First Instance and the Royal Court of Justice known as the Familial Relations Division (FRD), which would hear appeals from the Courts of Family Affairs as well as hear and try high-value family disputes in the first-instance. Hence, under the structure contemplated by the Familial Harmony in Litigation Decree, matrimonial litigation involving an estimated net matrimonial estate worth $3 million Élites or more, claims for spousal or child maintenance with a 'lump sum' payment of $410,000 Élites or more or periodical payments of $3,500 Élites or more per month (for each child and/or spouse), probate proceedings involving decedent estates with a net worth of $6 million Élites or more, and any civil claims (such as claims for amatory torts) seeking damages of $240,000 Élites or more, would be tried and determined by the FRD of the CFI in the first-instance. Likewise, matrimonial litigation involving an estimated net matrimonial estate worth $860,000 Élites or more, claims for spousal or child maintenance with a 'lump sum' payment of $170,000 Élites or more or periodical payments of $1,500 Élites or more per month (for each child and/or spouse), probate proceedings involving decedent estates with a net worth of $2 million Élites or more, and civil claims seeking damages of $95,000 Élites or more, would be tried and determined by the FRD of the RCJ in the first-instance. All other cases - the vast and overwhelming majority of them - would be heard by the various Courts of Family Affairs in the first-instance, with appeals from the Courts of Family Affairs being heard by the FRD of the RCJ, and appeals from the FRD of the RCJ being heard by the FRD of the CFI.

It should also be noted here as well, for completeness, that an inter-judicial joinder and transfer mechanism is also available to ensure that the delineated spheres of jurisdiction outlined above does not result in an artificial segmentation of different aspects of the same essential family dispute involving the same or similar parties. Hence, for example, if a high-net worth family is undergoing a divorce proceeding, the estimated matrimonial estate is around $8 million Élites (hence the divorce suit is filed in the Court of First Instance), the husband has filed an alienation of affections lawsuit against his wife seeking $150,000 Élites in compensatory damages (hence the civil suit is filed in the Royal Court of Justice), the wife is seeking spousal maintenance of around $3,000 Élites per month until the divorce decree nisi is granted (with the maintenance application being filed in the Royal Court of Justice), and the spouses have filed cross-applications seeking custody orders over the children of the marriage (which is filed in their local Court of Family Affairs), then logically all of these causes of action will be consolidated together during the case management conferences, and will be heard holistically as one combined case before the highest court with jurisdiction to hear all of the matters concerned (which, in the case of this example, will be the Familial Relations Division of the Court of First Instance).

Today, there are now over 2,000 family courts scattered across the Purgation State's mainland seven cantonal Districts hearing an estimated 16-18 million family disputes every year, with the FRD of the RCJ hearing approximately 700-800,000 cases in its appellate familial jurisdiction and another 650-750,000 cases in its original familial jurisdiction each year, and with the FRD of the CFI hearing around 80-100,000 cases in its appellate familial jurisdiction and another 65-85,000 cases in its original familial jurisdiction per annum.

The Courts of Mercantile Transactions are a specialised set of commercial courts established in 1982 by the Commercial Disputes Resolution Act 1981 in response to increasing demands from the Purgation business community for a set of specialised judicial bodies with expertise and experience in a whole swathe of common commercial disputes between businessmen parties, including commercial transactions disputes, admiralty or maritime shipping disputes, internal company constitutional disputes, bankruptcy and insolvency matters, financial and banking disputes, technology-related litigation concerning patent law, trade marks infringements actions, and actions concerning the protection of industrial trade secrets, real estate development, constructions and turnkey contracts, and professional conveyancing disputes, insurance and reinsurance disputes between commercial parties, and other matters concerning corporate governance or relating to mergers & acquisitions, amongst many other such business-related or commercial legal disputes. The disputes heard by such courts are often very high-value commercial disputes, oftentimes with an international angle or cross-border dimension, involving sophisticated commercial parties and a highly-specialised subject-matter area of the law, with cases numbering between 30-50,000 in any given year. Appeals from the decisions of Courts of Mercantile Transactions are heard by the Vindicatory Equities Division (VED) of the Court of First Instance, which hears approximately 12-18,000 of such commercial appeals every year. Moreover, commercial disputes deemed to involve highly complex factual or legal issues may be transferred from the Courts of Mercantile Transactions to the VED to be heard by the CFI in the first-instance, although this is quite rare in practice (with fewer than 100 of such 'specal cases' being heard in an average year).

A discussion of the specialised commercial courts within the Unified Judicature of the Purgation State would, however, be incomplete without discussing the role of commercial and international arbitration within the judicial structure of the Purgation legal jurisdiction. Arbitration has become an increasingly popular method of alternative dispute-resolution, especially for sophisticated commercial parties and businessmen seeking a neutral, non-national forum for the adjudication of their commercial disputes, which can be easily and reliably enforced in hundreds of jurisdictions around the world, under a variety of international treaties and conventions designed to promote neutral cross-border dispute-settlement via arbitration. The Purgation Court of International Arbitration (PCIA) has seen an increasing number of cases referred to it under arbitration clauses seated in Ravaliér naming the PCIA as the administering institution, with over 2,688 arbitral cases being referred to the PCIA in 2023, a steady rise from 2,504 cases in 2022. Many Purgation and non-Purgation companies also choose to arbitrate their commercial disputes outside of Purgatio, especially in smaller and more neutral jurisdictions such as the Visserien Vrijstaat (often seated in Havelkdaag and administered by the Havelkdaag Chamber of Commerce (HCC)) and the Freie Stadt Schwelitz (often seated in Inverburgh and administered by the Inverburgh Centre for International Arbitration (ICIA)). Such arbitration cases are, of course, not heard and determined by the Courts of Mercantile Transactions, being administered by the selected administering institution and arbitrated by the constituted arbitral tribunal. However, if the award creditor wishes to enforce their arbitral award within the Purgation jurisdiction, the application for enforcement is made to the VED of the CFI. Likewise, if the arbitration is seated in Ravaliér, and the award debtor wishes to set aside the award on any ground, or seeks curial assistance over the Purgation-seated arbitration (such as orders relating to discovery, interrogatories, depositions, or subpoenas for material witnesses), the application is also made to the VED of the CFI. Similarly, requests for interim relief or interim assistance in service of an arbitration seated in Purgatio or elsewhere, including applications for an asset-freezing injunction or a prohibitory anti-suit injunction are generally made to the VED of the CFI as well. Hence, in any given year, the VED of the CFI hears approximately 12-14,000 cases relating to arbitrations, be they arbitral proceedings seated in Ravaliér or overseas in foreign jurisdictions.

Finally, a relatively recent judicial innovation of the Unified Judicature of the Purgation State is the creation and establishment of the Permanent Chamber of the Tribunal of International Commerce (and often colloquially abbreviated and referred to as simply the "Permanent Chamber" for short), which began operating in 2018. The Permanent Chamber was created by the Magnificus Dominus in Executive Order (EO) No. 182 of 2015 (and often referred to as the "International Commercial Chamber Ordinance") on the recommendation of the Ministry of Justice and the Ministry of Commerce and International Trade, and the intention was to create an intermediate option for commercial parties that falls midway between traditional commercial litigation before the Courts of Mercantile Transactions, on the one hand, and the flexibility of international commercial arbitration (administered by the PCIA or otherwise and be they seated in Ravaliér or otherwise), on the other hand. Unlike all other judicial bodies in the Unified Judicature of the Purgation State, the Permanent Chamber does not have any mandatory or compulsory jurisdiction, and similar to an arbitral tribunal, it only possesses the jurisdiction which the parties consensually confer upon it, whether by way of a dispute-settlement clause in a commercial contract or, more rarely, in a post-dispute compromissory agreement or even by way of forum prorogatum after a case has been filed with the Permanent Chamber. Additionally, the ratione materiae subject-matter jurisdiction of the Permanent Chamber is delimited and defined in the International Commercial Chamber Ordinance only to "international commercial disputes" alone. The entire purpose of the Permanent Chamber is to offer commercial parties an alternative to both traditional commercial litigation and cross-border commercial arbitration. Consequently, the Permanent Chamber places greater emphasis on party autonomy compared to a traditional court. Not only is its jurisdiction dependent on the consensual submission to jurisdiction of the litigants involved, unlike a typically commercial court, parties can also customise the procedural regime applicable to the litigation. Hence, the Permanent Chamber has a set of procedural rules which apply by default in the absence of the parties' agreement to the contrary; however, parties have full freedom and autonomy to determine the procedural rules which would apply to govern a Permanent Chamber hearing, which can include a modification of the Permanent Chamber's default rules, specific exclusions of or derogations from particular default rules, or even the wholesale substitution of an entirely different set of procedural rules altogether. Likewise, the contract between litigants submitting pre-existing or future disputes to the jurisdiction of the Permanent Chamber may also prescribe the governing law to be applied to their legal relations, which need not be the laws of the Purgation State, but the laws of another jurisdiction altogether, which the Permanent Chamber would have to faithfully construe and apply in their adjudication of the matter. The compromissory or dispute-settlement agreement may even go further in providing that the dispute would be governed by general rules of international law instead of the laws of any national or municipal jurisdiction, or prescribe a set of substantive rules and norms which would apply instead of the laws of any legal jurisdiction in existence, or even prescribe that the dispute would be settled ex aequo et bono - in accordance with equity and consicence alone - without regard to any fixed, rigid, or immutable legal rules to be applied.

Additionally, while the judicial officers appointed to the Courts of Mercantile Transactions are (like that of most ordinary courts of law) all Purgation citizens appointed by the Purgation Ministry of Justice and its Judicial Service Council, the judges in the Permanent Chamber are international judges who are non-Purgation citizens and are chosen, in the first-instance, by the Secretariat of the PCIA (and assented to by the Purgation Ministry of Commerce and International Trade), and are esteemed and experienced arbitrators and litigators in the international commercial arbitration industry. Hence, the international judges in the Permanent Chamber generally have expertise in fields common to commercial arbitrations in the energy, petroleum, insurance, reinsurance, maritime carriage of goods, and constructions markets, amongst others, and there is a process for parties to choose which international judges will preside over their case from a standing list and panel of international judges. Moreover, there is no 'right of appeal' on the merits to the Purgation Judiciary per se, with the International Commercial Chamber Ordinance providing for a limited right of a party to seek an 'annulment' of the Permanent Chamber's judgment by the Purgation Court of Final Appeals on a list of limited grounds including, inter alia, acting in excess of jurisdiction, serious departure from a fundamental rule of procedure, and a failure to state reasons or address parties' submissions or arguments. Moreover, unlike a traditional commercial court, proceedings before the Permanent Chamber are, by default, private and confidential, and thereby inaccessible to the general public, in a clear departure from the traditional common law rule of 'open justice' intended to attract commercial parties who may be attracted to arbitration precisely because of its privacy and confidentiality.

However, proceedings before the Permanent Chamber differ from commercial arbitrations in many other respects as well. For one, since the Permanent Chamber is part of the Unified Judicature of the Purgation State, it possesses all of the coercive powers over third parties of an ordinary court, unlike an arbitral tribunal constituted only by the consent of the parties. As such, it has much broader powers to issue orders against third parties, including orders seeking third party discovery, interrogatories, depositions, and subpoenas compelling a witness to attend court. Moreover, since the Permanent Chamber is a Purgation court, its judgments are automatically enforceable in the same way as any other Purgation court order, without the need for a party to apply for the judgment to be enforced as an order of court. This also means that the robust and coercive slew of remedies for the enforcement of other Purgation court orders, including the issuance of arrest warrants for contempt of court, writs of search and seizure, garnishing of bank accounts, attachment of earnings and income, the freezing of assets, etc., are all available and may be applied for by a winning party seeking to enforce the judgment within the territory of the Purgation State. Likewise, the same is true of any interlocutory orders rendered by the Permanent Chamber before the disposition of proceedings, including asset-freezing injunctions to prevent the dissipation of assets, orders for seizures of material property or evidence, and search orders over relevant premises, which, unlike the interim awards of a tribunal, are automatically enforceable within the Purgation jurisdiction, with the breach thereof constituting criminal contempt of court and thus enforceable as such. Hence, the Permanent Chamber is an attractive option for commercial parties primarily seeking the enforcement of any orders resulting from their dispute within Purgatio as opposed to any foreign jurisdiction (for which neutral commercial arbitration would be more appropriate) and wishing for more robust enforcement avenues over the dispute-settlement process as compared to that available to an arbitral tribunal, whilst still being desirous of the flexibility, finality, and autonomy present in the arbitral context but absent from traditional commercial litigation before specialised commercial courts, thereby representing an intermediate option between traditional litigation and commercial arbitration, with the Permanent Chamber receiving approximately between 4-5,000 cases every year.

Finally, the last category of adjudicatory bodies within the Unified Judicature of the Purgation State to be considered and discussed are administrative tribunals which differ from courts of law in two major respects - first, they consist of tribunal judges appointed not by the Ministry of Justice's Judicial Service Council or the Magnificus Dominus acting under the advice and recommendation of the Judicial Appointments Commission (consisting of senior members of the Purgation Bar and Purgation Judiciary), but are appointed by individual governmental departments and ministries with charge and responsibility over the tribunal in question (for example, the Administrative Justice Committee of the Home Office makes appointments of tribunal judges to the Migration and Visas Tribunal); and second, administrative tribunal judges are often not legally-trained (at least not primarily) but are more likely to possess specialised administrative or policy-making expertise in highly niche areas of administrative law involving questions which are often highly dependent upon factual rather than legal determinations (for example, tribunal judges on the Labour Tribunal are generally much more likely to have expertise on matters pertaining to collective bargaining and industrial relations and thereby more capable of rendering rulings on highly-specialised questions of mixed fact and law relating to breaches of the 'quadripartite industrial negotiations' framework between the Ministry of Commerce and International Trade, Department of Labour Relations, L'Association Nationale des Travailleurs (ANT), and La Chambre de Commerce et d'Industrie (CCI)). The most prominent example of administrative tribunals exercising a quasi-judicial adjudicatory function whilst possessing such distinctive features which differentiate the system of 'administrative justice' from the so-called 'ordinary justice system' is, of course, the TECON-TECAT tribunal system, established in Executive Order (EO) No. 26 of 2011 or the "Special Tribunals Establishment Ordinance", promulgated by the Magnificus Dominus on 8 February 2011, which plays such a prominent role within the Purgation State that it will receive its own independent consideration in a separate sub-section.

As for the remainder of the so-called 'administrative justice system', however, it suffices to note here that administrative tribunals generally fall into two categories within the judicial hierarchy of the Unified Judicature. First, the overwhelming majority of tribunals are 'first-tier tribunals' which are administrative tribunals created by specific statutes and regulated and supervised by a responsible governmental ministry or department, charged with adjudicating policy-related disputes arising out of policy or regulatory decisions made by responsible organs or bodies acting under that same legislation or subsidiary legislation enacted thereunder. To provide a concrete example of such a scenario, the Taxation Tribunals adjudicate upon tax-related disputes and were established by way of PNC legislation in the Revenues Acts of 1979 and 1982, with the specific procedural rules of the tribunals being laid down by subsidiary legislation promulgated by various Secretaries of State of the Civil Treasury's Chambers (now known as the Royal Treasury's Chambers, helmed by the Secretary of State Charlotte de Laval). Hence, where the Royal Treasury's Chambers makes a determination in respect of a particular taxpayer, such as the denial of a requested tax deduction in relation to a specific tax assessment exercise, that taxpayer has a right to submit their dispute before the Taxation Tribunals to determine the issue in the first-instance. Tribunal judges on the Taxation Tribunals are generally chosen by the Tribunals Appointments Committee, which is an internal committee under the responsibility and supervision of the Royal Treasury's Chambers. Such a system has raised justifiable concerns over the alleged independence and impartiality of the administrative tribunals system, which pre-dated even the rise of the PNL one-party regime in the present day. In theory, however, certain institutional safeguards are in place which are, theoretically, intended to safeguard against executive interference in the administrative tribunal system. For example, the Tribunals Appointments Committee is generally staffed not by regular employees or policy officers of the Royal Treasury's Chambers, but outside experienced industry experts within the external taxation industry, including tax accountants, tax advisers, and tax lawyers. Generally speaking, decisions respecting the remuneration, promotion, and dismissal of tribunal judges are made by such appointments commissions or appointing committees within governmental ministries, helmed by external industry experts, and are not made by the Secretary of State of that department or influenced by the policy-making wishes or desires of other committees or organs within that same ministry or the regular civil servants thereof, although technically speaking, tribunal judges are still employees of the ministry in question and are paid out of the prevailing budget of that governmental department.

These considerations form the relevant background behind the enactment of the Tribunals Regulation and Administrative Justice Act 2013 ("TRAJA 2013") by the PNC, which received the assenting signature of the Magnificus Dominus on 17 November 2013. TRAJA 2013 established the Appellate Body of the Upper-Tier Tribunal, a standing permanent tribunal body whose sole purpose was to hear appeals on the merits from the various first-tier tribunals on points of law and fact alike. Prior to the enactment of TRAJA 2013, first-tier tribunals were treated as administrative bodies and challenges to decisions rendered by such bodies were a question of administrative law, with an aggrieved applicant filing an application for the judicial review of the tribunal's decision before the Executive Prerogatives Division (EPD) of the Court of First Instance (CFI), the same as any other application for judicial review under ordinary administrative or constitutional law, seeking a prerogative order for the quashing or cancellation of the tribunal's decision, as an administrative or executive act, on the usual grounds of review such as illegality or unlawfulness for legal error, manifest substantive unreasonableness, or procedural unfairness and injustice. The primary innovation of TRAJA 2013 was to create a standing permanent tribunal body the speciality of which would be hearing appeals against decisions of the first-tier tribunals and on the legal and factual merits thereof, in much the same way as the Royal Court of Justice would hear such appeals from the Courts of Seizures, Courts of Partitions, and/or Courts of Family Affairs, or the Court of First Instance would hear appeals from the Royal Court of Justice or Courts of Mercantile Transactions, or the Court of Final Appeals would hear appeals from the Court of First Instance. This standing Appellate Body, consisting of ~100 judicial officers of high esteem and regard (many are drawn from the senior leadership of the Court of First Instance and others are experienced members of the Purgation Bar, being appointed in the same fashion as CFI judges, namely, with the Magnificus Dominus issuing an instrument of appointment acting on the advice and recommendation of the Judicial Appointments Commission), would exercise an appellate rather than supervisory jurisdiction over decisions rendered by first-tier administrative tribunals, hearing appeals against such lower-tier judgments on the same ordinary grounds of appeal to a higher court against a lower court decision (i.e., legal error, manifest factual error, fundamental procedural error, abuse of discretion, etc.), with a further right of appeal being provided under TRAJA 2013, not to the Court of First Instance (CFI), but to the Court of Final Appeals (CFA) instead. Similar to other appeals to the CFA from the CFI, any appeals from the rulings of the Appellate Body may only be lodged with prior leave and permission of the CFA, hence the would-be appellant would first have to file a 'leave to appeal' application to the CFA, with written submissions persuading the CFA that the proposed appeal would raise a meritorious ground of appeal with a realistic prospect of success, and only after such leave is granted may the appeal then be litigated on the merits proper.

Finally, the Supreme Court of Cassation of Purgatio, as the highest court of the land, vested with ultimate Judicial Power, has the right to pronounce and declare the correct interpretation of any legal norm or principle, in any dispute which is brought before the court, with binding effect upon the entire Purgation legal jurisdiction. Certainly, the Supreme Court cannot make such pronouncements on its own initiative, and may only make such binding declarations of law in the context of a live legal dispute or controversy that is brought before its forum by an actual litigant or disputant. However, the Supreme Court is also not obligated to accept such disputes, since a power to pronounce upon the law (as was understood under Art 31(1) of the old written constitution of Purgatio) is certainly not a mandatory obligation to do so. Hence, where there is no further right of appeal that is available against a ruling or judgment rendered by a court, the aggrieved losing party may file a 'petition for cassation' to the Supreme Court, for the Supreme Court to deliberate upon and to either accept or reject. If accepted, the losing party, known as the 'petitioner', may make either written or oral submissions seeking to persuade the court to grant the petition presented, which will request the relief of a 'cassation order', which is an order that quashes, nullifies, or otherwise cancels and invalidates the decision that is petitioned against, with the winning party, known as the 'respondent', seeking to resist the grant of that same petition. It is entirely up to the discretion of the Supreme Court as to which petitions it accepts and decides to hear. On average, every year, the Supreme Court receives anywhere between 27,000 to 31,000 'petitions for cassation', with the mean average 'acceptance rate' hovering at around just 2-3%. Hence, in a typical year, the Supreme Court will hear anywhere between just under 540 judgments on the low end to slightly over 930 judgments on the high end, with the vast majority of petitions being rejected, meaning that the decision below is allowed to stand but without a Supreme Court judgment with precedential value. It should be added, for completeness, that under the Supreme Court's practice directions, such petitions can only be presented against a decision of a court or tribunal where no further relief or recourse against that judgment is otherwise available. For example, an aggrieved petitioner could not file a 'petition for cassation' against a ruling of the Appellate Body of the Upper-Tier Tribunal since a statutory right of appeal is provided to the Court of Final Appeals (CFA) which the petitioner has yet to exhaust. Hence, the petition is said to be inadmissible or irrecevable, not due to any substantive defect in the petition itself, but because it is being presented at a premature procedural stage, before the petitioner has exhausted an available remedy.

Since the Purgation legal jurisdiction is a unitary as opposed to federal jurisdiction, this same rule determining the admissibility or recevabilité of any cases presented before the Supreme Court applies also to 'petitions for cassation' that are presented against court or tribunal decisions within the seven Occupied Territories or Zones de Contrôle occupied by the PAF military since the close of the First Cleansing War of 2000-2002 and Second Cleansing War of 2006-2009. Prior to the PAF military occupation, these individual Occupied Territories had their own first-instance courts, intermediate appellate courts, and 'courts of last resort' or 'courts of final instance' from which no further appeal, review, or reconsideration was available to the losing party in their national jurisdictions, and these provincial judicial structures and hierarchies were left largely undisturbed following the beginning of the PAF military occupation of these territories. Hence, it follows that a 'petition for cassation' can be presented to the Supreme Court of Cassation of Purgatio but only against a decision of the 'courts of last resort' or 'courts of final instance' of the Occupied Territories, before which that petition is deemed to be inadmissible or irrecevable until all municipal remedies are exhausted within the legal jurisdictions of the Occupied Territories. It should also be noted for completeness, and as a practical matter, that due to the maturity of the formerly sovereign and independent jurisdictions of the Occupied Territories, the Supreme Court very rarely ever grants leave for 'petitions for cassation' to be heard where they are presented against the decisions of the apex courts of the seven Zones de Contrôle, hence such petitions are hardly ever presented by litigants in practice. Generally speaking, slightly over half of 'petitions for cassation' (around 50-55%) presented to the Supreme Court are petitions seeking the cassation (i.e., 'annulment') of the judgments of the Court of Final Appeal (CFA), in the exercise of its appellate jurisdiction, with the remaining petitions generally being statutory 'petitions for review' presented against appellate decisions rendered by the standing TECAT appellate body in Limogens, although in practice the Supreme Court rarely ever grants leave for 'petitions for review' to be heard against TECAT decisions due to the limited statutory grounds of review available and the comparative expertise and familiarity of the TECAT appellate body with the specialised subject-matter of such decisions (i.e., genetic re-classification decisions), thus the Supreme Court will generally only certify and hear 'petitions for review' against a TECAT decision where it touches upon a novel question of law or one of particular public importance meriting further consideration from the highest and most senior court of the land. Hence, the overwhelming majority of petitions actually heard by the Supreme Court in an average year (over 99% in fact) are petitions for the cassation of a CFA judgment as opposed to that of any other judicial body or organ.

Right below the Supreme Court in the judicial hierarchy of the Unified Judicature of the Purgation State is the Court of Final Appeals (CFA) (so-called because there is technically no 'right of appeal' from the CFA to any other court, since applications before the Supreme Court are termed 'petitions for cassation' instead and are hence not appeals per se), the case-load of which overwhelmingly consists of hearing appeals from decisions rendered by the Court of First Instance (CFI), whether in its original or appellate jurisdiction. The CFA has a 'sieving mechanism' for its appeals, similar to that of the Supreme Court in practice. Essentially, all appeals to the CFA, civil or criminal, may only be instituted with leave of a sitting Justice of Appeal of the CFA, which requires the desired appellant to present a written application requesting permission to appeal the decision below, stating the grounds of appeal and the reasons why the said grounds are meritorious and raise questions of fact, law, or procedure deserving of additional consideration. The CFA will not grant permission to appeal unless it is satisfied that the appeal is a meritorious appeal and stands a reasonable chance of satisfying the applicable standard of appeal, which in turn depends on the matter being appealed against and the grounds of appeal that are pleaded (if it is an alleged error of law, the CFA reviews it on a de novo correctness basis; if it is an alleged error of fact, the CFA reviews it by asking whether no reasonable fact-finder could ever have arrived at the factual finding that is appealed against because it was manifestly erroneous, plainly and unreasonably wrong, or otherwise palpably against the weight of the evidence below; if it is an alleged error of procedure, the CFA reviews whether the error constituted a fundamental breach of procedure which substantially deprived the appellant of a fair hearing or proper determination of its case; if it is an alleged error of discretion, the CFA reviews whether an abuse of discretion has been occasioned such that the discretionary power was exercised irrationally, unreasonably, on erroneous principles, or constituted a mistaken exercise of judgment clearly and palpably against the logic and effect of the case). Generally speaking, leave to appeal is more likely to be granted when the application for leave discloses an alleged error of law as opposed to an alleged error of fact, procedure, or exercise of discretion, given the lower standard of review applied to the review of pure questions of law. However, all types of appeals would be heard by the CFA provided that the Justice of Appeal hearing the application is satisfied that the proposed appeal is not hopeless or meritless or a bare unsubstantiated assertion that the decision below was wrong with little real prospect of success. Every year, on average, the CFA receives around 190-205,000 applications for leave to appeal, with nearly all such applications (just over 87%) being filed against decisions of the CFI, with the remainder generally being filed against decisions of the Appellate Body of the Upper-Tier Tribunal (although there is a statutory right to seek an 'annulment' of Permanent Chamber judgments by the CFA, such applications are very rare and none have been granted to date since the statutory grounds for annulment are very narrowly circumscribed in order to preserve the institutional independence and relative autonomy of the Permanent Chamber from the remainder of the Purgation Judiciary). The 'application for leave' process is much faster and cheaper than a full appellate hearing on the merits of the appeal, involving written submissions from the applicant and respondent followed by a decision rendered by a single Justice of Appeal, with brief written grounds accompanying the grant or denial of leave, often disposing of the application within months of it being filed, unlike a substantive hearing on the merits of the appeal which is typically heard in open court and involves many more hearings and far lengthier and more extensive submissions from counsel and examinations of the appellate record of the trial below which can often drag on for a year or more. Slightly fewer than 10% of such applications for leave to appeal (approximately 9-10%) are generally granted by a Justice of Appeal in an ordinary year. In theory, an aggrieved application for leave could file a 'petition for cassation' to the Supreme Court to overturn the Justice of Appeal's rejection of leave to appeal, but this is rarely done in practice because the Supreme Court has never granted such a petition to date. Hence, the Criminal Division of the CFA generally hears around 5-7,000 criminal appeals in an average year while the Civil Division of the CFA usually hears approximately 12-14,000 civil appeals.

The power of the senior appellate courts of law, especially that of the CFA and the Supreme Court, to shape the course of legal developments and innovations within the Purgation legal jurisdiction is best understood within the context of the Purgation State's 'common law interpretivist' system of jurisprudence. In essence, the common law model operates based on a fundamental principle of stare decisis, which places paramount importance upon the role of judicial precedent to shape a corpus of judge-made or judicially developed rules or norms, which are binding upon lower courts and influence the incremental development and evolution of future cases engaging similar rules and principles. Within the context of the judicial hierarchy of the Unified Judicature, stare decisis means simply that upper court decisions are binding upon lower courts which must apply those decisions in the determination of their own cases, without any discretion whatsoever to depart from superior judicial determinations. Moreover, decisions determined by the courts of the same tier of the judicial hierarchy are also considered legally binding on all courts within that tier, and should also be applied in future cases; however, a residuary discretion exists to depart from past cases, if necessary. In the interest of preserving certainty and predictability in the contents of Purgation law and prescribed legal relations and positions, however, such departure is only justified if compelling reasons are provided to persuade the court of the necessity of departing from prior case law, which can involve showing the court that prior cases have begun to contradict another line of cases which has since developed, resulting in conceptually inconsistent or contradictory outcomes, or that a prior line of cases was decided on the basis of older socio-economic conditions which have become anachronistic in the present day, or was founded upon false or mistaken assumptions of fact or law. For this reason, courts generally avoid outright contradicting or overturning a prior decision which is binding upon it under the common law principle of stare decisis, instead preferring alternatives such as distinguishing a past line of cases, limiting the scope of application of such cases through a very narrow interpretation of earlier case law, or explaining why prior cases may be regarded as wholly inapplicable to the facts of a present dispute because the current dispute contains unique factual and legal elements which could not be considered or taken into account in prior cases for whatever reason, in order to avoid having to undermine the legitimacy of judicial precedent by directly overturning prior law and disturbing the development of a jurisprudence constante through the gradual evolution and incremental development of the norms and principles of common law authorities over time. As such, the Supreme Court has an immense influence to shape the present state of the law in the Purgation jurisdiction as well as set the normative terms and overriding principles of law which the remainder of the Unified Judicature must follow, without exception, as well as develop a corpus of binding common law authorities to form a cohesive jurisprudence constante which may then go on to have a significant impact in shaping the course of subsequent legal developments undertaken by future Supreme Courts as well, under the principle of stare decisis.

[Purgatio]

Likewise, following the principle of stare decisis, and having regard to the different tiers of the judicial hierarchy of the Unified Judicature, judgments of the Court of Final Appeals (CFA) are binding upon all other courts within the Purgation legal jurisdiction save only for the Supreme Court (which can overturn CFA decisions), the TECAT appellate body (which hears appeals from TECON tribunal decisions and against which a 'petition of review' may then be filed to the Supreme Court, with the CFI and CFA being statutorily prohibited from exercising any supervisory or appellate jurisdiction over TECAT decisions), and the Permanent Chamber (for which a limited right to seek annulment of a Permanent Chamber decision before the CFA is provided for statutorily but on very limited and narrow grounds only, thereby excluding a power to review the merits of such decisions), and will also be pro tanto and presumptively binding upon future CFA corams as well, unless a particularly compelling reason is provided in a future CFA judgment for departing from or disregarding the rules and principles in a prior CFA decision. Likewise, judgments of the Court of First Instance (CFI) will only be binding upon the Royal Court of Justice, the Courts of Mercantile Transactions, the Courts of Family Affairs, the Courts of Partitions, and the Courts of Seizures. CFI decisions will not be binding upon courts of equal standing as the CFI, such as the Permanent Chamber, the Appellate Body of the Upper-Tier Tribunal, and TECON tribunals in rendering their genetic re-classification decisions, although they may certainly take account or notice of CFI decisions which are legally or factually relevant, but only as persuasive authority alone.

In the interest of developing a useful jurisprudence constante and a harmonious body of common law rules, principles, and interpretations which can constitute a corpus of coherent 'case law' all on their own, creating a set of cognisable, certain, and predictable rights and norms which can serve to guide and structure the future outcomes of the Purgation legal jurisdiction and shape subjects' legal relations across the Purgation State, the superior ordinary courts of law (i.e., the Supreme Court, the Court of Final Appeals, and the Court of First Instance) have, for more than a century (ever since the first Supreme Court was constitutionally established in 1835), generally followed a method of legal interpretation which may be referred to as 'common law interpretivism'. In essence, 'interpretivism' is a jurisprudential philosophy which treats the act of legal construction as an objective method of logical analysis from which the one objectively correct and accurate interpretative answer to any legal problem presented can, always and without exception, be rationally deciphered and divined as a matter of principle alone. The effect of this 'interpretivist' philosophy was that the Supreme Court in particular has generally treated the entirety of the Purgation State's preceding legal history - from the past halcyon days of the absolute monarchy, to the more modernist republican era, all the way to the reactionary fascism of the present day - as one singular continuous unending ongoing 'legal canvass' which is consistently evolving and producing new 'legal data' every day, which stands to be interpreted in a coherent and harmonious manner as if it were one integral and cohesive patchwork of legal norms and principles. The 'interpretivist' philosophy is based on a legal fiction that treats all preceding and successive governments, courts, and authorities within the Purgation State as pronouncing norms and promulgating rules on the behalf of a singular juridical entity - the Purgation State - creating a cohesive constitutional order, the fundamental norms and principles of which now stand to be interpreted in a 'best fit' fashion, divining and deciphering the undergirding rules and animating principles which may best justify the existence of past legal outcomes, as far as possible, whilst discarding the legal data which cannot be reconciled with the 'best fit' analysis of the Purgation legal jurisdiction's history and tradition, to form a coherent 'legal or juristic tapestry' of past legal acts that can be harmoniously interpreted and construed with each other to form a foundational bedrock of justificatory principles capable of being construed and applied to future legal dilemmas appearing before the courts.

Two fundamental consequences resulted from this system of common law interpretivism, wedded to notions of stare decisis, the development of a gradually evolving jurisprudence constante, and a desire to invoke the history and tradition of the entire past jurisprudential chronicle or juristic archive of the Purgation State's cumulative legal acts to develop a 'best fit' interpretation of the justificatory narrative of the Purgation State's legal jurisdiction, which would carry binding legal force in the present day - first, the Unified Judicature of the Purgation State, and in particular, the Supreme Court, functionally operated as a conservative, traditionalist, and often downright reactionary force within the Purgation State even during its liberal republican era, serving as a critical check upon the populist, modernising, liberalising impulses of more democratic forces of the constitutional order (such as the President, Prime Minister, Premier of the Purgation National Congress, etc.), effectively preserving authoritarian, draconian, and feudalistic socio-cultural norms and socially conservative values even as the country democratised and modernised in a comparatively egalitarian age; and, second, the Supreme Court became a much more powerful de facto law-making institution as compared to other democratic and de jure law-making forces within the Republic of Purgatio, wielding significantly weightier and far more long-lasting influence over the laws of Purgation State than even the PNC, Prime Minister, President, Premier, or provincial legislatures, due to the binding precedential power accorded to Supreme Court judgments which, under the principle of stare decisis, were normatively binding upon the entirety of the Unified Judicature of the Purgation State, coupled with the fact that the Supreme Court was not paralysed by the same constitutional and democratic checks which rendered other organs of government comparatively ineffectual, immobilised, and incapacitated from being able to either form competing legal norms of their own or directly challenge and negate the vast norm-creating powers of the Supreme Court, which consequentially went entirely unregulated by such democratic forces as a result. This is crucial because the rise of Purgation fascism in the 1980s and the downfall of liberal democracy often cannot be understood without appreciating the traditionalist and reactionary political force that was the Supreme Court of Cassation of Purgatio, and the seminal role the Supreme Court played in both delegitimising the very republican constitutional order which constituted it in 1835 whilst spawning and cultivating the fascistic, reactionary, and counter-revolutionary social forces which would culminate in the PNL movement and eventually bring down and destroy Purgation liberal democracy altogether - all with the judicial fiat and approving imprimatur of the Republic of Purgatio's highest court laying down the highest laws of the land.

First, the Supreme Court's reactionary role in politics is, in large part, attributable to the profile of judicial officers who entered into the Purgation Judiciary. In 1835, when the Purgation State's first-ever written constitution was codified and promulgated by the liberal revolutionaries, the Purgation legal profession was a highly feudalised and cartelised profession, dominated by a small elite strata of wealthy families drawn disproportionately from the former ruling classes of pre-revolutionary Purgatio, particularly the feudal nobility and landowning gentry classes whose loyalties and sympathies remained wedded to the former Purgation absolute monarchy which had been overthrown. To uproot and overturn the entire existing structural framework of the Purgation legal system and train her entire legal profession from scratch would have been costly, difficult, and disruptive, so instead the revolutionary government elided that Herculean feat and consequently left the overall form and structure of the then-prevailing Purgation legal system intact, which included the closed and exclusionary Inns of Court which controlled admission into the Purgation Bar and, at the same time, was largely determined by age-old aristocratic familial connections instead of merit, a feudal guild system of apprenticeships, journeymen, and guildmasters which likewise privileged students from more prestigious law schools such as that of the University of Savoy-Ducasse and the University of Pétrus (admission into which was largely determined by family connections, the prestige of one's high school, and one's parental alumni status) the law graduates of which often disproportionately dominated the most attractive legal apprenticeships that were available in the industry at that time, coupled with a judiciary that was likewise disproportionately drawn from these Purgation barristers who were the most experienced members of the Purgation Bar, having the legal experience and expertise to perform such judicial work. The result was that, even after the Purgation Revolution, the Purgation legal industry of the 19^th Century remained highly dominated by the counter-revolutionary or reactionary social classes of society - the former aristocracy, the large landowning gentry, and members of the haute bourgeoisie which had assimilated into the traditionalist socio-cultural milieu of such prestigious ennobled circles - having the social and cultural capital to blend seamlessly into and navigate the exclusionary and cartelised world that was the Purgation Bar, entering the best law schools, having the connections to snag the best apprenticeships and gain admission into the closed Inns of Court, and then garnering the necessary experience in the industry to have the credentials to then enter the Purgation Judiciary thereafter. This trend was only exacerbated by the fact that practically every experienced judicial officer in the Purgation State at the time had garnered that judicial experience as a judge of the Purgation feudal monarchy that had been overthrown, oftentimes as judges serving on the royalist Crown Chamber of Valois or the security tribunals of the Sacred Order of St. Troyes (SOST), doling out harsh sentences against dissident critics of the Valois monarchy for such offences as sédition, scandale, l'obscénité, and lèse-majesté, or aristocratic magistrates upholding the feudal order in the provincial countryside by serving on local 'holy councils of inquisition', punishing and persecuting critics of the Catholic Church and local aristocracy for vice, blasphemy, and irreverence. Such persons were, however, also the individuals with the greatest amount of experience and familiarity with the day-to-day running of a judicial system and the practical ins-and-outs of shaping the niceties of practical legal and civil procedure. Perhaps in the interest of avoiding the mammoth struggle of building up a brand-new legal and judicial system entirely from scratch without the assistance and expertise of the persons with the practical technical knowledge and intricate know-how to accomplish that task, the revolutionary government took the comparatively easier route of simply keeping the Purgation legal and judicial professions as they were, dominated as they were by members of such feudal, royalist, and aristocratic social classes, perhaps content with the notion that such barristers and judicial officers would, in any event, have to apply and enforce brand new laws, the normative contents of which would be determined not by local feudal lords or an absolutist king, but by popularly elected democratic institutions, and that these would be modernist and progressive laws far different from the feudal and traditionalist laws that had existed in the pre-revolutionary Purgation State.

If that had been the expectation of the revolutionaries at the time, the reality of what would emerge would look very different. Based on the notion of 'common law interpretivism', the feudally-dominated Purgation Judiciary developed an 'interpretivist' philosophy which provided justification for using the legal acts and judicial determinations of pre-revolutionary Purgation institutions as binding precedent to guide and shape the common law of the post-revolutionary Republic of Purgatio, with the rationale being that according such precedential weight to these past judicial decisions would help to preserve the integrity and predictability of subjects' legal relations, safeguard the legitimate expectations of individuals, draw on the weight of the jurisdiction's collective and cumulative experience, and promote the incremental development and evolution of binding jurisprudence that would properly supplement the contents of the law to fill gaps and lacunae and minimise interpretative uncertainty in the process. For the most part, this process appeared benign enough in the vast majority of cases. Aspects of the legal system of late stage feudalism helped to inform the contents of early stage mercantile and industrial capitalism in many situations, with the Purgation Judiciary often drawing clear analogies between, or reasoning by way of logical extension from, the stipulatio serfdom contracts signed between feudal lords and landless peasants to develop the common law of contracts, using the contents of feudal banalités tenurial rights of landowners to develop rights relating to real property and cognisable numerus clausus interests over land, drawing on notions of usufructs and sub-usufructs to develop more sophisticated notions of trusts law and the separation of legal and beneficial ownership interests in property, relying on the infeudation and sub-infeudation of superior and inferior feudal estates in land to develop common law real property concepts of leasehold estates and superior reversion expectant interests, citing principles of l'infamie to help develop aspects of the copyright droit moral rights of authors, and even using older torts and civil delicts developed for the purposes of protecting concepts of honour and dignity essential to maintaining the feudal social hierarchy between peasants and nobles and the social distinctions thereof to develop the contents of a whole range of common law dignitary torts, like drawing on the delict of dérogeance to develop the tort of passing-off, using the delict of scandale to develop the tort of l'outrage (often referred to as scandales à la dignité for that reason), and even drawing on civil aspects of the law of sédition and blasphème, especially the older legal concepts of 'seditious libel' and 'blasphemous slander', to develop the contents and contours of the modern reputational torts of slander and libel.

However, other aspects of this developmental and incremental process of 'common law interpretivism' had far less benign results and, altogether, had the overall effect of establishing the Purgation Judiciary as a highly traditionalist, conservative, and downright reactionary political force in a post-revolutionary Purgation State that was increasingly attempting to democratise and modernise, thereby wielding the power of the judicial imprimatur to preserve traditionalist feudalistic and hierarchical values in an ostensibly liberal egalitarian or republican state. Viewing the Purgation State as a singular coherent jurisdiction, consisting of one harmonious 'common law' which could be coherently interpreted to divine consistent principles running throughout its legal history effectively meant that highly conservative judgments rendered by the authoritarian and monarchist Crown Chamber of Valois (and sometimes even decisions rendered by individual feudal inquisitorial councils or the infamous closed-door security tribunal hearings of the monarchist SOST secret police force) were often cited as authoritative precedents by a Purgation Judiciary operating and existing in a post-monarchist, post-revolutionary Purgation State, based on a 'law as integrity' philosophy of 'interpretivism' which conceived of the role of a judicial officer as divining and deciphering the collective meaning of the Purgation State's entire legal and jurisdictional history, which for centuries had been a jurisdiction whose entire raison d'être had been the preservation of feudal hierarchical norms and the despotic unchecked absolutist power of feudal lords and their divine rulerships over the fiefdoms and domains (and the people thereon) which were theirs by right to dominate and control. The consequence of this 'interpretivist' approach to adjudication and judicial determination was the perpetration of both politically corrosive and socially damaging effects on the viability of the Purgation State's republican constitutional order, entrenching the role of an increasingly powerful Purgation Judiciary - especially the Supreme Court - the judgments and decisions of which were often actively hostile against, and antagonistic towards, democracy, liberty, and egalitarianism.

Second, in addition to the demographic profile of the Purgation Judiciary (dominated by feudalistic, aristocratic, and other traditionalist counter-revolutionary segments of Purgation society) and the judicial and legal philosophy of 'interpretivism' which provided justification for the judiciary's invocation of monarchist precedents to develop and shape the contents of even post-revolutionary common law, there were other structural reasons explaining how the Purgation Judiciary obtained this effective carte blanche to develop the laws of the Purgation State virtually unchecked by any other constitutional force or organ. In theory, the Purgation Judiciary was only one branch of government and its powers were checked by a constitutional framework that contemplated a 'separation of powers' mechanism with power being divided between the elected Legislature (PNC), the elected head of state (President), the elected executive branch (Prime Minister and his Cabinet), various administrative bodies and organs under their charge and supervision, and of course, the Purgation Judiciary. In fact, conceptually speaking, the Purgation Judiciary was, at least in theory, supposedly subordinated to the interests of the other organs of power, particularly that of the PNC and the President, which together held the ultimate Legislative Power in the entire Purgation State (as in Article 26(1) of the written constitution), having the power to make and unmake the ultimate and highest laws of the land, ranking in priority and taking precedence over every single other legal norm or rule throughout the Purgation legal juridsiction as a whole (save only for the written constitution itself, which could also be amended by the PNC and President acting together), by passing PNC Congressional legislation to be promulgated into law by the President's assenting signature (as in Articles 26(2)-(5) of the written constitution), whereas the Purgation Judiciary 'only' had the power to interpret and apply such laws, with the Supreme Court being vested with ultimate Judicial Power in Article 31(1) as opposed to ultimate Legislative Power in Article 26(1), and hence, to the extent that the courts ever 'made' new law in a very limited sense (such as by creating and/or discovering common law principles or rules), these fresh norms always ranked inferior to the higher norms found in primary legislation passed by the PNC (acting together with the President), which would certainly override any judge-made common law rules in the event of any conflict therewith. In theory, therefore, the constitutional framework erected by the Purgation revolutionaries made the judicial branch of government subordinate to the power and authority of the elected Legislature (PNC) acting together with the elected head of state (President), especially as, under Article 30(4), all Justices on the Supreme Court were appointed by the elected President, after being nominated by the Prime Minister, followed by the majority ratification of Congressional legislators, which only further cemented the theoretically subordinated role of the Supreme Court compared to other organs of power such as Congress and the Presidency.

Given that constitutional framework, how did the Purgation Judiciary end up becoming the most powerful de facto legislative or law-making force in the Purgation jurisdiction, wielding greater influence over the norms and rules of the Purgation State than even that of the Legislature and the President? Ironically, the answer lies in the reality of the constitutional separation of powers framework. It is one of the greatest ironies of Purgation history that a principle intended to check and limit the power of, inter alia, the Purgation Judiciary ended up being the very principle that allowed the Purgation Judiciary to become the most dominant and powerful political force in the Purgation State, because the effect of the separation of powers framework of the Purgation State's written constitution is that all democratic and elected bodies in the country were paralysed and left unable to govern effectively, leaving the law-making acts of the Purgation Judiciary virtually unchecked and untouched by any other legislative or political force in the country. For most of the Purgation State's history, political pluralism meant that the PNC was rarely ever controlled by any one political party, with the largest political party often commanding weak legislative majorities or even no majority at all, relying upon minority governments or coalition governments to function. Moreover, it was often the case that the elected President hailed from a different political party than the largest party in the PNC, and since laws could only be passed by the PNC voting a piece of legislation into law, followed by the President appending his assenting signature to the law, the politically divided nature of these elected institutions meant that it was often very difficult to pass legislation. The result was that the Purgation Judiciary was left with free reign to develop the normative contents of the Purgation legal jurisdiction through 'common law interpretivism', safe in the knowledge that while the 'President-in-Congress' could, in theory, override any of their judgments or decisions if they desired to, political gridlock and constitutionally igrained deadlock would all but guarantee that that would basically never happen, giving the Purgation Judiciary free reign and carte blanche to make and unmake the common law of the Purgation State howsoever they pleased. The worst consequence that the Purgation Judiciary could expect to fear from its more controversial decisions was, at the very most, a stern public reprimand from the Prime Minister or the President, if a judgment that was politically unpopular with the masses ever came to be pronounced by them, but with little practical legislative action to ever back up any such strong words.

This combination of interpretative freedom and institutional breadth of action was wielded and exploited by the Purgation Judiciary to maximum effect to undermine the more politically pluralistic, liberal, egalitarian, or populist elements of the new republican constitutional order, in the interest of preserving the traditionalist, reactionary, counter-revolutionary values of the Purgation State's absolute monarchist era, a process of jurisprudential conservatism which reached its apogee in the decades preceding the fall of liberal democracy and the rise of the fascistic PNL regime, and arguably paving the way for the fascistic takeover of the constitutional organs of the Purgation State. The most common manifestation of such judicial conservatism was in manipulating the malleable provisions of the common law and the prevailing jurisprudence constante to actively repress the political left whilst simultaneously providing cover for, and practical legal immunity and impunity to, equivalent actions of the political right, especially that of the reactionary far right. In conjunction with the efforts of an equally feudalistic and reactionary police force (whose membership was disproportionately composed of former feudal vassals and members of knightly chivalric orders and inquisitorial bailiffs and enforcers of the 19^th Century in the immediate aftermath of the Purgation Revolution) and federal prosecutorial service (likewise drawn from the same Purgation Bar as the judiciary and thereby composed largely of members of the pro-monarchist anti-democratic nobility, gentry, and aristocratic social classes), the Purgation Judiciary provided carte blanche for the active political repression of the actions of leftist, socialistic, and even socially democratic political movements, stifling protests, smothering demonstrations, endorsing the persecution of such civil society organisations, by creating broadly worded common law offences of public nuisance, public disorder, and breaches of the peace, drawing upon equivalent concepts in the monarchical era of the Purgation State and citing judgments of the Crown Chamber of Valois (CCV) on such broadly worded political crimes as sédition, lèse-majesté, l'obscénité, and l'infamie, which in the past had been used by the monarchist CCV judges to persecute anti-monarchist political activities, as precedential authority to justify the equivalent persecution of nascent left-wing political movements on the grounds of protecting the 'integrity of the socio-political constitutional order' and as a 'prophylactic to safeguard the peace, order, and social harmony and good governance of the sovereign structure of the Republic', adopting analogous language to that which the CCV used to justify the recognition of common law 'offences against the integrity of the Crown'. Civil society groups fighting for stigmatised or marginalised segments of society, including and especially human rights organisations advocating for nomadic traveller communities, vagabonds, homeless people, convicted criminals, juvenile delinquents, welfare recipients, and irregular migrants, were particularly targeted for harassment, whilst receiving the seal of approval of the Purgation Judiciary whenever enforcement action was undertaken against such groups by police or prosecutorial forces or whenever such organisations attempted to lodge legal challenges against such acts which always met predictable failure before the conservative and reactionary Purgation Judiciary.

In stark contrast, however, the Purgation Judiciary bore a significantly more permissive and tolerant attitude to the disorderly and disruptive conduct of the Purgation far right, even where such political activities were violent and outright illegal or even terroristic in character. This outcome was achieved through judicial creativity and innovative reasoning, through a number of techniques. First, the Supreme Court in particular took advantage of very broadly worded 'fundamental human rights' provisions in Articles 3-22 of the written constitution to provide selective protection to the political activities of the reactionary far right, while refusing comparative protections to similar political activities of the political left and the organised activities and campaigns of left-wing or socially democratic organisations, civil society activists, and trade unionist organisers, and sometimes even using human rights provisions to justify the political repression and persecution of such organisations. The broadly worded nature of the Republic of Purgatio's human rights provisions had been intended by the liberal revolutionaries to provide robust protections for certain individual rights, particularly political freedoms touching upon ideals of public democratic participation (such as freedoms of conscience, speech, expression, association, and assembly), yet the broadly worded nature of such provisions also accorded much wiggle-room and flexibility for interpretative malleability, enabling the Purgation Judiciary, especially the Supreme Court, to apply these constitutional provisions selectively to justify the persecution of leftist activists by non-State paramilitary organisations (like the fascistic volontaires auxiliaires) or even by State institutions like the federal prosecutorial and national policing forces while simultaneously protecting the political activities of far-right reactionary organisations such as the PNL or the volontaires auxiliaires.

Thus, when it came to attempts by the government to suppress the political activities of the growing Purgation far right reactionary political movement (such as the PNL) in the 1970s and 1980s, the Purgation Judiciary's construction of fundamental rights provisions was broad and protective in its approach. For example, when the PDP minority government and its Ministry of Media Affairs and Cultural Developments utilised powers under the 1971 Law on Hateful Publications and Communications Inciting Discrimination to issue a 1979 ministerial order prohibiting Geneviève Aumont from publishing and distributing her famous political treatise La Solution Finale au Problème de la Classe Génétiquement Dysfonctionnelle et de la Détérioration de l'Organisme National, also published under the English name The Final Solution to the Problem of the Genetically Disordered Strain and the Degeneration of the Body National, on the basis that it allegedly sought to incite genocide against various 'socially undesirable' groups in the community, including criminals, the disabled, the homeless, welfare dependents, and the unemployed, the Executive Prerogatives Division (EPD) of the Court of First Instance (CFI) quashed that ministerial order as a violation of Article 12 of the constitution and its guarantee of freedom of speech and expression, which the Supreme Court upheld, citing a variety of Crown Chamber of Valois (CCV) judgments which drew a distinction between 'publications which motivate patriotic feeling in defence of the constitutionally anchored form of the national order' versus 'seditious publications instigating the levying of war and insurrection to the destruction and degeneration of the integrity of the broader social organism', in its determination of whether a publication amounted to a breach of the King's peace under common law. Using a common law interpretivist method of adjudication, the Supreme Court reasoned by analogy from such monarchist CCV judicial precedents to argue that Geneviève Aumont's La Solution Finale amounted to 'protected speech' under Article 12 because "insofar as that publication may be said to incite hatred, discrimination, and even violence against such demographics, nevertheless, it is quite clear to us that, on any plain reading of the communication that is targeted by the impugned ministerial order, the underlying purpose of the publication remains the defence of the socio-political integrity of the underlying constitutionally anchored form of the body politic, that is personified and described therein as the so-called 'national organism' or l'organisme national, and speech which is defensive in its underlying constitutive character cannot be treated as in any way similar or comparable to speech which is offensive and antagonistic in its character, designed to bring destruction to that same socio-political integrity, which the history and tradition undergirding the enacted constitutional compact shows clearly and unambiguously to be unprotected by Article 12 thereof; this publication, however, cannot be said to amount to or be of such character as to qualify as such an unprotected communication" (see, The Secretary of State for the Ministry of Media Affairs and Cultural Developments c. Notre République de la Révolution (sur l'application de Geneviève Aumont) [1981] 9 RJRP 9005 ("Media and Culture Ministry c. Aumont") at [38]).

This distinction was necessary for the Supreme Court to reconcile its judgment that prohibiting the publication of the political treatise La Solution Finale was an unconstitutional violation of Article 12's freedom of speech protections with its prior case law which had often upheld criminal convictions of various left-wing political activists on broad judge-made common law offences of treason, sedition, sabotage, subversion, mutiny, insurrection, agitation, instigation, obscenity, and criminal conspiracy to injure, which had often been justified on the basis that Article 12's free speech protections did not cover speech that was "fundamentally anathema and repugnant to the constitutionally anchored form of the Republic which was so immutable, intrinsic, and inhered within the constitutional compact that was in existence at the time of the written promulgation of the codified form of that constitutional order that they form the unwritten seminal assumptions that the drafters must have taken for granted at the time, being so deeply rooted within the history and tradition of the common law at the time that it would have been regarded as too obvious to put into writing for any reason whatsoever, and now stand to be divined and deciphered through an interpretivist approach towards the entire collective history of this jurisdiction's jurisprudence constante" (see, Media and Culture Ministry c. Aumont at [33]), which was a coded reference to the politically repressive judgments of the monarchist Crown Chamber of Valois and the royalist secret security tribunals of the Sacred Order of St. Troyes (SOST), which had regularly repressed and imprisoned anti-royalist anti-monarchical political dissidents, campaigners, and activists, prior to the onset of the liberal Purgation Revolution and the establishment of the Republic of Purgatio (see, Media and Culture Ministry c. Aumont at [31]-[32] and [34]). Such an interpretivist approach meant that while far right political speech such as La Solution Finale was deemed by the courts to be constitutionally protected free speech under Article 12, any other political speech (such as the political activities of leftist groups, including communists, anarchists, trade unionists, civil society organisations, human rights groups, socially democratic groups, etc.) could be easily designated as 'unprotected' speech under Article 12 on the basis of being 'repugnant and anathema to the constitutionally anchored form of the body politic', and consequentially perfectly free game for reactionary elements of the national police forces to violently suppress or assault or for equally traditionalist segments of the federal prosecutorial service to jail and imprison such activists or protestors on a whole host of broadly worded judge-made common law offences.

A similar distinction could be seen in the Supreme Court's treatment of political violence and terrorism emanating from the Purgation far left as opposed to that of the Purgation far right. In the immedate aftermath of the 1979 incident of La Révolte Rouge en Lusignan, when the far-left socialist terrorist organisation L'Épée du Peuple staged an attempted communist revolt and uprising in the province of Lusignan, violently seizing control of the state parliament building in the city of La Roche, before the revolt was eventually put down by local fighters in the provincial volontaires auxiliaires, the provincial government in Lusignan engaged in a massive purge of the political left in an attempt to prevent a similar communist revolt from recurring in future. In addition to targeting suspected members of L'Épée du Peuple, the provincial authorities also cracked down on all labour unions and arrested tens of thousands of left-wing youth activists and labour organisers, on the basis that the 1979 revolt had actually been the result of an escalation of violence following a province-wide general strike of workers, organised by labour unions in conjunction with left-wing civil society organisations and activists, many of whom were handed over to the federal prosecutorial service to be charged accordingly for their alleged crimes. Many of the labour unionists who had organised the general strike were charged with sedition, manslaughter, instigation of violence, agitation of rights-violations, and criminal conspiracy to cause economic injury by unlawful means, by instigating and inducing their members to join in the workers' strike, in an attempt to hold them constructively liable for the thirty-six civilians who died at the hands of L'Épée du Peuple terrorists during the violence and chaos of La Révolte Rouge en Lusignan. Many of the defendants launched constitutional challenges against their prosecutions on such a broadly construed constructive criminal liability, claiming that it violated their freedom of liberty in Article 7, right to a fair trial in Article 8, conviction and punishment only in accordance with due process of law in Article 9, right to a private life free of undue interference in Article 10, freedom of conscience in Article 11, freedom of speech and expression in Article 12, and freedom of assembly and association in Article 13.

Such constitutional challenges were consolidated into a combined set of appeals which was accelerated to the Supreme Court by the federal prosecutorial service under a 'leapfrog appeal' system, which allowed the Supreme Court to hand down its landmark and truly remarkable decision in Thierry Neveux et alia c. Procureur-Général des Citoyens [1982] 3 RJRP 2759 ("Thierry Neveux"), which predictably dismissed all the constitutional challenges and upheld the criminal convictions of the left-wing activists, social campaigners, and labour unionists convicted for their involvement in the 1979 general strikes in the province of Lusignan. Using its familiar constructive method of 'common law interpretivism', the Supreme Court justified this outcome in a number of ways. First, it engaged in a 'law as integrity' interpretation of the 'history and tradition' of the Purgation State's jurisdiction and once again cited monarchist precedents from the Crown Chamber of Valois (CCV) and closed door security tribunals of the royalist Sacred Order of St. Troyes (SOST) to broadly construe the contents of common law offences such as sedition, instigation, agitation, and criminal conspiracy, as including an element of "constructive enterprise liability" such that "any accused who voluntarily engages in criminal acts in concert with other persons to fulfill a coordinated syndicated result must accept all of the consequences flowing from the enterprise he or she participates in", hence there was "nothing objectionable in principle with the prosecutorial case theory advanced here - viz., that as the accused persons here chose, by their own volition and exercise of individual free will, to engage in an unlawful criminal enterprise through the planned and organised incitement of members of various labour unions to engage in a whole range of illegal activities, including the forceful unlawful occupation of private premises, the disruption of public order and commissions of public nuisances outside the targeted industrial facilities, the application of abusive and insulting words in public directed against strikebreakers, and the instigations of communal breaches of contracts in an unlawful deprivation of contractual stipulatio bargaining rights, with the criminal and turpitudinous character of such acts standing in full accordance with the history and tradition of this nation and the jurisprudence constante thereof owing to its cumulative recognition of the sanctity of bargains under the seminal principle of pacta sunt servanda, and they must therefore accept fully all of the consequences causatively flowing from their criminal acts, howsoever severe or grave they may be, for once they embarked upon their contemplated criminal conduct, it suffices that that criminal conduct was committed without any further need for any particular consequence or outcome to be within their contemplation at the relevant time. The entire object and purpose of an enterprise of any kind is to share in the losses and profits gained from the contemplated enterprise through an intentional pooling of efforts and resources expended towards a collective aim and goal of a criminal character, and therefore it is the enterprise itself that is the subject of the said consolidation and coordination of efforts which needs to be in the contemplation of the enterprise's members and not any particular result potentially inuring therefrom. Whether or not the deaths of the thirty-six victims in this case, during the terroristic violence in April of 1979, may be said to be causally linked to the unlawful enterprise of these accused persons in wilfully organising an illegal general strike in the province of Lusignan, is a pure question of fact which the fact-finders, following a full trial on the merits, plainly found to be satisfied beyond a reasonable doubt in the present case, which, in our view, should definitively and conclusively close the inquiry altogether as to the material criminal liabilities of these accused" (see, Thierry Neveux at [24]).

Next, regarding the claims that such an understanding of their criminal obligations based on a theory of 'constructive enterprise liability' would violate various provisions of the fundamental rights provisions of the Republic of Purgatio's written constitution, the Supreme Court in Thierry Neveux disposed of such arguments rather quickly and easily by reference to its 'common law interpretivist' method of analytical reasoning. In short, the court held that the fundamental rights provisions contemplated a 'balance of rights' framework requiring a calibrated balance to be struck between the fundamental rights of different rights-holders. More significantly, the court held that the federal prosecutorial service could claim to be a 'vicarious right-holder' based on a 'quasi-principal-agent relationship arising by operation of public law', which it divined based on a coherent interpretivist construction of Purgation common law and the historical role that servants and agents of the King, Le Saint-Roi, had played and the legal constitutional role they had occupied in respect of that office and in representing the rights and interests inured within the historic legal personality of the Crown, that juridical entity being the living embodiment and expression of the entirety of the sovereignties of the Purgation State. Applying a 'common law interpretivist' approach of effectuating a harmonious interpretation of the collective legal history of all legal acts within the jurisdiction of the Purgation State, the court creatively held that the principal-agent relationship imputed upon servants of the Crown asserting the sovereign rights of the body and personage of the King, qua Souverain, was modified in application by the written codified constitution of the Republic of Purgatio of 1835, which included such provisions as a guarantee of the right to vote and democratic participation in Article 1(2) of that constitution. In the court's view, that fundamental human right to democratic representation "established a new principal-agent relationship imputed upon public officers by operation of constitutional law, that is, that civil servants and agents of the State have now become the new representative agents acting vicariously for the collective communal undifferentiated body politic of the wider citizenry at large, thus embodying the principle of collective national self-determination that stands to be effectuated into practical operation through the acts of the citizenry's representative agents, much in the same way as servants of the Crown were deemed at one point to stand in a similar principal-agent relationship as a matter of public law, arising by way of imputation from the principles of the common law, which are here capable of being applied much in the same way as was understood within the history and tradition of this jurisdiction and her ancient common law norms" (see, Thierry Neveux at [28]). Accordingly, public bodies or officers acting within the scope of their public duties and responsibilities, including the Commissioner of the Purgation Police Force (PPF) and/or the chief federal prosecutor (known as Le Procureur-Général des Citoyens) could be 'vicarious rights-holders' under the fundamental rights provisions of the Purgation constitution, and assert the rights of the collective citizenry on their behalf by seeking the vindication of the public's collective, undivided, and undistributed fundamental human rights in a court of law, in their capacity as agents standing in a constitutionally imputed principal-agent relationship, arising by operation of law, which in the court's view embodied the principle of collective national self-determination which the right to democratic participation in Art 1(2) of the written constitution had been intended to enshrine and protect in law.

Once it was determined that the Procureur-Général des Citoyens could also assert fundamental rights under the constitution, in discharge of his prosecutorial functions, it became easy to summarily discard the human rights arguments asserted by the accused persons in the case of Thierry Neveux. The accused persons' argument now represented, in the court's words, a 'wilfully one-eyed and thoroughly one-sided approach to the protection of fundamental human rights codified and enshrined under Arts 3-22 of the republican constitution bearing no textual, contextual, genetic, rational, or teleological justification whatsoever', and failed to account for the manner in which their prosecution and conviction served to vindicate the collective human rights of the Purgation citizenry. The court identified several human rights which, in its view, had been violated by the accused persons' organising of a general strike in the province of Lusignan which was found beyond a reasonable doubt to have resulted in the deaths of thirty-six persons in the subsequent political violence and insurrection, including the right to life under Article 3(1), the freedom from torture and inhuman and degrading treatment under Article 4(1), conviction and punishment only in accordance with due process of law under Article 9 (which the court rather creatively construed as including death without due process of law, even though the language of Article 9 only spoke of deprivation of liberty and property without due process of law due to the abolition of the death penalty in the republican constitution, on the basis that a deprivation of life necessarily deprived the deceased of their liberty and property as well), and a right to pursue a private life free of undue interference under Article 10(1) (which the court likewise creatively construed to include the freedom of contract of strikebreaking workers and factory owners who had concluded employment contracts with the workers who had been induced to enter into a general strike in violation of the implied terms of such contracts of service by the alleged instigations of the accused persons). The court therefore held, under a "balance of rights" framework, that "le Procureur-Général des Citoyens is well-entitled to submit, as he has in this case, that since the actions of the accused persons here contravened the fundamental human rights guaranteed by the constitution of this Republic to all persons, it can no longer be sensibly argued that actions undertaken by the Procureur-Général to vindicate and enforce those same constitutionally guaranteed rights can somehow be regarded as unlawful and unconstitutional for violating the fundamental rights provisions of the constitution, in respect of the accused persons here. Such an argument would make a nonsense of the fundamental rights provisions of our constitutional compact and cannot be considered a sensible or rational construction of the balance of rights contemplated by the constitutional codification of 1835 which included therein the conferral of human rights upon all Purgation citizens throughout our national body politic as a whole, and not merely human rights limited to particular special individuals such as the accused persons in this case. In fact, it is the view of this court that the actions of the Procureur-Général, in his capacity as a vicarious right-holder under our constitutional framework, in prosecuting and procuring the criminal convictions of these accused persons, did in fact vindicate and repair the very constitutional rights and fundamental freedoms which the accused persons illegally, seditiously, profanely, and perfidiously flouted and contravened by their most depraved and repulsive conduct during the conflagration of events in March-April 1979. Hence, far from contravening the constitution of this Republic, the Procureur-Général des Citoyens can indeed be said to have thoroughly vindicated the integrity of the rights-based constitutional protections therein" (see, Thierry Neveux at [36]).

As a result, the Supreme Court upheld the constitutionality and validity of the criminal convictions of all the accused persons in that case, on a whole host of common law offences, including for sedition and manslaughter, because the accused persons were held strictly and constructively liable for all of the harmful consequences flowing from their unlawful organisation of the general strike, including the communist insurrection in La Révolte Rouge en Lusignan and the deaths of thirty-six (36) civilians resulting therefrom. Consequently, the Supreme Court not only upheld their criminal convictions as constitutional, but also upheld the punishment that was imposed upon the accused persons by the Criminal Justice Division (CJD) of the Court of First Instance (CFI), which was life imprisonment without the possibility of parole (i.e., a 'whole life order'), on account of the multiple deaths caused by their actions (see, Thierry Neveux at [39]-[45], [48]-[49], [57], [63]-[64], and [68]).

The Supreme Court's approach to the civil society campaigners, left-wing student activists, and labour unionist organisers in Thierry Neveux can be readily contrasted with the comparatively lenient and indulgent approach taken towards far-right political violence in the aftermath of the infamous June 1980 coup attempt launched by Nicolas Charlet (paternal uncle of Delrico Charlet, future Commandant en Chef of the Purification Order), in Le Putsch Pétrussien de Charlet, in which Nicolas Charlet led his local provincial volontaires auxiliaires to storm a court-house in the city of Pétrus following a dramatic conclusion to the high-profile criminal trial of nineteen suspected terrorist operatives accused of involvement in the mass shooting in the Genovese Market area committed by a lone gunman from an Islamist terrorist group known as The Brigade of Deir Yassin, which ended in the surprising acquittal of the nineteen accused. In response to the announcement of that acquittal, the local volontaire auxiliaires, led by Nicolas Charlet and Louis Paradis, ordered their soldiers to storm the court-house in Pétrus, rounded up all persons therein as hostages, tortured and summarily executed all nineteen defendants and fourteen jurors, mutilated their bodies, and hung them outside the court-house as a warning to other alleged 'traitors' to the Purgation people. Nicolas Charlet declared himself the dictateur of the city of Pétrus and the entire province of Le Tellier, his volontaire auxiliaires then staged a violent coup d'état against the provincial government of Le Tellier before provincial police forces arrived and forcefully put down the revolt, seized control of the court-house, and Nicolas Charlet and Louis Paradis were arrested on 25 June 1980 (with 18 deaths being caused in the process).

Both Nicolas Charlet and Louis Paradis were tried by federal prosecutors for the common law offences of treason (for levying war against the government), torture and murder (of the nineteen defendants and fourteen jurors), and criminal conspiracy (for running a syndicated criminal organisation, namely, the local municipal volontaires auxiliaires in Pétrus), with the remaining participants in the attempted putsch being tried by the provincial prosecutors of Le Tellier instead. Even then, the leniency of the federal prosecutorial service to the Purgation far-right was demonstrated in the indulgent plea offer that was extended to Nicolas Charlet and Louis Paradis - for them to plead guilty to the far less serious offences of public nuisance, rioting, obstruction of justice, resisting arrest, and criminal contempt of court, in exchange for the serious charges being tabled and stood down - which would have resulted in a significantly shorter custodial term, but which the defendants nevertheless rejected. The trial was conducted in September-October 1982 before a criminal jury (as was constitutionally required at the time by virtue of Article 9(3)) and presided over by a trial judge of the Criminal Justice Division (CJD) of the Court of First Instance (CFI), and the defendants were convicted on all charges. The trial judge, Le Juge-Président Aimé Renault, would further demonstrate the Purgation Judiciary's indulgent attitude towards far-right political violence at the time by sentencing Nicolas Charlet to just seven years' imprisonment (with the possibility of parole after four years) and Louis Paradis to only five and a half years' imprisonment (with the possibility of parole after three years), sentences which were significantly below the prevaling precedential guidelines for the offences of treason, torture, and that of murder especially (prior case law for murder emanating from the Supreme Court and Court of Final Appeals had generally prescribed life imprisonment with the possibility of parole as the default sentence and starting position for any conviction for murder involving an intentional taking of human life as opposed to mere intent to cause serious bodily harm), on the basis that the defendants' "vindication of a most justifiable public anger and collective fury" at the "travesty of justice in Pétrus" and "righteous rage against the scourge of terrorism and sedition ravaging our realm" constituted an "extraordinary mitigating factor, amounting to a most exceptional circumstance indeed". The reactionary sympathies of the federal prosecutors towards Purgation far-right groups was again demonstrated by the fact that the prosecutors declined to appeal against the unusual sentence, even expressing agreement with the sentence handed down by the court and the views of the bench that vigilante violence to vindicate the Purgation public's rage at Islamist terrorism and sedition constituted a valid mitigating factor in sentencing.

[Purgatio]

The sympathies of a right-wing dominated federal prosecutorial service also explains why the case ended up on a 'leapfrog appeal' to the Supreme Court, due to the agreement of federal prosecutors in that case and legal counsel for Nicolas Charlet and Louis Paradis, which resulted in the Supreme Court rendering one of its most controversial judgments to date, and certainly the most controversial judgment that it had ever rendered throughout the Purgation State's republican era, reported as Louis Paradis et alius c. Procureur-Général des Citoyens [1983] 1 RJRP 387 ("Louis Paradis"), which granted the defendants' appeals against their criminal convictions and remanded the case for a fresh trial. The court's remarkable decision may be split into three parts, based on the categories of charges that were appealed against by the defendants. On the common law charge of running a criminal conspiracy, based on the claim of the volontaires auxiliaires being a 'criminal organisation' or 'criminal syndicate', the court distinguished the case from that in Thierry Neveux, holding that while in Thierry Neveux it had been appropriate to hold the left-wing student activists, civil society campaigners, and labour unionist leaders strictly and collectively responsible for the unlawful general strike they had organised and constructively liable for the causal consequences of that general strike (which included the left-wing political violence that resulted in the deaths of 36 people), that same doctrine of 'constructive enterprise liability' could not be applied to the present factual matrix. The court's justification for that distinction exploited and took advantage of the broadly and generally worded fundamental human rights provisions in Arts 3-22 of the Republic of Purgatio's written constitution to readily explain away the difference in treatment. The invocation of 'constructive enterprise liability' had been justified in Thierry Neveux on the basis that the underlying criminal acts proved to have been committed in that case - the deliberate and intentional organising of the general workers' strike - had been in itself unlawful per se and also a trespass upon the fundamental constitutional rights of other persons in society, including the freedom of contract of their employers and strikebreaking workers which the court interpreted as part of the Article 10(1) constitutional right to pursue a private life free of undue interference. However, the actions undertaken by the alleged 'criminal syndicate' in this case, which was the general demonstration outside the court-house of Pétrus organised by the local volontaires auxiliaires and helmed by the defendants, could not be said to be unlawful per se, since no fundamental constitutional rights were violated by such conduct. In fact, the court cited the precedent set in Media and Culture Ministry c. Aumont to hold that speech which vindicated the socio-political integrity of the realm and her people constituted 'protected speech' under Article 12(1) of the constitution, read together with the history and tradition of Purgation common law, since unlike the general strike in Thierry Neveux which was a breach of public peace and public order, the protest in Louis Paradis had been a vindication of the sovereignty and security of the Purgation State, in expressing public outrage and anger at Islamist fundamentalist terrorists whose actions had endangered public welfare and jeopardised the collective security of all the Purgation people. Reasoning by analogy from the 'protected speech-unprotected speech distinction' delineated in Media and Culture Ministry c. Aumont, it was likewise held that the demonstration organised by the local volontaires auxiliaires in Pétrus was a valid exercise of their Article 13(1) right to freedom of association and Article 13(2) right to freedom of assembly and demonstration, since the purpose of the organised demonstration had been a 'historically ordained object and a lawful constitutionally protected purpose', unlike that of the general strike in Thierry Neveux. Hence, by citing relevant monarchist and royalist case law handed down by the Crown Chamber of Valois (CCV) and the Sacred Order of St. Troyes (SOST), which had also been relied upon and invoked with approval in Media and Culture Ministry c. Aumont, the Supreme Court concluded that since the underlying conduct in Louis Paradis had not trespassed upon any constitutionally guaranteed rights (unlike the general strike in Thierry Neveux, which had), and in fact constituted an exercise of constitutionally guaranteed rights under Article 13 of the constitution, accordingly, while it had been lawful for the prosecution to apply the doctrine of "constructive enterprise liability" to the constitutionally unprotected demonstration organised in Thierry Neveux, in contrast, it would be unlawful and unconstitutional to apply that same doctrine to the constitutionally protected demonstration organised in Louis Paradis. Since the charge of criminal conspiracy (based on the allegation of running a criminal organisation or syndicate) had been founded upon legally and constitutionally erroneous grounds, the defendants' convictions had to be vacated (see, Louis Paradis at [13]-[16], [18]-[20], [25], and [28]).

Second, in respect of the charge of common law treason, the Supreme Court also vacated that conviction on the basis that no reasonable jury, properly instructed as to the contents of the common law, could have arrived at the conclusion that the defendants were guilty of treason, on the facts and evidence presented at the trial below, and therefore the conviction must have been founded upon a misapprehension of the law. In the court's view, whether an act constituted treason had to be assessed with reference to whether the "antagonistic force against which the alleged traitor is levying war, insurrection, and revolt thereupon can truly be said to constitute a fundamental emanation of the principally ingrained and constitutionally anchored form of the sovereign Purgation realm, or a mere temporary aberration fleetingly donning her crown and shield in a transitory manner not reflective of her core characteristics and representing a deviation from the essential constitutional character of the sovereign Purgation State herself and considered against the entire constitutional history and tradition thereof" (see, Louis Paradis at [34]). What this arcane jargon means, in simple English, is that it is not enough for a defendant to have deliberately levied or waged war against some public body or governmental organ to constitute the common law offence of 'treason'; rather, it must also be determined that the target of the said insurrection represented a fundamental part of the Purgation constitutional order and not a mere deviation or transgressive force within the temporarily prevailing governing regime, such that the so-called treasonous 'insurrection' against that transgressive governing entity had, in fact, been an attempt to vindicate and defend the permanently ingrained fundamental constitutional order of the Purgation State which the transgressive governing entity had been acting in opposition to. Applying its typical method of 'common law interpretivism' to effectuate a 'law as integrity' analysis of the case, the Supreme Court drew upon the pre-revolutionary historical precedents of incidents when riots or rebellions would be waged against the Crown by individual feudal lords, and certain vassals and commoners would wage war or incite insurrection against those feudal lords in defiance of their obligations of fealty and loyalty to their local liege lord. The Supreme Court cited examples such as the Peasants' Revolt of 1516 in which the Prince of Lazaisvín opportunistically sided with the leaders of a local peasant revolt in his domain in order to overthrow the Valois monarchy's rule over the Principality of Lazaisvín, and various local knights and vassals staged an insurrection against the Prince of Lazaisvín and successfully overthrew him instead by the start of 1541. After the failure of the peasants' revolt, the reigning Le Saint-Roi François VII issued a famous lettre d'atteindre which branded the Prince of Lazaisvín, together with all the vassals who had been loyal to him and fought on his side, as "perfidious and seditious traitors to the Crown". In contrast, all of the vassals who had broken their oaths of homage and fealty to the Prince by rebelling against him and staging a successful insurrection against the rulership of their own liege lord were accorded full legal impunity for their actions, which were not deemed to constitute treason in law, in the eyes of the Crown, because the insurrection against their liege lord had been in vindication of their true and ultimate allegiance to the Valois monarchy, and therefore could not constitute treason. As a reward for their actions, the feudal domain of the Principality of Lazaisvín was abolished and broken up into smaller feudal domains and fiefdoms to be distributed amongst the vassals who had fought against the rebelling (and last ever) Prince of Lazaisvín, as a reward for their loyalty to the Crown. Likewise, during the Religious Civil Wars of 1568-1593, when the rise of a new Protestant sect of Christianity known as Les Canavairres led to tension with the ruling Purgation Catholic Church upon which the Valois monarchy was founded, resulting in a bout of deadly religious wars between Catholic clerical forces and zealous Canavairres converts, with La Sainte-Reine Aurélie I firmly siding with the Catholic side of the civil wars throughout much of the conflicts, various Purgation nobles and feudal lords had sided with either the Catholic forces or the Canavairres rebels throughout the course of the civil wars, and during which time many of the Canavairres-sympathetic nobles had been stripped of their titles and holdings and sentenced to death or exile by the Valois monarchy under a series of draconian lettres d'atteindres issued by La Sainte-Reine Aurélie I which had labelled and proscribed such nobles as "traitors to the Church and Crown" and, more importantly, excused and pardoned any of their vassals, peasants, or serfs who had staged insurrections, revolts, or violent uprisings against Canavairres-sympathetic nobles in favour of the Purgation Catholic Church and the authority of the ruling Valois monarchy, even if such uprisings against their local feudal lord would have otherwise constituted an illegal riot, mutiny, insurrection, sabotage, brigandage, or even outright treason and/or sedition under the law (see, Louis Paradis at [29]-[35]).

The Supreme Court cited these historical examples, which it regarded as relevant because a 'law as integrity' interpretation of the fundamental foundational norms of the Purgation State's constitutional order required a cohesive and coherent interpretation of the 'unifying web of principles and integral tapestry of justificatory legal norms and ideals undergirding the history and tradition of the Purgation jurisdiction and all her essential and fundamental common law principles'. Moreover, various judicial precedents rendered by the monarchist CCV judges and royalist SOST security tribunals had cited such historical case studies as being relevant and instructive in illuminating the contents of the common law offences of treason, sedition, subversion, sabotage, mutiny, rioting, and insurrection, amongst others. Accordingly, the Supreme Court reasoned that, for a defendant to be guilty of treason, it was not enough that he had waged war or insurrection against a body or organ wielding some public authority, it also had to be determined that the public authority against which the mutiny or insurrection was pursued was acting in accordance with the "underlying fundamental and essential constitutional structure of the sovereign Purgation State" rather than being a "deviant, transgressive, rebellious force within that same structure but imbued only with a formalistic title and mere colour of lawful authority alone", similar to the Prince of Lazaisvín in siding with the peasants that revolted against the Crown or the Canvairres-sympathetic nobles who had acted perfidiously against the reigning Purgation Catholic Church. In such cases, such governmental agents or public bodies, whilst holding a position of power within the prevailing order, had acted deviantly and transgressively against the fundamental constitutional order of the sovereign Purgation State, and thus the waging of a war against such persons would not constitute treason against the "constitutionally anchored form of the sovereign Purgation State and her essential constitutional order" (see, Louis Paradis at [39]-[42] and [45]).

Applying that test to the facts in Louis Paradis, it was held that the actions of the provincial judiciary in Pétrus (particularly the jury that had acquitted the nineteen defendants in the terrorism trial of nineteen suspected members of The Brigade of Deir Yassin) were not emanations or expressions of the 'constitutionally anchored form' of the Purgation State and her sovereignty; rather, they acted under colour or cloak of authority but their actions were transgressive deviations from, and violations of, that fundamental constitutional order. This was because they had sided with an internal antagonistic force that was engaged in an ongoing war against the Purgation people and body politic as a whole, viz., the Islamist fundamentalist organisation calling itself The Brigade of Deir Yassin which had planned and orchestrated the mass shooting in the Genovese Market of Pétrus. As such, the provincial judiciary, in acquitting nineteen terrorists who had conspired to destroy the internal safety and security of the Purgation community, had sided with the enemies of the Purgation State and its underlying constitutional structure. As such, it could not constitute treason under the common law for Louis Paradis and Nicolas Charlet to wage a war against the Pétrus judiciary to put an end to their complicity with, and assistance to, the enemies of the Purgation citizenry, viz., The Brigade of Deir Yassin and the nineteen defendants in particular. The same was true of the provincial government of the province of Le Tellier, which had sided against the local volontaires auxiliaires which had taken over the Pétrus court-house and executed the ninteen defendants and the fourteen jurors who had acquitted them. By attempting to fight against and undermine the forces fighting to vindicate the 'constitutionally anchored form' of the Purgation State, the provincial government of Le Tellier had sided against the Purgation State and in favour of her enemies, including The Brigade of Deir Yassin, and thus the attempt by the defendants and their volontaires auxiliaires forces to overthrow the provincial government of Le Tellier was not a treasonous attempt to overthrow the 'constitutionally anchored form' of the Purgation State, but was actually an attempt to vindicate and defend the 'constitutionally anchored form' of the Purgation State against a deviant and transgressive segment of the prevailing governing order. As an essential ingredient of the common law offence of treason had never been put to the jury, the convictions for treason were also unsafe and had to be vacated (see, Louis Paradis at [46]-[47]). The effect of this most remarkable interpretation and construction of the ingredients of the common law offence of treason was that the Supreme Court was effectively delegitimising the entire then-prevailing governmental order of the Purgation State as a weak, deviant, temporary, and transgressive force that had provided assistance and cover to the enemies of the Purgation State, derailing and sabotaging the fundamental constitutional order of the sovereign Purgation State, by not only failing to take any effective action against the terrorists busy waging an ongoing war against the Purgation people (such as the Islamist fundamentalist fighters in The Brigade of Deir Yassin) but by going further in opposing the organisations that were taking such effective action by properly waging a war against those enemies, thereby legitimising the far-right volontaires auxiliaires as the true agents and protectors of the Purgation State that were vindicating her permanent and fundamental constitutional order, with the present republican authorities being mere transitory and transgressive elements thereof who were basically complicit in shielding and protecting the enemies of the Purgation people that the volontaires auxiliaires were valiantly fighting against.

However, as politically radical and remarkable as the court's treatment of the common law offence of treason may have been, the most shocking and groundbreaking part of the Louis Paradis judgment was its proffered justification for vacating the petitioners' convictions on the charges of torture and murder, in respect of the mutilation and hanging of the nineteen defendants and fourteen jurors in the Pétrus court-house after they had seized control of those premises back in June 1980, and it was here that the Supreme Court's jurisprudential approach in Louis Paradis reached the true zenith and ultimate climax of that decision's judicial creativity and resourcefulness. Le Lord Président Romain de Saint-Aulaire, who authored the unanimous majority 13-0 judgment in Louis Paradis which the Supreme Court heard en banc, began by making the uncontroversial observation that it was clear beyond a reasonable doubt that the defendants had intended to inflict pain and suffering on the nineteen acquitted defendants who were charged with terrorism as well as the fourteen jurors who had acquitted them, and it was also equally clear that they had intended to kill them, because the defendants themselves admitted these facts in open court, having been so unashamed and unabashed about their actions they proudly admitted them during the trial and that the purpose had been to punish the thirty-three victims through torture, mutilation, and summary execution, as a warning to other traitors to the Purgation people who would similarly attempt to wage war against the Purgation community or give assistance and support to her enemies. In any event, these facts were also equally established by the over forty eye-witnesses who testified for the prosecution who had been trapped in the Pétrus court-house as hostages at the relevant time and were able to give eye-witness testimony as to the relevant acts of the accused persons, Louis Paradis and Nicolas Charlet, to that effect. Hence, it was not open to any doubt that the essential ingredients of the common law offences of murder and torture were made out (see, Louis Paradis at [10]-[12], [48]-[50], and [53]-[54]).

The majority judgment of Le Lord Président Romain de Saint-Aulaire went on to observe that the accused had sought to rely on an 'expanded' conception of the common law defence of 'private defence', where a person acts proportionately to prevent an imminent risk of harm or injury to their own person or property or that of another person, causing proportionate harm or injury to the victim's person or property in the process, on the basis that the nineteen acquitted defendants had been members of a terrorist organisation, The Brigade of Deir Yassin, and had been involved in an ongoing war against the Purgation people by, inter alia, planning and organising the Genovese Market mass shooting attack, and that the fourteen jurors had aligned themselves with these terrorist operatives and were therefore allied with violent and dangerous enemies waging an ongoing war upon the Purgation community; hence, it was argued that the torture and killing of the thirty-three victims had been a proportionate act of private defence to defend the Purgation people from further harm. The Supreme Court agreed that there was no room to overturn the jury's conviction on this ground. Certainly, it was not in manifest error or plainly wrong for the jury to have rejected this defence, not only because it was far from clear that the elements of imminence and proportionality were satisfied on the evidence adduced below, but perhaps far more importantly, the accused persons' own explanation for their actions, in their own oral testimony and evidence at the trial below, made clear that the real motive for the torture and killings had not been to defend any potential future victim from subsequent harm, but to punish the nineteen defendants and fourteen jurors for their past actions already committed, namely, the Genovese Market mass shooting and the jurors' acquittal of the defendants suspected of having been involved in instigating and organising that attack (see, Louis Paradis at [9]-[10], [52], and [55]-[56]). "Hence," the unanimous judgment explained, "this distinction is fatal to the petitioners' invocation of the common law defence of an 'act in private defence' invoked at the trial below, since the entire rationale of the 'private defence' doctrine is the prevention of imminent and ex post harm and injury to one's self or against another, and certainly cannot be extended to include an act done intentionally with an eye towards inflicting punishment upon another for ex ante harm and injury already past and materialised which cannot be undone or prevented. As the doctrine of 'private defence' is fundamentally protective rather than punitive, that protective rationale can have no application to such past harm and injury already occasioned and completed, with such injuries consequently being obviously and entirely incapable of any retrospective prevention" (see, Louis Paradis at [57]).

However, the Supreme Court went on to recognise a new common law defence to the offences of torture and murder, which it deciphered by way of logical extension and parity of reasoning, by rationalising its existence into being based upon what the court regarded as a mere principled extension from other existing common law defences. That new defence was a 'right of private penalisation', in other words, a right of a private citizen to inflict a rightful and proportionate punishment upon a person guilty of committing a criminal offence not in the interest of preventing any future harm or injury but purely as an act of punitive retribution against the target for a past criminal act already done and completed. The court began by observing the existence of other established and uncontroversial common law defences, such as the right to effectuate a 'private arrest' (i.e., to detain a person where reasonable grounds exists to demonstrate that they committed a seizable offence, using proportionate force before handing them over to the proper lawful authorities, which would operate as a defence to such crimes as battery, assault, wrongful restraint, or false imprisonment), as well as the 'shopkeeper's privilege' also recognised at common law (which allows a shopowner to temporarily detain a person reasonably suspected of having committed any unlawful theft or destruction of goods or properties in his store for the purposes of handing them over to law enforcement). In the civil context, the Supreme Court noted the historical existence of the 'doctrine of distraint' which had previously permitted the private seizure of property, even without any prior court approval, by a creditor in satisfaction of an unsatisfied debt or claim or in reparation of any unlawful injury, even referencing the effectuation of so-called 'private re-possessions' by lienholders over the subject-matter of the lien in the event of unpaid debts, such as automobile lenders who extend a loan to customers to purchase a car subject to a lien over the automobile which the lender retakes physical possession of in the event of a default by the borrower through the lender's own private action and without any replevin legal action in court (see, Louis Paradis at [59]-[64]). The majority judgment reasoned that all of these defences and doctrines rested upon a common animating principle of "limited and proportionate self-help", the idea being that the law "accords to individuals a private right of action, subject to certain fair and reasonable constraints to prevent abuse, to vindicate the right, the just, and the proper, and to restore the lawful position in the community where that lawful and rightful state of affairs has been wrongfully and unjustifiably disturbed and disrupted by another" (see, Louis Paradis at [66]).

The Supreme Court's unanimous judgment did acknowledge, however, that many of these defences existed in a residuary or supplementary fashion, intended to accord a limited right of action to the defendant to facilitate the administration of justice by the established legitimate authorities; for example, a right to effectuate a private arrest was limited to keeping the criminal detained until regular law enforcement could arrive to take the person into custody and subject the criminal suspect to the usual due process of law. It did not, however, grant a right of 'unrestrained vigilantism' to take the law into one's hands and to take upon the mantle of arresting officer, bailiff, judge, jury, and executioner, all in one. Consequently, the Supreme Court acknowledged the possible rebuttal that such a rationale could not go so far as to justify the petitioners taking the law into their own hands and unilaterally deciding upon the punishment and execution of these nineteen defendants who had already been subject to established due process of law and legitimate procedures and acquitted for their alleged crimes. However, the Supreme Court reasoned, that more limited 'supplementary' function of such private rights of self-help or private enforcement of the law only operates where there is an established legal framework for the self-help remedy to 'supplement' to begin with. Applying its ordinary 'common law interpretivist' method of constructing legal principles, the court noted that historical private remedies such as distrant had always given way where statutory remedies and avenues for redress were created; thus, where the 1925 Law on the Protection of Distrainors and Seizure of Indebted Properties created a statutory remedy for creditors to institute an 'action for distraint' before the ordinary civil courts to obtain a 'distraint order' for the seizure of the debtor's chattels to be enforced by court bailiffs, it correspondingly constrained and limited the scope of the private right of distraint to a narrow set of circumstances, such as where there is a demonstrated risk of the debtor moving or shifting his personal chattels to avoid or frustrate the satisfaction of any judgment debt ordered against him, hence giving rise to time-sensitive circumstances which necessitate the creditor immediately seizing the chattels as a prophylactic measure before turning to the civil courts to grant a proper 'distraint order' through legitimate avenues of law, but otherwise, creditors could no longer rely on the self-help measure of seizing the chattels of the debtor without first seeking regular recourse through court-ordered remedies (see, Louis Paradis at [66]-[68]). "Consequently," Le Lord Président Romain de Saint-Aulaire reasoned in his written unanimous majority judgment, "the view of the common law is that the size and scope of the private self-help remedy shrinks or grows depending on the role played by centralised legal authorities in the adjudication, determination, and enforcement of the same. Where the established and centrally determined role is limited, the scope of the private self-help remedy expands to leave a greater breadth of action for the individual to vindicate the rightful state of the law where the established avenues do not govern or determine the same; but, where the established centralised avenues expand in their scope of redress and field of governance of that same area, such as by statutory provision or amendment, then the private self-remedy correspondingly shrinks, giving way to the field of governance now occupied by the centralised legal avenue instead. In this way, the private self-help remedy and centralised legal remedies prosecuted through established procedures occupy complementary roles within our prevailing common law order, and what the latter leaves vacant and hollow, the former will grow to occupy, and vice versa" (see, Louis Paradis at [68]).

Effectuating a harmonious or coherent interpretation of the undergirding principles of the common law, through a 'law as integrity' interpretivist approach to adjudication, the Supreme Court reasoned by way of logical extension and analogy to the circumstances of the factual matrix in Louis Paradis to recognise a common law defence of 'private penalisation', reasoning by analogy from existing common law defences such as the right of 'private defence' and 'private arrest' (including the 'shopkeeper's privilege'). Applying the court's interpreted understanding of the complementary roles of private self-help remedies as against established centralised legal remedies subject to a state body's determination and adjudication, the Supreme Court noted that such a principled construction readily and sensibly explained the contours and modalities of these other recognised common law defences. The right of 'private defence' made sense because it was a proportionate response by a private citizen to an immediate and imminent danger which a regular law enforcement officer could not be expected to respond to at that point in time. Hence, while the prevention of crime may be the ordinary province of the Purgation Police Force (PPF), where a PPF officer is not at the scene of an imminent infliction of harm or injury upon one's person or property or that of another, the common law recognised a complementary private sphere of self-help and unilateral self-enforcement of the rightful legal state of affairs (i.e., the non-injury of one's body or deprivation of one's property). Similarly, the right of 'private arrest' and 'shopkeeper's privilege' operated in a similar fashion in the court's view, it allowed a private person to seize and restrain a suspected criminal but only to the limited extent of preventing their escape so they could be handed over to the proper legitimate authorities and subjected to the established processes of law. Such defences operated in a supplementary or complementary fashion to the established criminal investigatory process for the limited purpose of preventing such criminal suspects from eluding arrest altogether before the official PPF police officers could arrive at the scene of the crime (see, Louis Paradis at [71]-[73] and [75]).

However, the court asked, what of a scenario where the law fails to act and fails to properly punish a person guilty of a serious offence in law? Is the juridical criminal obligation to be left vacant and hallow, with neither private person nor established legal authorities empowered to inflict the penalty necessary to enforce and vindicate the obligation the performance of which is left wanting and owing as a result? In the Supreme Court's view, the answer is clearly no. Reasoning by analogy from its understanding of private self-help remedies and established legal procedures playing complementary roles, with one shrinking as the other expanded and vice versa, the court reasoned that where a proper penalty cannot be inflicted by established legal procedures, the necessary implication is that that right is delegated to private persons instead of to centralised legal bodies. This is where the Supreme Court's judicial creativity and inventiveness reached its apogee in the Louis Paradis judgment. The court cited the constitutional abolition of such punishments as the death penalty and methods of penal torture to justify its recognition of a common law defence of 'private penalisation'. It noted that Article 3(2) of the written constitution had abolished capital punishment as a method of punishment by law, and that Article 4(5) had prohibited a whole range of former punishments which used to be recognised under the old Purgation feudal monarchy which constituted inhuman and degrading treatment (in violation of the fundamental human right therefrom under Article 4(1)), including judicial whipping and lashing, being placed in the stocks or pilloried in public, penal beating, branding, or mutilation, or burning at the stake. Interestingly, the Supreme Court cited these prohibitions in support of its view that the common law recognised a right of private persons to inflict the very punishments which such provisions had textually abolished. It reached this conclusion by virtue of its 'law as integrity' approach to the norms of the Purgation jurisdiction and with reference to its 'common law interpretivist' method of legal construction. In the same way as private self-help remedies contracted to give way to new statutorily enacted centralised legal remedies which take their place, the reverse can occur as well, namely, a private self-help remedy expanding in scope to fill the gaps and lacunae left vacant by a contraction in the scope of the available centralised legal remedies (see, Louis Paradis at [78]-[79] and [83]-[84]). In the words of Le Lord Président Romain de Saint-Aulaire, "[w]here the law imposes a performance debt which is owed and owing, is that debt, valid and binding by law, deemed to simply evaporate and dissipate into nothingness merely because one provision of law forecloses a possible method for the enforcement of that debt and the full complete vindication of that performance that is wanted and wanting? That cannot be the case, for logically a legal obligation - especially that of a criminal character - of a mandatory and imperative kind cannot be unilaterally dissolved by the duty-ower's wrongful default and non-performance, shirking off the performance debt through a simple non-conformity, leaving the juridical duty hollow, vacant, and non-existent, and indeed, altogether dissolving its binding juridical character and transforming it into a consultative, advisory, and facultative notion alone. It would make a complete mockery of the force and rule of law if the integrity and inviolability of an imperative juridical duty, imposed to guarantee a rightful entitlement of the community, could be said to be completely dissolved and altogether destroyed, either in part or in whole, in such scenario. Such an outcome would be thoroughly repugnant and altogether anathema to not only the entire collective history and tradition of this jurisdiction, but I would go further to observe that such a result is wholly incompatible with the very nature of a civilised legal order in itself, defined by the existence of rights and obligations, and secondary means of substituting for those rights and obligations where they are left unperformed and owing, in restoration of the integrity of the rightful and legitimate state of affairs as compulsorily prescribed by that same law. As such, where the written codified constitution of 1835 foreclosed only particular avenues for the imposition of a rightful penal consequence prescribed by law as the just and righteous result in proportionate vindication of the performance debt that is owed and owing in respect of certain criminal obligations of a particular severity, gravity, and intensity in terms of the said default, it cannot be the case that the proper vindication of that debt which is owed and owing is rendered completely impossible by words which appear, on their face, ex facie, to only foreclose an avenue for the obtaining of that redress without foreclosing all methods therefor. Thus, for the foregoing reason, the argument that Articles 3(2) and 4(5) of our written constitutional compact constitute an absolute prohibition upon any and all persons inflicting such penalties in law cannot be accepted and is thoroughly repugnant and repulsive to the entire history and tradition of the common law and its recognition of the binding juridical character of criminal obligations, for which redress and remediation (by which, of course, I mean the full vindication of the entirety of the performance debt and the whole of the quantity and gravity thereof, which cannot be arbitrarily substituted with a lesser more indulgent penalty amounting only to a partial substitution and vindication of the same) must always be possible, in at least some capacity. It is clear, in fact, even on the textual face of those provisions, ex facie, that they only prohibited the State from imposing such penalties as, for example, judicial execution or judicially-ordered lashing or bodily mutilation. These provisions say nothing whatsoever, however, about whether other persons, including private persons and non-State actors, may correspondingly take upon the forfeited mantle of vindicating the integrity of the grave criminal obligation violated and flouted by an offender that is consequentially left wanting of full redress and proper enforcement to the complete quantitative and qualitative extent that is demanded by the historically ingrained dictates of the common law. Thus, it follows therefrom that if the proper, established, and centrally determined legal avenues for such redress via the State is foreclosed by law, the necessary implication must therefore be that that same right of redress has accordingly been automatically delegated by operation of that same law to some other non-State person or entity to perform and enforce the same that has been concordantly surrendered by the State and consequentially is to be imbued upon another" (see, Louis Paradis at [82]).

Applying its ordinary 'common law interpretivist' method of treating the entire legal history of the Purgation State's legal jurisdiction as one long coherent and cohesive tapestry of consistent legal outcomes capable of being normatively rationalised and reconciled as a matter of principle, the Supreme Court cited pre-revolutionary monarchist and royalist precedents rendered by the Crown Chamber of Valois (CCV) and Sacred Order of St. Troyes (SOST), which held, inter alia, that judicially-ordered capital punishment as well as judicially-ordered whipping, lashing, mutilation, branding, beating, and bodily mutilation were proper and righteous punishments to be ordered for the most serious common law offence of them all, that is, the common law offence of treason. The court held that a harmonious and coherent reconciliation could be effected between that prior jurisprudence and the republican written constitution through its reading of private self-help remedies and established centralised legal remedies as playing complementary roles in the collective enforcement of legal rights, norms, and obligations. Thus, where the State was now prohibited from applying judicially-ordered execution and judicially-ordered torture upon traitors, but the common law still recognised that such penalties were the rightful, proper, and proportionate penalties to be extracted from one who commits a violation as grave and severe as that of treason, the necessary and logical reconciliation to be arrived at must be that non-State private actors are now empowered, by virtue of the constitutional prohibition on State-ordered execution and State-ordered torture, to effect and enforce the same (see, Louis Paradis at [80]-[81] and [86]-[88]). In addition, the Supreme Court felt further reinforced in this conclusion by citing the historical precedent of the Valois monarchy's issuance of lettres de représailles, whereby a private group of brigands or highwaymen which may have acted on their own accord to inflict vigilante private violence upon an individual (such as a local feudal lord, vassal, or merchant) who had committed acts of treason against the monarchy would be retroactively 'deputised' as having acted on the behalf of the Crown in inflicting such violence, thereby cloaking their otherwise illegal actions with the shield of delegated or derivative royal immunity, and in fact many of the oldest chivalric orders in the Purgation State's feudalistic era, including Les Saints-Chevaliers de la Jarretière Génoise, began as private mercenaries who acted outside of the law by inflicting private force and violence upon enemies of the Crown or enemies of other various local feudal lords before being 'knighted' by that superior lord (be it the king as lord paramount or another feudal lord below him) in recognition of their services, which retroactively legalised and immunised all of the private violence they had previously inflicted, officially legitimising these former brigands or privateers into a formal consolidated chivalric order from thereon, which the court likewise regarded as a useful and illustrative historical analogy providing further legal precedential support for its view that the right to inflict formerly judicially-ordered punishments such as capital punishment or bodily mutilation had, as a result of the constitutional prohibition upon the government inflicting such penalties, been effectively and consequentially outsourced to private actors to perform and effectuate the same (see, Louis Paradis at [89]).

In order for this right of 'private penalisation' to be kept confined within proper limits, the same safeguards which would have applied if the State had been the actor inflicting the punishment in question must, necessarily, apply to a private individual. What this means, in practice, is that if a private person wishes to invoke the defence of 'private penalisation' to justify an act of torture or an act of murder, he would have to prove beyond a reasonable doubt that the victim was guilty of an offence which, under the established and entrenched principles of Purgation common law, was punishable by death and/or other methods of judicially-ordered torture, such as the common law offence of treason. If a defendant was unable to discharge their burden of proof of proving the guilt of their victim beyond a reasonable doubt for such an offence (in the same and analogous way as the State would have had to do the same if it had been the actor seeking to inflict the judicially-ordered punishment(s) in question) then they cannot invoke the defence of 'private penalisation', for since the private actor is claiming in stand in a substitutive position to that of the State in inflicting the punishments in question, he or she can stand in no better position than the State would have been in if the State had been the actor seeking to inflict the particular penalties at issue upon their victim or victims. Thus, the test for whether the victim of the said torture or killing was guilty of the offence in question was a pure objective question of fact which did not depend upon the state of mind or knowledge of the defendant. Therefore, the defendant could not seek to argue that he or she honestly or even reasonably believed their victim to be guilty of that offence, he or she would have to go further and prove, as a matter of objective fact, beyond a reasonable doubt, that that victim had actually committed the offence in question, if not he would be guilty of the offences of murder and/or torture irrespective of their individual state of mind at the time of his or her offending (see, Louis Paradis at [94]-[96]). Since the common law defence of 'private penalisation' had never been put to the jury at the trial below, the petitioners' convictions on the charges of murder and torture were unsafe and had to be vacated and remanded for a fresh trial (see, Louis Paradis at [98]).

Although not strictly necessary at all to resolve the dispute before the court, Le Lord Président Romain de Saint-Aulaire went on to make additional obiter dicta remarks that, in his own view, the nineteen acquitted defendants had been guilty of the common law offence of treason, proven beyond a reasonable doubt, for deliberately joining and working for a criminal terrorist organisation that was in the midst of active hostilities against the Purgation State by waging and levying an ongoing terroristic war of Islamist insurrection against the Purgation polity and people (The Brigade of Deir Yassin), and that the fourteen jurors had also been guilty of treason in the eyes of the common law for giving intentional aid and comfort to the enemies of the Purgation community through their deliberate acquittal of the nineteen Islamist terrorists whose guilt for such offences, in the view of the court, "had been most clearly and unambiguously demonstrated and was therefore not even reasonably or conceivably open to be questioned by any faithful, loyal, and right-thinking member of our community" (see, Louis Paradis at [103]). He even went further to make additional obiter observations that the common law offence of treason would not be made out in respect of members of the volontaires auxiliaires whose actions were "attempts to vindicate the constitutionally anchored form of the sovereign Purgation State in line with the deeply rooted constitutional traditions considered in conformity with the entire legal history of this jurisdiction as a whole", while the offence "would be made out in respect of deviant and transgressive actors seeking the wholesale destruction of, or the infliction of deleterious injury upon, the sanctity and integrity of the intrinsic constitutional framework that has governed our nation and people for centuries", and named such actors as the Communist Party of Purgatio (CPP) and its armed wing L'Épée du Peuple as examples of groups that were acting against the "constitutionally anchored framework of the Purgation State" as opposed to seeking the proper vindication, restoration, and re-establishment of the socio-political integrity thereof, in order to distinguish the outcome of Louis Paradis from the seemingly discordant and contradictory result reached in Thierry Neveux (see, Louis Paradis at [107]). While one can only speculate as to why the court felt the need to go further in making these additional obiter comments which were not necessary to resolve the 'petition for cassation' presented before the court, a possible explanation is that these clarifications were a pre-emptive attempt to prevent the newly invented common law defence of 'right of private penalisation' from being exploited by the political left to provide cover for their acts of public disruption or political violence, by establishing clearly that the defence was only available, in the eyes of the court, to political actors fighting to 'defend' the historically ordained and constitutionally anchored form of the Purgation State (i.e., far-right groups like the volontaires auxiliaires in the case of Louis Paradis) and was not available to political actors fighting against such defenders and/or fighting to overthrow or undermine that same historically, traditionally, and constitutionally anchored framework of the Purgation State (i.e., far-left groups such as the CPP and L'Épée du Peuple or other left-wing civil society groups and activists such as those whose criminal convictions were contrastingly upheld in the case of Thierry Neveux). It should also be noted for completeness that, while the Supreme Court vacated the petitioners' convictions and remanded the case back to the Court of First Instance (CFI) for a fresh trial, the Federal Prosecution Service (FPS) actually withdrew all charges against the two defendants and declined to prosecute them any further in light of the court handing down its judgment in Louis Paradis, expressing the view that the newly judicially recognised common law defence of 'private penalisation' was fully and satisfactorily made out on the facts since the victims had all been guilty of the common law offence of treason, thereby demonstrating the similar reactionary sympathies of the Purgation federal prosecutors towards the burgeoning political right.

[Purgatio]

While the rendering of the Louis Paradis judgment had been met with a predictably enthusiastic and celebratory reaction from the Purgation far right, with the PNL issuing an official statement on 4 March 1983 terming the outcome a 'vindication' of the 'brave and valient heroes Messieurs Louis Paradis and Nicolas Charlet' who 'far from being traitors, were protectors of our realm and fighters selflessly laying down their lives and liberties for the safety, security, and freedom of our people and compatriots', the reaction from the mainstream Purgation political spectrum at the time was much more alarmed and condemnatory. The Prime Minister (PM) of the PDP minority government, Émile-Auguste Mousnier, condemned the Supreme Court's reasoning as a 'dangerous endorsement of terrorism and vigilantism' and a 'grave threat to political freedom and civil society', and the Leader of the Opposition (LO) and Party Leader of the LPP, Florence Ghesquière, echoed such sentiments and remarked in the PNC legislative debates on that decision that the Supreme Court had 'struck a blow against democracy and a free and civilised order' and 'run roughshod over our basic constitutional compact and our freedom from senseless slaughter and inhumane brutalisation as was guaranteed by the Framers of our republican constitution'. Attempts were made to overturn the Louis Paradis decision through legislation, but none of them came to fruition, because the dominant political actors at the time were deeply divided as to the appropriate response to the Supreme Court's decision. The PDP leadership under PM Émile-Auguste Mousnier wanted to simply abolish the common law defence of 'private penalisation' and to clarify by express legislation that all acts of violent insurrection against any governmental organs would constitute treason irrespective of whether the court deemed the target to be part of the 'constitutionally anchored form' of the Purgation State or not. However, the PDP was a minority government, holding only 379 seats in the PNC out of a total of 860 seats, below the threshold of 431 seats needed to have an outright legislative majority. Therefore, the PDP depended upon the Purgation Libertarians (PL), which held 46 seats, to remain in power as a minority government under a flexible 'confidence and supply' arrangement, although even then, the PDP and PL parties only held 425 seats between them, meaning even if all PDP and PL legislators acted together, unanimously, without dissent, they would still need a handful of crossover votes from the other side, especially from the largest opposition party at the time, the LPP, which held 371 seats, to pass any Congressional legislation by a simple majority vote. However, neither the LPP nor the PL were supportive of the proposals of the PDP minority government to overturn the Louis Paradis holding of the Supreme Court. The LPP wanted also to codify the common law offences of treason, murder, and torture, and to amend and/or clarify aspects of these offences to limit the scope of these crimes (which, in the past, had been defined entirely through judge-made common law reasoning), but the PDP minority government disagreed with such proposals because it feared that its conservative base would not support any limitations upon the scope of such offences and, from a pragmatic perspective, feared that such legislation could be easily twisted by the PNL as a 'soft on crime' measure designed to make it harder to convict defendants for such serious offences like treason, murder, and torture, which could be conveniently portrayed on the campaign trail as an attempt to make it easier for such crimes to be committed without any consequence and accountability. Meanwhile, the PL opposed the proposal because it wanted the PDP minority government to go further and abolish the crime of treason altogether and to place cognisable limits upon the ability of the police forces to invoke the common law defences of 'private defence' and the 'prevention of crime' in addition to abolishing the newly recognised defence of 'private penalisation'. Such radical proposals were anathema to the comparatively moderate PDP and LPP legislators, but the PL legislators absolutely refused to support any legislation that did not incorporate such reforms. Meanwhile, the communist legislators in the CPP (who held only 24 seats at the time) obviously opposed the Louis Paradis judgment, but since they also opposed the Thierry Neveux judgment, they refused to lend support for any legislation to repeal the Louis Paradis holding unless it also repealed the Thierry Neveux holding at the same time. This was supported by some of the PL legislators (and opposed by others) but was absolutely opposed by the great majority of the PDP legislators as well as the centre-right LPP legislators who were staunch anti-communists and largely supportive of the Thierry Neveux decision because it provided greater latitude and freedom for the authorities to crackdown on the Purgation far-left. Lastly, the PNL legislators (who held 33 seats) and the white supremacist Patriotic Front of Purgatio (PFP) (which held 7 seats) were supportive of the Louis Paradis decision and would not countenance any legislation seeking to overturn or repeal the Supreme Court's holding therein. Hence, the politically fractured state of the PNC had the oxymoronic result that while the overwhelming majority of Congress consisted of political parties that were opposed to the ratio decidendi of Louis Paradis and wanted that holding overturned (i.e., the PDP, LPP, PL, and CPP, which together held 820 out of 860 seats in Congress), no legislation could be passed even by a simple majority to achieve that rather simple outcome because none of the political parties were willing to compromise from their positions or give up their particular demands to reach a compromise proposal, which had the ironic effect of allowing that more ideologically extreme Supreme Court judgment, supported by only a tiny minority of the political parties in the PNC (i.e., the PNL and PFP, which held only 40 out of 860 seats in Congress), to stand completely unchallenged and unamended. This position was only further complicated by two additional difficulties - first, that some constitutional scholars argued at the time that since Louis Paradis had engaged questions of constitutional interpretation, that any effective overturning of that decision would actually require a two-thirds supermajority vote of Congress (which was obviously a complete non-starter since the PDP minority government could not even pass its proposed repeal of Louis Paradis by a simple legislative majority vote); and second, any such legislation, even if passed by Congress, would need to be signed into law by the President, and the elected President at the time, Pierre de Craon, while being from the PDP political party, hailed from the more traditionalist conservative right-wing of the PDP and had expressed tacit support for the Louis Paradis decision, or rather, more accurately, his office issued a vague, non-descript statement that while he 'regretted' the court's decision he 'understood' the public anger that motivated the outcome and was 'sympathetic' to the plight of the victims of the Genovese Market attack and Islamist terrorism more broadly, ending off his statement with an equivocal remark that he hoped that the families of the victims of that mass shooting were able to find some measure of comfort, solace, and closure from the final outcome of that tragedy, an extremely ambiguous statement which was difficult to parse and which only cast further doubts upon whether the President would or would not sign such legislation overturning Louis Paradis into law. This provides a clear and useful illustration of how the constitutional paralysis and political diversity of other constitutional organs and bodies of power in the Purgation State had the effect of giving the Supreme Court practical free reign to make and unmake the common law as it pleased without having to fear the prospect of legislative or constitutional retaliation, no matter how politically unpopular or controversial the decision may be; and thus, regardless of the stern words and condemnatory remarks that politicians had for its most recent judgment, Louis Paradis would nevertheless remain the law of the land.

The combined effect of such groundbreaking decisions as Media and Culture Ministry c. Aumont, Thierry Neveux, and Louis Paradis was, predictably, to further embolden the Purgation fascists and reactionaries on the far right to inflict violence, harassment, and persecution upon their political opponents with impunity while not only withholding that same immunity to similar actions emanating from the Purgation far left (or even centre-left and more socially democratic groups, human rights activist organisations in civil society, or the organised labour movement) but according a similar practical immunity to the police and prosecution to inflict acts of harassment and persecution upon the political left which would have plainly been regarded as unlawful and unconstitutional if inflicted in similar form upon the political right. In this way, the legalistic philosophy and jurisprudential adjudicative approach of 'common law interpretivism', adhered to by the Purgation State's Unified Judicature, its superior ordinary courts of law, and by the Supreme Court in particular, had the effect of fashioning the Supreme Court into a politically traditionalist and reactionary force, functionally and as a matter of practice, providing justification for the Supreme Court to 'look back' and rely upon older and archaic monarchist, royalist, and feudalistic rulings and precedents to import those principles into present day legal disputes on the pretextual justification of effectuating a 'harmonious' reconciliation of modern day legal outcomes with previous legal outcomes still holding precedential weight and authoritative value in the eyes of the present Purgation Judiciary. This reactionary and conservative methodology of judicial adjudication culminated in the Supreme Court's famous ruling in Re Ministry of Justice No. 74/1988, the seminal unanimous decision of the Supreme Court which provided a legitimising judicial imprimatur and legal stamp of approval to the PNL fascists' takeover of the Purgation State's governance and the wholesale dismantling and destruction of her liberal democratic socio-constitutional order, by formally recognising the unchecked absolutist authority of the Magnificus Dominus to govern however he pleased without legal constraints or limits based on a newly recognised constitutional norm of Le Principe du Chef (viz., the so-called 'leader principle'), which the Supreme Court similarly rationalised, on a 'common law interpretivist' model of adjudication, as a return to, and restoration of, the once unified and integrated sovereignty originally and historically vested in a single person - Le Saint-Roi or La Sainte-Reine, the absolute monarch of the old Purgation Valois feudal monarchy - which had now been re-unified and re-consolidated into the Magnificus Dominus, who was the new living embodiment and expression of all the sovereign powers of the Purgation State rolled into one, just as the Purgation State had been before the revolution (see, Re Ministry of Justice No. 74/1988 at [77] and [79]-[80]).

In this way, the Supreme Court successfully paved the way forward for the downfall of liberal democracy and the rise of reactionary fascism in the Purgation State, and its promulgation of the landmark constitutional judgment in Re Ministry of Justice No. 74/1988 merely christened the radical new constitutional order which it had fought so hard to usher in through its consistently traditionalist and culturally reactionary jurisprudence constante, thereby demonstrating the true power and influence that the ingrained jurisprudential philosophy of 'common law interpretivism' has had in forevermore changing and fundamentally altering the socio-legal shape of political developments in the Purgation State, spelling the death-knell of Purgation liberal democracy and ushering in reactionary, counter-revolutionary politics that sweepingly reversed the reforms of the Purgation Revolution.

[Purgatio]

TECON-TECAT Parallel Tribunal Regime for Genetic Re-Classifications

Two of the most powerful adjudicative organisations throughout the Unified Judicature of the Purgation State, acting in a judicial or quasi-judicial capacity, stand as a parallel justice system standing side-by-side with the ordinary courts of law, vested with a separate and insular sphere of juristic compétence all of their own. They are Les Tribunaux Extraordinaires pour la Conservation de l'Organisme National, roughly translated as "The Special Tribunals for the Preservation of the National Organism" (also known as "TECON" for short), and the standing body that hears appeals against awards and decisions rendered by individually constituted TECON tribunals, known as Le Tribunal Extraordinaire de Cassation aux TECON, roughly translated as "The Special Tribunal of Annulments Against the TECON" (and also known as "TECAT" for short"), which sits in the city of Limogens, the provincial capital city of the District of Villehardouin. Collectively, this parallel justice system and procedural mechanism is often referred to as the "TECON-TECAT Parallel Tribunal Regime" as a very common colloquialism, having percolated into the commentary and oft-used lexicon of jurists and academics in particular.

The TECON-TECAT Parallel Tribunal Regime was established by the Magnificus Dominus in consultation with the standing 27-member Executive Directorate of Purgatio (EDP), when, on 8 February 2011, he formally promulgated into law Executive Order (EO) No. 26 of 2011 or EO 26/2011, more often referred to by journalists and commentators as the "Special Tribunals Establishment Ordinance". The legislative object and purpose of the Special Tribunals Establishment Ordinance had been to erect a formalised legal process for the determination of persons' legal classifications as either Génétiquement Sain or Génétiquement Dysfonctionnel, which would carry serious legal implications, given that a person labelled as Dysfonctionnel by law cannot enjoy the rights and privileges of Purgation State citizenship and, more significantly, would be subjected to the Tripartite Commission's prevailing 'liquidation through labour' regime erected under the authority of Executive Order (EO) No. 103 of 1994 or EO 103/1994 (often referred to as the "Dysfonctionnel Nationwide Liquidation Decree"), providing for the State-sanctioned eradication of the Dysfonctionnel through a regimen of forced labour, malnourishment, and taxing overwork, thereby constituting a legal classification of grave and immense significance.

Despite the extreme and unvarnished seriousness of the practical implications accompanying the Sain-Dysfonctionnel distinction in law, prior to the enactment of the Special Tribunals Establishment Ordinance, there had been no formalised process or regularised procedure for determining genetic re-classifications of such persons, and the manner in which individuals were singled-out and targeted for State persecution as a so-called Dysfonctionnel individual was often erratic, capricious, haphazard, and entirely irregular in nature. Regular PPF police officers, PICOS secret police forces, and irregular Purification Order paramilitary soldiers, would often make arbitrary arrests or round-ups of troublesome, disruptive, and perceived disorderly and antisocial elements of their local community and detain them without trial or due process, taking advantage of the 'Article 27 emergency legislation' enacted by the PNL-PDP Coalition Cabinet in the immediate aftermath of the 1987 legislative and presidential elections. Such persons were deemed to be phenotypically Dysfonctionnel merely by virtue of such suspicion and detention from these official authorities alone, as part and parcel of the fulfilment of the PNL's 1987 campaign promises to secure "Law and Order at any cost whatsoever" which included the elimination of such due process protections and procedural safeguards in order to grant law enforcement officers free reign to crackdown upon the activities of Marxist-Leninist insurgent groups like L'Épée du Peuple, The Brigade of Deir Yassin terrorists, Les Frérots criminal syndicate members and gangsters, the recent spate of 'Asian grooming gangs', and other such dangerous or disorderly elements of society against which the impatience and frustrations of the Purgation electorate had finally broiled over, without being burdened by checks and balances and thresholds for seizure and detention which would serve to hamper the practical efficacy of such preventative security measures and the deterrent effects thereof.

Consequently, when the Director of the PIGC came to eventually promulgate PIGC Order No. 86 of 1988 on 7 October 1988 (also known as the "Genetic Identification Ordinance"), laying out a list of characteristics which were regarded as 'genetically disordered' and guidelines for how the Auspex Operandi predictive algorithm would classify genomes in the national DNA database as Sain or Dysfonctionnel based on allelic frequencies, there had already been an ingrained pre-existing practice of the PPF, PICOS, and Purification Order troopers and officers seizing and detaining alleged antisocial and disorderly elements of their local neighbourhood on suspicion of their involvement in various criminal or seditious activities. Within that environment, the Genetic Identification Ordinance only provided further cover for such law enforcement officers to continue such conduct because the broad grounds in that order for deeming a person to be 'disordered' meant that, in practice, such organisations had extremely broad discretion to exercise their arbitrary judgment to determine whether or not a person would be seized and detained as Dysfonctionnel. In practice, these powers were wielded as weapons to quickly and conveniently deal with more troublesome elements of the neighbourhood deemed to be a 'nuisance' and a 'menace' existing to the general annoyance of others. For example, the local drunk who got heavily intoxicated every weekend and would often shout and scream incoherently in the faces of random passers-by on the street, to the considerable alarm and distress of his neighbours, could be reported to the local Purification Order paramilitaries for him to be seized and detained for being a social nuisance. If his detention came to be challenged or questioned by anyone, the Purification Order need only point to the broad terms of the Genetic Identification Ordinance to retroactively justify the seizure, pointing out that the detainee is an antisocial, disorderly, and/or parasitical element of the community, constituting a 'vandal' (for his public nuisance and disorderly behaviour), a 'vagrant' (for roaming about in public without visible means of support or sustenance), or an 'addled and incontinent' person (for his frequent and habitual intoxication and general drunk and disorderly behaviour), or a combination of any or all of the above. Consequently, in practice, the decree simply gave law enforcement authorities broad discretion to maintain public peace, order, and tranquility howsoever they pleased to meet the needs of the local neighbourhood, by seizing and locking up any disruptive or antisocial elements of their community and then retroactively justifying such arrests by invoking one of the many vague and ambiguous grounds for deeming a person to be 'genetically disordered' listed under the Genetic Identification Ordinance. The Home Office (if a PPF officer made the arrest), PICOS (if a PICOS trooper made the arrest), or the Purification Order (if a private paramilitary made the arrest) would then forward their 'seizure report' to the PIGC scientists, laying out their broad grounds for exercising their discretion to arrest a particular person on the grounds of being a threat to public order in some capacity, and the PIGC would take the report at face value and make the necessary editing of their formal legal classification in the Auspex Operandi from Sain to Dysfonctionnel. This was the arbitrary and haphazard way in which the so-called 'primary data' in the Auspex Operandi database was received and recorded, following which the Auspex Operandi would work off of that primary data to generate secondary results and classifications by generating a predictive algorithm intended to assess the relative likelihood or probability of other genomes in the database being classified as Dysfonctionnel based off of their genetic data and allelic frequencies alone and their genome's relative proximity to, or dissimilarity from, the remainder of the primary data that the system had been fed.

This system of arbitrary arrests and detention without trial, which was culturally and socially normalised in a high-crime society at the time, was only further cemented when the GEM launched their insurgency campaign against the PAF regular armed forces in 18 November 1990, beginning a gruelling civil war which would not thaw or dissipate until around the First Cleansing War of 2000-2002, more than a decade later. In that disorderly and chaotic environment, there was an even stronger impetus for the EDP Government to give members of the PAF armed forces, as well as PICOS troopers and Purification Order paramilitaries assisting the PAF in maintaining their firm control and occupation over GEM-infested regions of the country, even greater freedom and latitude to seize and detain any suspected members of the GEM insurgency at their discretion and, more broadly, any Dysfonctionnel persons deemed likely to be a supporter of the GEM lending comfort and assistance to their seditious, terroristic cause, a general policy mandate which eventually broadened to indiscriminately include the entire Dysfonctionnel community more broadly. Such circumstances of emergency and exigency, first against the scourge of organised syndicated offences and violent criminality plaguing the inner cities and densely-populated urban areas in 1987-1988, followed by the gruelling and taxing civil war of 1990-2000, led to a widely accepted practice of the EDP Government according to PICOS and the Purification Order a significant measure of deference and latitude in favour of their free exercise of discretionary judgment to police disordered elements of the community howsoever they pleased and to seize and detain any troublesome or annoying elements of society if they deemed it necessary or beneficial to maintain general societal peace, tranquility, and harmony, in order to more efficiently and efficaciously root-out supporters of the GEM insurgency and other such anti-governmental oppositional segments of the community that could potentially threaten the stability of prevailing PNL rule over the Purgation State, with the regular PPF police force and regular PAF armed forces - as well as the rest of the EDP Government - largely acquiescing to such a concerted practice given the unique circumstances of the prevailing national crisis and the disordered and dangerous wartime circumstances of the day.

In January-February 2011, however, after the Second Cleansing War of 2006-2009 had been fought to a stalemate and PICOS and the Purification Order had had several years to detect and mop up scattered pockets of Dysfonctionnel elements within the conquered Occupied Territories, and the civil war against the GEM was deemed to be long over and in the distant past, the EDP Government's strained and waning tolerance for such a chaotic and irregular system of detecting Dysfonctionnel and allegedly 'antisocial' elements of the community, unchecked by any prevailing legal process or established procedures, had begun to fade away, and there was an increasing appetite for a more formalised and regularised due process for determining the applicable criteria and circumstances governing whether a person should or should not be re-classified from Sain to Dysfonctionnel in the Auspex Operandi system based upon their perceived phenotypical expressions with reference to their allegedly parasitical conduct (this may be contrasted with a 'genotypical' re-classification as such, where the Auspex Operandi algorithm makes an automatic prediction that a person is Dysfonctionnel based solely upon the contents of their genetic data and the relative allelic frequencies thereof, as opposed to being based upon that person's conduct or alleged conduct). This was the historical and contextual background behind the procedural mechanism erected in the Special Tribunals Establishment Ordinance, which came into effect on 1 January 2012 after all of the necessary and incidental procedural rules had been discussed and drafted and all of the relevant judicial appointments had been duly-effected. Now, the process for effecting a 'genetic re-classification' before the TECON-TECAT Parallel Tribunal Regime may be divided into the following stages - Stage One: Identification; Stage Two: Complaint; Stage Three: Detention; Stage Four: Assessment; Stage Five: Institution; Stage Six: Negotiation; Stage Seven: Hearing; Stage Eight: Award; Stage Nine: Appeal; Stage Ten: Review; and finally, Stage Eleven: Liquidation. Each of these stages of the genetic re-classification process will be discussed individually and in turn.

The first stage, that of Identification, refers to the very beginning of the process when the potential genetic re-classification respondent is brought to the attention of one of the three designated 'stakeholders' in the re-classification process (i.e., the Home Office, the PIGC, or PICOS). This can happen in a number of different ways and for a very wide spectrum of varied reasons, due to the broad categories outlined in the PIGC's Genetic Identification Ordinance and reiterated in the Special Tribunals Establishment Ordinance under which a person may be regarded as 'genetically disordered'. These are as follows:

• "Vandals" (meaning persons engaged in riotous, disruptive, or disorderly behaviour contrary to societal harmony, discipline, and good order, including criminals, delinquents, hooligans, and gangsters);
• "Cripples" (meaning persons with a debilitating physical or mental disability resulting in their inability to support themselves or maintain their own unkeep);
• "Vagrants" (meaning persons roaming about public spaces without visible means of self-support or self-sufficiency, including the homeless, panhandlers, vagabonds, and other derelicts);
• "Work-shy moochers and leechers" (meaning persons deemed incapable of self-reliance with a tendency to burden societal resources, including the persistently unemployed, severely impoverished, those deemed to be burdening welfare or social and public services for an extended period of time, and those who repeatedly default upon regular payments);
• "Insane and unsound" (meaning persons with psychological impairments or cognitive ailments severely impacting their capacity to contribute to society);
• "Addled and incontinent" (meaning persons regarded as incapable of exercising self-control or restraining their impulses due to a chronic addiction, including addictions to sexual activity, gambling, abuse of psychoactive drugs, nicotine, and alcohol);
• "Indolent and slothful" (meaning persons who are morbidly obese for a prolonged period of time); and,
• "Imbecilic, retarded, and feeble-minded" (meaning persons with intellectual impairments or a severely low IQ of below 70).

However, a few points should be noted about the above categories. First of all, they should not be viewed as rigid and immutable rules, but part and parcel of a broader, more flexible multi-factorial analysis. In other words, it is not the case that just because a re-classification respondent may be said to fall into one of the above categories, that automatically ipso facto renders them Dysfonctionnel in the eyes of the law. Rather, the above categories are not rules but factors and considerations which the tribunal is to take into account as part of a broader, holistic inquiry into whether the re-classification respondent has an underlying genotype which results in them bearing a permanent and pathologically "antisocial, deviant and/or parasitical disposition" (Art 1(1), Genetic Identification Ordinance and Art 1(2), Special Tribunals Establishment Ordinance), which is the real underlying question which determines whether a person is to be classified as Sain or Dysfonctionnel in the eyes of the law. Secondly, the above eight categories are, at least in theory, not intended to be exhaustive, hence conceptually a person may still be regarded as Dysfonctionnel if they are demonstrated to bear an "antisocial, deviant and/or parasitical disposition" overall, irrespective of whether they may be said to fall into any of the aforementioned eight categories. In practice, however, the categories are so broadly worded that it is generally not difficult for the complainant to slot the re-classification respondent into at least one of the above categories, and in the vast majority of re-classification cases the complainant tends to argue that the respondent falls into multiple of the above eight categories in order to strengthen the case for re-classification and demonstrate to the satisfaction of the tribunal that the respondent is a net burden upon the Purgation State and their general existence in society is a net loss to the well-being of the Purgation people.

Broadly speaking, a re-classification respondent usually comes to the attention of one of the three designated 'stakeholders' in the TECON-TECAT re-classification process via one of three routes, which may be referred to as the "Criminal Prosecution Route", the "Public Disorder Route", and the "Social Services Route", for the sake of convenience. The Criminal Prosecution Route is the most straightforward - where a criminal is charged and prosecuted by the Crown Prosecution Service (CPS), which is helmed by the Procureur-Général du Roi (or Procureuse-Générale du Roi, as she presently is) and staffed by various des procureurs du roi, during the pendency of the prosecution, the 'stakeholders' will be kept apprised of the status of the investigations and the prosecutorial proceedings. The 'stakeholders' will come to an internal position as to whether they believe the offence merits genetic re-classification, depending on such factors as the severity of the crime and the profile of the offender. In the event that the 'stakeholders' come to the conclusion that the offence does merit re-classification, then in the event of a conviction, one of the 'stakeholders' (usually PICOS, by convention) will file an official 'complaint for re-classification' to the Attorney-General's Office. The prosecutor, being apprised of this, will seek a 'stay of execution' of sentence, and the convicted criminal will be transferred to a PICOS concentration camp for the remainder of the re-classification process. This is the most straightforward of the three routes for such identification given that there is a structured process that immediately precedes and sets the stage for the later re-classification proceedings (i.e., the criminal prosecution and conviction). It is also quite common, especially for 'intermediate offences' tried before the Royal Court of Justice (RCJ) and the less serious of the offences triable before the Court of First Instance (CFI), for re-classification considerations to pervade the plea bargaining process between the prosecutors and the defendant. Thus, the prosecution may offer a deal to the accused for them to plead guilty to the charges in exchange for an undertaking secured by the prosecutors from the relevant 'stakeholders' that in the event of a guilty plea, no re-classification proceedings will be instituted against them. In contrast, for the more serious of offences triable before the Court of First Instance (CFI), re-classification proceedings are practically inevitable in the event of a conviction, hence plea bargains are rare to non-existent in that context, while on the other end of the spectrum, most offences triable before the Courts of Seizures and Courts of Partitions generally do not result in re-classification, hence guilty plea offers are frequently extended in these courts for offenders to plead guilty in exchange for a barristers' undertaking from the Crown prosecutors promising to ensure no re-classification proceedings are instituted against such defendants (with over 90% of such prosecutions being settled by guilty plea bargains), save only for a small minority of defendants who appear before these courts with extensive criminal histories and lengthy lists of antecedent convictions on their record.

The identification of a potential re-classification respondent via the Public Disorder Route, however, is less straightforward and can take a variety of many different forms. Sometimes, a regular PPF police officer or Crown prosecutor believes that certain minor public order offences or cases of antisocial behaviour are simply too minor or trivial to merit formal prosecution. However, if the person has been a 'repeated public nuisance' and has been the subject of multiple complaints from the local community, the police officer or prosecutor may nevertheless believe that a meritorious case exists for genetic re-classification on the grounds of the respondent's general recalcitrance and their repeated 'nuisance behaviour(s)'. In such circumstances, the police or prosecutors will write directly to the 'stakeholders' informing them that they do not intend to press charges against the respondent, but given the history of the respondent's behaviour, they are of the view that re-classification proceedings are needed. The 'stakeholders' will then perform their own internal assessment of the facts and determine for themselves whether or not to exercise their right to institute a 'complaint for re-classification' to the Attorney-General's Office (AGO). However, the police and prosecution are not the only organs that may raise a potential respondent to the attention of the 'stakeholders' under the Public Disorder Route. In fact, many such complaints originate from local councils and local authorities instead, following their identification of a member of their own neighbourhood who has been a general 'thorn in the side' and a repeated nuisance or annoyance to the community due to their disruptive or antisocial behaviour. These may, in turn, have originated from members of the community complaining to the local council about the potential respondent's behaviour, including from parents' groups, local school boards, homeowners' associations, neighbourhood watchmen, and real estate agents or developers concerned about the property prices of the area due to the actions of a particular individual. In particular, it is very common for 'vagrants', 'tramps', and so-called 'drifters', 'beggars', and 'vagabonds' to be caught up or swept up in the re-classification process via this route, where members of the community tire of the various social ills deemed to be associated with the presence of the homeless in their community, deeming that individual to be an irritation, an eyesore, a danger to their children, or an unhygienic irritation they simply do not want around anymore. Persons who repeatedly annoy members of the public with their continual and persistent antisocial behaviour may also find themselves the subject of complaints to their local council, including persons who persistently fail to amend their behaviour for a prolonged period of time after many repeated noise complaints, complaints about indoor smoking in prohibited areas and enclosed accommodations, or other complaints about, for example, their public drunkenness, loud, disruptive, and disorderly conduct in public, public nudity or other lewd and obscene behaviour in public spaces, public harassment or intimidation, vandalism and littering, public defecation or urination, general rudeness, noise pollution, offensive singing, public spitting, other broadly nauseating or uncomfortable behaviours in public, and so on and so forth. Depending on the severity of the behaviour and repeated or prolonged character of the conduct alleged, the 'stakeholders' may or may not agree that the gravity of the complaint from the local council merits a re-classification action. If they regard the complaint as being exceedingly trivial or minor, they may simply dismiss the report as a petty local municipal complaint not meriting re-classification or any further action. Nevertheless, this is still a judgment call for the 'stakeholders' to make once the report is brought to their attention by either the local council or local police, and the 'stakeholders' will consider the circumstances and the severity and gravity of the public disorder alleged to determine if the person should in fact be genetically re-classified, especially having regard to the personal history of their conduct in the community and how they responded to past complaints about their antisocial behaviour. Given the broad variety of circumstances that could potentially trigger a report to the 'stakeholders' under the Public Disorder Route, the practical reality is that local councils and local police far are more likely to simply threaten to make a report to the 'stakeholders' as a tool to inflict fear and extract compliance from a recalcitrant offender who has begun to seriously annoy and irritate the local community than to actually make such a report unless the circumstances truly worsen over time. In this way, threats to report a so-called 'nuisance individual' to the 'stakeholders', especially to PICOS or to their local Purification Order paramilitaries (to take immediate action and then bring the matter to the attention of PICOS thereafter) are very commonly uttered in the context of local neighbourhood disputes or community rows and arguments, and plays a huge role in influencing how people behave in such local municipal disputes even though only a small fraction of such public order complaints will ever escalate to the grave and serious level of an actually instituted genetic re-classification action.

Finally, there is the Social Services Route, where a potential re-classification respondent is brought to the attention of the 'stakeholders' by a provider of various public services, including healthcare providers, education providers, social services and welfare agencies, and local councils providing various municipal services to the community. Various social agencies and statutory bodies under the charge and supervision of the Department of Welfare, Work, and Pensions (DWWP) continue to administer a number of means-tested, anti-poverty welfare programs which are holdovers of the pre-PNL Purgation State's more liberal welfare policies, which were trimmed and curtailed by the PNL regime but not altogether eliminated. Such payments include short-term unemployment payments, means-tested child benefits schemes, coupons for the education of children in low-income households, jobseeker's allowances, means-tested medical subsidies for private insurance premiums, means-tested renters' assistance, income tax credits for lower-income earners, public transport rebate schemes, and so on. Many of these payment schemes were subjected to severe cuts and stringent austerity measures in the aftermath of the PNL's takeover of the Purgation State's governance, with a series of quantitative caps on the amounts payable under these schemes, tightened means-tested eligibility criteria, and time limits regarding the length of time a person can remain on such programs before being cut-off and disqualified. More importantly, however, the DWWP maintains a register and record of all persons receiving any payments under any DWWP social program, monitoring the length of time they have remained under various schemes, how long they have remained under certain schemes, how many schemes they are claiming welfare under, and the total amounts paid out to a person during their lifetime. The DWWP maintains certain internal departmental guidelines as to the circumstances under which it will 'flag' a welfare recipient as a potential 'moocher and/or leecher' for the purposes of the Genetic Identification Ordinance. In such a scenario, it will immediately cut-off all further social payments to the recipient and file a report with the 'stakeholders' bringing to their attention a potential re-classification respondent. The primary purpose of this system is to heavily deter and dissuade persons from turning to social welfare and assistance to begin with, in order to allow the DWWP to conserve limited public funds and resources and to minimise the quantity of such welfare payments and hand-outs. Hence, it is common for DWWP officers to send 'warning letters' to benefits recipients urging them to voluntarily cease claiming payments with an implied or sometimes express threat to report the recipient to the 'stakeholders' accompanying the said letter. DWWP welfare agencies and social assistance administering bodies are not the only organs which make reports to the 'stakeholders' under the Social Services Route. Another major source of reports is the healthcare sector, specifically doctors, nurses, and hospital administrators. Under prevailing medical professional rules, all licensed medical practitioners and nurses, whether in government-run hospitals, not-for-profit private charitable trusts, or for-profit private hospitals, have to be on the alert for what the profession calls 'self-inflicted illnesses and/or afflictions of election', in other words, lifestyle diseases deemed to be attributable to the fault and choice of the patient. These are self-regulated professional rules instituted under authority of the 1990 Congressional legislation known as the Enabling of Anti-Dysfonctionnel Exclusion Act, and were implemented under heavy pressure not only from the PNL-controlled Ministry of Health and Human Services (MHHS), but more significantly, from the private health insurance industry as well, which saw an opportunity to bring down average premiums while increasing profit margins at the same time by outsourcing to doctors and nurses the responsibility of identifying and curtailing 'problematic patients' responsible for increasing premiums for all other insurance customers. The Purgation Medical Association (PMA) adopted these rules in 13 August 1990, and in a departure from medical ethics rules in other jurisdictions, the PMA codified the 'paramountcy principle' which states that the first and paramount patient which the doctor owes an overriding duty to is not the individual patient they are serving but the health and well-being of the entire national body, constituting the general body of potential patients whose collective health and safety should be the first and paramount priority for every doctor and nurse to safeguard and protect. Based on that justification, the PMA imposed a self-regulated professional duty upon all doctors to identify when a patient in their hospital is suffering from an illness which is self-inflicted or due to the fault of the patient, with examples of such including lung cancer and ephysema for smokers, liver cirrhosis for drunkards, emergency room patients suffering from voluntary drug overdosing, atherosclerosis and pulmonary heart disease for obese patients, Type 2 diabetes for patients taking excess sugar, self-immolation in the case of suicidal or clinically depressed patients, sexually-transmitted illnesses for promiscuous patients, and so on. Where a doctor identifies a patient as suffering from a 'self-inflicted illness', they are required to report the patient to the PMA and place the patient on a nationwide 'no-treatment list', meaning that all licensed doctors across the nation are prohibited from applying any medical treatment to that patient whatsoever, on pain of revocation of their licence to practice medicine, potential administrative sanctions from the Ministry of Health and Human Services, and even criminal sanctions if the requisite mens rea of intentionality or knowledge is present. There is a process for patients to apply to the PMA to be removed from the national 'no-treatment list', which typically requires the patient to satisfy the PMA that serious and sincere efforts will be made on their part to correct the self-inflicted condition - for example, if the patient has been flagged as obese and suffering from atherosclerosis, they may be treated with the permission of the PMA board but on the strict pre-condition that they undertake to meet certain weight loss goals or follow a particular eating and exercise regimen. There is a residuary discretion for doctors to report the patient to the PMA as having a 'self-inflicted illness', but to treat the patient anyway in an emergency time-sensitive scenario, where, in the doctor's view, the self-inflicted illness is a one-off or incidental or isolated incident not reflective of the patient's overall disposition, such as where it is the first time the patient has suffered such a serious illness as a result of their self-inflicted condition, and they are satisfied of the patient's sincere commitment to change their behaviour. However, conversely, if the doctor notes a long and extensive history of the patient suffering from a whole host of lifestyle illnesses without change or modification to their conduct, then they must file a report with the 'stakeholders' seeking a genetic re-classification of their patient on the grounds of the patient being a burden to society generally and to the limited resources of the healthcare industry more specifically, or risk sanctions from the PMA or commercial backlash from the insurance industry. A similar process exists in respect of physically or mentally disabled patients requiring particular care and attention from the medical industry, even if not self-inflicted. If the doctor is of the view that the disability is relatively mild and does not prevent the patient from living a self-sufficient, self-reliant life or deprive them of the ability to maintain themselves, they are not required to report the disability and may continue treating the patient normally. However, if the disability is a congenital disability (such as a genetic disorder) or a self-inflicted disability (such as morbid obesity or chronic substance addiction), and it is severe enough that the patient requires long-term care and consistent medical upkeep, costing the healthcare sector resources far beyond the capacity of the patient to maintain or sustain on their own efforts, the doctor is required to flag the case to the PMA and to make a report to the 'stakeholders' recommending genetic re-classification. Due to the market pressures of the insurance industry, in particular, doctors at commercial for-profit private hospitals are especially assiduous at enforcing the prevailing inspection regime in respect of their patients, because strict adherence is generally demanded by the insurance industry as a pre-condition for that hospital and all her medical practitioners remaining 'in network'. The Health Ministry also conducts similar checks upon government-run hospitals in particular because, similar to the DWWP, there is a similar administrative incentive to keep healthcare subsidies to a minimum and reduce the quantity of patients repeatedly burdening the healthcare sector due to austerity measures and budgetary cuts implemented by the PNL regime. Charitable healthcare trusts are the only industry without the administrative or market incentive to assiduously apply the prevailing healthcare inspection regime to be 'on the lookout' for so-called 'burdensome' or 'parasitical' patients, which has had the predictable result of disabled patients and patients suffering from lifestyle ailments generally seeking out charitable trusts over government-run hospitals and private for-profit hospitals. The result is that the most expensive and cost-inefficient patients are concentrated within the not-for-profit charitable sector, burdening the coffers of healthcare charities while relieving the coffers of the private insurance industry and their customers (in respect of private for-profit hospitals) and the public purse of the Health Ministry (in respect of government-owned hospitals). The effect has been that, since 1990, there was been a serious decline in the number of charitable not-for-profit hospitals available across the Purgation State, which are being squeezed by fiscal and market pressures from having to service a patient body that is disproportionately more likely to fall ill and require treatment more frequently when compared to the patient bodies which frequent for-profit private and government hospitals. In the three decades since, the number of charitable healthcare trusts still around today is less than a quarter of the charitable trusts in existence in the 1990s, as many charitable trusts had to shutter their doors or file for winding-up due to bankruptcy and insolvency, and many of the remaining charitable hospitals have had to jack up their prices in order to remain afloat. The result is that patients with disabilities that make them reliant on healthcare services and patients with so-called 'lifestyle ailments' are quickly being squeezed out of the healthcare industry altogether with few to no affordable options still being left available in the marketplace to obtain treatment, often having to make the difficult choice between getting medical treatment and risking a re-classification report being filed against them or avoiding medical treatment and suffering all of the physiological consequences thereof. From the perspective of the Purgation government and the for-profit insurance industry, this has had the desired public policy outcome of relieving the burden on the healthcare sector of having to deal with the patients who are the most likely to tax and burden the limited resources of the industry. Another major source of 're-classification reports' under the Social Services Route stems from local councils and local municipal authorities who provide other public services such as the maintenance of parks and recreational spaces, the maintenance of roads, bridges, highways, sewage systems, drainage services, ambulance and emergency services, and hiring private contractors with respect to other infrastructural services such as telecommunication towers, fibre optic cables, and public utilities like water, heating, and electricity. Many local councils charge mandatory payable flat 'service and conservancy fees' to the local community as remuneration for providing such public services, and private contractors providing other privatised services such as water and electricity will charge 'tariffs' to individual households for the use of such services. The same is true of local education authorities who may have trouble obtaining payment from lower-income parents in respect of their school fees or fees payable for school lunches, uniforms, and textbooks. Repeated defaulters who fail to pay such charges over a prolonged period of time risk being deprived of public services or, alternatively (and especially where the good is non-excludable in nature, such as a local flood control mechanism), these contractors, local councils, and municipal authorities will file a re-classification report against such persistent defaulters to the 'stakeholders' as "moochers and/or leeches" burdening municipal services, or threaten to file such a report as a last-ditch attempt to scare and intimidate defaulters into coughing up whatever monies they have available to pay off their debts and liabilities to the local council, or risk being subjected to a genetic re-classification process in retaliation.

Hence, these are three methods via which a potential re-classification respondent may be brought to the attention of the three 'stakeholders' in the TECON-TECAT genetic re-classification process - the Criminal Prosecution Route, the Public Disorder Route, and the Social Services Route - after which each of the 'stakeholders' will have to make an internal assessment, based on their prevailing administrative or departmental policy, as to whether to seek the genetic re-classification of the potential respondent who has been brought to their attention in a given report, or to take no further action against them, under all the circumstances of the case. If at least one of the 'stakeholders' decides that the case merits the institution and prosecution of a re-classification action, then the matter will move onwards and onto the next stage.

That next stage is, of course, the Complaint stage, whereby one of the three 'stakeholders' (viz., the Home Office, the PIGC, and PICOS) exercises their statutory rights of exclusive ius standi under the Special Tribunals Establishment Ordinance to file a 'complaint for re-classification' to the Attorney-General's Office (AGO). Only these three 'stakeholders' are empowered with the legal standing to bring such a complaint before the AGO. Hence, if all three 'stakeholders' decline to file a complaint, the matter ends and no further action can be taken against the potential re-classification respondent, even if the original complainant (which could be the police, the prosecutors, the local council or municipal authority, Health Ministry, Welfare Department, or Purgation Medical Association (PMA), as the case may be) may still be aggrieved and may strongly desire that the matter to be pursued further, they have no authority to override that decision of the 'stakeholders' or to institute a private action for genetic re-classification on their own accord. Only three institutional office-holders - viz., the High Inquisitor of PICOS, the Director of the PIGC, and the Secretary of the Home Office - possess that exclusive procedural right and exhaustive ius standi to kick-start the process with a formal complaint to the AGO (Art 2(3), Special Tribunals Establishment Ordinance), meaning that if none of the 'stakeholders' institute a genetic re-classification complaint before the AGO, or subsequently withdraw that complaint at any stage of the proceedings, no other actor, not the AGO nor the original complainant nor any other individual, may continue to prosecute the re-classification proceedings on their own accord and without the consent and agreement of at least one of the three 'stakeholders'. As such, the Home Office, the PIGC, and PICOS, have essentially been statutorily anointed as the three exclusive 'gatekeepers' of the TECON-TECAT re-classification process. No genetic re-classification proceedings may even start or continue without their agreement therewith or their co-operation therein.

In practice, it is usually PICOS which institutes the genetic re-classification complaint, if any, for a number of reasons. The biggest reason is that re-classification respondents most commonly arise from an arrest made by either PICOS troopers or irregular Purification Order paramilitary soldiers seizing a potential re-classification respondent accused of disorderly, disruptive, antisocial conduct or general 'nuisance behaviour' in their local neighbourhood, prior to the institution of the complaint, for PICOS to make an internal assessment as to whether the circumstances of their case and the personal history of the respondent merit the initiation of a re-classification proceeding. Even where the respondent may have been initially arrested by the Purgation Police Force (PPF), as part of a formal criminal prosecution by the Crown Prosecution Service (CPS), when those criminal proceedings have concluded and a genetic re-classification process is about to begin, the PPF will transfer custody of the convicted person to a PICOS detention facility, and that respondent will be held in PICOS's possession for the purposes of the genetic re-classification process. The reason for this is a mixture of policy and practice. As a matter of pure logistics, PICOS handles security for all concentration camps and 'liquidation facilities' of the Dysfonctionnel across the Purgation State. Even where a facility has been privatised, while commercial operations may be in the hands of the concessionaires, the maintenance of internal security, camp discipline, and general good order, remain the province of the PICOS guards and troopers stationed at that facility. Hence, from an operational perspective, it makes sense for PICOS to also handle the maintenance of remand facilities to detain potentially Dysfonctionnel re-classification respondents, to hold them during the pendency of their proceedings before their eventual transfer to a concentration camp which is also under PICOS's control. Moreover, of the three 'stakeholders', PICOS is the 'stakeholder' that is often the most likely to favour re-classification, generally being supportive of a proposed re-classification action against around 75-80% of respondents brought to PICOS's attention, whereas that percentage falls to just 65-70% for the PIGC and a mere 55-60% for the Home Office. Hence, as a matter of institutional practice, potential respondents are generally brought to the attention of PICOS first, for reasons of administrative convenience, since if PICOS is unwilling to institute that re-classification proceeding, it is highly unlikely that the PIGC and the Home Office would be willing to countermand that refusal and institute their own complaint instead, whereas in the inverse scenario, if the PIGC or Home Office were consulted first and they declined to institute a re-classification complaint before the AGO, the complaint could still be brought to the attention of PICOS since there is a fair chance PICOS would be willing to institute that complaint instead, making that second consultative step totally duplicative and unnecessary, which can easily be avoided by first asking PICOS to consider the prospect of a re-classification action against a potential respondent, in the initial instance. Finally, this inter-institutional practice between the three organs has been formalised in the Genetic Identification and Re-Classification Rules codified and promulgated by the senior leadership of the Court of Final Appeals (CFA) in 1 January 2012 ("GIRCR 2012"), which gives the High Inquisitor of PICOS - and not the other two 'stakeholders' who are the Home Secretary and PIGC Director - the right to seize and detain potential re-classification respondents and hold them in their preventive custody in PICOS-run remand jails throughout the pendency of the proceedings (see, r 11(8), GIRCR 2012), which is a concession to the practical reality that it tends to be PICOS instituting their re-classification 'complaint' before the AGO and not either of the other two 'stakeholders'.

Hence, while the Home Office, the PIGC, and PICOS may all possess the ius standi to initiate a re-classification proceeding with a 'complaint' to the AGO, as a matter of inter-institutional practice, the Home Office and PIGC generally permit PICOS to make the first assessment as to whether a 'complaint' is warranted or not. If PICOS declines to institute an action, generally speaking, it is taken for granted that the other two 'stakeholders' would be extremely unlikely to interfere with that finding and institute a 'complaint' of their own, even if they technically possess that right under the GIRCR 2012 procedural regime. In contrast, if PICOS does initiate the re-classification process by filing a 'complaint' with the AGO, then the Home Office and the PIGC will have the opportunity to appraise the facts and circumstances of the 'complaint' and come to their own independent assessment as to whether to support or oppose that 'complaint'. Hence, as a matter of practice, of the three 'stakeholders', it tends to be PICOS that decides whether to initiate the re-classification process in the first place or decline to prosecute such an action against a particular respondent at all, although it bears reiterating that this practice arises out of de facto policy and not de jure law.

If PICOS decides in favour of instituting a 'complaint', the next stage of the proceedings is the Detention stage, although it should be noted that the potential respondent is usually in the custody of PICOS or Purification Order auxiliaries prior to PICOS instituting the formal 'complaint' before the AGO. The logical reason for this is that, when the respondent is brought to the attention of PICOS through whatever avenue (see, the Criminal Prosecution Route, Public Disorder Route, and Social Services Route as was outlined above), PICOS troopers or Purification Order soldiers will first detain that potential respondent, as a protective or prophylactic measure, and highlight their case to a PICOS officer for him or her to make a preliminary assessment as to whether or not the respondent's circumstances merit genetic re-classification, for if it were otherwise, the incentive for the potential respondent to flee to the outskirts of the Purgation State in order to escape the terrible prospect of re-classification and 'liquidation through labour' once they learnt of the report being filed to PICOS would, naturally, be extraordinarily high. The prevailing procedural regime in the GIRCR 2012 gives PICOS the right to preventatively detain a potential respondent without a formal 'complaint' to the AGO for up to 72 hours to assess whether the initiation of a re-classification 'complaint' is warranted or not (see, r 35(3), GIRCR 2012); hence, following a seizure by PICOS or the Purification Order, the case will be escalated to the 'immediate attention' of a PICOS officer to come to a quick assessment such that the 72-hour deadline is not breached. Within that 72-hour timeframe, the PICOS officer will have to arrive at one of three possible decisions - first, he or she may decide that no meritorious case for re-classification arises and the complaint should be dismissed and the prisoner released at once; second, he or she may decide that a case for re-classification is made out and institute a formal 'complaint' to the AGO, which officially begins the re-classification process, and once that formal 'complaint' is filed, PICOS has the power to continue detaining the prisoner beyond the 72-hour deadline throughout the entire pendency of the proceedings (see, r 35(6), GIRCR 2012); or third, an intermediate option is that the PICOS officer may decide that further investigations or fact-finding may be required for PICOS to come to an institutional landing on the case.

In the final instance, before the applicable 72-hour deadline expires, PICOS will have to present the prisoner before an adjudicator in the standing secrétariat juridique of the TECON tribunals, which is a permanent body of judicial officers charged and empowered with making all administrative, interlocutory, and other case management decisions prior to the formation of an individually constituted TECON tribunal to determine the merits of a re-classification 'complaint' (see, r 112(2) & r 158(1), GIRCR 2012), in what is often referred to as a 'pre-complaint detention hearing'. This is an adversarial process presided over by an adjoint (ou adjointe) au secrétariat who will hear arguments from the PICOS officer, and from the respondent (or their counsel, if they are represented), and come to a determination as to whether the respondent should remain in PICOS custody beyond the 72-hour deadline prescribed in the GIRCR 2012. PICOS will have to present a prima facie case for the respondent's genetic re-classification and provide reasons for why PICOS is unable to proceed to file a 'complaint' against the respondent just yet, such that a further period of detention without a formally instituted 'complaint' is warranted under the circumstances (see, r 39(1), GIRCR 2012). This is usually satisfied by PICOS explaining the need for further investigations, what those further investigations would seek to uncover, and how the results thereof would be relevant to PICOS's exercise of its discretion to institute, or decline to institute, a re-classification action against the respondent - although, at the end of the day, whether to grant or refuse PICOS’s request for an extension of the period of pre-complaint detention is ultimately up to the judicial discretion of the adjoint (ou adjointe) au secrétariat and what order(s) would better serve the administration of justice and the efficacy of the TECON-TECAT re-classification process overall (see, r 39(2), GIRCR 2012).

After PICOS has formally filed a 'complaint' to the AGO, which opens up the re-classification proceeding against the respondent, there is a further avenue for a 'pre-trial/post-complaint detention hearing' to be held, but this time that process is initiated by the respondent filing an application to the TECON secrétariat juridique, for an adjoint au secrétariat or adjointe au secrétariat to determine whether the respondent should remain in a PICOS remand facility during the pendency of the proceedings, or if the respondent should instead be released on bail bond (subject to the provision of monetary security of a determined quantum) throughout the same (see, r 45(3)-(4), GIRCR 2012). The legal burden of proof is on the respondent to satisfy the adjoint (ou adjointe) au secrétariat that he or she is not a flight risk and that, under the circumstances of their case, it would better serve the general public interest for him or her to be released on bail bond than to be locked up under PICOS pre-trial custody throughout the duration of the re-classification process (see, r 45(5), GIRCR 2012). It is generally up to the discretion of the adjoint (ou adjointe) au secrétariat to grant or refuse the request for release on bail bond, although there is a statutory list of factors to be taken into consideration, including the prima facie merits or likelihood of success of the re-classification action, the respondent's reputation and standing within the community, their links and ties to the Purgation State's jurisdiction and their local community, their personal history of offending and/or absconding, as well as whether less-restrictive alternatives are available to prevent the escape of the respondent without having to keep them under lock-up and in the physical custody of PICOS (see, r 47(1), GIRCR 2012). That last statutory factor has become increasingly influential in recent years, for while in the first few years following the inception of the TECON-TECAT Parallel Tribunal Regime, it was generally rare for respondents to be released on bail bond given the perception that respondents would inevitably take the opportunity to run away if released from custody due to the highly-damaging consequences of a successful re-classification action (namely, 'liquidation through labour' in a PICOS concentration camp), it has become increasingly common for more and more re-classification respondents to be released on bail bond subject to bail conditions intended to stringently monitor the respondent's post-release conduct and whereabouts, which generally include the freezing of most or all of their assets, electronic tagging, curfews, regular check-ins and inspections by PICOS officers, use of certain identification cards in daily living to trace their transportation and transactions, and most importantly, requiring the released person to remain strictly within the boundaries of certain of the most highly-surveilled, highly-monitored densely-populated metropolitan areas of the country (such as inner-city Ravaliér, Savoy-Ducasse, Avidité, Pétrus, Poisson, Provence, Limogens, and La Roche) where the Nos Yeux dans les Airs surveillance network has significantly greater reach and accuracy, to better monitor the movements of released persons through surveillance cameras and facial recognition technology, after placing them on the Home Office's 'watch list' to facilitate such tracking. Hence, it is now generally the norm for re-classification respondents to be released on bail bond subject to such ordinary bail conditions, save for those respondents who were convicted in a court of law for a particular criminal offence which resulted in re-classification proceedings being instituted against them, since for such respondents, their court-ordered custodial sentence has already been handed down with its execution being stayed and suspended for the purposes of the re-classification proceedings, thereby increasing their flight risk while also reducing the persuasive weight of the argument that their liberty interest would be unfairly prejudiced by their pre-trial detention in a PICOS-run remand facility. Nevertheless, the formal legal position remains that the burden is on the respondent to demonstrate that the public interest would be better served by their release from pre-trial detention, and it is ultimately entirely within the judicial discretion of the individual adjoint (ou adjointe) au secrétariat to decide whether to release the respondent on pre-trial bail bond and subject to what conditions.

[Purgatio]

During the course of the respondent's pre-trial detention or their release from PICOS lock-up on bail bond subject to conditions, the proceedings will then progress onto their next stage, the Assessment stage, more specifically, the AGO's assessment of the merits of the 'complaint' filed by one of the 'stakeholders' (usually that of PICOS, by convention), to come to a determination as to whether to prosecute that re-classification action or to decline to so prosecute. A unique feature of the GIRCR 2012 procedural mechanism is that, although the three 'stakeholders' (viz., the High Inquisitor of PICOS, the PIGC Director, and the Home Secretary) are possessed of the exclusive ius standi to initiate the re-classification process with the filing of a 'complaint' to that effect, it is the Attorney-General of Purgatio with the sole and exhaustive right to determine whether or not that 'complaint' is prosecuted or withdrawn; hence, the Attorney-General's Office (AGO) is vested with the Attorney-General's power to determine "at his or her discretion whether a complaint as referred to under Rule 7 shall be prosecuted, continued, discontinued, or withdrawn, whether it be conditionally or unconditionally or otherwise, and subject to such terms and/or absenting such conditions as the Attorney-General may think fit" (see, r 43(1)-(3), GIRCR 2012).

In order to come to a decision on that issue, the AGO is entitled to receive the views and input of all of the 'stakeholders', especially the 'stakeholders' which are not the complainant who initiated the re-classification process in the first place. Hence, when the complainant 'stakeholder' (usually the High Inquisitor of PICOS, by convention) files their complaint with the AGO state counsel, they must, on the same day, personally serve that 'complaint' upon the re-classification respondent (or, if the respondent is already being detained, the full contents of that complaint must be provided to the detained respondent by the PICOS prison guards at the remand detention facility in which they are being held), and then, within 3 working days, serve a copy of that same complaint on the other two 'stakeholders' who are not the complainants in this matter (usually the Home Secretary and PIGC Director, again, by conventional practice only), and that re-classification complaint must contain, inter alia, the complainant's Statement of Case (SOC) and a Summary of Facts (SOF), laying out in brief the complainant's case for the genetic re-classification of the respondent from Génétiquement Sain to Génétiquement Dysfonctionnel, accompanied by a brief summary of the facts and evidences in support of that case (see, r 7(1)-(4), GIRCR 2012). Within 28 days of being served the complaint, the other two non-complainant 'stakeholders' must file and serve on the AGO, and all other 'stakeholders', a Statement of Support (SS) or a Statement of Opposition (SO), laying out the official position of the 'stakeholder', the reasons why they support or oppose the complaint for re-classification, and a brief summary of the facts and evidences laid out by the complainant which they agree with, disagree with, or lack sufficient information to form an opinion on at that stage of the process (see, r 8(1)-(2), GIRCR 2012). Under the plain wording of the GIRCR 2012, it is clear that the non-complainant 'stakeholders' are required to come to an express position on the 'complaint' presented by filing either an SS or an SO - in other words, they cannot choose to file nothing with the AGO or file a non-committal statement expressing their neutrality or without taking any position supporting or opposing the proposed 'complaint' eitherway. Within 14 days of being served the SS or SO, the complainant 'stakeholder' may, if it wishes, file a Statement of Reply (SR) if they wish to respond to any new facts, submissions, evidences, or arguments raised in the SS or SO which were not already addressed in the initial complaint and the original contents thereof (see, r 8(5), GIRCR 2012). Thereafter, no further documents or representations may be filed with the AGO state counsel by the three 'stakeholders' unless the AGO state counsel exercises his or her right to expressly request, in writing, for further representations to be submitted from any one or all of the 'stakeholders', and any such representations filed with the AGO must also be served on all other 'stakeholders' by way of ordinary service (see, r 10, GIRCR 2012). It should be noted that, at this stage, the respondent is only entitled to be served with the contents of the original complaint filed against them, but nothing in the GIRCR 2012 provides that they must be served with copies of the other representations filed by the 'stakeholders' with the AGO. Likewise, it is expressly provided that the re-classification respondent (or their legal representative) is not entitled to make any representations to the AGO state counsel at this stage, be it in reply to the complaint's contents or independently urging the AGO state counsel not to prosecute the re-classification complaint against them owing to other extraneous facts or grounds (see, r 12, GIRCR 2012), the rationale being that the respondent will be permitted to make such representations to the AGO if or when the AGO state counsel decides in favour of prosecuting the re-classification complaint, whereas if the AGO decides to withdraw the complaint, such representations would have constituted irrecoverable costs 'thrown away' or simply duplicative and repetitive efforts which could have easily been avoided if the respondent's representations had been reserved only for the scenario wherein the AGO decides in favour of proceeding with the re-classification complaint, and not otherwise.

At this stage, the AGO state counsel will consider whether or not to prosecute or withdraw the genetic re-classification 'complaint', often with reference to officially published and publicly disseminated AGO guidance notes and policy-making circulars, which publicises and promulgates the standardised 'prosecutorial framework' which the AGO state counsel will apply in exercising its executive discretion, depending on the offences and/or transgressions forming the basis for the respondent's genetic re-classification from Sain to Dysfonctionnel. As an example of how such standardised prosecutorial frameworks are operationalised in practice, Attorney-General's Office (AGO) Circular No. 1171 of 2021 (Amended Version No. 13) (also known as "AGO CN 1171/2021" for short) establishes a two-dimensional 'matrix' which AGO state counsel are required to apply their mind to when determining whether reported 'complaints' of morbid obesity (falling under the category of the "indolent and slothful" for the purposes of the Genetic Identification Ordinance and Special Tribunals Establishment Ordinance) should be prosecuted or not, with an x-axis based upon the reported Body Mass Index (BMI) of the respondent and a y-axis based upon the length of time during which the patient has been either obese or morbidly obese as reported within their documented medical history. Hence, where the patient's BMI and length of period of obesity falls on the lower end of the spectrum, there is a pro tanto presumption in favour of withdrawing or discontinuing the re-classification action, whereas where both matrices are on the higher side, there is an opposite presumption in favour of re-classification, and in other cases (such as where both matrices are middling or average), re-classification depends upon a whole host of characteristics which the AGO state counsel is required to take into account under administrative law (and in particular, under the doctrine of substantive legitimate expectations), inclusive of the estimated cost of treating the respondent's obesity-related health problems to date as assessed by healthcare sector professionals, whether any proven and sincere attempts have been made to lose weight, other lifestyle health habits of the respondent (such as smoking, alcoholism, lack of any physical exercise, etc.), any demonstrated remorse or contrition of the respondent for their actions, and if the respondent has minor children under their care and control, whether those children are obese or not (which could be deemed to be indicative of the respondent promoting the so-called 'contagion' of obesity in society) (see, AGO CN 1171/2021 at [11(a)]-[11(g)]).

There is no hard time-limit within which the AGO state counsel must come to a decision as to whether the re-classification action would be proceeded on or withdrawn, following the institution of the 'complaint' by the complainant 'stakeholder' or from the date of the filing of relevant statements and submissions by the non-complainant 'stakeholders' or otherwise. The general expectation, however, is that after all submissions have been filed by the 'stakeholders' (i.e., the SS, SO, and SR (if any)), the AGO state counsel should strive to quickly and efficiently reach a considered decision, in accordance with all prevailing and applicable circulars and guidances issued by the Attorney-General, either by withdrawing the 'complaint', proceeding on the 'complaint', or if further information is required to make a decision, then directing the complainant 'stakeholder' (usually PICOS, again by convention and practice) to gather more facts on a particular topic or area. If further investigations are directed, the complainant 'stakeholder' will file and serve a Further Statement of Facts and Evidences (FSFE) laying out the results of their further investigations and the facts uncovered which are relevant to assessing the alleged social worth or relative value of the respondent, and whether or not they should be genetically re-classified (see, r 16(8), GIRCR 2012). The other two non-complainant 'stakeholders' will then have a chance to respond to the FSFE by filing and serving a Reply and Response to the Further Statement (RRFS), which will either agree or disagree with the new facts alleged and/or evidences raised in the FSFE, and confirm whether the 'stakeholders' are holding to their original position(s) either in support (in their SS) or opposition (in their SO) to the 'complaint' or instead changing their position in light of the new evidence presented (see, r 16(9), GIRCR 2012).

With the benefit of the information and arguments contained in the submissions of the 'stakeholders', including the 'complaint' (together with the appended SOC and SOF), SS, SO, FSFE, and RRFS, which is not binding upon the Attorney-General but constitutes the useful factual substratum for the AGO to exercise its executive discretion, the AGO state counsel will reach a determination, and the case will progress onto the next stage of the proceedings, namely, the Institution stage. Here, the AGO state counsel will decide whether or not to proceed upon, or withdraw, the re-classification 'complaint', and whatever decision is made in either direction, the state counsel will have to draft an 'Explanatory Memorandum' (EM) that is intended to provide reasoned justifications and detailed explanations for his or her decision, including with references to any relevant and applicable prosecutorial frameworks established in the Attorney-General's guidance notes and official policy circulars, demonstrating that the AGO state counsel properly applied the prevailing framework and took into consideration all factors and matters which they were required to take into account in the exercise of their discretion in the matter, and personally serve the EM on the re-classification respondent (see, r 18(1), GIRCR 2012), whilst serving copies of the EM upon the three 'stakeholders' by way of ordinary service within 3 working days of serving the EM upon the respondent (see, r 18(3), GIRCR 2012).

Whether the 'complaint' is prosecuted or withdrawn is entirely within the executive discretion of the AGO; hence, in theory, the AGO state counsel could choose to prosecute even if the two non-complainant 'stakeholders' believe that the 'complaint' should be withdrawn, and likewise, the AGO state counsel may also decide to withdraw the 'complaint' even if all three 'stakeholders' unanimously believe the re-classification action should be pursued. The one and only thing that the AGO cannot do, however, is initiate the re-classification process proprio motu and on their own accord, because at least one of the 'stakeholders' has to file the 'complaint' to the AGO to open up the process against the respondent, and to that extent, the Attorney-General does not have the power of initiative in law in that respect. The statistics also show that, in practice, while the AGO does not regularly countermand and contradict the expressed will of the 'stakeholders', and usually abides by their official advice and takes their recommendations into serious consideration, AGO state counsel are also not unwilling to break from the institutional position adopted by the 'stakeholders', in a not insignificant proportion of cases. According to statistics in a 2023 Home Office report, in the year of 2022, the AGO decided to proceed on an estimated 21.364 million re-classification 'complaints' in that year, and decided to withdraw approximately 15.472 million re-classification 'complaints' presented to the Attorney-General of Purgatio by the High Inquisitor of PICOS in that year, amounting to a 'complaint institution rate' of around 58%. All 36.836 million re-classification 'complaints' in the year 2022 had been presented to the AGO by PICOS. Amongst that number, the PIGC filed and served Statements of Support (SS) in respect of roughly 86.6% of such 'complaints' from PICOS, or approximately 31.899 million re-classification 'complaints', whereas the Home Office filed and served Statements of Support (SS) for only 25.306 million re-classification 'complaints', thereby supporting re-classification in only 68.7% of the 'complaints' presented by PICOS. The fact that the AGO has a slightly lower 'complaint institution rate' of about 58% would suggest that while, in the great majority of cases, the AGO follows the will of the 'stakeholders' and pursues the re-classification 'complaint' where all three 'stakeholders' are supportive of such action, nevertheless, in a small minority of cases, the AGO is willing to withdraw a 'complaint' despite the fact that a majority - or even all three - of the 'stakeholders' want the 'complaint' to be pursued.

In the event that the AGO decides to withdraw a re-classification 'complaint' that is presented to it, any one of the 'stakeholders' has the right to present a court application before the Executive Prerogatives Division (EPD) of the Court of First Instance (CFI), which is expressly empowered by law to conduct an "independent full merits review" of the Attorney-General's decision to withdraw or discontinue the initiated action for genetic re-classification (see, Art 12(2) of the Special Tribunals Establishment Ordinance). Hence, the court can engage in a de novo assessment of the correctness and propriety of the Attorney-General's exercise of executive discretion to withdraw the complaint, which can involve a scrutiny and examination of the reasons provided in the Explanatory Memorandum (EM) and the policy merits thereof, instead of being limited to the narrower grounds of administrative and judicial review (e.g., illegality, lack of jurisdiction, manifest unreasonableness, etc.) in common law. In order to exercise that right, the 'stakeholder' seeking to challenge the AGO's decision must, within 7 days of being served with the AGO state counsel's EM, file a Notice of Review with the CFI Registry and serve copies of that notice on the AGO, the other two 'stakeholders', and the re-classification respondent (see, r 22(1) & r 22(2), GIRCR 2012). In that proceeding, the 'stakeholder' seeking to challenge the AGO's exercise of discretion is the judicial review applicant, the Attorney-General is the respondent (see, r 22(3), GIRCR 2012), and the other two 'stakeholders' and the re-classification respondent are permitted, but are not required, to intervene in the proceedings as third parties thereto (see, r 22(4), GIRCR 2012), by filing and serving an 'intervener's notice' to that effect (see, r 22(7), GIRCR 2012). Although the language of "independent full merits review" as utilised within the GIRCR 2012 legislation might seem to suggest that the court possesses very broad and flexible discretion to fully review and freely interfere with the AGO's decision to withdraw the re-classification 'complaint' against the respondent, in practice, the CFI has repeatedly clarified in multiple judgments that it will not readily interfere with the AGO's exercise of discretion unless "clearly wrong" and "obviously erroneous and improper", based upon an assessment of the explanatory rationale provided in the AGO state counsel's EM and the adequacy and sufficiency of the reasons provided therein (see, e.g., High Inquisitor of the Purgation National League (PNL) Inquisitorial Committee for Order and Security c. Attorney-General (Louis-Gabriel Taofifénua, intervening) [2013] CPIPG 23488 (EPD) and High Inquisitor of the Purgation National League (PNL) Inquisitorial Committee for Order and Security c. Attorney-General (Chloé Surprenant, intervening) [2014] CPIPG 47559 (EPD)). Hence, in practice, the 'stakeholders' rarely file legal challenges against the AGO's decision to withdraw the re-classification 'complaint' (case in point, according to the 2023 Home Office report, while the AGO withdrew 15.472 million 'complaints' in the year of 2022, the Home Office and the PIGC filed zero challenges against such withdrawals in that same year, while PICOS only filed challenges in court for fewer than 0.1% of such cases - viz., only 15,387 applications - none of which actually succeeded before the Executive Prerogatives Division of the Court of First Instance).

On the contrary, however, if the AGO state counsel decides in favour of proceeding on the re-classification 'complaint', and personally serves the Explanatory Memorandum (EM) on the respondent to that effect, with the 'complaint' taking effect on the date of service of the EM (see, r 21(8), GIRCR 2012), the respondent will have to consider their position and decide whether or not to legally challenge the AGO's decision and seek judicial review thereof pursuant to established principles of administrative law. Unlike where the 'stakeholders' seek to challenge the AGO's refusal to proceed on the 'complaint' and seek an "independent full merits review" thereof (see, r 22(6), GIRCR 2012 and Art 12(2), Special Tribunals Establishment Ordinance), there is no statutory or legislative provision providing for the same in respect of a respondent who challenges the AGO's decision to proceed on the 'complaint' instead. Hence, it has been clarified by the courts repeatedly that where it is a respondent filing a judicial review application in such circumstances, the default position under common law applies, namely, that as an administrative act, the actions of the Attorney-General may only be challenged on the usual La Société d'Arôthe grounds of judicial review, viz., general illegality or unlawfulness, want of jurisdiction (ultra vires) owing to any errors of law, manifest substantive unreasonableness or irrationality, or procedural unfairness and breach of natural justice occasioning serious and substantial processoral prejudice (see, e.g., De Magnificus Dominus (sur l'application d'Alizée Valluy et alius) c. Attorney-General [2014] CAFPG 1238 (Civ) and De Magnificus Dominus (sur l'application de Lucas-Aldéric et alia) c. Attorney-General [2015] CAFPG 4484 (Civ)). The oft-provided justification for that double standard, as was articulated by the Supreme Court recently in De Magnificus Dominus (sur l'application de Léonie Delphine Cordonnier) c. Attorney-General [2022] 2 RJRP 1109 ("Leonie Cordonnier"), is that "according greater breadth to full juristic scrutiny coupled with the real prospect of more exacting judicial interference is animated by the rationale and understanding that the review of an administrative act which is final on the merits must, necessarily, be more demanding and assiduous than an act of an interim and interlocutory character only. Likewise, it follows that where the Attorney-General engages in an executive or administrative act which is, by definition, final in character, through the withdrawal of a proposed re-classification complaint, the justification for judicial scrutiny and interference is obviously much stronger in that case than in a scenario where the Attorney-General's administrative decision is of a temporary and reversible character, such as where the Attorney-General decides to proceed on that complaint instead, the legal, factual, and/or policy merits of which have yet to be adjudicated before an independent tribunal, with the power to grant or dismiss that complaint upon a full hearing thereupon, coupled with a statutory appeals and review process already provided for under the prevailing procedural regime. The courts are loath to prematurely interfere at such an early stage of the proceedings, particularly where the tribunal has not even had an opportunity to consider the merits of the complaint and conduct a trial on all of the contested allegations to allow opposing arguments to be fully litigated and ventilated in a common law adversarial process, and especially as any errors of law committed therein may always be corrected at the post-award stages of appeal and review. As such, it is only in the clearest cases featuring the most obvious of errors and the most patent of illegalities and improprieties that the ordinary courts of law should act to intervene by quashing the Attorney-General's decision to proceed on the complaint for genetic re-classification, based upon any of the typical common law grounds enumerated in La Société d'Arôthe, before that complaint has even had the chance to proceed to a full trial on the merits thereof" (see, Léonie Cordonnier at [21]).

Despite that holding by the Supreme Court in Léonie Cordonnier, and perhaps due to the severe consequences of a genetic re-classification, it is common for judicial review challenges to be filed against the decision of the Attorney-General to proceed on a re-classification 'complaint'. For example, according to the statistics published in the 2023 Home Office report, of the 21.364 million re-classification 'complaints' which the AGO decided to proceed on in the year 2022, more than half of them (approximately 11.216 million of them) resulted in judicial review applications being filed before the Executive Prerogatives Division (EPD) of the Court of First Instance (CFI). Under the current procedural regime, the respondent must file a Notice of Review with the Registrar's Chambers of the Court of First Instance (CFI) within 7 days of having been served with the AGO state counsel's EM (see, r 21(1), GIRCR 2012), and serve copies of the Notice of Review on all 'stakeholders' and the Attorney-General on the same day of such filing (see, r 21(2), GIRCR 2012). Following which, the respondent is required to file their originating summons in court seeking relevant prerogative orders against the Attorney-General within 14 days of having filed their Notice of Review, together with their affidavit of case-in-chief, and serve the originating process documents on the Attorney-General on the same day (see, r 21(3), GIRCR 2012), without having to also serve the originating process documents on the 'stakeholders', unlike for the Notice of Review (see, r 21(4), GIRCR 2012). If this requirement is not met, the judicial review application will be "deemed to have been withdrawn by the applicant" (see, r 21(3), GIRCR 2012). The respondent will be the applicant in the judicial review application while the named respondent will be the Attorney-General, and while the 'stakeholders' may wish to intervene as third parties in that proceeding, there is no automatic right or entitlement provided for in the GIRCR 2012 for the 'stakeholders' to participate in that process, hence the 'permission to intervene' application will be assessed on ordinary legal principles, same as with other such applications. In order to sieve out 'meritless' applications, the judicial review application can only proceed if either the Attorney-General consents or the secrétariat juridique of the TECON tribunal mechanism grants "permission to review" (see, Art 12(6) of the Special Tribunals Establishment Ordinance). Hence, if the AGO state counsel does not consent to the judicial review application (and in the year 2022, the AGO did not consent to any of the judicial review applications filed throughout that year), the re-classification respondent will have to file an application to the secrétariat juridique seeking such "permission to review", and the application will be heard as a pending summons in action, with a hearing on the summons being presided over by an adjoint (ou adjointe) au secrétariat. The respondent will have to file their summons with the secrétariat juridique within 7 days of filing their originating summons and affidavit of case-in-chief in court or within 7 days of the Attorney-General refusing consent in writing for the judicial review application, whichever is later (see, r 21(5), GIRCR 2012), after which an adjoint (ou adjointe) au secrétariat will be appointed to determine the matter, who will convene a Case Management Conference (CMC) on the respondent's summons within 15 days of the filing thereof and set the necessary timelines for the filing of affidavits (if any) and parties' written submissions (see, r 21(6) & 21(7), GIRCR 2012). The summons applying for "permission to review" will only be granted if the adjoint au secrétariat (or the adjointe au secrétariat) is persuaded that the judicial review application is "not hopeless" and has a "real and substantial prospect of success" (see, Art 12(7), Special Tribunals Establishment Ordinance and r 21(9), GIRCR 2012). Given the holding of the Supreme Court in Léonie Cordonnier at [21], however, it should not come as a surprise that very few of such applications for permission are granted, with only 112,272 judicial review applications (slightly over 1%) being permitted to proceed to court in 2022. The refusal of "permission to review" of the secrétariat juridique is also deemed to be "final and conclusive" and is expressly provided to be "not open to be challenged, reviewed, or appealed against in any court of law, on any basis or ground whatsoever" (see, r 21(10), GIRCR 2012). For those cases where permission is granted, the Attorney-General has 14 days from the date of the judgment or order of the secrétariat juridique granting "permission to review" to file an affidavit-in-reply to the CFI Registry responding to the facts and evidences raised in the applicant's affidavit of case-in-chief (see, r 21(12), GIRCR 2012), which must be served on the respondent on the same day by way of ordinary service (see, r 21(11), GIRCR 2012). And of the 112,272 judicial review applications permitted to proceed in court and filed by genetic re-classification respondents in 2022, only 5,521 of them (fewer than 5%) ended up succeeding before the CFI.

The two most common grounds invoked in the judicial review applications seeking to challenge the Attorney-General's decision to proceed on a re-classification 'complaint' pursuant to administrative law are (a) errors of law based upon alleged misinterpretations of the legislative objects and purposes of the Special Tribunals Establishment Ordinance (which overlaps with the sub-categories of grounds of review such as 'want of jurisdiction' based on alleged mis-constructions of one or more of the categories of antisocial or disordered tendencies under the legislation, 'improper purposes', 'irrelevant considerations', and 'fettering of discretion'); and (b) frustration of substantive legitimate expectations (arising from the publicised policy guidances or circulars promulgated by the Attorney-General and alleged misapplications of the prosecutorial frameworks established therein). Hence, for example, in Léonie Cordonnier, the genetic re-classification respondent there was challenging the AGO state counsel's decision to proceed on the 'complaint' against her, based on an alleged misapplication of the 'three-band' prosecutorial framework for inter-caste sexual offences established by the Attorney-General in Attorney-General's Office (AGO) Circular No. 358 of 2019 (Amended Version No. 19) ("AGO CN 358/2019") by misclassifying her offending under the intermediate Band 2 instead of the more lenient and less severe Band 3, amounting to an alleged frustration of her substantive legitimate expectations (SLE) as were derived from the representations in AGO CN 358/2019 (see, Léonie Cordonnier at [13]-[15]).

If the CFI affirms the Attorney-General's decision to prosecute, or the respondent is refused "permission to review" by the TECON secrétariat juridique, or declines to file a judicial review application challenging the AGO state counsel's Explanatory Memorandum (EM), then the re-classification 'complaint' is proceeded on and the case will progress onto the next stage, that is, the Negotiation stage. At this stage, the respondent (or their counsel, if they are legally represented) will usually write 'letters of representation' to the AGO state counsel in an effort to persuade them to drop the re-classification action, whether unconditionally or subject to conditions or reciprocal undertakings from the re-classification respondent. Such 'letters of representation', if marked as 'confidential' or 'without prejudice', and are written and communicated with an eye towards consensual case disposal and the pre-trial settlement of the dispute between parties, are protected by common law 'without prejudice' (WP) privilege which has since been codified and confirmed, and its contents are consequently inadmissible before the TECON-TECAT tribunals or any ordinary court of law, unless that WP privilege has been waived by the re-classification respondent (see, r 63(3) & r 63(4), GIRCR 2012). Thus, respondents or their counsel are able to speak freely without fear of any prejudicial repercussions in their representations, including by frankly admitting the fault or liability of the respondent in order to express the remorse or contrition of the respondent and to persuade the AGO state counsel of their capacity to change and reform and their rehabilitative potential. While the AGO state counsel will rarely, if ever, agree to wholly drop the re-classification action unconditionally (save for those circumstances where a fundamental factual allegation in the 'complaint' is shown to be in doubt or questionable due to new information raised in the letters of representation), it is not uncommon for consensual case settlements to be reached between the AGO and the respondent whereby the AGO state counsel discontinues the re-classification proceedings conditionally, subject to undertakings being entered into by the re-classification respondent as consideration for the AGO's withdrawal of the re-classification 'complaint' against them. These undertakings can take many forms, depending on the exact factual matrix supporting their re-classification, in more minor cases they can involve the respondent swearing to not engage in further antisocial or disorderly conduct in future whether they be general or specific in nature, in intermediate cases they can require the respondent to abide by a particular regimen or programme with strict timelines and specified milestones (be it counselling, a drug rehabilitation programme, a domestic violence or batterers' rehabilitation programme, a mental health or psychiatric treatment programme, an addiction treatment programme, a weight loss and healthy eating and exercise regimen, etc., depending on the exact circumstances of their case), and in more serious cases it can involve the respondent voluntarily agreeing to serve a certain time-limited custodial term in a PICOS-operated detention facility as an alternative to facing the prospect of potential genetic re-classification before a TECON tribunal which, if successful, would carry the far worse consequence of enslavement and extermination (i.e., 'liquidation through labour') inside a PICOS-controlled 'liquidation facility'.

Such voluntary settlement agreements between the AGO and the respondent can be arrived at in a number of ways. In the easiest set of circumstances, the respondent may send a letter of representations to the AGO state counsel, seeking the withdrawal of the re-classification 'complaint' subject to certain conditions and undertakings. The AGO state counsel may be satisfied with the offer and 'accede' to the representations by communicating their agreement in writing to the respondent or their legal representatives, after which a contract is deemed to have been formed between the AGO and the respondent under the ordinary common law principles of 'offer and acceptance'. If the AGO state counsel is not satisfied with the conditions in the proposed undertaking, he or she may propose a counter-offer which, if accepted by the respondent and such acceptance is communicated to the AGO in writing, would likewise give rise to a contract under similar 'offer and acceptance' principles. In more difficult and contentious cases, however, the AGO and the respondent (or their legal counsel, if represented) may need to meet in person to negotiate and discuss in detail the finer elements of the specific terms and conditions of the proposed undertaking, in a more contentious and difficult back-and-forth bargaining and bartering process. And in even more difficult cases, however, the AGO and the respondent may agree to undergo mediation, with the most common route being to use the free-of-charge mediation services of the pro bono Social Relations and Communal Amity Mediation Scheme (SocRelCAMS), operated by trained and accredited mediators, who will help facilitate the negotiation and bargaining process between the AGO state counsel and the re-classification respondent. For well-resourced respondents, however, they may offer to pay for the services of private mediation and even private conciliation to help facilitate a settlement agreement with the AGO using the services of trained mediators and conciliators in the private sector. This would require the consent and agreement of the AGO, but AGO state counsel rarely refuse their consent to participate in a private mediation and/or conciliation process with the respondent unless they have doubts about the legitimacy of the proposed private service-provider or the respondent's case is so egregious and outrageous (for example, in cases of serial murder or child sexual abuse) that the AGO state counsel already knows in advance that there is absolutely no prospect of the re-classification 'complaint' being withdrawn under any circumstances, even subject to a conditional reciprocal undertaking from the respondent.

Roughly a third of re-classification 'complaints' result in settlement agreements between the AGO and the respondent, with a conditional withdrawal of the re-classification action, whatever the route or avenue via which that consensual case disposal is attained. In the year 2022, out of the 21.364 million 'complaints' which the AGO proceeded on, 6.989 million (approximately 32.7% of them) resulted in a settlement agreement being concluded between the AGO and the re-classification respondent, with the 'complaint' being withdrawn against them. The terms of these agreements, however, have to be very carefully considered, not just by the AGO state counsel, but more importantly, on the part of the respondent as well. This is because 'settlement agreements', even in re-classification proceedings, have the force of ordinary contractual law under ordinary common law principles, and are subject also to the general principle of pacta sunt servanda. A breach of the terms of such settlement agreements is therefore enforceable as a matter of contract law. This is significant because the AGO has a policy of requiring, as a condition precedent of entering into such settlement agreements, that an 'automatic re-classification clause' be inserted into the agreement, which, as the name would suggest, provides that a violation of the terms of the undertaking given by the respondent would result in their immediate genetic re-classification without having to undergo a TECON tribunal hearing. The clause is usually worded by providing that, in the event of a violation of any of the terms of the respondent's own undertaking, they are to consent or agree to be re-classified from Sain to Dysfonctionnel without there being any contentious/adversarial process therefor. The AGO's view is that such an 'automatic re-classification clause' is intended to be a true test of the alleged remorse or contrition of the respondent and their proclaimed rehabilitative potential. It is not uncommon for respondents and their counsel to make bold claims to the AGO state counsel that they are sorry for what they have done, they are committed to changing and turning over a new leaf, and they will never engage in antisocial behaviour ever again if given another opportunity to change and reform. The 'automatic re-classification clause' is intended to force respondents to put their money where their mouth is and test the sincerity of their proclaimed or asserted rehabilitative potential. If a respondent is unwilling to agree to such a clause being inserted into their settlement agreement, the AGO takes the view that that must mean that the respondent is not actually remorseful for their actions and not genuinely committed to reforming themselves, the rationale being that if they genuinely believed in their own rehabilitative prospects, then they would have absolutely no reason to fear the insertion of such a clause into their agreement since they would be confident that they would have turned over a new leaf and not engaged in any breaches of the undertaking in future. The respondents who agree to the insertion of such an onerous clause into their settlement agreements likely do so because entering into the contract immediately terminates the re-classification action against them and provides them a real opportunity to avoid being re-classified to Dysfonctionnel as long as the terms of their own undertaking remain satisfied.

It has been held by the Supreme Court in the case of Fabien Voignet c. Attorney-General [2018] 4 RJRP 3338 ("Fabien Voignet") that an 'automatic re-classification clause' can be enforced by way of an order for specific performance, and that settlement agreements struck between the re-classification respondent and the Attorney-General constitute a "mutually enforceable, bilateral, synallagmatic contractual agreement capable of being enforced pursuant to the ordinary principles of private law, not before the TECON-TECAT tribunals, but the Private Stipulations Division (PSD) of the Court of First Instance (CFI), as with any other contractual agreement in this jurisdiction" (see, Fabien Voignet at [17]). Hence, if the AGO attempted to seek the respondent's re-classification from Sain to Dysfonctionnel contrary to the terms of the settlement agreement (i.e., when the respondent has not breached their undertaking), that breach of contract can be restrained by the ordinary courts of law, through injunctive relief prohibiting the AGO's re-classification action from being prosecuted any further (see, Fabien Voignet at [25] and [29]-[31]). Likewise, the inverse scenario is also true, namely that if the respondent breaches the conditions of their undertaking, the AGO is similarly entitled to seek the specific performance of their obligations under the contract, avoiding the TECON-TECAT re-classification process entirely by relying upon the 'automatic re-classification clause' in their agreement. In such a scenario, the only question to be determined is whether the respondent has or has not breached the terms of their undertaking in the settlement agreement. If so, the 'automatic re-classification clause' is engaged and the Court of First Instance (CFI) is entitled to grant an order of specific performance re-classifying the respondent from Sain to Dysfonctionnel without having to undergo a full TECON-TECAT re-classification process, in the interest of enforcing the sanctity of the bargain struck between the Attorney-General and the re-classification respondent (see, Fabien Voignet at [42], [45], and [49]-[52]).

If no settlement agreement is reached and the re-classification 'complaint' is not withdrawn through a process of negotiations - which, according to the 2023 Home Office report, was the case for 14.375 million re-classification 'complaints' which proceeded to a full hearing on the merits in the year 2022 - then the proceedings continue onto their next stage, namely, the Hearing stage. In order to provide adequate berth and ample opportunity for the re-classification respondent and the AGO state counsel to bargain and negotiate a consensual settlement of their legal dispute, under the prevailing procedural regime, the TECON tribunal is only to be constituted when either the AGO or the respondent has formed the view that there is no longer any point or purpose in attempting to negotiate a consensual disposal of the case, and consummates and expresses that view by filing a Notice for Constitution of the Tribunal with the TECON secrétariat juridique, and serving that notice upon all three 'stakeholders' as well as upon their party-opponent by way of ordinary service (see, r 214(1) & r 214(2), GIRCR 2012). Once that notice has been served, within 30 days from the date of being served with a copy of that notice, each of the three 'stakeholders' must choose the person that they intend to appoint onto the TECON tribunal for that case, and file a Notice of Appointment of Tribunal Member with the TECON secrétariat juridique, together with a copy of the appointed member's curriculum vitae, within the 30-day deadline, whilst serving a copy of that notice on both the AGO and the re-classification respondent on the same day (see, r 214(4) & r 214(6), GIRCR 2012) - note that there is no requirement for the other 'stakeholders' to be served with the notice of appointment. Either the Attorney-General or the re-classification respondent may, if they wish to do so, object to the appointment of a particular Member of the Tribunal by filing a Notice of Objection to Appointment with the TECON secrétariat juridique within 12 days of being served with a copy of the notice of that member's appointment thereto and serving copies of that notice upon their party-opponent and upon the 'stakeholder(s)' which appointed the objected-to Tribunal Member(s) (see, r 227(1), GIRCR 2012). Their party-opponent must, within 10 days of having been served with notice of that objection, then file with the TECON secrétariat juridique a 'statement in reply' clearly setting out their position on the objection, and whether they are of the view that the objected-to Tribunal Member should remain on the TECON tribunal or be removed therefrom, and serve copies of that statement upon both the objecting party and the 'stakeholder(s)' which appointed the objected-to Tribunal Member(s) (see, r 227(2), GIRCR 2012), and if no statement is filed and served within the 10-day deadline, the party-opponent is deemed to consent to the objection (see, r 227(3), GIRCR 2012). If both parties are agreed (or deemed to agree) that the Tribunal Member should be removed from the TECON tribunal, then the member's appointment is revoked by consent and the 'stakeholder' which appointed them has to file and serve another Notice of Appointment of Tribunal Member within 28 days of having been served with the party-opponent's 'statement in reply' clearly setting out their agreement with the objection to appointment, or where the party-opponent is deemed to consent to the objection owing to their failure to file and serve any 'statement in reply' within the applicable 10-day deadline, then within 28 days of the expiry of that deadline onwards (see, r 227(4), GIRCR 2012). The process for objecting to the substitute appointment of the Tribunal Member is exactly the same as the process set out above for objecting to an original first-instance appointment and with the same deadlines and timelines applying thereto (see, r 227(7) & r 227(8), GIRCR 2012).

If neither the AGO nor the respondent object to the removal of any Tribunal Member, then the TECON tribunal is considered fully constituted on the date of the expiry of all applicable deadlines for the filing of any relevant objections (see, r 230(1), GIRCR 2012). That date is significant because all timelines respecting reciprocal pre-hearing disclosures between the parties begin to run from the date of the constitution of the TECON tribunal (see, r 236(6), GIRCR 2012). If the AGO and re-classification respondent are not agreed as to the appointment of any Tribunal Member or the revocation thereof, the contested objection(s) must be disposed of by an adjoint (ou adjointe) au secrétariat, who will convene a Case Management Conference (CMC) within 7 days of the filing and serving of the relevant 'statement in reply' by either party setting out their opposition to their party-opponent's objection to the appointment of any one or more Tribunal Member (see, r 231(4), GIRCR 2012). At the CMC, the adjoint au secrétariat or the adjointe au secrétariat will set the timelines for the filing of affidavits and written submissions by parties (see, r 231(1) & r 231(2), GIRCR 2012) before convening a hearing on the 'summons for revocation of appointment', to reach a final and conclusive decision on whether the Tribunal Member's appointment should be affirmed or revoked (see, r 231(5), GIRCR 2012). There are several different grounds for a Tribunal Member's appointment to be challenged, but the two most common grounds are either that the appointed member is "lacking in independence or impartiality, whether real or apparent" (see, r 210(1)(e), GIRCR 2012) or is "lacking in the requisite knowledge, experience, expertise, or professional competence over the subject-matter which stands to be adjudged" (see, r 210(1)(h), GIRCR 2012). It should also be noted that while, in theory, objections may stem from either the AGO or the re-classification respondent, in practice, nearly all (if not all) objections to appointments come from the re-classification respondent and not from the AGO state counsel. This is because each of the three 'stakeholders' make appointments from a pre-existing panel of potential adjudicators, oftentimes being persons with a combination of both legal expertise and subject-matter experience within their respective agencies and departments, and prior to the inclusion of a potential adjudicator's name within that panel, the 'stakeholders' will obtain the approval and clearance of the Attorney-General (AG) to ascertain if the AG has any concerns regarding the fitness and competence of that potential adjudicator. As a matter of practice, the 'stakeholders' generally avoid including the names of any potential adjudicators onto their standing panels without the agreement of the AG in order to avoid future objections from AGO state counsel. Hence, as a matter of practical reality, objections to the appointments of Tribunal Members generally tend to arise from the re-classification respondent, and the AGO state counsel will very rarely consent to or agree with such objections except in those rare circumstances where the re-classification respondent's objection to the appointment of the Tribunal Member raises fresh facts and new information which was not known to the AG when the AG initially communicated his assent to their inclusion within the standing panel of potential adjudicators of the 'stakeholder' in question. The applicable legal standard for the appointment of a Tribunal Member to be revoked is a high bar, because the TECON secrétariat juridique needs to be persuaded of the "manifest lack" of the relevant quality (see, r 210(1), GIRCR 2012), as well as that the absence of that quality would "entail a real and material risk of occasioning substantial injustice to the objecting party under all the circumstances" (see, r 210(2), GIRCR 2012).

If the adjoint au secrétariat or adjointe au secrétariat dismisses the objection(s), the TECON tribunal is deemed to be constituted as on the date of such dismissal (see, r 210(3), GIRCR 2012), whereas if any one objection is affirmed, the TECON tribunal is only deemed to be constituted once a substitute adjudicator is appointed by the relevant 'stakeholder' or 'stakeholders' and the affirmation-and-objection process for those substitute appointments has been concluded. In order to prevent any party from endlessly delaying the proceedings by filing repeat objections to substitute appointments ad infinitum, each party only has the absolute right to object to an appointment made by a particular 'stakeholder' once; however, if a 'stakeholder' is making a substitute as opposed to first-instance appointment of a Tribunal Member, and a party wishes to object to the substitute appointment despite also having objected to the original appointment, the TECON secrétariat juridique has the power to summarily dismiss that objection without a hearing unless the objecting party first discharges their legal and evidential burden of proving that their objection is made genuinely with clearly demonstrated bona fides, not amounting to an "abuse of process" under the circumstances (see, r 243, GIRCR 2012).

Once the TECON tribunal is fully constituted, timelines for parties' mutual disclosure obligations begin to run from that date onwards (see, r 236(6), GIRCR 2012). Within 60 days of the date of such constitution, parties must disclose the following to the other party - first, a list of witnesses (LOW) they intend to call at the TECON tribunal hearing; and second, a list of documents (LOD) they intend to rely upon at that hearing as part of their evidence-in-chief - by filing their 'compliance affidavit' to the TECON secrétariat juridique containing the LOW and LOD and serving a copy of their 'compliance affidavit' on their party-opponent on the same day (see, r 236(1), GIRCR 2012). Within 14 days of the expiry of that 60-day deadline (but not before), the adjoint (ou adjointe) au secrétariat will convene a Pre-Hearing Case Conference (PHCC) to ascertain whether parties' have met their disclosure obligations, and if either party has failed to meet their obligations, the adjoint (ou adjointe) au secrétariat has broad discretion to determine how best to respond to the breach, including by imposing fines on the non-compliant party, providing the non-compliant party another opportunity to comply with a subsequent deadline, setting a hearing date without giving the non-compliant party the chance to file a compliant LOW or LOD whilst disallowing the non-compliant party from calling any undisclosed witnesses or presenting any undisclosed documents in their evidence, or invoking the 'nuclear options' of either summarily dismissing the re-classification 'complaint' (if the AGO state counsel is the non-compliant party) or summarily re-classifying the respondent to Dysfonctionnel (if the respondent is the non-compliant party) (see, r 237(2) & r 237(3), GIRCR 2012). An available alternative short of invoking such 'nuclear options' straight away, however, is to issue an 'unless order', providing a final deadline for the non-compliant party to comply with their disclosure obligations, or otherwise the re-classification 'complaint' will be dismissed or the respondent will be genetically re-classified, as the case may be (see, r 239, GIRCR 2012). The consequences of failing to disclose a witness on the LOW or failing to disclose a document on the LOD, in addition to the possible sanctions imposed at the PHCC, are twofold - first, no undisclosed witness may be called at the hearing before the TECON tribunal and no undisclosed document may be admitted into evidence at that hearing without the consent of both parties or the prior leave and permission of the TECON secrétariat juridique (see, r 238(1)(a), GIRCR 2012); and second, the TECON tribunal may draw any adverse inferences against the non-disclosing party that it deems appropriate if they attempt to call an undisclosed witness or present an undisclosed document at the contentious hearing (see, r 238(1)(c), GIRCR 2012).

Once both parties have complied with their initial disclosure obligations, and filed their LOW and LOD accordingly, parties then have another 60 days (by default) from the date of the PHCC to file before the TECON secrétariat juridique and serve a copy on their party-opponent the following documents - first, affidavits of evidence-in-chief (AEICs) in respect of all witnesses that party intends to call at the hearing before the TECON tribunal, setting out in full the evidence of that witness; second, copies of all documents which that party intends to adduce into evidence at that hearing, appended to the AEIC of the witness through which the party intends to adduce that document into evidence; and third, in the case of any evidence not taking the form of witness testimony or documentary evidence (such as audio or video recordings), a statement to that effect within the AEIC of the relevant witness through which that evidence will be introduced, together with a sufficient and adequate summary of the contents of that evidence (see, r 236(2), GIRCR 2012). The adjoint (ou adjointe) au secrétariat will then convene another PHCC within 14 days of the expiry of these 60-day deadlines (and not before then) to verify that the secondary disclosure obligations are also satisfied, with precisely the same discretionary powers as before to respond to any non-compliance therewith (see, r 237(5) & r 237(7), GIRCR 2012). Parties are not entitled to present any new evidence at the TECON hearing not contained within the disclosed contents of their AEICs without the consent of the TECON tribunal (c.f., where either party wishes to call an undisclosed witness or present an undisclosed document at the TECON hearing, the grant of prior leave and permission to do so by the TECON secrétariat juridique is required and the consent of the TECON tribunal at the hearing itself will not suffice) and even where the TECON tribunal provides such permission, it is entitled to draw any adverse inferences it thinks fit from the failure of that party to disclose the relevant evidence in the witness's AEIC (see, r 238(2), GIRCR 2012). The AEICs must comply with the mandatory requirements of the GIRCR 2012 and the 1936 Law on the Swearing of Oaths, the Making of Affirmations and Declarations, and the Notarisation of Documents (as amended in 1999 and 2000), which means that the affidavit must be either sworn or affirmed, depending on the deponent's religion, with the only options being that the deponent can swear an oath to the Mandate of Nature (if they are of the Mandatum Est faith), an oath to God (if they are of the Purgation Catholic faith), or otherwise they may affirm the affidavit (see, r 247(7), GIRCR 2012), the affidavit must be sworn or affirmed before a licensed Commissioner for Oaths or Notary Public (see, r 247(8), GIRCR 2012), with a knowingly false attestation by a notary public or a deponent knowingly swearing or affirming to the untrue contents of an affidavit constituting criminal offences under the 1936 Congressional legislation.

[Purgatio]

The final pre-hearing step is for parties to comb through the contents of each other's AEICs and determine whether they object to the admissibility of any particular contents of the evidence of a particular witness, object to the admissibility of a specific piece of documentary or non-documentary evidence, or exceptionally, they object to the calling of a witness entirely because the evidence sought to be admitted through that witness is wholly and completely inadmissible in law, such as where all of their testimony sought to be introduced can be shown to be irrelevant and/or unduly prejudicial (see, r 242(1) & r 242(2), GIRCR 2012). A summons applying for a witness to be disallowed or a piece of evidence to be deemed inadmissible before trial must be filed and served by the objecting party at least 7 days before the next PHCC date as fixed by the responsible adjoint au secrétariat (or the adjointe au secrétariat) at the previous PHCC at which compliance with the secondary or supplementary disclosure obligations had been verified and ascertained (see, r 242(4), GIRCR 2012). If no such application is filed, all evidence disclosed by parties in their AEICs is automatically deemed to be admissible and relevant in law, without prejudice to parties' rights to attack the probative weight to be accorded to that evidence, in inter alia their cross-examinations of their party-opponent's witnesses or in their opening and closing oral submissions, and the adjoint au secrétariat (or the adjointe au secrétariat) will then proceed to fix the hearing dates before the TECON tribunal, and inform the Tribunal Members of the hearing dates accordingly. If there are objections to any pieces of evidence, however, those objections must first be dealt with as a preliminary matter by the TECON secrétariat juridique before the hearing is fixed, assessed based on ordinary common law principles of evidence law, including that of relevancy and prejudice, and if the evidence is ruled inadmissible in law, parties are strictly prohibited from citing that information, calling that witness, or raising that piece of evidence at the TECON hearing for any reason whatsoever (see, r 243, GIRCR 2012). Finally, it should be noted that any applications for further adjournments to be granted so that parties can search for certain witnesses they intend to call or documents or other non-documentary pieces of evidence that they intend to introduce at the TECON hearing should also be made at least 7 days before this same PHCC by filing and serving the relevant summons to that effect (see, r 244(2), GIRCR 2012), and the same deadline applies for any party seeking to file for a subpoena compelling a witness to attend the TECON tribunal to give oral evidence or produce any documents thereat (see, r 244(4), GIRCR 2012).

Once the TECON hearing dates are fixed, the contested hearing on the merits of the re-classification 'complaint' generally follows the standard procedure of a typical civil trial on the merits. First, the parties will summarise their cases to the TECON tribunal in their oral opening submissions. Then, the AGO as the complaining or prosecuting party will begin calling their witnesses to affirm the contents of their AEICs, before opening up that witness to being cross-examined by the respondent or, if they are legally represented, by their legal counsel, after which the AGO state counsel may proceed to re-examine their own witnesses (if they wish to do so). Then, the AGO will close their case after introducing all witness testimony and exhibits they intend to adduce into evidence, and the respondent may make a submission of there being 'no case to answer' (in which the TECON tribunal must assume the truth of the complainant's evidence, unless inherently incredible or wholly unworthy of credit, to determine if no prima facie case for re-classification is made out even on that evidence), or otherwise proceed to open their case by calling their witnesses to affirm the contents of their AEICs, opening up their witnesses to be cross-examined by the AGO state counsel, and re-examining their own witnesses if the respondent or their counsel so desires. The AGO will then be entitled to present rebuttal evidence only if that rebuttal evidence had been disclosed earlier to the TECON secrétariat juridique at the earlier PHCC, after identifying the portion of the respondent's evidence-in-chief that they intend to rebut and complying with all necessary disclosure obligations respecting that rebuttal witness, the only exception to that general rule being if the AGO state counsel wishes to call rebuttal evidence in response to new evidence introduced by the respondent that was not disclosed in their AEICs and was raised for the very first time at the TECON hearing itself with the permission of the TECON tribunal or the TECON secrétariat juridique (as the case may be), in which case the AGO is entitled to call that rebuttal witness and present that rebuttal evidence without any prior disclosure to the respondent and without the prior leave or permission of the TECON secrétariat juridique or tribunal (as the case may be), but only insofar as that rebuttal evidence replies to the respondent's undisclosed evidence, otherwise it is absolutely inadmissible. Those rebuttal witnesses will provide oral testimony in their evidence-in-chief, followed by their cross-examination by the respondent, followed by re-examination by the AGO state counsel. Finally, once all admissible evidence has been adduced by both parties, parties will provide their oral closing submissions to the TECON tribunal (see, r 249(8), r 249(10) & r 250, GIRCR 2012). All witnesses must be sworn in for their AEICs to be admissible into evidence (see, r 249(9), GIRCR 2012), and the standard form and language of the oaths or affirmations of witnesses, depending on their religion, and the criminal consequences of perjury and the giving of false testimony under oath or affirmation, follow precisely the same rules as that for the swearing or affirming of affidavits (see, r 247(3)-(5), GIRCR 2012).

Once the contested hearing has been concluded, the TECON Tribunal Members will deliberate on the merits of the re-classification 'complaint' and the evidence presented before them, and once a decision has been made, the case will progress onto its next stage, namely, the Award stage, where the TECON tribunal either grants or rejects the re-classification 'complaint', either unanimously or by a majority of its three members (see, r 208(4), GIRCR 2012), with a written award that serves to officially close the first-instance genetic re-classification hearing (see, r 255, GIRCR 2012). The broader question of mixed fact and law, which the TECON tribunal has to answer in the round, is whether the re-classification respondent possesses an "antisocial, deviant and/or parasitical disposition" overall (see, Art 1(1) of the Genetic Identification Ordinance and Art 1(2) of the Special Tribunals Establishment Ordinance), as a person, as opposed to a determination as to whether certain particular or specific individuals acts were or were not committed by them. The AGO, as the complaining party, bears the legal and evidential burden of proof of demonstrating the respondent's "antisocial, deviant and/or parasitical disposition" to the adequate satisfaction of the TECON tribunal (see, Art 6(3) of the Special Tribunals Establishment Ordinance), based on an intermediate evidentiary standard of a "preponderance of the evidence" (see, Art 6(4) of the Special Tribunals Establishment Ordinance and r 262(2) of the GIRCR 2012). It should be noted here that the 'genetic re-classification rate' by ad hoc individually constituted TECON tribunals is rather high, with the 2023 Home Office report estimating that of the 14.375 million re-classification 'complaints' which proceeded to a full hearing on the merits in 2022, 12.478 million of them were granted (around 86.8%) while the remaining 1.897 million (about 13.2%) were dismissed in the first-instance.

Explanations proffered for the high re-classification rate have differed depending on the source of the explanation. Foreign journalists and international human rights organisations have generally been of the view that the high re-classification rate raises serious concerns about the independence and impartiality of the TECON re-classification process, and serves to cast serious doubt upon the institutional independence of the ad hoc TECON tribunals from inter alia the pressures and interferences of the Purgation State's executive branch, in particular. In the view of such critics and detractors, the system of ad hoc appointments of individually constituted TECON tribunals in particularised cases, without a standing permanent judicial body of stipendiary judicial officers with security of tenure, and chosen by policy-making governmental organs and bodies within the executive branch, creates real concerns of both executive influence over the adjudicative process of individual TECON tribunals and casts real doubts over the capacity of such TECON tribunals to be truly independent from the policy-making wishes and desires of the three 'stakeholders' which have a direct governmental interest in further reinforcing the robustness and stringency of the Sain-Dysfonctionnel eugenical and genetical distinction. Such critics often point to the fact that the potential adjudicators listed on the existing panels of the three 'stakeholders' often have histories working for departments and agencies within PICOS, the PIGC, and the Home Office, whether directly as employees of the ministry or indirectly as independent contractors and sub-contractors or employees hired by sub-committees or sub-agencies thereof, and their policy-making or executive expertise as civil servants, police officers, scientists, or enforcement officers is often far longer and far more extensive than the more limited exposure they have in the field of law and jurisprudence, which may consist of legal training in a form as limited as a one-or-two-year graduate legal diploma. In addition to the strong ties such adjudicators may possess to the three 'stakeholders', in terms of their professional histories, many have also expressed concerns about the system of ad hoc appointments, since Tribunal Members are paid by the hour in respect of the cases they preside over, out of the budgets of the three 'stakeholders', as opposed to having a fixed salary as is the case for an ordinary judicial officer employed as such on a full-time basis. This means, effectively, that the salary of a potential adjudicator depends upon the frequency and regularity with which the 'stakeholders' appoint that adjudicator to ad hoc TECON tribunals. In other words, the more frequently they are appointed by their designated 'stakeholder' to preside over a greater quantity of cases, then the higher their remuneration. Critics of the TECON re-classification system speculate that this gives the TECON adjudicators a very strong personal incentive to vote in line with the expressed position of the appointing 'stakeholder' (as would have been expressed either in the re-classification 'complaint' itself or the Statement of Support (SS) or Opposition (SO) filed at the very beginning of the re-classification process) as they may fear that displeasing their 'stakeholder' could result in a reduced number of subsequent appointments to future TECON tribunals, which would affect the quantity of their professional fees and the amount of their hourly remuneration. In the view of such critics, these fears are accentuated by the statistics which show that, where TECON tribunals issue 'split decisions' (which generally occurs in only approximately 20-30% of cases), it is nearly always a 'split decision' wherein the PICOS-appointed adjudicator has voted for re-classification, the Home Office-appointed adjudicator has voted against re-classification, and the PIGC-appointed adjudicator constituted the tie-breaking vote which voted in favour or against re-classification in different cases, tracking the overall pattern of support and opposition of the three 'stakeholders' in terms of their support for or opposition to the initiation and institution of genetic re-classification 'complaints'. Finally, concerns have been expressed that there appears to be a surprising and worrying convergence between the number of respondents who end up being genetically re-classified every year and the average number of Dysfonctionnel slave labourers who die in Purgation 'liquidation facilities' per annum. For instance, according to the 2023 Home Office report, in 2022, 12.478 million persons were re-classified as Génétiquement Dysfonctionnel in the first-instance proceeding before an ad hoc TECON tribunal. That number is generally consistent with the first-instance re-classification numbers (without accounting for the outcomes of any post-award appeals and reviews) as reported by the Home Office in previous years (13.338 million re-classifications in 2021, 11.877 million re-classifications in 2020, and 12.115 million re-classifications in 2019, etc.). Interestingly, the numbers reported by the Tripartite Commission have estimated that, each year, the number of Dysfonctionnel slave labourers who die in PICOS-controlled 'liquidation facilities' ranges, on average, from 11.183 million on the low end to 12.679 million on the high end, which suggests that the numbers of persons who get genetically re-classified to Dysfonctionnel every year seems to hover around the numbers of Dysfonctionnel prisoners who die in an average year. While this convergence could, theoretically, be a pure coincidence, it further fuels the critics of the present TECON genetic re-classification process, who worry that TECON Tribunal Members may be motivated by executive pressures and policy influences of the Purgation State government to tweak the re-classification numbers not with an eye towards achieving a just and fair outcome in individual cases but to adequately 'replenish' the 'liquidation facilities' of their deceased and dying numbers without expanding their total numbers to an unmanageable sum. Indeed, these anxieties have only been accentuated by allegations from foreign observers and international human rights groups who have claimed to have compiled lists of TECON adjudicators with 're-classification friendly' voting records going on to snag lucrative consultancy positions or boards of directorship positions in top Purgation corporations which are either concessionaires over the concentration camps and the slave labourers therein or invest in concession-linked derivative financial products (des profits à prendre) which directly or indirectly profit from the slave labour of these camps or who went on to become well-paid lobbyists for La Chambre de Commerce et d'Industrie (CCI), the business group that aggressively represents their interests to the Purgation State government and the PNL-controlled Ministry of Commerce and International Trade in particular (which oversees and monitors the system of privatised concession contracts over the liquidation facilities and the enslaved labour thereof), which was only fuelled further worries of a risk of TECON adjudicators being motivated by a personal profit incentive to favour re-classification with an eye towards securing a future lucrative career in the private sector, as the real driving factor behind the relatively high 'genetic re-classification rate' of around 86-87%.

In contrast, the Purgation State government, and especially the Attorney-General, have generally dismissed and rebuffed such expressed concerns, with the AGO in particular holding the view that the high re-classification rate is entirely attributable to the AGO's careful sieving and winnowing of cases such that only the comparatively serious, truly meritorious cases make it before a contentious hearing with an ad hoc TECON tribunal to begin with. The AGO frequently points to the fact that it only ends up proceeding upon an estimated 55-60% of all 'complaints' (that percentage was around 58% in 2022) instituted by the complainant 'stakeholder' - usually, if not always, being PICOS, as a matter of convention - and that in approximately 8-13% of such PICOS-instituted 'complaints', the AGO state counsel was even willing to withdraw the 'complaint' against the re-classification respondent despite the fact that all three 'stakeholders' had been supportive of such re-classification. Moreover, an estimated one-third of the 'complaints' which the AGO proceeds on never make it to a contested hearing before an ad hoc TECON tribunal due to a voluntary settlement agreement being reached between the AGO and the re-classification respondent. Hence, from the time PICOS brings a 'complaint' to the attention of the Attorney-General, to the time a 'complaint' is put before a TECON tribunal that has been constituted ad hoc to finally dispose of it on its merits, nearly three-quarters of all such 'complaints' would have already been withdrawn by the AGO state counsel by that point, leaving only the most serious and the most patently and obviously meritorious of re-classification cases, which, in the AGO's view, better explains the high re-classification rate - in fact, it has even been frequently argued by organisations like PICOS, the PIGC, and the Purification Order, that given the level of 'filtering' involved, not to mention the fact that many 'complaints' brought to the attention of PICOS officers never result in a re-classification action before the AGO to begin with, the fact that even as many as around 13-14% of re-classification actions are still being routinely dismissed by TECON tribunals is proof of the institutional independence and impartiality of such tribunals, and there is even room to argue that the percentage of successful re-classifications is actually far too low, as opposed to being too high, when one factors in the number of re-classification cases which are dropped or discontinued before it ever proceeds to a contentious hearing to begin with. As for the credentials and expertise of the TECON adjudicators, the AGO has argued that the fact that TECON Tribunal Members are not, primarily, subject-matter experts on law and jurisprudence is in fact a benefit of the TECON system and not a drawback. It has been argued by the AGO that the question of whether a person is better classified in law as Sain or Dysfonctionnel is, in fact, a "question of mixed fact and law", requiring not primarily legal expertise per se but rather detailed subject-matter expertise on the specific contours and modalities of the Purgation State's Sain-Dysfonctionnel eugenical classification scheme, and the defining features and characteristics of one class versus that of another. In the AGO's view, it is better for the adjudicators on the TECON tribunal to be persons with expertise and experience in maintaining the quality and vitality of the genetic stock and blood of the Purgation national community, and to that end, the fact that most persons listed on the panels of potential adjudicators, as are maintained by the three 'stakeholders', are persons who worked for many years as, inter alia, PICOS enforcement officers, PPF police officers, Purification Order soldiers, Home Office civil servants, or PIGC scientists, is a benefit of the present system, by allowing genetic re-classifications to be determined by subject-matter experts on Purgation eugenical public policy, allowing the TECON genetic re-classification system to be a specialised procedural regime tailored to the unique and specific subject-matter therewithin. Given that the issues confronting TECON tribunals are generally factual as opposed to legal in nature, it is no problem that TECON Tribunal Members generally have more limited exposure to legal training, such as by undertaking a one-year or two-year graduate legal diploma course, and have more extensive experience in maintaining and enforcing Purgation public policies in the fields of eugenics and genetic differentiation under the auspices of the Home Office, the PIGC, the PPF, PICOS, or even the Purification Order. Any strictly legal questions would have been determined as a pre-hearing matter by the TECON secrétariat juridique and their individual adjoint (ou adjointe) au secrétariat, who are graduates with undergraduate law degrees and are qualified barristers with their primary subject-matter expertise being in the fields of law and jurisprudence. Finally, the AGO has argued that the system of ad hoc appointments of individual TECON tribunals helps to maintain the flexibility of the present system, creating greater ease and operational flexibility for new names to be freely added onto the adjudicative panels maintained by relevant 'stakeholders' without having to formally hire and fire as is the case for a standing judicial body, while maintaining adjudicators on the panel who have undertaken other part-time or even full-time work in other fields and careers (reducing the quantity of TECON cases they take on as a result), hence avoiding all of the bureaucratic hassle and manpower concerns occasioned by having to employ or retrench judicial officers on a strictly full-time basis only, thereby allowing the 'stakeholders' to quickly and efficiently incorporate 'new talent' into their pool of existing adjudicators as and when they arise, whilst retaining the specialist expertise of the experienced adjudicators who may wish to explore other career routes on the side, and that any lingering concerns about the individual or institutional competence and impartiality of TECON Tribunal Members are adequately addressed by existing procedural safeguards already incorporated into the TECON re-classification process, including mechanisms for the challenge of individual appointments, and systems of appeal and review to correct any errors of law that may be made.

Whatever the view one may adopt as to the overall policy merits or demerits of the specialised TECON process for genetic re-classifications, certain mandatory formal requirements must be satisfied in respect of every award rendered by an individual ad hoc TECON tribunal - first, the award must be published in writing (see, r 257(1)(a), GIRCR 2012); second, it must be signed and dated by at least a majority of Tribunal Members (see, r 257(1)(b), GIRCR 2012); third, the award must state, directly and explicitly, at the ending dispositif thereof, whether the respondent is to be classified from henceforth as Génétiquement Sain or Génétiquement Dysfonctionnel, with no intermediate alternatives or extraneous options being available to be ordered instead (see, r 257(1)(c), GIRCR 2012); fourth, the award must provide reasons for its genetic classification that is ordered in the dispositif (see, r 257(1)(d), GIRCR 2012); and fifth and lastly, the award's reasons must address the evidence adduced at the hearing and the arguments and submissions of parties (see, r 257(1)(e), GIRCR 2012).

The responsibility is on the TECON secrétariat juridique to ensure that the imperative formalities of a TECON award are satisfied. An adjoint au secrétariat or adjointe au secrétariat will double-check and verify whether the above formality requirements of r 257 are fully met, and to authenticate and notarise the award rendered (see, r 257(2), GIRCR 2012). Once their notarisation is appended or affixed to the award, the award is regarded as validly rendered, and the TECON tribunal is treated as functus officio from then on (see, r 258(3), GIRCR 2012). The adjoint (ou adjointe) au secrétariat is then required to transmit and deliver authenticated copies of the written award to the AGO, the re-classification respondent, and all three 'stakeholders' (see, r 257(3), GIRCR 2012). Once the TECON tribunal is functus officio, no further changes, amendments, and alterations of the form or contents of the award may be made any longer (see, r 258(1), GIRCR 2012), hence the words and substance contained in an authenticated and delivered award are to be treated as final and inalterable by all interested parties.

Once the parties have received the final authenticated copy of the TECON tribunal's award, it is time for them to consider their positions as either the winning or losing party and contemplate their next course of action, at which point the proceedings may move onto their next stage, that is, the Appeal stage of the process. The AGO may wish to appeal a TECON award refusing to re-classify the respondent from Sain to Dysfonctionnel (see, r 310(a), GIRCR 2012), and likewise, the re-classification respondent may similarly wish to appeal against a TECON award which grants or affirms a re-classification 'complaint' against him or her (see, r 310(b), GIRCR 2012). The procedure for seeking leave to appeal is the same for both parties, namely, the appellant must file a Notice of Appeal to the TECAT chef du registre within 16 days of having received the signed and notarised authentic copy of the TECON tribunal's award as transmitted by the TECON secrétariat juridique, and serve a copy of that notice on the party-opponent by way of personal service (see, r 313(1), GIRCR 2012). Then, within 24 days of the filing and serving of the Notice of Appeal, the appellant must file an Appellant's Bundle with the TECAT chef du registre, setting out the grounds of their intended appeal, the points of law and fact to be raised on that appeal, a bundle of all legal authorities or precedents the appellant wishes to cite in support, a request for a transcript of the TECON hearing below with an undertaking to bear the costs and disbursements of producing that transcript, and an originating summons for permission to appeal or leave to appeal to be granted by the TECAT chef du registre, serving a copy of the Appellant's Bundle on their party-opponent on the same day (see, r 313(2)(a), GIRCR 2012). Next, within 30 days of being served with the Appellant's Bundle, the respondent must then file their Respondent's Bundle with the TECAT chef du registre, containing a statement as to whether the respondent consents to or wishes to challenge the appellant's application for permission or leave to appeal against the TECAT award, and if they wish to so challenge the application, they must set out their grounds for seeking refusal of leave to appeal, a bundle of legal authorities or precedents the respondent wishes to cite in support, and written submissions establishing why the respondent believes the requisite threshold has not been crossed for leave to appeal to be granted to the appellant, whilst serving a copy of the Respondent's Bundle on the appellant by way of ordinary service on that same day (see, r 313(2)(b), GIRCR 2012). If the respondent agrees that leave to appeal should be granted, then permission is granted by consent (see, r 313(2)(c), GIRCR 2012), although in practice this almost never happens. If the respondent objects to permission to appeal being granted, and files written submissions to that effect, the appellant is given an opportunity to respond by filing his or her written submissions-in-reply to the TECAT chef du registre within 15 days of having been served with the Respondent's Bundle and serving a copy on the respondent on the same day (see, r 313(2)(d), GIRCR 2012).

A sous-chef du registre will then be appointed to determine whether leave to appeal should be granted or refused. At this stage, a certified copy of the transcript of the hearing below will usually be available by this point in time. The sous-chef du registre will thus convene a Case Management Conference (CMC) and invite the parties to make further written submissions and to file and serve supporting affidavits with the benefit of being able to make reference to the contents of the TECON hearing transcript, and to set timelines and deadlines therefor (see, r 313(3), GIRCR 2012), before convening a hearing on the originating summons, to hear oral submissions from parties and make a ruling on whether leave to appeal should be granted or denied (see, r 313(4), GIRCR 2012).

The TECAT standing appellate body has a plenary appellate jurisdiction to affirm, reverse, or vacate (and remand for a fresh hearing) the TECON award that was rendered below (see, Art 15(2), Special Tribunals Establishment Ordinance). It has broad discretion to reverse and/or interfere with or amend any findings of law, findings of fact, procedural rulings, and other exercises of discretion by the decision-makers below, including the pre-hearing rulings of the TECON secrétariat juridique and the hearing award rendered by the ad hoc TECON tribunal itself. It was been held by the Supreme Court, however, that the appellate jurisdiction of TECAT should be exercised in a similar fashion as the appellate jurisdiction of an ordinary court of law (see, e.g., Maël Beausoleil et alius c. Attorney-General [2016] 4 RJRP 3989 and Claire-Louise Chassaigne et alia c. Attorney-General [2018] 10 RJRP 9980), that is, alleged errors of law can be corrected on an independent de novo basis, alleged errors of fact can only be overturned or reversed if the first-instance factual finding is manifestly erroneous or clearly wrong whilst according due deference to the findings of the initial fact-finder (such as, for example, findings as to whether a witness is credible or incredible) given that the appellate judge will not have had the benefit of presiding over the initial hearing and assessing all of the evidence presented first-hand, and finally, alleged procedural improprieties are to be assessed on an 'abuse of discretion' basis such as an exercise of discretion that was 'clearly and palpably against the logic and effect of the case and that of the record below'. Thus, in assessing whether permission to appeal should be granted, the TECAT sous-chef du registre is to assess whether the proposed appeal raises 'credible points of appeal' which are 'not hopeless' and that possess a 'realistic and reasonable prospect of success' (see, r 326(1), r 326(3) & r 326(4), GIRCR 2012). What this means, in practice, is that the sous-chef du registre will generally deny permission to appeal if, for example, the appellant merely rehearses the factual or evidential arguments made below which the TECON tribunal already heard and rejected, or repeats first-instance arguments regarding witness credibility, or raises only errors of fact (and no errors of law) in their stated grounds of appeal without the appellate record of the hearing below disclosing any patent, obvious, or manifest errors of factual reasoning or the drawing of factual inferences from the evidence below. Likewise, even if the grounds of appeal raises alleged errors of law (which are assessed de novo, meaning without according any deference to the first-instance interpretation of the law), the appeal would be deemed meritless and hopeless by the sous-chef du registre if the legal argument being made is obviously unsustainable even on a prima facie examination thereof, such as where the appellant attempts to argue that the TECON tribunal misinterpreted the law but the TECON tribunal's interpretation was clearly supported by the plain wording of the relevant legislation or covered by an existing judicial precedent.

The statistics show that, generally speaking, re-classification respondents are far more likely to attempt to appeal against TECON awards rendered against them as compared to the AGO state counsel which are typically far more reticent about appealing against TECON awards which are not made in the Attorney-General's favour. Perhaps because of the severe legal consequences of being re-classified as Dysfonctionnel, nearly all re-classified respondents seek to appeal against their re-classification, with the 2023 Home Office report showing that, in the year 2022, more than 80% of genetic re-classification respondents lodged 10.411 million applications to the TECAT chef du registre filing originating summonses seeking permission to appeal against TECON awards re-classifying them from Sain to Dysfonctionnel, whereas in contrast, the Attorney-General only lodged such applications against just under 10% of TECON awards that dismissed their re-classification 'complaints', amounting to only 182,217 originating summonses in the whole of 2022. Perhaps due to that discretion and selectivity, the 2023 Home Office report also found that the TECAT sous-chefs du registre were significantly more likely to grant leave to appeal to the AGO state counsel's applications as compared to the re-classification respondents' applications. Only slightly over 10% of such re-classification respondents were granted leave to appeal in 2022 (a total of 1.042 million appeals to TECAT) whereas over 60% of the AGO's applications for permission to appeal (a total of 111,038 appeals to TECAT) were granted, by way of contrast. The decision of the TECAT chef du registre to grant or to refuse permission to appeal is final and may not be appealed against, reviewed, or challenged before any court or tribunal (see, r 326(2), GIRCR 2012).

Unlike TECON tribunals which are ad hoc tribunals constituted to hear individual and disaggregated cases, TECAT is a standing judicial appellate body with permanently employed judicial officers engaged to perform full-time adjudicative work, by regularly hearing appeals against TECON awards (where permission to appeal is granted) as a superior court of record, in its appellate jurisdiction (see, Art 15(1), Special Tribunals Establishment Ordinance). Similar to the Court of Final Appeals (CFA), TECAT is imbued with similar powers of the CFA and, more importantly, its approximately 6,172 appellate judges are all appointed through instruments of appointment issued directly by the Magnificus Dominus (see, Art 15(5), Special Tribunals Establishment Ordinance), on the recommendation of the Judicial Appointments Commission (JAC), often drawn from the most senior, esteemed, and experienced members of the Purgation Bar, drawing upon their collective legal expertise in the process. The implication of this is that, under the legal and constitutional principle of Le Principe du Chef, judgments issued by TECAT appellate judges rank hierarchically and normatively superior to the awards rendered by TECON tribunals, whose members are not appointed directly by the Magnificus Dominus, qua Souverain. TECAT hears approximately 1 million to 1.1 million appeals per annum, and all appeals are heard in person in a series of TECAT court-houses and facilities in the provincial capital city of Limogens, unlike TECON proceedings which are conducted in cities and localities scattered across the Purgation State. Hence, if a re-classification respondent is placed on bail bond pending appeal, they must be prepared to travel to Limogens and have the willingness, means, and ability to reside in that city on an extended basis, otherwise they risk having the appeal summarily dismissed (if they are the appellant) or summarily granted (if they are the respondent) by the TECAT sous-chefs du registre on the grounds of their non-appearance at regular Pre-Hearing Case Conferences (PHCCs). If a re-classification respondent is refused bail bond pending appeal, the situation is more straightforward since the onus will then be on PICOS to transfer the respondent to a PICOS detention facility in Limogens, and make proper arrangements for them to be produced in court for all of their scheduled court appearances.

On the subject of bail bond pending appeal, the default rule is that a TECON award takes immediate effect on the date that it is rendered and transmitted to parties and the mere filing of a Notice of Appeal and the grant of permission to appeal do not automatically operate as a stay of execution of the TECON award (see, r 259, GIRCR 2012). This means, for example, that if the TECON award has ordered for the genetic re-classification of the respondent from Sain to Dysfonctionnel, then that award takes immediate effect with all the knock-on legal consequences upon the respondent, including their susceptibility to be transferred to a PICOS-controlled 'liquidation facility' to be subjected to 'liquidation through labour'. Instead, the onus is on the party seeking a stay of execution of the TECON award to apply for a stay of execution by filing a summons in action to the TECON secrétariat juridique within 14 days of the authenticated award being transmitted to that party (see, r 270(1), GIRCR 2012). In order to prevent the award from being enforced by PICOS within the 14 day interregnum, there is also a procedure by which the service of a Notice of Intention to seek a stay of execution upon the Attorney-General operates to effect an automatic interim moratorium staying the execution of the TECON award for a period of 28 days starting from the date of such service, unless the TECON secrétariat juridique extends that period (see, r 270(2), GIRCR 2012). To prevent the abuse of this automatic moratorium, however, it should be noted that the appellant may only serve an NOI once and not subsequently for any reason whatsoever (see, r 270(5), GIRCR 2012), and the effect of an NOI is to stay the execution of the Dysfonctionnel classification and consequentially liquidation but, as a trade-off, PICOS is permitted to preventatively detain the re-classification respondent to prevent their absconding until the TECON secretariat juridique hears the application for a stay of execution and grants bail bond pending appeal (if any) thereat (see, r 270(6), GIRCR 2012). Although it is a matter of judicial discretion whether a stay is granted or not, as a matter of common-sense, given that the respondent's 'liquidation through labour' by PICOS would clearly render the intended appeal otiose and redundant, the TECON secrétariat juridique will typically grant the requested stay of execution practically as a matter of course. The standard form of the order is that the stay of execution will lapse either on the date that the TECAT chef du registre denies permission to appeal or on the date that the TECAT judge dismisses the appeal, whichever is applicable. If the TECON award refuses to re-classify the respondent to Dysfonctionnel, there is no avenue for the AGO to seek a stay of execution of that award (see, r 270(3), GIRCR 2012), since the award's effect is negative rather than positive, being an omission as opposed to a legal act capable of being stayed.

In all cases, however, after the Notice of Appeal has been filed and served, whether it is against a TECON award that grants or refuses re-classification, the question of whether bail bond pending appeal should be granted, and on what terms, necessarily arises. The procedure for this differs slightly depending on which side is appealing against the TECON award below. If the re-classification respondent is the one appealing against a TECON award re-classifying him or her as Dysfonctionnel, the question of bail bond pending appeal is determined as a consequential matter after a stay of execution is granted (see, r 271(1), GIRCR 2012). Hence, after the TECON secrétariat juridique has granted a stay of execution, it can proceed to consider the question of bail bond pending appeal on its own accord, proprio motu, without the summons seeking a stay of execution having to formally request for bail bond pending appeal as well (see, r 271(2), GIRCR 2012). If, however, the AGO is seeking to appeal a TECON award refusing genetic re-classification, the procedure necessarily differs since there is no avenue for the AGO to seek a stay of execution of that award. The default rule is that, once the TECON tribunal has dismissed a re-classification 'complaint', there is no longer a res justifying the continued detention or bail bond of the respondent who was the subject of that res. Consequently, by default, a respondent is to be released from PICOS detention once that award is rendered and takes effect, and if they were released on bail bond, that bail bond and all its conditions will expire on that date as well (see, r 271(5), GIRCR 2012). If the Attorney-General wishes for the respondent to be placed on bail bond pending appeal, it must put in a summons in action to that effect within 7 days of filing and serving its Notice of Appeal (see, r 271(3)(a), GIRCR 2012), and the TECON secrétariat juridique will make a ruling on whether to impose bail bond pending appeal, and if so, the conditions of that bail bond, which invariably (but not necessarily) will often differ from the terms of the bail bond before a TECON award was rendered dismissing the AGO's re-classification 'complaint'. Typically, even if bail bond pending appeal is granted in such circumstances, the bail quantum is likely to be lower, and the restrictive conditions of the bail bond, including curfews, placements on Home Office 'watch lists', and restricted residence within highly-surveilled neighbourhoods, are likely to be dropped or relaxed, since the TECON tribunal's acquittal of the respondent is regarded as a weighty factor significantly lowering the respondent's 'flight risk' and reducing their prospect of absconding or fleeing the jurisdiction. If the AGO fears that there is an 'imminent risk' of the respondent absconding before its application for bail bond pending appeal can be heard and decided, there is an exceptional provision for PICOS to preventatively detain the respondent for a maximum of 48 hours (see, r 271(3)(b), GIRCR 2012), and before the expiry of that deadline, the respondent must be produced before an adjoint (ou adjointe) au secrétariat of TECON to determine, under all the circumstances, whether the respondent should be released on bail bond subject to conditions or released without conditions altogether (see, r 271(3)(c), GIRCR 2012). It is not possible, in such circumstances, for a respondent who was acquitted by the TECON tribunal to be preventatively detained pending the appeal lodged by the Attorney-General (see, r 271(3)(d), GIRCR 2012). Otherwise, the applicable default rule remains that the respondent is to be released without conditions until and unless bail bond pending appeal is granted on the application of the Attorney-General to that effect.

Given the due deference which TECAT accords to first-instance findings of fact and initial exercises of discretion by TECON at the hearing below, as is typical for all exercises of appellate jurisdiction more generally, it should not come as a surprise that most appeals, whether they are lodged by the re-classification respondent or the Attorney-General, come to be dismissed by TECAT appellate judges. Based on official statistics published in the 2023 Home Office report, out of the approximately 1.153 million appeals which were permitted to proceed in the year 2022, around 13-14% of such appeals were successful, with 156,808 appeals being granted and the remaining 996,192 appeals being dismissed. For appeals lodged by the re-classification respondent, the success rate of such appeals was 12.2%, with 127,124 of such appeals being granted and their genetic re-classifications either being reversed entirely or vacated and remanded for a fresh hearing before a newly constituted TECON tribunal by TECAT judges, whereas the success rate for appeals lodged by the Attorney-General stood at about 26.7% with 29,684 appeals being granted by TECAT appellate judges in that same year, meaning that the genetic re-classifications were either granted outright despite the 'complaint' having been dismissed by the TECON tribunal below or the award refusing re-classification was simply vacated with the case being remanded for a fresh hearing before a new TECON tribunal by TECAT appellate judges.

Once the appeal is heard and determined, parties must consider their positions further in respect of the final recourse available to them, which lies at the Review stage of proceedings. This stage refers to the final domestic 'remedy of last resort' which is available for the losing party to exhaust, that is, to seek a review of the TECAT decision by the Supreme Court of Cassation of Purgatio, which is sought by filing a 'petition for review' to the Supreme Court (see, Art 16(3), Special Tribunals Establishment Ordinance), which is similar in many respects to the ordinary process of filing for a 'petition for cassation' seeking a quashing order or writ of certiorari from the Supreme Court cancelling or annulling the decision of the court below, in this case being the decision of the TECAT standing appellate body. The Supreme Court is not obligated to accept the petition, and has the full and unfettered discretion to either agree to hear and consider the petition or decline to hear the petition entirely. In reality, the Supreme Court very rarely accepts 'petitions for cassation' presented against judgments of the Court of Final Appeals (CFA), for which the acceptance rate hovers at around 2-3% per annum, and generally only accepts to hear a petition when it raises an important question of law that is unclear or unsettled in the court's prior jurisprudence, thereby offering the Supreme Court the opportunity to provide much needed clarity and certainty over a legal issue of major public importance. The acceptance rate is even lower in respect of 'petitions for review' presented against decisions of the TECAT standing appellate body, in no small part because the procedure for seeking 'review' of TECAT rulings is expressly limited by statute only to determining "any question of law or jurisdiction" as engaged by the TECAT decision below (see, Art 16(6), Special Tribunals Establishment Ordinance), which further limits and narrows the possible grounds that may be raised by the petitioner to seek the quashing or reversal of the TECAT judgment below. Hence, according to official statistics of the Supreme Court in 2023, it was reported on its website that in the year 2022, the Supreme Court received 23,727 'petitions for review', with most of them (22,311 petitions or over 94% thereof) being filed by the genetic re-classification respondent, and the remainder (1,416 petitions or fewer than 6% thereof) being filed by the Attorney-General. The acceptance rate for 'petitions for review' was very low - less than 0.1%, in fact - with the Supreme Court only accepting and hearing 23 of such petitions in 2022, and with the petition eventually failing in 22 out of those 23 cases and succeeding in only one (that was the successful petition filed by the AGO state counsel in Attorney-General c. Gérard-Marlon Doutreleau [2022] 12 RJRP 11014, which held that TECAT had erred as a matter of law in adopting the overly narrow or rigid interpretation of the category of the "imbecilic, retarded, and feeble-minded" in Art 1(3) of the Special Tribunals Establishment Ordinance as a class categorically excluding intellectual disabilities which did not result in the respondent having an 'unduly low IQ or otherwise impaired cognitive ability', such as Tourette syndrome, which was the disorder the respondent had in that case, wherein the Supreme Court held that while there was no categorical rule that having such intellectual impairments ipso facto qualified for the category of the "imbecilic, retarded, and feeble-minded", unlike intellectual impairments which did produce an unduly low IQ of below 70, neither was there any contrary categorical rule to the effect that such impairments were entirely excluded from such a legal category, their qualification or otherwise as being reflective, or not, of an "antisocial, deviant and/or parasitical disposition" would depend on the facts of the case and how the disorder manifested in practice in the day-to-day living and general existence of the respondent).

Through the statutory 'petitions for review' regime and procedural avenue therefor, the Supreme Court has had the opportunity to pronounce upon and declare major and fundamental questions of law affecting the genetic re-classification process as a whole, of which three bear mentioning given the seminal impact that they have had on how TECON tribunals and TECAT judges decide re-classification cases on a day-to-day basis. The first is the case of Nicodème Friesen c. Attorney-General [2015] 2 RJRP 1957 ("Nicodème Friesen"), which is an oft-cited precedent concerning the meaning and application of the intermediate evidential standard of 'preponderance of the evidence' that is unique to the genetic re-classification process alone and to no other area or aspect of Purgation State law, falling somewhere midway between the 'beyond reasonable doubt' standard in criminal law and 'balance of probabilities' in civil law. The Supreme Court in Nicodème Friesen endorsed the now-famous definition of the 'preponderance of the evidence' standard in the following terms, to wit, "that where a 'balance of probabilities' requires the party on whom the burden of proof falls to make out that the thing to be proved is more likely to be true than false, in other words, a probability or likelihood of at least above 50% even if only slightly or marginally so - indeed, a demonstrated 50.00001% likelihood would suffice for the purposes of ordinary civil or private law - the unique standard of 'preponderance of the evidence' embraces something higher, more substantial, more real and material than that. It requires that, on a consideration of all the evidence, the likelihood that the fact in issue is true as opposed to false is largely, materially, and substantially greater than otherwise. No strict or rigid mathematical formula is conceptually possible or, indeed, helpful in individual cases; however, while it is not necessary for the proving party to exclude any and all articulable, plausible, and reasoned doubts arising out of the evidence, the comparative likelihood that the fact in issue is true, as opposed to false, cannot be something bare, slight, or minimal. The broad and substantial weight of the evidence presented should tilt and militate, largely, materially, and appreciably, in favour of the conclusion that the fact in issue is more likely to be true than false, although it need not be overwhelmingly so. Where the 'beyond reasonable doubt' standard is often said to be satisfied where the fact-finder looks at all the evidence and concludes, in respect of a possible doubt raised about the accuracy of that fact, that 'well, I suppose that that may be possible but not very probable', the 'preponderance of the evidence' threshold may be said to be crossed where that fact-finder looks at that evidence and forms the considered view, in respect of the countervailing evidence presented against the fact in issue, that 'oh, I suppose that there is a fair chance of it being false but a more substantial and weightier chance of it being true'" (see, Nicodème Friesen at [27]).

Beyond this articulation of the relevant evidentiary standard, however, that case is also notable for its pronouncement of the famous 'non-segmentation principle' in law, respecting the application of the 'preponderance of the evidence' standard. It was reiterated that the burden of proof is on the Attorney-General to prove its case on a 'preponderance of the evidence', and the question of mixed fact and law which the AGO state counsel must prove to the satisfaction of that standard is whether the respondent possesses an "antisocial, deviant and/or parasitical disposition" overall (see, Art 1(1) of the Genetic Identification Ordinance and Art 1(2) of the Special Tribunals Establishment Ordinance). In the view of the Supreme Court, this does not require the AGO to prove each and every fact it seeks to allege against the respondent on a 'preponderance on the evidence' standard, provided that that global and holistic question of fact is proved to the satisfaction of that legal threshold (see, Nicodème Friesen at [34]-[36], [44], and [53]). That case had involved a respondent who had served on the board of directors of a commodities trading company who had been charged with 13 counts of securities fraud, 10 counts of fraudulent trading, and 8 counts of embezzlement, for his involvement in a massive 'sham bonds' round-tripping scandal involving sums as large as $411 million Élites which drove a once-profitable trading entity into bankruptcy and liquidation (see, Nicodème Friesen at [8]-[9]). Following an extensive trial on the matter, the Presiding Justice sitting in the Court of First Instance (CFI) convicted him of some charges and acquitted him of others (on the basis of reasonable doubt as to the true motive behind certain impugned financial transactions and whether they were legitimate or improper at the time) (see, Nicodème Friesen at [14]-[15]). At the TECON hearing below, the AGO state counsel raised many factual allegations concerning not only the charges on which the respondent had been convicted, but also the charges on which he had been acquitted, since the criminal evidential standard of 'beyond reasonable doubt' was higher and more onerous than the re-classification evidential standard of 'preponderance of the evidence' (see, Nicodème Friesen at [13]). The re-classification respondent's counsel argued, relying on similar arguments made in the criminal trial, that the unclear and ambiguous evidence that was available could not prove on a 'preponderance of the evidence' standard that the impugned financial transactions forming the subject-matter of the acquitted charges had been illegitimate, fraudulent, or in any way improper (see, Nicodème Friesen at [2]-[3] and [11]-[12]). The TECON tribunal disagreed and took the view that it only had to assess, overall and holistically, whether it was satisfied of the respondent's genetically disordered tendencies on the 'preponderance of the evidence', and it did not have to satisfy itself that that evidential standard was also satisfied in respect of each and every financial transaction, hence the TECON tribunal granted the re-classification in its award, and the TECAT appellate judge affirmed that outcome and agreed that no error of law had been disclosed in that approach of the Tribunal Members (see, Nicodème Friesen at [16] and [19]).

[Purgatio]

The Supreme Court held clearly that the TECON tribunal and TECAT appellate judge had been correct on the law. It was "patently and plainly logical fallacious" to suggest that the fact in issue respecting the "antisocial, deviant and/or parasitical disposition" of the genetic re-classification respondent could only be shown on a 'preponderance of the evidence' if each and every factual allegation forming the factual substratum of the Attorney-General's case was individually proven to the satisfaction of that same standard (see, Nicodème Friesen at [31]). The judgment provided the following thought-provoking hypothetical to illustrate what the court saw as the logical fallacy in the respondent's argument, "[s]uppose it is accepted, for the sake of argument here, that the fact-finder is persuaded that a demonstrated paedophile who is guilty of the sexual abuse and exploitation of minors is, indeed, a person who possesses a 'parasitical' disposition, for the purposes of showing their genetically disordered tendencies in law. The Attorney-General's only evidence takes the form of the contestable oral evidence of eight alleged child victims, each of whom gives testimony accusing the respondent of having performed sexual acts upon them, where such evidence is of questionable reliability or veracity, for whatever reason, consisting as they do of both credible and incredible elements and aspects thereof. Suppose as well that, in that scenario, it could be mathematically and precisely proven, statistically, that each alleged victim's evidence has a 50.1% probability of being true, and a 49.9% probability of being false, individually and independent of each other. In that scenario, the testimony of one victim, alone, would clearly not suffice to show, on a 'preponderance of the evidence', that the respondent had in fact perpetrated an act of sexual abuse upon a minor, for the purposes of making out his alleged dysfunctional disposition as a human being. Is the conclusion then that since each alleged victim's testimony would, individually and considered in isolation alone, fail to meet the requisite evidentiary threshold for the purposes of genetic re-classification proceedings, that all of their accusations of sexual abuse of a minor should be rejected wholesale as non-facts or unproven facts for the purposes of adjudging the complaint? That would plainly be fallacious, resting on a wholly erroneous understanding of what, precisely, that heightened evidential standard is intended to apply to. The question to be proven on a 'preponderance of the evidence' is the disordered disposition of the respondent overall, and not the separate, individual, and independent facts alleged against the respondent and said to form the supportive ground for relevant inferences of fact to be drawn as to the disordered disposition of the respondent as a human being. In the scenario provided, while the probability of the respondent having sexually abused any one individual minor witness may only be 50.1%, the probability of the respondent being entirely innocent of sexually abusing any of the alleged victims is less than 0.4% - in other words, there is a more than 99.6% likelihood that the respondent sexually exploited at least one of the eight alleged minor victims in question. In such a case, it can correctly be said to be proven on a 'preponderance of the evidence' that the respondent has sexually abused or exploited a minor, and if that fact is deemed by the fact-finder to be enough ipso facto to constitute a genetically disordered tendency, in law as well as in fact, then the disordered disposition of the respondent will necessarily have been proven to the satisfaction of the 'preponderance of the evidence' legal standard, in full discharge of the complainant's burden of proof, even if the individual alleged incidents of sexual abuse, when considered independently and separately from each other, would not have sufficed in isolation to satisfy that same threshold" (see, Nicodème Friesen at [33]).

Another seminal and landmark judgment issued by the Supreme Court respecting the laws of genetic re-classification was rendered in Jean-Julien Labiorteaux c. Attorney-General [2016] 7 RJRP 6788 ("Jean-Julien Labiorteaux"), which established the legal 'principle of respondent-centricity' in re-classification proceedings. That case concerned a respondent who was a homosexual male who had engaged in so-called 'serial cruising' and 'serial cottaging' activities contrary to public order and public decency roughly hundreds of times from 2004-2012, before being caught in November 2012 by a janitor who entered a public lavatory and caught the respondent masturbating therein (see, Jean-Julien Labiorteaux at [9]-[10] and [12]). A key issue of controversy at the TECON hearing was whether the public order offences committed by the respondent were serious enough to meet the threshold of showing an "antisocial, deviant and/or parasitical disposition" overall, with the TECON tribunal voting unanimously to re-classify the respondent to Dysfonctionnel, on the basis of the "repeated and recalcitrant nature of the repetitive public nuisances and antisocial behaviours demonstrated by a most defiant and unusually intractable respondent" (see, Jean-Julien Labiorteaux at [11(a)]) combined with the "respondent's instigative nature and his established proclivity to pressure and encourage other more socially-minded homosexual males in this country into indulging in such public depravities and profane degeneracies, creating a social hazard of moral corruption, particularly of young people, thereby creating a heightened need for public protection" (see, Jean-Julien Labiorteaux at [11(b)]). That re-classification award was affirmed on appeal by a TECAT appellate judge, who adopted the view that while acts of 'public cruising' and 'public cottaging' would not, by themselves and in isolation, be sufficient to meet the serious threshold to justify genetic re-classification, "no error of fact or law was disclosed in the award rendered below" on account of the "combination of the two critical factors identified by the tribunal", referring to the high quantity of the offending acts considered together with the fact that the respondent was the primary instigator of many such acts and therefore deemed to pose a social risk of the moral corruption of the young (see, Jean-Julien Labiorteaux at [12]-[13]).

That finding by TECAT - that it was only the combination of those two aggravating factors combined which met the necessary threshold of severity to justify re-classification - proved critical to the respondent's petition to the Supreme Court, because the finding that the respondent was the so-called 'primary instigator' of these acts of 'public cruising' and 'public cottaging' rested entirely on the testimony of a single witness for the Attorney-General. The AGO's evidence of the respondent's public indecencies and public nuisances generally consisted of oral evidence from third parties such as police officers, janitors, park rangers, and joggers, who attested to either the sexual and obscene noises made by the respondent in various locales, the states of undress that he was found in on various occasions, and circumstantial evidence concerning passers-by who attested to seeing the respondent frequenting certain lavatories, cubicles, or forested areas of parks which were alleged by various police officers to be 'known homosexual haunts' or 'reputed cruising locales frequented by degenerate sex pests and gay perverts' (see, Jean-Julien Labiorteaux at [15]-[16]). Hence, the only direct first-hand evidence provided as to the behaviour and conduct of the respondent in performing such sexual acts in public was the oral testimony of Monsieur Ansel de Lussan, son of the Home Secretary, Madame Joslyn de Lussan, who was discovered to have been involved with the respondent in various public sexual acts or 'public cottaging' activities from 2009-2010, whilst he was a young university student at the PIGC's Grande-École for Higher Education and Learning in his early-twenties (the respondent was in his early-forties in that period of time), due to photographs and messages between Monsieur Ansel de Lussan and the respondent that were found by police investigators on the latter's mobile phone and computer following his arrest and a post-arrest search conducted on his residence in November 2012 (see, Jean-Julien Labiorteaux at [2]-[5]), which caused a huge public scandal besetting both the Home Office and Home Secretary when such shocking revelations were leaked to the press back in 2013. In short, Monsieur Ansel de Lussan's evidence was that he had met the respondent in a public bathroom in Ravaliér, in a neighbourhood or area in which many gay nightclubs, bars, and other such establishments were concentrated, and it was the respondent who pressured him into giving him oral sex in a lavatory despite the witness's unwillingness to do so. It was also his evidence that the respondent continued pestering and harassing him for oral sex on that occasion and on multiple subsequent occasions whenever the pair ran into each other in that neighbourhood, and gave further evidence on the more salacious details of the specifics of the sexual acts he subsequently performed with the respondent on a number of occasions, in public spaces including parks and toilets. Crucially, this meant that the TECON tribunal's finding of fact that the respondent was the instigator and author of these acts of public indecency as opposed to being a mere passive participant therein rested wholly and entirely upon the uncorroborated testimony of a singular witness, to wit, Monsieur Ansel (see, Jean-Julien Labiorteaux at [6]-[9] and [12]-[13]). Thus, in his 'petition for review' to the Supreme Court, the re-classification respondent presented a number of questions of law attacking the TECON tribunal's treatment of Monsieur Ansel's evidence (see, Jean-Julien Labiorteaux at [1]).

The first issue raised was whether the 'preponderance of the evidence' standard can be said to be satisfied merely by reference to the uncorroborated evidence of a lone witness. The Supreme Court answered that question in the affirmative, holding that there is no rigid rule of law to the effect that a finding that the respondent possesses an "antisocial, deviant and/or parasitical disposition" overall as a person, on a 'preponderance of the evidence', categorically cannot be satisfied with reference to the uncorroborated evidence of a single witness in every and all cases; rather, all will depend upon the weight to be accorded to that evidence, based on a full assessment of the reliability and credibility thereof, with reference to the usual metrics of such reliability, including the witness's self-interest, the consistency (external and internal), coherency, and cogency of their testimony, their tone, mannerisms, and demeanour on the stand (and especially in cross-examination), the details and the completeness of their account, the comprehensiveness of their evidence, their asserted basis for their evidence and their personal knowledge thereof, indicators of whether the witness is partisan or neutral in their testimony, and the inherent believability, plausibility, and reasonable likelihood of their asserted account, in the natural and ordinary course of human events (see, Jean-Julien Labiorteaux at [24]-[26]). The critical holding, however, is that there is 'no special rule of law' that stands to be applied to the evidence of a single witness as opposed to the evidences of multiple witnesses, all will depend on the unique and individual circumstances of each case. It is for the TECON tribunal, as the primary fact-finder, to make a holistic assessment of the credibility of a witness and the relative weight to be accorded to the whole or part of their evidence. There is no categorical rule, however, that the evidence of a single witness, where adjudged to be credible and reliable, cannot ever cross the requisite threshold of proving the 'complaint' on a 'preponderance of the evidence', merely because it originates from the mouth of a single uncorroborated witness, for the "determination of whether the evidential threshold is met and the applicable legal burden of proof is discharged is, at the end of the day, a global and holistic assessment, to be evaluated in the round, without reference to rigid rules or the mechanistic applications of categorical prohibitions or universal principles. Whether a witness is credible or not and the weight to be accorded to their evidence is to be determined in a nuanced and fact-sensitive fashion, and the weight to be accorded to different considerations will invariably differ in the wide variety of facts, evidences, and circumstances that confront individual ad hoc tribunals charged with making such first-hand assessments in the initial instance. It suffices to state here, however, that there is no categorical rule prohibiting a tribunal per se from coming to the conclusion that the 'preponderance of the evidence' standard has been crossed or satisfied merely because the supporting evidences emanate from the lone testimony of a singular witness whose account of events is uncorroborated and lacking in extrinsic support from independent or external sources. Much will depend upon the relative weight and influence that the fact-finder decides to accord to the evidence provided by that witness based on all the circumstances of the hearing below" (see, Jean-Julien Labiorteaux at [27]). Likewise, the Supreme Court rejected the 'alternative submission' of the petitioner that, in any event, the fact-finder needs to be satisfied that that witness's testimony is 'extraordinarily or exceptionally credible' or 'uncommonly weighty and influential' to justify a finding that the 'preponderance of the evidence' standard is satisfied based on their lone testimony alone, categorically rejecting the suggestion that "any heightened standard of review is required in law in respect of the testimony of a single witness merely because their evidence is uncorroborated, for the question, as always and in all cases, is merely whether the 'preponderance of the evidence' standard is met in respect of all the evidence provided, however few or many they may be, based on the weight to be accorded thereto. The exercise of the assessment of the credibility of a witness, however, is a holistic and fact-sensitive one and does not depend upon such rigid considerations as how many other witnesses are attesting to the same, for that is only one factor in a broader constellation of factors which are relevant and salient to the inquiry into the credibility of that witness and their testimony. In assessing that multifarious tapestry of relevant factors, however, there is no rule of law that any one factor - such as the presence or absence of independent corroboration - is to be accorded automatic primary or presumptive decisive weight over any and all other relevant considerations in that assessment, so as to justify the unique application of such a so-called 'heightened standard of review' attracting 'additional scrutiny', as the petitioner suggests herein, respecting the adjudgment of the appraisal and determination of the credibility of one witness as opposed to that of another" (see, Jean-Julien Labiorteaux at [28]).

The next question raised in the respondent's 'petition for review' was whether it is contrary in law for the TECON tribunal to accord decisive weight - or, indeed, any material weight at all - to the testimony of a witness whose own genetically disordered tendencies were in doubt, or there was reason to believe that the presence or absence of their own "antisocial, deviant and/or parasitical disposition" is in serious question. This question stemmed out of the respondent's assertion of an alleged double standard in the treatment accorded by the AGO and the three 'stakeholders' to Monsieur Ansel de Lussan as opposed to that which had been meted-out to the respondent, which had in fact been the subject of an earlier 2013 judicial review application instituted by the respondent against the AGO's prosecution of the re-classification 'complaint' against him on the grounds of alleged inequality of treatment amounting to an error of law and/or procedural impropriety (based on the sub-grounds of improper reasons, irrelevant considerations, fettering of discretion, breach of procedural legitimate expectations (PLE), and procedural inequality), all of which the Executive Prerogatives Division (EPD) of the Court of First Instance (CFI) had decisively rejected (see, De Magnificus Dominus (sur l'application de Jean-Julien Labiorteaux) c. Attorney-General (Ansel de Lussan, intervening) [2013] CPIPG 14529 (EPD) at [44]-[45], [65]-[70], and [81]-[84]) and for which leave to appeal was denied by the Court of Final Appeals (CFA), thereby allowing the re-classification proceedings to proceed and permitting the 'complaint' to be heard. This question of law in the 'petition for review' was arguably an attempt to re-litigate that decided issue through the backdoor, albeit in the context of altogether different proceedings that concerned rather different issues of law raised at a more advanced and developed stage of that process. At the TECON hearing below, the respondent had testified in his own defence, claiming that he had not been the primary perpetrator or instigator of these sexual acts, that in all instances he had acted on the agitation and encouragement of the other party to these acts of 'public cruising' and 'public cottaging', inclusive of Monsieur Ansel (see, Jean-Julien Labiorteaux at [11]-[12]). After he was re-classified, on appeal before TECAT, his counsel argued that since the TECON tribunal had been of the view that being a primary instigator of publicly indecent and offensive acts and encouraging other more passive participants to partake in such activities could give rise to a valid ground for re-classification, the respondent, by his testimony, had effectively put in issue the genetic classification status of a material witness for the AGO, namely, Monsieur Ansel. In his counsel's view, this is significant since if a witness ought, rightfully and in law, to be genetically classified as Dysfonctionnel as opposed to Sain, it would be incompatible with the legislative objects and purposes of the re-classification scheme (in the Special Tribunals Establishment Ordinance and GIRCR 2012) for the TECON tribunal to accord anything more than little or immaterial weight to the evidence of a Dysfonctionnel person, for the purposes of determining whether another person was Dysfonctionnel or not. Hence, the TECON tribunal was required to make an express finding of fact as to whether or not Monsieur Ansel was properly classified as Sain or Dysfonctionnel, based on the evidence adduced below, and insofar as the TECON tribunal's award failed - and indeed refused - to opine on that issue, it failed to consider a pertinent point raised by the respondent and the award should be vacated on that ground. The TECAT appellate judge disagreed, however, and affirmed that the TECON tribunal is not required to inquire into the proper genetic classification status of a witness on either side of the process, and that there was no rule of law that the weight to be accorded to a witness's evidence in a re-classification proceeding depended upon their proper or rightful genetic classification status in law. In its 'petition for review', the petitioner suggested to the Supreme Court that that conclusion had been legally in error (see, Jean-Julien Labiorteaux at [3], [5]-[7], and [9]-[10]).

The Supreme Court disagreed with that suggestion and established the 'principle of respondent centricity'. In essence, it was held that the object and purpose of the re-classification process was to determine the disposition and proclivity of the re-classification respondent, and not the disposition or proclivity of any other person. There was no basis in the Special Tribunals Establishment Ordinance or the preamble or legislative context and history thereof to support the petitioner's suggestion that the TECON tribunal had to adopt a 'subjective', 'comparative', or 'relative' approach towards adjudging the proper genetic classification of the respondent by comparing the alleged dysfunctional tendencies of the respondent against the alleged dysfunctional tendencies of other persons involved in the proceedings, be they a material witness for the Attorney-General or a person otherwise alleged to have been involved in similar activities as that of the respondent. The proper forum for adjudging the re-classification status of that witness is a re-classification proceeding in respect of them, that requires the institution of proceedings by the Attorney-General upon the 'complaint' of one of the three 'stakeholders', which did not occur in respect of Monsieur Ansel. There was no basis, therefore, for the TECON tribunal to begin making inquiries into his proper genetic status in law for the purposes of an altogether separate and distinct re-classification proceeding, in which the focus of the process is on the proper genetic status of the respondent and not that of any other person who may be said to have had some involvement or participation in the re-classification process or the underlying subject-matter(s) thereof (see, Jean-Julien Labiorteaux at [36]-[38]). Nor was there any categorical rule of law suggesting that the mere fact that a material witness may have been involved in similar activities as that of the respondent or that their proper genetic status in law ought to be Dysfonctionnel as opposed to Sain was sufficient ipso facto to reduce the weight that ought to be accorded to their evidence, which is based on a holistic assessment of the reliability and credibility of their testimony, not their alleged or ostensible genetic classification (see, Jean-Julien Labiorteaux at [30]-[31]). In the court's words, "the petitioner's notion that the entire legislative and prescriptive raison d'être of the TECON-TECAT re-classification system rests upon the drawing of distinctions between biologically desirable and undesirable characteristics in the body national, and that therefore the fact-finder must inquire into the proper genetic status of a material witness for the Attorney-General and compare their socially disordered tendencies against that of the respondent to adjudge the relative weight to be accorded to each of their testimonies is an absurd nonsense finding no support whatsoever within the procedural framework at hand nor in the legislative history and context thereof. The object and purpose of a re-classification hearing is to determine the proper classification of the respondent and not that of any other person. The fact that some other person - be it a material witness, an alleged victim, an alleged co-participant, or the original complainant - is alleged to have certain disordered or dysfunctional biological tendencies of their own is of absolutely no consequence and is totally and wholly irrelevant to the merits of the re-classification 'complaint'. That is entirely beside the point and can have no bearing whatsoever on the altogether independent question of the potentially disordered or dysfunctional biological tendencies of the re-classification respondent, or the lack thereof. Whether or not such tendencies were demonstrated is to be adjudged based on the credibility and reliability of the evidence adduced against the respondent and whether that evidence suffices to prove the disordered or dysfunctional disposition of the respondent, on a 'preponderance of the evidence'. In that regard, we reiterate that there is no rigid or categorical rule of law that the fact-finder must reduce the probative weight accorded to the evidence of a witness simply because the witness is said to possess certain disordered or dysfunctional tendencies of their own, for it is irrelevant to the merits of the re-classification 'complaint'. For that reason, we find that the ad hoc tribunal cannot be said to have erred in law in having declined to make any finding of fact, either way, as to whether Monsieur Ansel de Lussan ought to be properly classified as Sain or Dysfonctionnel, based on the evidence before it, or that the Tribunal Members must have satisfied themselves that Monsieur Ansel de Lussan cannot be said to be Dysfonctionnel on a 'preponderance of the evidence' before them, in order to proceed to accord any material weight to his testimony. That is most definitively and unequivocally not the law of this land. To that extent, the ad hoc tribunal was correct to refuse to inquire any further into the allegations of the respondent as to the proper genetic status of Monsieur Ansel - and indeed, it would have been wholly inappropriate and improper for the Tribunal Members to engage in that exercise, given that no re-classification 'complaint' had ever been made against Monsieur Ansel and it had no legal standing whatsoever to contemplate that issue or consider that question - as the alleged classification of a material witness is simply not relevant to adjudging the merits of the 'complaint' against the respondent, to the weight to be accorded to their evidence whether alone or in comparison to the evidence of the respondent, or to the proper classification status of the respondent and the presence or absence of dysfunctional tendencies in his or her biology. As such, the supposed or alleged genetic classification status of any other person, irrespective of their involvement in the re-classification process or in the acts inhered in the underlying factual matrix giving rise to the action in the first place, is legally and evidentially irrelevant and thus can bear no probative value whatsoever to a re-classification process that is focussed solely and exclusively upon the question of the alleged "antisocial, deviant and/or parasitical disposition" of the respondent, and their ostensible dysfunctional or disordered biologically ingrained tendencies or otherwise overall, and not that of any other stranger or third party to the proceedings who has not been made a subject thereof" (see, Jean-Julien Labiorteaux at [32]).

Finally, the Supreme Court further articulated on the proper principles to be applied to a re-classification action, and to assess the presence or absence of a so-called "antisocial, deviant and/or parasitical disposition" of the respondent, as a human being, in the leading case of Zéline-Viera Tonye Quívrin c. Attorney-General [2017] 5 RJRP 5013 ("Zéline-Viera Quívrin"), which concerned a respondent who was found to be a habitually homeless vagrant who had wandered and travelled around major metropolitan cities as a so-called 'vagabond' without stable employment or source of long-term economic support from 2010-2015, before being arrested by local Purification Order soldiers in August 2015 (following a complaint by the local city council of Provençal following multiple 'public nuisance' complaints lodged by angry and frustrated residents to their local councillors) and accordingly reported to PICOS. The respondent's case was said to fall into a number of different categories under the Genetic Identification Ordinance and Special Tribunals Establishment Ordinance, including the legal classes of "vandals", "cripples", "vagrants", and "work-shy moochers and leechers", amongst others (see, Zéline-Viera Quívrin at [3]-[7]). A number of propositions were laid down by the Supreme Court in this judgment. First, the Supreme Court articulated the relevant legislative object and purpose behind the entire re-classification scheme, in the context of how an ad hoc TECON tribunal ought to determine the question of whether the threshold for re-classification is met, based on the proven behaviour and evidenced conduct of the respondent, arising out of the re-classification respondent's submission in her 'petition for review' that the TECON tribunal had erred in law in its application of the legal test for re-classification. The court explained that "[t]he entire purpose and conceit behind the present TECON-TECAT genetic re-classification scheme is the identification of the genetically disordered based upon their evidenced phenotypical expression, of a disordered or dysfunctional character, which is said to be a mere manifestation of their innate biological tendencies as a human being. The first port of call for the tribunal should, therefore, always be to have regard to the actual text and wording of the legislation, and the use of the words 'antisocial', 'deviant', and 'parasitical', categories which are understood to be either conjunctive or disjunctive as demonstrated by the draftsman's use of the words 'and/or' in Art 1(2) thereof. In the context of the philosophy of Mandatum Est that forms the underlying rationale and raison d'être of the prevailing re-classification regime, such terms must be understood within that philosophy's conceptualisation of the community as a 'body national' or 'national organism', with social behaviours (that are a mere expression of a person's inner biology and nature) either contributing to, or sapping the strength and vitality of, that national being and community constitution. In that context, 'antisocial' behaviour is a broad category embracing any disruptive or disorderly conduct that could damage national order or public security, stability, and well-being more generally; 'deviant' behaviour is a similarly broad category encompassing rebellious, irregular, transgressive, or otherwise non-conforming conduct (in a perverse or perverted fashion) that harms community cohesion or jeopardises the spirit of communal collaboration and broader social harmony and coordination that forms the necessary foundation for any efficient and smoothly functioning society; finally, 'parasitical' behaviour should be understood as a miscellaneous 'catch-all' category intended to capture any other conduct which takes and saps from the community more than it contributes, which harms the public weal to a greater extent than it benefits the same. Lastly, such descriptors are always modified throughout by, and to be understood and construed with reference to, the draftsman's use of the word 'disposition', which is key. Whilst the fact-finder must, necessarily, consider the conduct of the subject of the re-classification complaint to evidence the inner proclivity or intrinsic orientation of the re-classification respondent, as a person, nonetheless it should never be forgotten that the ultimate inquiry is never into the conduct or behaviours of the respondent per se, but rather, it is an inquiry into the overall disposition of the respondent, in other words, their holistic tendency and global propensity, as a whole and as a person, of which their specific behaviours may form only a mere part of that whole kaleidoscope of actions aligned towards a particular direction, within their nature and their biology, that now stands to be determined and discovered by the tribunal" (see, Zéline-Viera Quívrin at [28]).

Hence, in relation to the petitioner's argument that the TECON tribunal erred in law in failing to consider the positive contributions she alleged that she had made to the community in the past, which included, in her own estimation at least, being a good mother to her four children, volunteering for various charities (back in the past when her financial circumstances were better), and being a faithful and devoted Christian, the Supreme Court held (in agreement with the TECAT appellate judge) that the TECON tribunal had been correct to accord "little to no material weight" to such considerations (see, Zéline-Viera Quívrin at [24]-[25]). It held that the exercise for the fact-finder is to conduct a proper "cost-benefit analysis" of the entire history of the respondent's conduct, to determine whether the relevant social, cultural, and economic liabilities of the respondent, as a human being, which burden the Purgation State community, may accurately be said to quantitatively and qualitatively outweigh and exceed the varied contributions of the respondent towards the same. Hence, while the factors raised by the respondent were certainly legally relevant and probative, for the purposes of being admissible into evidence, little weight should be accorded to alleged contributions of a 'normal, typical, ordinary, and merely rote and rudimentary character', which will invariably be satisfied by quite a great number of persons in the nation anyway, and especially where multiple statutory categories of dysfunctional conduct are clearly established in law and on the evidence (see, Zéline-Viera Quívrin at [26]-[27]). In the court's view, "rather mundane alleged contributions to the community cannot rationally be said to outweigh a clearly established pattern of inalterable and recalcitrant behaviour which, overall, clearly and convincingly demonstrates a long-term orientation and ingrained nature tending towards such dysfunctional behaviours of vandalism, vagrancy, incapacity, and parasitical work-shy proclivities overall in her persistent pursuit of a homeless and careless Bohemian lifestyle, as an elective vagabond and wanderer, cavalierly drifting from neighbourhood to neighbourhood and community to community with not a single care in the world whilst burdening countless millions throughout our nation as an incorrigible nuisance derelict in the process" (see, Zéline-Viera Quívrin at [30]).

Another interesting legal issue that was raised in the 'petition for review' was whether the TECON tribunal erred in law in its treatment of the fact that the petitioner had a congenital condition known as neurofibromatosis, which did not impair the petitioner's physical or mental capacity, but resulted in so-called 'facial disfigurement' or 'facial deformities' affecting the petitioner's external appearance without tangibly impinging upon her material ability to contribute to society. The petitioner argued that the TECON tribunal had erred in law in according weight to that congenital disability as further evidence (amongst other factors) indicative of her dysfunctional disposition as a human being overall, and likewise that the TECAT appellate judge had also erred in affirming the TECON tribunal's approach to her neurofibromatosis condition (see, Zéline-Viera Quívrin at [10]-[11] and [15]). The Supreme Court relied upon its broad construction of the proper meaning of the applicable legal test of an "antisocial, deviant and/or parasitical disposition", as was outlined above, to find that the TECON tribunal was well within its rights to give weight to the petitioner's neurofibromatosis, insofar as it impacted the petitioner's physical and facial appearance, which was not a legally irrelevant consideration as the petitioner sought to allege. In the court's view, there was no basis in law to construe the notion of imposing a cost or burden upon the national community in an artificially narrowed sense to exclude what it termed 'deleterious effects upon the amenity (as opposed to material) value of the community and the reasonable comfort, convenience, and enjoyment of the collective national body in their use and benefit of public spaces, services, and facilities' (see, Zéline-Viera Quívrin at [36]-[37] and [40]). The court explained that the notion of an 'antisocial' disposition embraced tendencies that were 'injurious to public peace and public order within the broader sense of those concepts, inclusive of the general public's reasonable comfort and convenience in public spaces and their use and enjoyment of public facilities and services, and they cannot be narrowly construed, in the ordinary meaning of the word 'antisocial', to be limited solely and exclusively to only physical, economic, material, or tangible damage and injury inflicted upon members of the public' (see, Zéline-Viera Quívrin at [41(a)]). Likewise, the notion of a 'deviant' disposition embraced tendencies that were 'contrary and anathema to established community notions of decency, wellness, public policy values, and general social and communal propriety, inclusive of the imposition of public nuisances and general undue disturbances to, or unreasonable annoyances of, members of the public as they engage in the ordinary pursuits of their lives and in the course of their conduct of their rightful personal business and affairs' (see, Zéline-Viera Quívrin at [41(b)]). Finally, the court held that the concept of a 'parasitical' disposition meant 'simply that the detriments imposed upon the national community owing to the consequences flowing from the respondent's general existence as a human being - whether owing to their conduct, omissions, or even their mere presence alone - may be said to outweigh any benefits and advantages inuring to the body national from the personal existence of the same, and we can see no basis in law or in the general principles of legislative construction, be it genetic, lexical, contextual, or teleological, to narrowly construe the notion of parasitism to exclude damage of an emotional kind to the amenity value of public spaces, inclusive of the infliction of general nuisance, annoyance, irritation, distress, discomfort, or inconvenience to the wider community' (see, Zéline-Viera Quívrin at [41(c)]).

The court also expressly rejected the petitioner's argument that the costs or benefits of the re-classification respondent's existence had to arise from certain attributable acts or omissions of the respondent, reasoning that it would be "contrary to the entire purpose and spirit of the genetic re-classification regime, the whole rationale of which is to determine the intrinsic genotype of the subject of the proceedings as opposed to the evaluation of any discrete or individual acts thereof. It would be incompatible with the object and purpose of the legislative schema for the legal criteria for genetic re-classification to be construed to exclude harms and detriments inuring from the mere existence of the subject, as a person, and there is no textual or teleological basis to read into the legislation an additional element which is absent from the provisions thereof, viz., that those harms or detriments must be attributable to an act or omission of the subject" (see, Zéline-Viera Quívrin at [40]). As the court explained in that case, "it has never been the law of the re-classification scheme that the test for re-classification imports any element of personal fault or culpability into the fact-finder's broader holistic consideration of the requisite statutory standard and their exercise of discretion thereon. The test for re-classification rests upon the overall nature and quality of the subject's existence and the intrinsic tendencies of their genetic and biological constitution and does not import any extraneous considerations of fault, blameworthiness, malice, negligence, or otherwise, for it is the subject's general existence which stands to be adjudged, and whether the Purgation body national can fairly or reasonably be expected to put up with and suffer the burdens and liabilities flowing therefrom. Given the absence of fault-based liability in the inquiry, there is no good reason in our view to impose the artificial imperative of requiring the fact-finder to identify a particular act or omission as evidence of the dysfunctional disposition of the subject of the re-classification proceedings" (see, Zéline-Viera Quívrin at [44]). Hence, the TECON tribunal was entitled to find, as a matter of fact, that the neurofibromatosis of the petitioner, and the resulting facial disfigurement occasioned to her, amounted to an "antisocial, deviant and/or parasitical disposition", insofar as they were persuaded that the harms and detriments of that condition, including any injury to the 'amenity value' of the community, outweighed or exceeded any benefits inuring from the existence of the petitioner as a human being (see, Zéline-Viera Quívrin at [48]-[49] and [53]).

Lastly, the case of Zéline-Viera Quívrin is also an oft-cited legal precedent both within and outside of the context of genetic re-classification proceedings, and in other areas of the law, for the purposes of explaining the specific contours and modalities of the common law 'rule against hearsay'. The reason for this is because of a dispute between the parties over the admissibility of the testimony of one of the witnesses for the Attorney-General, La Gentille-dame Hodierne Stuart, who attested to the contents of her affidavit of evidence-in-chief (AEIC), which claimed that her six-year-old son frequently burst into tears whenever they walked pass the re-classification respondent (and whilst she was a homeless vagrant), on a regular basis, whenever they were walking to their local Fraîcheurs in Provençal. Her AEIC included claims that her son would scream or shriek in horror upon seeing the respondent's disfigured face, or bury his face into her stomach, wince in discomfort, or tightly and harshly grip down on her palm in evident distress, making such remarks as 'she's so hideous, Maman!', 'Maman, it's that monster again!', 'I'm really scared, Maman, please, she's ghastly, she's so horrible!', or 'please, Maman, I want to go home, I don't feel well, please, I'm begging you, she's repulsive!', often bursting into tears in the process (see, Zéline-Viera Quívrin at [13]-[14]). Since her son did not testify or provide any AEIC of his own, it was argued by the respondent's counsel, before the TECON secrétariat juridique below, that the AEIC of La Gentille-dame Hodierne should be deemed inadmissible in law as hearsay evidence, since in the respondent's view, these statements of her son were clearly been admitted for a 'testimonial purpose', namely to attest to the objective hideousness or repulsiveness of the respondent's physical and facial appearance, based on the out-of-court testimony of her son (see, Zéline-Viera Quívrin at [8]). In contrast, the AGO state counsel argued that these statements from the son were being admitted for a non-testimonial purpose, in other words, they were being admitted as evidence that the son had said these words and not for the purposes of proving the truth of the son's words as evidence of the correctness of the contents therein. The TECON secrétariat juridique agreed and held that the son's words were not inadmissible hearsay because the witness was attesting to the fact that the words were uttered and not the truth thereof, they were admissible in order to prove the objective effect which the respondent's appearance had on passers-by and onlookers, which was relevant for the TECON tribunal to adjudge the alleged public nuisance, annoyance, or distress occasioned to the general community by reason of the respondent's congenital condition of neurofibromatosis, and the TECAT appellate judge agreed, refusing to overturn the TECON award on the basis that the admission of the AEIC of La Gentille-dame Hodierne into evidence amounted to any such alleged error of law or procedural mistake (see, Zéline-Viera Quívrin at [7]).

The 'petition for review' argued that this finding of TECAT had been in error, since in the view of the petitioner's counsel, the so-called 'non-testimonial exception' or 'offered for a non-truth purpose' doctrine recognised in common law was limited to those circumstances where the out-of-court statement is relevant to the facts in issue irrespective of whether the statement is true or false, because the fact that the statement was made is, in and of itself, a relevant fact, for example, in a libel lawsuit, the fact that third parties had repeated the libellous sting of the defendant's libel would be relevant in itself, irrespective of the truth of such statements, hence it does not offend the common law 'rule against hearsay' for a witness (such as the plaintiff) to attest to the fact that such statements had been made, since the statement is non-testimonial, it is the fact that the statement was uttered at all which is being attested to, first-hand, by the witness, regardless of whether the contents of the statement are true or false. In contrast, the petitioner argued that, here, if the son's statements are assumed to be false - i.e., if it were assumed, for the sake of argument, that the respondent was not in fact objectively hideous, repulsive, or offensive to look at, as the son alleged - his statement would be irrelevant to the merits of the re-classification 'complaint'; hence, it must be the case that his out-of-court statements were being adduced for a testimonial purpose, in other words, to prove the truth of the son's assertions that the respondent's facial appearance was said to be objectively hideous and repellant to look at, and since he was not available to be cross-examined on that evidence, his statements were inadmissible in evidence and it was an error of law to permit La Gentille-dame Hodierne to take the stand and attest to the contents of her AEIC (see, Zéline-Viera Quívrin at [18]).

The Supreme Court disagreed and relied upon the historical 'verbal act' exception to the common law 'rule against hearsay', which it expounded upon in greater detail in the judgment (see, Zéline-Viera Quívrin at [19]-[24]). In the court's view, "the fact that a statement was uttered and beheld by the ears of a witness is as much an objective fact capable of being attested to in much the same way as an act that was done in the presence of that witness. Consider an eyewitness to a robbery who testifies to the fact that the accused held his victim by the throat before snatching the purse from her fingers as she screamed for help, before running off with her purse as she yelled after him 'help, help, he's stolen my purse!' and pointing his way. Such testimony is evidently admissible in law and would not offend any such rule against hearsay known to the common law of this land. If it were suggested that that eyewitness attesting to the utterance of such words by the victim were to constitute an attempt to introduce an out-of-court testimonial statement without the benefit of their cross-examination, and that that out-of-court statement bore a testimonial character because if it were assumed to be false, as the petitioner attempts to argue here, it would bear no further purpose or relevance to the facts that are in issue - i.e., if the woman in question was assumed to be lying and her purse was not in fact stolen by that accused, as she so claimed in her screams, her statement would be irrelevant to the question of whether the accused committed the act of robbery or not – the common law's ample response to such an argument is simple: the woman's statement is a verbal act that occurred first-hand in the presence of the eyewitness, which he or she is just as capable of attesting to, based on what they saw and heard at the time, and the admissibility of that eyewitness testimony cannot depend or turn on such artificial distinctions as whether the acts or omissions that were witnessed were of a verbal or non-verbal character, they were acts performed before them all the same. The test is not whether the 'verbal act' would be relevant to the merits of the case if it were assumed to be false, for indeed, the probative value of both verbal and non-verbal acts may often be said to turn upon questions of the reliability and accuracy of the inferences to be drawn therefrom and the general interpretation thereof. The inquiry into whether the out-of-court utterance bears a testimonial or non-testimonial character cannot, therefore, turn on whether the utterance would be relevant if its contents were assumed to be totally false. Instead, the central question must be to determine whether the core and the essence of the alleged probative value of that utterance lies in the very fact that it was uttered at the time at all, or as a form of testimony providing a first-hand account and narrative of the relevant facts in issue. Much will depend upon the context of the out-of-court utterance. If, in our hypothetical example, the victim were to give a detailed account of the robbery she suffered to the police officer, recorded in a witness statement, then it would obviously and patently offend the rule against hearsay for that officer to take the stand and attest to the contents of the victim's witness statement in court, for the simple reason that the core purpose behind the victim's witness statement is to give a full account and explanation of first-hand facts and acts which she bore witness to, in a testimonial fashion, which the police officer is simply repeating in a second-hand manner, thereby adducing testimonial evidence without the benefit of cross-examination. In contrast, where the eyewitness attests to the fact that the victim uttered the words 'help, help, he's stolen my purse!', screaming as the accused ripped the purse from her fingers and ran off, as she yelled and pointed in his direction, these are verbal acts which did, in fact, occur at the time, which explain the context and background of all the other non-verbal acts which the eyewitness saw and experienced, personally, first-hand, and at the time of these events. The testimonial account in that case is the account of the eyewitness and not the words uttered by the victim, for there it is the eyewitness who intends to provide his or her first-hand recollection of these events, of which the verbal acts of the victim are a mere part of the whole picture of the factual matrix providing the necessary context and background to the wider series of verbal and non-verbal acts of the victim and the accused which the eyewitness beheld with his or her own eyes and ears. The question is, thus, not whether the utterance, if assumed to be false, would thereby cease to bear any further relevance to the merits of that proceeding. Rather, the question is whether, on any broad, common-sensical examination and understanding of the account being given, the objective purpose is for the witness to provide a first-hand testimonial account of what occurred, or conversely, to merely regurgitate and repeat, in an indirect second-hand fashion, the out-of-court testimonial account of the speaker who had previously relayed that same narrative to that same witness at the material time. The overall inquiry is into the objective purpose that is reasonably served by the repetition of the out-of-court utterance by the witness, in the context of the entirety of that witness's evidence, and while the fact that the utterance would remain relevant even if its contents were assumed to be false would often be powerful evidence of its non-testimonial purpose, the petitioner is incorrect in submitting that the contrary must therefore follow therefrom, or that simply because an utterance would not be relevant if its contents were assumed to be false, that must mean that the utterance is being adduced by the witness for a testimonial purpose. That simply does not follow, and indeed, it is a classical case of the logical fallacy of denying the antecedent, also known as the inverse error fallacy - if A, therefore B; hence, if not A, therefore not B - but, just because Jean is a doctor and therefore holds a job, it does not follow therefrom that if Jean is not a doctor, then he therefore holds no job, for that is quite plainly false" (see, Zéline-Viera Quívrin at [22]).

Hence, it was held by the court that the son's words as attested to by the testimony of La Gentille-dame Hodierne had clearly been adduced for a non-testimonial purpose, namely, as evidence of the fact that her son had uttered those words at the time and not as evidence of the truth of the contents thereof. The purpose served by such testimony was clearly to show the evident distress and emotional harm suffered by the son as a result of the re-classification respondent's facial and physical appearance, and the fact that there was a causal link between the facial disfigurement of the respondent and the injury occasioned to the reasonable comfort and convenience of her son in the course of his own use and enjoyment of public spaces in the neighbourhood. Within that context, the purpose served by attesting to the son's words was not as a form of indirect second-hand repetition of another's first-hand testimonial account, but as first-hand evidence of 'verbal acts' of the son, as witnessed by his mother, which contextualises and colours the son's 'non-verbal acts' at the time, including his screams, his crying, and his state of mental distress, fear, confusion, and the general emotional suffering he sustained as a result of the re-classification respondent's appearance. Accordingly, they fell squarely within the scope of the 'verbal act' exception and so did not offend the common law 'rule against hearsay' (see, Zéline-Viera Quívrin at [23]-[26]).

The cases of Nicodème Friesen, Jean-Julien Labiorteaux, and Zéline-Viera Quívrin, help to illustrate the kinds of 'big picture' questions of law, with broad and general applicability and implications, which the Supreme Court tends to hear and determine in the 'petitions for review' that it accepts and chooses to hear, in its ultimate discretion, and also helps to explain why the Supreme Court accepts such a small proportion of these 'petitions for review' in the first place, since invariably most petitions against a TECAT judgment will not raise such major questions of law of such broad and general public importance. In contrast, the legal principles articulated in these three cases clearly bear relevance to a broad spectrum of genetic re-classification cases and can be expected to feature prominently, and indeed have frequently been cited, in many future cases appearing before subsequent ad hoc TECON tribunals.

[Purgatio]

Once the Supreme Court has either declined to hear a 'petition for review' or agrees to hear the petition and has decided it either in favour of or against the petitioner, the proceedings will finally progress onto its last stage, the Liquidation stage, for all those re-classification respondents who are eventually re-classified from Génétiquement Sain to Génétiquement Dysfonctionnel as the final outcome, after all of the above remedies and avenues have been fully pursued and exhausted. It was estimated by the 2023 Home Office report that, in the year 2022, the number of persons who were finally re-classified to Dysfonctionnel, after all remedies had been exhausted, including appeal to TECAT and review by the Supreme Court, amounted to approximately 12.386 million, which is relatively consistent with the final re-classification numbers reported from prior years, which stood at around 13.275 million in 2021, 11.798 million in 2020, and 12.013 million in 2019. In accordance with the terms of Executive Order (EO) No. 103 of 1994 promulgated by the Magnificus Dominus on 23 February 1994 (often abbreviated as either "EO 103/1994" or even the "Dysfonctionnel Nationwide Liquidation Decree" by foreign commentators, journalists, and academics), the prescribed fate of all persons classified as Génétiquement Dysfonctionnel is to be eradicated and eliminated by the Purgation State via a policy of 'liquidation through labour'. The precise details and requirements of the 'liquidation through labour' framework are established by the Tripartite Dysfonctionnel Liquidation Commission, made up of representatives and officials appointed by the same three 'stakeholders', viz., the Home Secretary, the Director of the PIGC, and the High Inquisitor of PICOS. The Tripartite Commission determines such matters as the estimated quantity of food, water, and other nutritional sustenance to be provided to forced labourers, the hours of work, the type and manner of work and the physical exertion thereof, the amount and frequency of rest, the conditions of the camps themselves (including, inter alia, heating, health, and sanitation), disciplinary measures and various manners of punishments to be applied to any rowdy or unruly workers, etc., to balance the competing considerations of regulatory flexibility of the framework (so as to not overly burden and fetter commercial innovation and the diversity of ways and means by which different concessionaires may wish to exploit the forced labour of the Dysfonctionnel) against the underlying policy aim of ensuring that all Dysfonctionnel condemned to die in such 'liquidation facilities' eventually perish, slowly but surely (with the average life expectancy of a prisoner in a 'liquidation camp' presently standing at approximately 28-31 years following the date of their confinement to such facilities), and are 'liquidated' through a combination of overwork, exertion, exposure, malnourishment or malnutrition, exhaustion, poor sanitation and hygiene, disease, torture and physical abuse, etc., amongst other such causes. It is also the power and responsibility of the Tripartite Commission to determine which 'liquidation camps' any newly re-classified Dysfonctionnel slave labourers will be sent to. In exercising that power, a key consideration which the Tripartite Commission will take into account is whether concessionaires in control of privatised 'liquidation facilities' have been complying with the prevailing Labour Liquidation Framework. The Tripartite Commission has the power to monitor and supervise the compliance of private concessionaires therewith, with attendant powers to sanction them for their non-compliance(s), ranging from more lenient penalties such as the levying of fines and imposition of contractually stipulated liquidated damages, to more severe penalties such as the termination of the 'concession contract' altogether (with control of the 'liquidation facility' then reverting back to the Tripartite Commission, with PICOS retaining control over prison security and discipline matters), to the intermediate penalty of placing some or all of the 'liquidation facilities' of a non-compliant concessionaire 'under suspension', meaning that no further Dysfonctionnel slave labourers will be sent to the facilities of that concessionaire until the Tripartite Commission is persuaded that they have rectified their non-compliance(s) with the general terms and conditions of the Labour Liquidation Framework.

Thus, in accordance with the rules and the general terms of the prevailing regulatory framework, once the respondent's legal genetic re-classification from Sain to Dysfonctionnel has become final and conclusive, and is no longer available to be reviewed or appealed, whether because the applicable deadline to file for permission to appeal or to file a 'petition for review' has expired, or the appellant's application for leave or petitioner's 'petition for review' has been dismissed, or the appeal or petition has been dismissed by TECAT or the Supreme Court (as the case may be) on the merits thereof, or the respondent was not re-classified in the first-instance by the TECON tribunal and that finding was then subsequently reversed on appeal to TECAT or on a petition to the Supreme Court, whatever the case may be, the AGO state counsel will have to inform the PICOS arresting officer in charge of either detaining the re-classification respondent (if they are not on bail at the time) or monitoring their compliance with their bail bond conditions (if they are) that the respondent's status as Dysfonctionnel is no longer subject to further review or appeal. PICOS will then make the necessary arrangements to detain the respondent in a temporary holding facility and convene a meeting of the Tripartite Commission to determine which 'liquidation facility' the respondent will be sent to, based on such considerations as the concessionaire in control of the facility (and their track record of compliance or non-compliance with the prevailing 'liquidation through labour' framework), the numbers of slave labourers in different facilities, the proximity of various facilities to the respondent's present holding facility, the numbers of slave labourers that have been 'liquidated' in various facilities to determine how many new prisoners should be sent to that facility in the interest of 'replenishment' of human resources, and the number of PICOS concentration camp guards and officers stationed at various facilities for the purposes of maintaining camp security, discipline, and good order, and whether those security personnel are capable of adequately maintaining such security given the present numbers thereat (determined by looking at whether there have been any 'slave riots' or 'slave rebellions' which have broken out at that facility in the past few years and the causes thereof). After accounting for all these considerations, the Tripartite Commission will assign the respondent to a particular facility and PICOS will then proceed to transport the respondent to their assigned destination to properly begin the process of their final 'liquidation through labour' thereat.

That, in a nutshell, amounts to a most comprehensive overview of all of the different procedural steps and stages of the present-day TECON-TECAT Parallel Tribunal Regime and the practical ins-and-outs of the current genetic re-classification process in the Purgation State, as it exists today.

[Purgatio]

Society, Culture, and Religion

State Religion Mandatum Est (La Solution Finale: Geneviève Aumont's 'Little Blue Book')

The largest religion in the Purgation State - and the official religion and philosophy of the Purgation State - is a relatively new and recent belief system known broadly as 'The Mandate' or Mandatum Est, an oblique or abbreviated reference to the so-called 'Mandate of Nature' which is the central premise and overriding thesis of that belief system. Determining when the religion was founded is a difficult question to answer, given the fluidity and ambiguity of where the belief system's tenets start and those of another religion end, especially when considered alongside the philosophy's rather syncretistic character; however, a reasonable view is that the religion only formally began when the young geneticist La Gentille-dame Geneviève Aumont wrote her now-famous (or infamous) quasi-scientific socio-political treatise known as La Solution Finale au Problème de la Classe Génétiquement Dysfonctionnelle et de la Détérioration de l'Organisme National or The Final Solution to the Problem of the Genetically Disordered Strain and the Degeneration of the Body National. That treatise - often referred to by its fanatical and enthusiastic supporters as the "Little Blue Book", because the short and pithy twelve-chapter monograph, about the length of a novella, is frequently published under a leatherette cover coloured under a shade of Chefchaouen blue, often associated with the pro-Valois Purgation royalists of old and which later became the official colours of the Purgation National League (PNL) when it was founded in 1981 - is frequently regarded as the foundational text of the Mandatum Est religion that encapsulates her central and most important principles, beliefs, and values.

The "Little Blue Book" was formally published by Geneviève Aumont on 15 November 1976, when she was just 18 years old and a bright young researcher on a research and vocational training programme under the National Institute for Biomedical Research and Innovation (NIBRI), the precursor to the Purgation Institute of Genetic Cleanliness (PIGC) of today. Back then, the "Little Blue Book" - which Geneviève Aumont published under her real name - had been explosive, provocative, and controversial, due to its reactionary, socially conservative, eugenical, and genetically discriminatory philosophy, so much so that Geneviève was initially suspended from the NIBRI young researchers' vocational training programme for her 'incitement of hatred, bigotry, and incendiary propaganda against the most vulnerable in our society' in January 1977, and the Media and Culture Ministry banned the publication of the "Little Blue Book" in February 1979 for discriminatory hate speech under the 1971 Law on Hateful Publications and Communications Inciting Discrimination. These actions were equally controversial at the time, for while many condemned the "Little Blue Book" for promoting eugenics and genetic discrimination through its fatalistic and naturalistic perception of human behaviour, many others resonated with the themes in the book and its condemnation of criminality, vagrancy, incontinence, wastrelism, and other so-called 'socially parasitical tendencies', given the general disorder and malaise experienced by so many during Les Années de Sang et de Plomb. As such, the effect of Geneviève's suspension and the suppression of her work had been to make her into a martyr, becoming a political darling and celebrity to the Purgation far right at the time, given her young age, her outspoken nature, her apparent bravery and courage to speak her mind, and the perceived oppression and persecution she had suffered at the hands of the Purgation State and the political establishment. That martyrdom and celebrity status was only accentuated by the twin legal victories secured by the young Geneviève in early 1980, which included the Court of First Instance (CFI) handing down a mandatory injunction compelling the NIBRI executive committee to reinstate Geneviève's position in its vocational training programme, on the basis that her suspension had constituted unlawful discrimination against Geneviève on the basis of her political views (see, Notre République de la Révolution (sur l'application de Geneviève Aumont) c. The National Institute for Biomedical Research and Innovation [1980] CPIPG 10954 (EPD) at [24]-[26]), and a second legal victory where the CFI struck down the 1979 ministerial order banning her "Little Blue Book" as a violation of Geneviève's constitutional rights to freedom of speech and expression (see, Notre République de la Révolution (sur l'application de Geneviève Aumont) c. The Secretary of State for the Ministry of Media Affairs and Cultural Developments [1980] CPIPG 13365 (EPD) at [43]-[46] and [50]). These twin legal victories practically propelled Geneviève to media and political superstardom at a very early age of her career, reviled by the political left and centre while becoming a beloved heroine within the political right and the aligned tabloid press, and had the effect of shining a huge spotlight upon the contents of the "Little Blue Book" and the ideas she espoused therein. In many ways, these early events were not only a catalyst for the birth of the PNL party, which Geneviève de la Fayette (née Aumont) founded on 29 April 1981 (together with her recently wedded husband, Chalon-Arlay de la Fayette), but also for the birth of her new religion, Mandatum Est, based upon the ideas and beliefs she expressed in her "Little Blue Book".

With that introduction, one should turn to now consider the contents of the "Little Blue Book" and the ideas that that publication stands for. As the name of that belief system would suggests, the core premise or central thesis of the Mandatum Est religion is the so-called 'Mandate of Nature', demonstrating the non-theistic, non-deific character of the religion and its materialistic, naturalistic philosophy. As Chapter I, paragraph 1.05 explained, "[t]he Mandate describes simply the ultimate and overriding powers constituting the highest governing authority over all who inhabit our material existence - Nature, which governs life, dictates death, and regulates and directs every minutiae of an organism's fortunes, prospects, and the terms of their corporeal continuance in the world. Humans, animals, plants, bacteria, fungi, are all subject to Her whims, Her fancies, Her every dictate, rule, principle, and commandment. It matters not if we deem those rules to be just or unjust, arbitrary or sensible, compassionate or cruel, for they rule us all the same. Nature is neither right nor wrong: She simply is". This illustrates that philosophy's rather resigned and nihilistic worldview, wedded to the idea that concepts of 'right' and 'wrong' do not rest upon any objective notions of human rationality or the fair and just dictates of a supernatural deity; rather, all that existed was Nature, and what Nature provided for. As Chapter I, paragraph 1.13 put it, "[t]he parasite ravages the host, the shark devours the salmon, the hawk hunts the rodent, and Nature persists onward in Her pitiless disinterested apathy, without a single care in the world for the frivolous and arbitrary notions of morality, rightness, fairness, justice, arrogantly and wholly invented from the cloth by one of Nature's species and unilaterally imposed upon the entirety of her realm and all of her other creations as an ostensibly 'objective' creation. The 'Mandate of Nature' does not bend to such subjective whims and fancies as these".

Based on that materialistic, naturalistic, nihilistic, and some would even say cynical, worldview, Mandatum Est espouses the value and importance of such concepts as natural selection, competition for resources, reproductive success, survival of the fittest, the impact of selective pressures on genetic variations within a population group, and such other socially Darwinistic views. In the Mandatum Est doctrine, however, these aspects or facets of natural selection are not merely mentioned in a neutral descriptive fashion; instead, the religion goes further in assigning normative importance to these concepts, regarding them as part of a mandatory and imperative decree or command of the natural world - or, in other words, a 'Mandate of Nature'. They are considered part of the fundamental inalienable rules of the natural universe that bind all living organisms and biological creatures, the 'inner morality' of every life form's internal and essential nature that cannot be escaped or repressed, the crucial fabric that intrinsically defines all human and non-human existence alike. According to the Mandatum Est religion, this is how Nature maintains balance and harmony within the natural realm, by controlling and regulating the numbers and behaviours of all living creatures while most efficiently rationing limited resources amongst them through a 'winnowing' or 'sieving' process of natural selection, in which, presumably, the fittest, the strongest, the 'best of the best' and la crème de la crème, will automatically rise to the top, perpetuating their fitter genes and biological traits while discarding and leaving behind the unfit and the incapable who are comparatively ill-suited to surviving and thriving under the same conditions.

A key belief of the Mandatum Est philosophy, therefore, is that human beings - as living biological creatures all the same - are bound by these very same inalienable 'natural rules'. As reasoned in Chapter II, paragraph 2.31, "[o]ne cannot overstate this fundamental and essential reality of all natural life, inclusive of human life. Humans are biological creatures, first and foremost, and are as much a product of the very same 'Mandate of Nature' that governs and controls the behaviours of plants, animals, and all other living organisms. Even the creation of a human society is not clinically isolated from the rules of nature, and the functioning of that society, far from being 'artificial' or 'inorganic', is as much of a subject governed by the 'Mandate of Nature' as the actions and behaviours of any other living organism. Yet humans - in our infinite ignorance, arrogance, and folly - often forget this crucial fact, but alas, Nature's laws persist in binding us all the same, whether or not we choose to accept Her commands or acknowledge her decrees or fecklessly attempt to close our collective minds to the same. These cardinal rules of natural selection, survival of the fittest, the competitive exclusion principle, and the heritability of defective and desirable traits in organisms, are as much of a natural and biological reality in human societies as they are within the wider ecological system; hence, the strength and flourishing of a human society or a eusocial and prosocial human community will depend upon that community's relative ability to adapt to the constraints of the 'Mandate of Nature', by promoting the perpetuation of the biologically fit, and lessening and mitigating, as far as is feasibly possible, the uncontrolled and unmanageable perpetuation and continuation of the biologically unfit and of their transmissible traits and characteristics".

A strange feature of the Mandatum Est religion on this point is the seeming prima facie paradox that, while the religion speaks of the ostensible rules of natural selection as these inalienable and unavoidable precepts or some kind of innate 'natural law' encoded within the inherent biological materials of all living organisms, including humans, it nevertheless appears to advocate for a form of artificial genetic selection within the context of human societies and communities in contradistinction to that found in respect of any non-human living creature. Indeed, many critics of the Mandatum Est religion will often point to this very feature to argue that the belief system suffers from an inherent and irresolvable internal logical contradiction that is fatal to the reasoning espoused by that faith. However, the "Little Blue Book" does proffer an explanation for this seeming contradiction, although the persuasiveness of its explanation is, of course, quite inevitably a matter of one's own subjective preference and opinion. Nevertheless, the religion's explanation for this paradox is simple - the very adaptive and evolutive forces that have enabled humanity to flourish and thrive, over the course of millennia, have had the oxymoronic effect of checking and curtailing those very same forces. Hence, the continued success of a human community requires a replication of Nature's typical forces of natural selection through a process of artificial selection that seeks to achieve, as far as possible, the same effect.

According to that faith, the biological competitive advantage of the human species has been its capacity for efficient social organisation of labour and communal collaboration of efforts. As expressed in Chapter III, paragraph 3.27, "[t]he homo sapien species is certainly far from unique in banding together into organised tribes and communities in order to optimise the chances of the survival and reproductive success of its individual members, and yet, it is our unparalleled mastery of eusociality, kin selectivity, prosociality, effective social organisation, efficient hierarchies between the governors and the governed, the coordination of efforts and the pooling of labour, talents, and resources, that has allowed this one species to dominate the other creatures of our natural realm and to obtain for itself a self-appointed lordship over the Earth. It is the foundation of every human innovation and cultivation, responsible for such feats as the Neolithic Revolution, the Agricultural Revolution, the Industrial Revolution, and beyond. Alas, while it may be possible to conquer Nature's creations, Nature Herself is unconquerable, for Her rules and precepts remain encoded, irrevocably, within the very constitutive fabric of every single human life form. Her commands are inevitable and unavoidable. Such is the paradox of humanity's accomplishments, laid bare at the foot of Her eternal throne - the homo sapien species risks becoming a victim of its own success. Through our vain hubristic conviction in our own somehow unique exemption and impunity from Nature's rules, we have crafted in Her place these artificial rules that curtail the effective natural winnowing and sieving of the unfit, the incompetent, and the incapable from amongst our flock and breed, synthetically propping up and maintaining their inefficient existences through these man-made social infrastructures and regulatory architectures entirely alien to the natural realm, cursing future generations of our collaborative eusocial and prosocial communities with their unfit genes and ill-bred traits, all in service of equally man-made and arbitrary egalitarian ideals, principles, and values wholly repugnant and anathema to the aristocratic principle of Nature. The 'Mandate of Nature', however, is self-regulating. While Her creations' compliance therewith may not be guaranteed, the consequences for their non-compliances are, to wit, that the species and sub-species which embraces the realities of Nature's ordinary biological process are bound to out-compete and out-match the ones which futilely attempt to reject and foreswear the same. Is the answer, then, to reject the forces of eusociality, prosociality, and social collaboration that made humanity great in the first place? Certainly not. Instead, the answer is to incorporate Nature's rules and commands into the artificial social structures of a functional human community. How? Simply put, by substituting in place of the forces of natural selection the forces of man-made artificial selection instead, not with an eye towards replacing or running counter to Her laws, rules, and commandments, but in fulfilment of those same ends, just through different means".

That, in a nutshell, is the Mandatum Est justification for the adoption of eugenical policies of genetic discrimination within a human society. This is coupled with a belief in biological determinism, in other words, the idea that most desirable and undesirable human characteristics are attributable, at least in part, to the inheritable genetic constitution of different human beings. This view is amply expressed in Chapter IV, paragraph 4.28, in such terms, "many human societies are beset with the dangerous myth of pure social constructivism - this noble lie preaches that positive and negative social traits within a society are purely a product of social construction, never innate biological qualities. This myth of biological equality ignores the reality of human genetics and the heritability of healthy and unhealthy traits which constitutes a core and ubiquitous component of the natural order; indeed, an indispensable component which cannot be ignored by any component biologist, geneticist, or even an ordinary farmer, rancher, or any breeder of plant varieties or livestocks. At the end of the day, humans are biological creatures, and to pretend that acts of violence, criminality, indolence, chronic addiction, lunacy, and feeble-mindedness have no connection whatsoever to genetics - the basic elemental foundational building block of all human life and existence - when the very same impulses to perform such actions or manifest such tendencies are so inextricably connected to such features as one's physiology, neurology, and endocrinology, constitutes blindly cruel naïvete of the very worst kind, the kind which so often destroys civilisations and curses to ruin otherwise-thriving and productive societies. Once one admits that socially desirable and undesirable traits and attributes are, at least in part, derivable from one's immutable genetics and fundamental biology, then pursuant to the overriding 'Mandate of Nature', it is clear that the flourishing of any human society will inevitable depend, in great and substantial part, upon the relative quality of its biological and genetic constitution, and whether the composition thereof tends towards the promotion of social and cultural flourishing, creativity, and productivity, or conversely, is more so predisposed towards social destruction, desecration, degeneration, and the ultimate ruination of all civilised cultural living".

The faith's doctrinal messaging about what constitutes 'healthy' versus 'unhealthy' traits and characteristics follows from its conception of human beings as a fundamentally eusocial, prosocial, and socially collaborative species, the biological success of which has thrived upon healthy and efficient social coordination. Hence, in the Mandatum Est worldview, biologically ingrained or genetically determined traits which contribute to that eusocial and prosocial communal process are considered socially 'healthy', whereas those which detract from or burden the same are considered socially 'unhealthy'. As explained in Chapter VII, paragraph 7.19, "[w]hat do I mean when I speak of such words as 'desirable' and 'undesirable', 'healthy' and 'unhealthy', 'fit' and 'unfit'? These are not moral terms nor normative conceptions of abstract 'good and evil'; rather, they are purely descriptive adjectives designed to accurately capture a biological reality in existence, a bio-anthropological portrayal of how eusocial and prosocial human societies rise and fall, thrive and languish. Traits and characteristics which tend towards the promotion of the eusocial and prosocial process of the pooling of efforts, the division of labour, the assignment of roles and responsibilities, the efficient production and distribution of resources, and socio-cultural progression, development, and innovation more broadly, necessarily amount to 'fit', 'healthy', and 'desirable' traits, not from any objective moral standpoint of what is good, virtuous, or morally obligatory, but instead, from the naturally descriptive standpoint of what traits tend towards the flourishing of the human species and the promotion of humanity's competitive biological advantage, to wit, efficient prosociality and eusociality. Examples of such tendencies and dispositions would be law-abiding behaviours, cognitive intelligence, physical health, longevity, and vitality, impulse-control, mental resilience, and emotional fortitude, amongst others; whereas, tendencies and dispositions which deviate from, and indeed burden the process of, eusocial and prosocial collaboration of efforts, talents, and resources, would include, inter alia, vandalism, hooliganism, incapacity, incontinence, imbecility, lunacy, indolence, work-shy tendencies, and other disordered traits predisposed towards antisociality and parasitism, wholly incompatible with a thriving, functional, efficient, harmonious homo sapien community primed for success in the brutal and vicious competition of Nature. It needs to be emphasised here, however, that the descriptor of such traits as 'disordered', 'deviant', 'antisocial', 'parasitical', et cetera, is in no way condemnatory, pejorative, or stigmatising. They are descriptors of an organic and natural causality and not a passing of moral judgment. As I have said, the 'Mandate of Nature' does not care for arbitrary man-made notions of morality, She cares only about the objective existence of biological cause and effect. To state, therefore, that the over-abundance of certain human traits and characteristics would tend towards the burdening and fettering of human prosocial and eusocial cooperation and efficient social collaboration, thereby hampering the exercise and enjoyment of the homo sapien competitive advantage ordained in Nature, is the assessment of an objective and scientific determination of Nature's assigned cause and effect and not the subjective assignation of worth and value of a pontificating moralist dressing up an arbitrary and purely personal value judgment as some universal truth. Nature deals only with objective existence, She concerns Herself solely with such questions as the ascertainment of what is and what is not, not with what is right and what is wrong".

That emphasis on eusociality, prosociality, and the efficient collaboration and coordination of human efforts fits neatly with the Mandatum Est ideal of human corporatism, i.e., the notion that human beings, in an optimal state of affairs, belong to a collective, and the success of the collective would depend upon each of its parts playing their assigned role, discharging their designated responsibility within the corporate whole, working together in concert, complementing each other's efforts and labours in harmony and accord with every others', like functional cogs in a well-oiled machine. That corporatistic philosophy is reflected in the Mandatum Est concept of L'Organisme National - i.e., the 'national organism' or more commonly translated as the 'body national'. The 'body national' is the Mandatum Est biological or pseudo-scientific metaphor for the modern nation-state, which is a socially constructed form of human social organisation but presented in the Mandatum Est worldview as some natural, organic, and biologically inevitable evolution of human progression and advancement over the millennia. In a clear demonstration of that religion's commitment to proffering a biologically deterministic explanation for every socially constructed human phenomenon, the "Little Blue Book" goes so far as to suggest, in Chapter IX, paragraph 9.32, that "[t]he modern nation-state, born out of the ashes of previous iterations of collaborative human inventions - e.g., the scattered commerce-driven slave-holding poleis, the mandalas of civilisational suzerains perpetually beset by internal rebellions, the fragmented multi-national empires, the internally divided disunited feudal kingdoms and fiefdoms constantly beset by strife and infighting, etc. - represents the naturally pre-ordained apex of human social evolution, striving towards better and ever-more-perfect forms and methods of eusocial and prosocial cooperation and social collaboration, with older, less efficient forms thereof being discarded in the dustheap of history through the 'winnowing' process of natural selection, competition for resources between human societies, leaving only the most dynamic, adaptive, maximally efficient forms of human social organisation, conquering and destroying their less-competitive, less-efficient counterparts in the process. From that process of evolution, it is clear that the nation-state is the most biologically efficient means of homo sapien eusocial and prosocial cooperation known to mankind, our biological tendencies and genetic predispositions being constitutively weaned and winnowed over time, over millennia, through that inevitable process of natural selection and the survival of the fittest. The nation-state, therefore, achieves the happy medium and the perfect balance between excess assimilation of unsustainable numbers of human beings, creating societal diseconomies of scale through the heightened coordination costs of having to manage an unmanageable morass of competing wants, goals, and desires, as against the inverse extreme of an inadequate incorporation of human resources, labours, efforts, and reproductive capacities into the communal fold, leaving the collective most impoverished and bereft of the needed fuel to survive in the 'dog eat dog' world of international geopolitics. The nation-state unites a singular population group, brought together as one by a common history, culture, language, and heritage, manifestations of their innate biological connection to their continental cline and ancestral soil, encoded into their genes and their blood over the course of millennia, forming a truly distinct and differentiated polity imbuing that community with unique traits, special characteristics, incapable of replication or imitation elsewhere by other competing biologically and genetically distinct population groups, forming rival nation-states of their own in just the same process as has been described and amply characterised above".

There has been much theological debate within the Purgation State as to whether the above excerpt of Geneviève's "Little Blue Book" was intended as, or can be fairly interpreted as, an endorsement of the concept of the ethnostate, where the nation-state is defined around the racial ancestral population associated with the long-standing ancestry and descent of a particular territorial landmass. Litigating that interpretative debate would be far beyond the confines of this discussion; hence, for now, it suffices to note that one view is that the Mandatum Est philosophy does endorse the notion that the most efficient means of organising human societies is to build a homogenous nation-state defined around a single ethnical population tracing their collective ancestry to the territorial land and soil of that country, whereas another view is that the above excerpt merely describes the means by which natural selection and human competition contributed, over time, to the creation of the modern nation-state, defined by the genetic constitution of its present inhabitants with their unique biological traits and characteristics, but does not foreclose - and certainly does not condemn - the further evolution of that genetic constitution through, inter alia, a process of immigration, especially where the immigration process screens and pre-selects for precisely the genetic traits deemed to be desirable in the eyes of the Mandatum Est religion.

What is not open to theological debate, however, is the way the Mandatum Est doctrine conceives of the nation-state as a so-called L'Organisme National or 'body national', and how the health, vitality, and productivity of that 'body national' depends, substantially if not entirely, on the health of its individual components - i.e., the individual persons who constitute it. As Chapter XI, paragraph 11.81 puts it, "[t]he body politic or body national resembles a living organism more than most people - if not, most societies and civilisations - are willing to admit to themselves. This fact should not be surprising, as each member of the communal polity is, itself, a living organism; therefore, one should not regard it as anything out of the ordinary for the whole to resemble its component parts. This carries a rather clear implication, namely, that the health of the body politic or body national is entirely dependent upon the health of its individual components; thus, a body national with fit and healthy components will form a fit and healthy body national, whereas a body national with unhealthy and dysfunctional components will inevitably constitute an unhealthy and dysfunctional body national. Consequently, it follows that any society or civilisation which chooses to ignore the above causality does so at their own peril, for all societies and civilisations are, at the end of the day, beholden to the very same 'Mandate of Nature', whether they like it or not, which, in this case, informs us that a human community that promotes the perpetuation of an unfit biological typology amongst its members, which, in turn, tend towards such socially degenerative attributes as, inter alia, criminality, indolence, lunacy, incontinence, and feeble-mindedness, will eventually become a weak, degraded, and degenerative society, with the productive lifeblood of that body national having been so continually drained and depleted by its parasitical component parts. In contrast, a human community which promotes the perpetuation of fit biological typologies amongst their kind, those tending towards positive and prosocial attributes, including law-abiding conduct, cognitive intelligence, hard-working tendencies, diligence, and impulse-control, will make for a most healthy and flourishing society indeed, for their creative and productive biological tendencies will remain unhampered and unburdened by leeches and hangers-on amongst their number; thus, the biological and genetic composition of that body national is optimally primed towards promoting the overall success of the whole, thereby inuring to the collective benefit of all. Put simply, the health of a living organism is dependent upon the cauterisation and neutralisation of its unhealthy body parts, and the proper preservation and maintenance of its healthy and functional components. The continued health of the body national relies upon precisely the same".

The above excerpt is often regarded as the most controversial, or second-most controversial (subject to the final one below), passage within Geneviève's "Little Blue Book", and for detractors of the Mandatum Est faith, the excerpt quoted above is often regarded as nothing more than a celebratory clarion call for total genocidal eradication and extermination, claims which were always strenuously denied by Geneviève herself, as well as by her fanatical supporters, in the years leading up to the PNL's successful takeover of the Purgation State in 1987-1988 and for many years thereafter. In particular, in the years just prior to the PNL Purgation State's embarking on the wholesale eradication and extermination of the Génétiquement Dysfonctionnel, the official view adopted by many adherents of the Mandatum Est religion was simply that the above passage consisted of nothing more than a neutrally descriptive and objective scientific (or pseudo-scientific) exposition of a biologically demonstrated cause and effect occurring in nature, as manifested within human societies, and was not intended as a normative policy prescription about what ought to be enacted or implemented within any particular human society. In fact, the official institutional position of the Mandatum Est religion still remains - even to date - that the faith does not call for nor requires any extermination of genetically disordered persons within a national community. On this view, the Purgation State's ongoing genocide against the Dysfonctionnel is not performed to further any religiously ordained 'Mandate of Nature' but only a discretionary policy response to the uniquely urgent and exigent conditions of crisis besetting Purgation society throughout the 1990s and the exceptional social and cultural problems caused by the Dysfonctionnel rioters and terrorists within that turbulent and tumultuous period of Purgation State history.

That ambiguity, however, brings us to a rather strange and curious, but also wholly explicable (upon reflection), oddity of the "Little Blue Book": for a political treatise entitled with the words La Solution Finale, it never actually prescribes an outright or explicit solution to the urgent problem it catastrophically describes. Rather, it appears content merely to leave the reader with rather exigent and apocalyptic descriptions about what the scale and nature of the problem is, and then leaves it to the reader's own imagination - or intelligent inference - to determine what the referenced solution would actually entail, in practice. That perhaps deliberate equivocation reaches its apotheosis in the final and most controversial - or second-most controversial (subject to the penultimate excerpt just quoted above) - passage of the "Little Blue Book", found in its final (and shortest) chapter, Chapter XII, paragraph 12.06, where it describes the serious and exigent problem of dysgenics and the genetically disordered population of the Purgation State in the following manner: "I leave you, my avid and faithful reader, with the following challenge - a defining, existential challenge for the Purgation people to have to wrestle with - to mull on. If the quality of the body national depends, in substantial part, on the quality of its constitutive elements, it naturally begs the question, what is the future of the quality of the constitution of the Purgation body national? The prognosis, in my humble opinion, is a bleak and dire one. Violent criminals have more than twice the number of children, on average, than the law-abiding population. Single mothers on welfare - especially those claiming child benefits - have significantly higher numbers of children than taxpaying families in this nation. Women who receive graduate degrees from top universities have an average number of children throughout their lifetime than is less than a quarter of that of women who drop out of high school without a degree altogether - often because of unplanned pregnancies in their formative teenage years. Over a tenth of all children born in our land are born to illegal immigrants, who make up less than 3% of our population. And perhaps most bone-chillingly of them all, serial rapists, paedophiles, and incestuous sexual abusers father a higher number of children than nearly 70% of all Purgation men. I could go on. Ask yourself this, dear reader: what do these facts suggest about the future constitution of our body politic, the trajectory of the long-term composition of our people? What lies ahead on the horizon for us, for our children and our children's children, in the decades and centuries to come? Truth be told, dear reader, I find myself filled with great foreboding and languid despair, poring over the statistics as my heart sinks deeper into my stomach, aching within, considering what lies ahead. Indeed, it has come to such a dire point that I feel the need to risk it all, everything, my life, my liberty, my career, my reputation, just to think the unthinkable and speak the unspeakable, to even express this all-too-important thought that is forbidden to us all in our present political order - in terms of the health of our body national, our beloved Purgation Royaume, what consequences would naturally and inevitably follow from the growing and disproportionate enlargement of that dysfunctional sub-class of our society and the continued propagation of their existing tendencies through their plentiful and numerous progeny, if such demographic trends were to continue unabated? Crime? Drugs? Vagrancy? Urban poverty? Endless sexual assaults? Cyclical economic disaster and the debilitating bankruptcy of our social services, leading to the continuing insolvency and ruination of our nation? Perhaps the scariest and most frightening part of it all is not knowing, for certain, what lies ahead, looming on the horizon, as these disquieting demographic trends persist, and indeed, only appear to be getting worse and worse with every year that passes. Maybe, despite the fear and trepidation I feel in my heart, the answer lies still in the indomitable spirit of the Purgation nation, of our people, to rediscover that invigorating courage, innovative energy, and enterprising drive that made this country what it is today. I fear, however, that in our present social order, such solutions may yet elude us all, for no matter what the Purgation people may cry out for, the stilted consensus of our reigning political clique would seem to shun any and all radical change that could upset the liberal transnational cosmopolitan status quo that has become so deeply entrenched in our politics, it is nigh impossible to even imagine what - under present terms and conditions, at least - could ever possibly come to uproot it. I pray that we will find within us all the strength to reverse this incalculable damage to our already ailing and anaemic body national that we all cherish and love so dearly. I must confess, however, that I struggle to muster within me even a shred of hope or optimism on this issue. All I can do now, perhaps, is to speak the truth and at least shine a light on the danger, in the hopes that maybe you, dear reader, can find the fateful answer to this quandary that, alas, evades me still".

Compared to most major religions today, the Mandatum Est faith or philosophy is a very new and recent invention which has only been around for less than five decades. As of 2023, it counts roughly 49% of the resident population of the Purgation State as its adherents. The next most common religion in the nation, Purgation Catholicism (making up around 33% of the populace), by way of contrast, is a far more established religion that has existed in Purgation history for over a millennia, since the formal disaffiliation of the Burgondi Catholic Church from the papacy in Rome to establish a nationally independent caesaropapist Catholic Church for the Burgondi people, and later for all of the Anjous peoples, in the year 1013 CE. And yet, in just the course of a handful of decades, the religious demographics and affiliations of the Purgation State populace have changed incredibly drastically. In the year 1980, before the PNL party was founded, pollsters generally estimated that over 80-81% of the Purgation State population was Christian, with roughly 74-75% of the populace belonging to Purgation Catholicism and around 5-6% of the population belonging to various denominations of Protestant Christianity (including the Canavairres and Méroviennes). Around 7-8% of the population identified as Non-Religious or Irreligious, and every other relatively minor religious faith (Islam, Judaism, Hinduism, Jainism, Sikhism, Buddhism, etc.) all fell within the remaining 11-13% of the population. The Mandatum Est religion or philosophy was a relatively unknown one, and while Geneviève's La Solution Finale treatise was gaining traction and notoriety in the media, very few persons identified as adherents of that religion or even conceived of the treatise as a religious document to begin with, with many viewing it more as a political manifesto than an instrument of faith.

By the turn of the century, in 2000, roughly ten years into PNL one-party rule in the Purgation State, the local religious landscape had changed dramatically. The largest religion remained Purgation Catholicism, but its share of the population had declined significantly in just 20 years, down from a large majority of 74-75% of the population to a bare majority of just 53%. The percentage identifying with No Religion or Irreligious rose slightly from 7-8% to approximately 12% while the Mandatum Est faith saw a sharp explosion in its membership, scooping up 33% of the population. All other religions combined constituted just 2% of the Purgation State population, with certain religious groups suffering a steep decline in numbers after a decade of PNL rule, a trend often attributed to the systematic (but indirect) persecution of many of its members by the PNL regime and its followers, whether directly or indirectly - Canavairres and Méroviennes Protestants (religious minorities historically associated with dissension against the Valois dynasty and foreign aggression from the Animirian and Stulitian crowns); Muslims (associated with the Islamist extremism of The Brigade of Deir Yassin and the spate of 'Asian grooming gangs' in the inner cities); and Jews (associated with support for the Communist Party of Purgatio (CPP) and its armed L'Épée du Peuple militant wing).

These religious demographic trends have only continued in the same direction, with the 2023 Census showing the percentage of adherents of Purgation Catholicism falling further still from 53% to just 34% of the population, the percentage of persons identifying as Irreligious or with No Religion rising slightly from 12% to 16%, and with followers of the Mandatum Est religion escalating further still, climbing up from around 33% in 2000 to about 49% in 2023.

The causes for the sudden rise in the membership of the Mandatum Est faith, despite the relative recency and newness of the religion, may be attributed to a number of different causes. First, adoption of the new faith was easy by virtue of the religion's syncretistic nature - in other words, being an adherent of the Mandatum Est faith was perfectly compatible with one holding to other traditional religious practices, rites, or rituals. This feature is attributable to the very nature of the beliefs and ideals that make up the so-called Mandatum Est doctrine to begin with. The Mandatum Est faith is a belief system that, in many ways, blurs the distinction between a religious belief, on the one hand, and social, political, or philosophical beliefs, on the other. Academics often argue about where to draw the line between these two categories, and where the category of a so-called 'religious' doctrine begins and other categories of non-religious doctrines end. The answer to this question is far from clear or obvious. While some may define a religion as a belief in a supernatural deity or paranormal entity of some kind, even this definition is arguably overly limiting, and would arguably exclude many major faiths that exist today, including Buddhism, Jainism, and Confucianism. Many of these other non-theistic, non-deific religions also blur the line between a religion and a philosophy in their own ways, adding further complication to this discussion. If one considers religion to mean, broadly speaking, a worldview or doctrine that attempts to proffer an overarching and all-encompassing explanation for the meaning of life, one's place in the universe, the fundamental purpose of humanity's existence, and an answer to life's essential questions, then the Mandatum Est doctrine would certainly qualify as such, with its emphasis on the 'Mandate of Nature' as the guiding lodestar principle to properly structure a flourishing human society and a functional or harmonious community.

However, while some religions, most famously the Abrahamic faiths (Christianity, Judaism, Islam), are often viewed as presenting a unitary fundamentalist worldview which provides an all-encompassing explanation for how the universe is created and the singular monotheistic deity or being responsible therefor, which is by definition not compatible with other religious faiths and worldviews which may preach the existence of other deities or supernatural beings or contrary monotheistic deities, the non-deific nature of the Mandatum Est faith meant that it was, in theory, a syncretistic one that was capable of being harmoniously reconciled with nearly every religious faith or tradition a person may hold. This is not to suggest that there is no normative conflict whatsoever between the precepts of Mandatum Est and that of other religions. Most famously, the Purgation Catholic religion's traditional condemnation of abortion and sterilisation as immoral was obviously incompatible with the PNL Purgation State's pursuit of various eugenical policies motivated, in part, by the ideals and values of the Mandatum Est faith. However, religious belief is also extremely complex and intensely personal, being a highly unique affair to the individual. The relative weight which an individual worshipper may assign to various aspects of the religion, how seriously they take the religion as a whole, what aspects of the religion they value over others, whether they are a nominal or devout worshipper, whether they believe in the religion's fundamental tenets or view the religion as more of a traditional or ceremonial affair, adhering to the formal rites and rituals as opposed to certain fundamentalist beliefs and ideas, are all incredibly variable and will differ immensely from person to person. That individualised reality of religion meant that, in practice, the Mandatum Est faith could be rather seamlessly weaved and interwoven into the existing religious traditions of most worshippers of most faiths, save only for the most uncompromising and fundamentalist of believers, since it was not asking its would-be adherents to sign onto a unitary fundamentalist doctrine preaching an exclusive explanation for how the world was made and functions, together with an exhaustive list of all the deities and gods therein. It merely asked its adherents to accept that there were certain natural laws of the universe which ought to bind how a human community is organised, which is not, in theory, doctrinally incompatible with the existence of a set of gods or deities who created the universe, performed other feats and miracles, or bestowed other gifts upon humanity. That syncretistic character of the Mandatum Est doctrine was no doubt a big reason for the faith's rapid increase in members amongst the Purgation State population.

A second reason, however, stems from the active propagation and propaganda of the PNL-controlled Purgation State. Ever since the Education Secretary Urbain Robillard promulgated the Education Ministry Order No. 331 of 1990 in 21 June 1990, the government's 'Genetic Integrity Education' programme was rolled out to set out mandatory standards and guidelines which all educational institutions - public, charitable, and private - would have to comply with. As a result, many Purgation young people from the early 1990s onwards were exposed to State indoctrination and propagation about the eugenical ideals of the Mandatum Est philosophy, the danger of dysgenics, the social harm of a deterioration in the genetic quality of the 'body national', the heritability of socially undesirable traits, and the importance of eugenical policies and proper genetic discrimination. Many other organs of the Purgation State had already begun rolling out similar information and propaganda programmes, the PIGC ran many 'public information and awareness campaigns' from 1991 onwards that were intended to 'inform' the public about the serious impending dangers posed by the disordered genes and tendencies of the Génétiquement Dysfonctionnel and the need to stop and arrest the 'continual pollution and contamination of our blood'. Far-right movements within the PNL party, like Ça Suffit!, which brought together hardliners within the PNL rank-and-file, PIGC scientists, PICOS officers, and Purification Order paramilitaries, often held massive rallies and demonstrations ever since its founding in 1993, which would include demonstrators waving around Geneviève's "Little Blue Book" and extolling the virtues of its various eugenical ideals and beliefs. Ever since the Purgation State became a one-party state and it became mandatory for all public offices and positions of governmental authority to be held by party members of the PNL political party (in Executive Order (EO) No. 3113 of 1988), PNL party members have often had to undergo 'ideological training' to ensure that card-carrying members comprehended and espoused the core ideals and values of the party, based on guidelines and standards enforced by PNL Central Office and regulated by the High Office of the Magnificus Dominus (HOMD), in his capacity as the PNL Party Leader. And, of course, even before the PNL takeover of the Purgation State, far-right and right-wing media outlets owned by the Courvoisier and De Sablé families had already been putting out immense amounts of media propaganda demonising the Génétiquement Dysfonctionnel as existential threats and dangers to the country, threatening to plunge the nation into yet another economic downturn, stagflationary crisis, and waves of Islamist terrorism, grooming gangs, violent crime, and organised crime swarming into and overwhelming the densely populated inner cities and urban metropolitan areas of the country, which played a big role in contributing to a climate of fear and alarmism over the impending threat of dysgenics and genetic deterioration, with all of the social and economic problems that that would allegedly portend.

In fact, perhaps the clearest demonstration of the amount of influence the Purgation right-wing media had in stoking up fears about the Génétiquement Dysfonctionnel throughout this period is the very fact that the phrase Génétiquement Dysfonctionnel even exists in the Purgation lexicon at all. Directly translated, Génétiquement Dysfonctionnel is actually an adjective, meaning 'genetically dysfunctional', which, from a strictly grammatical standpoint, cannot be appropriately applied to describe actual people or human beings, which would require a noun: e.g., un homme génétiquement dysfonctionnel ("a genetically dysfunctional man") or un purgatien génétiquement dysfonctionnel ("a genetically dysfunctional Purgation"). And yet, the phrase Génétiquement Dysfonctionnel is routinely used as a noun to refer to actual people and human beings instead of as a descriptive adjective for those human beings. This shift in language demonstrates the power of Purgation State propaganda and the propaganda of their aligned media outlets. When the national ID system was first rolled out in 1988, the PIGC-issued identification cards included a category which read "Le Type: Génétiquement Sain" or "Le Type: Génétiquement Dysfonctionnel". This was the original grammatically correct usage of the phrase, it was an adjective and a descriptor for a sort or variety of person, a class, a 'type', as designated by the PIGC for the purposes of its own national identification system. It was Purgation State propaganda and media propaganda which then imbued that typological classification on Purgations' national ID cards with meaning and significance, through intense anti-Dysfonctionnel propaganda with headlines and sub-headings which routinely used the phrase Génétiquement Dysfonctionnel or just Dysfonctionnel not as an adjective, but as a noun, until eventually it became the accepted means of referring to the Dysfonctionnel as such. The earliest use of the word Dysfonctionnel in such a manner would appear in the Courvoisier-owned La Petite Auxiliorienne, which on 19 October 1988 ran a story with the headline "Des Génétiquement Dysfonctionnels - sont-ils une véritable bombe à retardment?", which roughly translates to "The Genetically Disordered - are they a ticking time bomb?", making clear that the new phrase on Purgation ID cards was being used specifically as a noun to refer to a type of people as a collective 'ticking time bomb' in that article. This new usage of the phrase would stick and eventually become so ubiquitous and pervasive in the Purgation media landscape that it would become entrenched within Purgation culture and Purgation language itself, and now, the use of the phrase Génétiquement Dysfonctionnel as a noun, rather than an adjective, has become the correct usage of that phrase in the modern Purgation language. Within such a media and cultural environment, it should not be surprising that the Mandatum Est faith and its eugenical tenets and precepts attained such swift popularity in such a short amount of time.

Next, the rise of the Mandatum Est faith was also the product of pre-existing demographic trends, or at very least, piggy-backed off of those demographic trends. Before Geneviève ever wrote her "Little Blue Book" in 1976 and before the PNL political party was ever founded in 1981, the dominant religion in Purgatio at the time - Christianity, and Purgation Catholicism more specifically - had already been a 'greying' religion on the decline. While around 80-81% of the Purgation population was Christian and 74-75% of the populace may have been Purgation Catholics, that percentage generally increased amongst older generations and decreased amongst younger generations, a demographic trend which meant that, over time, the percentage of Christians in the Purgation population was very likely to decrease in any event. For Purgation Protestants - the Canavairres and Méroviennes - who made up only about 5-6% of the population (already a steep decline from making up about 12-13% of the population in the 1930s), their percentage of the population was decreasing even faster not only because of these age-related demographic trends, but also intense historical persecution and discrimination against Purgation Protestants by the Purgation Catholic majority, resulting in decades of mass emigration and 'brain drain' to neighbouring Protestant-majority nations like Animiria and Stulitia. The combination of these factors meant that the dominant religion in Purgatio at the time - Christianity, which commanded 80-81% of the population - was on the inevitable decline in any event, regardless of whichever new religious faith (or lack thereof) would rise up to take its place. This clearly provided the demographic 'space' for the sudden and sharp rise of a new religious belief system, which, in this case, turned out to be the Mandatum Est doctrine.

This trend was only accelerated when Mandatum Est was officially made the State religion of the Purgation State in 16 May 2010 with the enactment of Executive Order (EO) No. 127 of 2010. This decision may have been mostly symbolic and ceremonial, in that it was not mandatory to espouse the Mandatum Est faith and no governmental policy was ever enacted attempting to force or compel people to convert to that new religion, but it demonstrated a swift turnaround and dramatic change in the religious demographics of that country, since such a ceremonial change would have been unthinkable when the PNL first came to power and believers of Mandatum Est made up only a tiny or negligible proportion of the Purgation population, largely confined to the far-right fringes of Purgation politics. By the time it was made a State religion in 2010, it commanded an estimated 40-41% of the Purgation population, nearly as much as the 45-46% still held by the Purgation Catholic religion. The move to make Mandatum Est the State religion, however, was not a purely symbolic gesture. It did have some material implications, including that Purgation courts of law oftentimes cited passages and excerpts from La Solution Finale as being representative of the public policy and ordre public of the Purgation State and her fundamental social values, citing as justification the fact that it was now, legally, the official religion of the Purgation State. The Supreme Court has also held, on the same justificatory basis, that it is permissible for TECON tribunals and the TECAT appellate body to cite works like Geneviève's La Solution Finale to determine the legislative object and purpose animating the Purgation State's genetic re-classification scheme (see, Nicodème Friesen at [13], Jean-Julien Labiorteaux at [22], and Zéline-Viera Quívrin at [14]-[15]). Moreover, once Mandatum Est was made the official State religion, it further legitimised the religion in the eyes of the Purgation populace and contributed to its increasing institutionalisation, moving from an informal grassroots philosophical belief system into an organ of the Purgation State, with temples being constructed in the public square, libraries and archives being set up compiling historical pro-eugenics materials, large statues and idols being erected in public locales, PNL party members being hired as 'ideological teachers' for the Mandatum Est doctrine - essentially, clergymen and preachers - to aid in the propagation of Mandatum Est tenets amongst the Purgation State populace and amongst other governmental organs and bodies in particular, all under the watchful eye of the Media and Culture Ministry empowered by the recent change in the law.

[Purgatio]

Finally, however, perhaps the most influential reason for the sharp rise in the number of adherents of the Mandatum Est doctrine from the 1980s and 1990s onwards was simply the unique social and economic conditions within the Purgation State that immediately preceded the rise of the PNL party, the Purgation far-right fascistic movement, which, by extension, boosted the popularity of the tenets and precepts of the Mandatum Est faith for much the same reason. The stock market crash on the Avidité Stock Exchange on 18 March 1986, which triggered the onset of a Great Recession in 1986, which sparked a stagflationary economic crisis that sent interest rates climbing, unemployment rates soaring, and saw violent crime quadruple in the inner cities as juvenile delinquency and organised syndicated offences became practically commonplace in all major metropolitan areas, these same social and economic conditions which drove the Purgation middle class and the Purgation right into the arms of the PNL also appeared, to many on the mainstream political right, as clear-cut vindication of Geneviève Aumont's message in her "Little Blue Book", allowing her Mandatum Est philosophy to garner mass appeal amongst a mainstream audience beyond the extremist fringes of the Purgation far right. It is not clear whether, when Geneviève wrote and published her treatise La Solution Finale back in 1976, she harboured any intentions whatsoever of starting a new religion as opposed to merely opining on certain social and political issues and expressing her personal views on her country. In the wake of the Great Recession of 1986 and the spark in youth crime, violent crime, and organised crime that it unleashed upon the nation, however, Geneviève's work began to be spoken about by the Purgation right-wing media in almost religious terms. The Courvoisier-owned tabloid Nous Sommes Tannés! would run a headline column in 4 October 1986 which read "Prophetess Geneviève!", with the sub-heading below reading "She tried to warn the nation - it didn't listen!". The De Sablé-owned broadsheet Le Courrier Purgatien would follow suit on 26 November 1986 with a similar headline that read "EXCLUSIVE: The Aumont Scandal and a Nation Betrayed by the Governing Classes!", that opened up with a fawning piece on the young Geneviève Aumont, bringing up her old "Little Blue Book" and claiming that it "all but predicted the mayhem, pandemonium, anarchy, imploding social services, and breakdown of public safety and law and order that would engulf our communities only a decade later", with the piece suggesting that "Aumont's seminal work is our canary in the coal-mine, a chilling and foreboding moment in our history when a bright young girl was shamed and persecuted into social oblivion by a ruthless and gutless political establishment for speaking unspeakable words which would all come to pass". This captures the general adulatory tone of the portrayal of the "Little Blue Book" in the mainstream political right and the right-wing press, her warnings about dysgenics and the degeneration of the Purgation 'body national' seemed to ring true in light of the skyrocketing crime and economic malaise experienced by the Purgation people in 1986-1987. Those conditions propelled Geneviève's new party, the PNL, into power, but it also gave the young Geneviève the status of a Sibylline prophetess who 'got it right', who made bold and courageous predictions about the terrible and catastrophic direction that the Purgation State was heading in, and was 'proven right' by the Great Recession and the social conditions and problems that it spawned. It also worked to transform what was, originally, likely intended as a political treatise, into a religious philosophy and fundamental belief system, lending credibility to the fledgling Mandatum Est belief system as a useful means of organising society and organising one's life that had been vindicated by history.

Hence, the confluence of these historical, cultural, and social factors all contributed towards propelling the Mandatum Est religion into becoming the largest and most influential faith within the Purgation State, lending credence and legitimacy to its various ideals of the 'Mandate of Nature' - natural selection, vicious competition between peoples for resources, social Darwinism, survival of the fittest, biological determinism, the health and harmony of the 'body national', and the seminal importance of adopting eugenical and genetically discriminatory policies for the long-term good of the nation and people - all of which have since had a huge and indelible impact in shaping the modern-day culture of the Purgation State, whilst maintaining the power and influence of the PNL one-party regime by providing the ideological groundwork for its ongoing genocidal project against the Génétiquement Dysfonctionnel through its official exterminatory policy of 'liquidation through labour'.

The longevity of the Mandatum Est doctrine within the Purgation State, however, remains to be seen, as the religion presently holds far less sway amongst the younger generations of the present day. In 2023, the overall percentage of the population that believes in Mandatum Est stands at around 49%, with the percentage for Purgation Catholicism standing at 34%, and No Religion standing at 16%. However, that number shifts greatly depending on the generation one looks at. Amongst the oldest generation at present, persons born before 1943 or 1948 (depending on the definition one uses), often referred to as La Génération Républicaine - termed as such because this is the generation that was well into adulthood when the PNL took over the Purgation State in 1987-1988, and thus spent about half their life or more under the old Republic of Purgatio - the Mandatum Est religion is a fringe one, believed by fewer than 4% of this generation. No Religion stands at only 2%, with over 89% identifying as Purgation Catholics, a further 2% identifying as Roman Catholics, and another 3% identifying as Protestants (mostly Purgation Protestant sects such as the Canavairres and Méroviennes).

Next, you have the generation of persons who were young people when the PNL took over the Purgation State, and thus have spent most of their lives under PNL one-party rule, but were born under the old Republic of Purgatio. This is often called La Génération du Grand Rajeunissement and refers to persons born between 1943-1962 or 1948-1967, depending on the definition one uses. This generation would have been too old to experience the pro-government, pro-Mandatum Est 'Genetic Integrity Education' that was rolled out across Purgation schools in the 1990s, but they would have experienced the chaos and disorder prior to the PNL take-over of the government, they would have been old enough to vote in the 1987 legislative and presidential elections and the 1988 legislative elections, and they would have been old enough to experience all of the turmoil and turbulent changes and radical reforms besetting the country within the first few years of PNL one-party rule, including the beginning of the PIGC genetic classification system, the GEM's civil disobedience and transformation into a violent insurgency, the governmental demonisation of the Dysfonctionnel and the vilification of that community in the pro-government pro-PNL right-wing press, and the jingoistic aggressive wars launched against the Purgation State's neighbours on her borders. However, as many members of this generation would have been well into adulthood when the Mandatum Est religion took off in the late 1980s and the 1990s, the Mandatum Est religion still commands only a minority of this group of 28-29%, with Purgation Catholicism commanding a majority of 63-64%, and No Religion scooping up just 5-6%, with all other religions making up just 2-3% of the population.

After that, you have the generation of persons who were infants or young children when the PNL came to power. They would have spent practically their whole lives (and certainly most of their entire adult lives) under the new PNL regime, their childhoods would have taken place around the time of the PNL takeover of the country in 1987-1988, thus they would have had some tender age experiences of the turmoil and turbulence immediately before and after that dramatic regime change. Most of them were also young enough to have experienced the pro-government and pro-eugenics propaganda of 'Genetic Integrity Education' that was rolled out across schools in the Purgation State in the 1990s, and thus they are often referred to as La Génération de la Pivoine (named after the Peony Throne of the old Valois dynasty, a reference to the royalist restoration and re-assertion of traditionalist reactionary politics effectuated by the PNL one-party state). The range for this generation would include persons born between 1962-1981 or between 1967-1986. As expected, this is the generation at which adherence to the Mandatum Est religion reaches its peak, with support for the Mandatum Est religion amongst this group climbing to a huge 71-72% of this generation, while No Religion clinches 10-11% of this group, and adherence to Purgation Catholicism falls sharply down to just 17-18%, with all remaining religions making up less than 2% of this generation.

Finally, you have the youngest generation (with at least some members in adulthood in the present day, that is), persons born from 1981-1999 or 1986-2004, often referred to as La Génération de la Paix, so called because this generation would have spent most of their life - and certainly most of their adult life - under relatively stable, peacetime conditions, they would not have experienced the bulk of the instability, chaos, violence, and turbulence of Purgatio's domestic political conflicts in the 1980s, the initial unstable years of PNL rule in the 1990s including the GEM insurgency, and the wars with Purgatio's neighbours in the 2000s. In this generation, the Mandatum Est religion clinches a far reduced majority of this group, standing at about 56-57% of this generation. Belief in Purgation Catholicism falls further still amongst this generation to a dismal 7-8%, with the percentage identifying with No Religion shooting up drastically from all previous generations and standing at around 34-35%, with all other religions making up less than 2% of this group.

It is this sharp increase in the percentage of young people identifying with No Religion, and the correspondingly substantial fall in the percentage of Mandatum Est adherents in this generation, when compared to the immediately preceding generation, which causes great concern amongst the PNL regime and the present governing elite. It does not pose an immediate short-term threat to the Mandatum Est faith, since the percentage of Mandatum Est believers is statistically likely to grow as a proportion of the Purgation State population in the next couple of decades, given that there are comparatively lower percentages of Mandatum Est believers in the older generations which are slowly dying out. However, it does raise long-term concerns about the longevity of the Mandatum Est religion if the present trend continues and adherence to and belief in the Mandatum Est faith drops in the subsequent generations succeeding La Génération de la Paix, since it would mean that, in about half a century's time, the Mandatum Est religion would then take the present place of Purgation Catholicism as the so-called 'dying religion' being adhered to by older Purgations but with lesser subscription amongst younger Purgations. For now, however, these generational trends mean that Mandatum Est remains on the rise at present as the older generations with fewer Mandatum Est believers pass on and the comparatively younger Mandatum Est believers in La Génération de la Pivoine and La Génération de la Paix come to take their place. The long-term future of the religion, however, remains shrouded in doubt, and will depend in no small part on whether the religion retains its ideological hold amongst the younger generations that are yet to come thereafter.

[Purgatio]

Nature Personified as 'Trinity Goddess' (La Nature: Karioleur; Elosthérenée; Porthiarâté)

The Mandatum Est religion - in its original inception in Geneviève Aumont's famous 1976 treatise, La Solution Finale - is a materialistic, non-theistic philosophy without a deity. However, the concept of a deity or god-like figure taking centre stage in a religious worldview has become such an entrenched aspect of religious life within the Purgation State for centuries that it was practically inevitable that deific and theistic connotations would be read into the Mandatum Est religion by its adherents after the religion took off in the 1980s and 1990s. This has had an interesting effect on the Mandatum Est faith: while the La Solution Finale treatise often speaks of the 'Mandate of Nature' as the central premise and thesis of that religion, it never conceives of or portrays that Mandate as an embodiment or expression of any cognitive will, conscious spirit, or emotional desire of any particular thinking, feeling supernatural entity. It is, quite literally, a mere physical force of nature and not a conscious but divine person or entity of any kind.

However, Chapter I of the "Little Blue Book", which introduces the reader to the concept of the 'Mandate of Nature', does often speak of Nature in somewhat personified terms, although this was likely only for literary or dramatic effect, as an expressive style, and was probably not intended to be construed literally. For example, Chapter I, paragraph 1.02 includes the line, "Nature can be defied, She can be ridiculed, She can be foresworn; but, to overcome Her dictates is a complete impossibility. Note, dear reader, that I do not write that to overcome Nature would be wrong, or evil, or immoral; no, I write that it cannot be done. That is common-sense, for She who forges the building blocks of life defines existence itself. She establishes the very terms and conditions of our presence in this world. Indeed, She constitutes our flesh, our bones, our blood. Some throughout history have said we are slaves to Nature, perhaps in a resigned and regretful manner. I do not hold such futile reservations. Instead, I say that we are heirs to Nature's bequest. It is a bequest we cannot reject or revoke. We may do as we please with Her inheritance, of course, but the particular contents of Her inheritance are immutable and irrevocable and entirely out of our control. I choose not to look upon that fact with feckless fury, however, for to shame Nature's devise and legacy bestowed upon our very body, bones, and being, would be to shame our very existence itself. It is our responsibility, therefore, to make the most of what She has given us, instead of uselessly complaining that She bestowed this peculiar chattel upon our blood and not some other we may prefer".

Given that the Mandatum Est philosophy was growing in its mainstream appeal amongst a Purgation populace that had been steeped for centuries in religious cultures that were deific and theistic in nature - i.e., Purgation Catholicism, which has been around since the 11^th Century, and Roman Catholicism, which has been around since the 2^nd Century - it should not be surprising that those cultural connotations were read into passages such as the above excerpt, to conjure up the image of a personified goddess with an autonomous will, wish, and desire, a living embodiment of Nature that rules over all of humanity and, indeed, the entire natural world and realm. Thus, from the Mandatum Est religion, there came a new goddess and deity which became a fixture of modern Purgation culture and a ubiquitous part of the Mandatum Est doctrine as believed and espoused by many of its adherents today - La Nature, the personification of Nature itself.

However, La Nature was not only conceived of as a goddess, She was increasingly perceived as a 'Trinity Goddess', a three-in-one personification, with three different worldly embodiments, expressions, and personages, all being representatives of the same fundamental essence. This three-in-one 'trinity deity' concept is, no doubt, influenced greatly by the fact that the Purgation State has been, historically and traditionally, a Catholic nation, and many of the modern-day followers of the Mandatum Est religion would have been raised in Purgation Catholic households and grown up exposed to many Purgation Catholic rites and rituals. As such, the notion of a 'Trinity Goddess' very much mirrors the concept of a 'Trinity Christian God', with Father, Son, and Holy Spirit all being personifications and expressions of the same underlying divinity.

As for the textual basis for this 'three-in-one' personification of La Nature as a 'Trinity Goddess', this is often derived from the final line in the first chapter of La Solution Finale, in Chapter I, paragraph 1.16, which reads as such: "Such is Nature's omnipotent power over our world, as we must acknowledge and accept: She authors all creatures and constitutes all beings. She moulds the terms of life and crafts the circumstances of natural existence. She winnows through her creations and clips the thread of life. Fate, fortune, and destiny lie solely and squarely in Her hands. All of us - humanity and beasts alike - may do no better, at the end of the day, than to live in perpetual subjection to Her unlimited sovereignty over Her bountiful domain".

From this line, the concept of La Nature as a 'Trinity Goddess' is derived therefrom, with three clearly demarcated roles laid out in the above excerpt - first, L'Auteure (i.e., The Author), who creates and constitutes the living and organic material of all biological creatures; second, La Mouleuse (i.e., The Moulder), who moulds and shapes all of the terms and conditions of one's natural existence, including the availability of food, water, resources, climate, diseases, natural disasters, and other such environmental conditions determining reproductive potential and success; and third and last of all, La Vanneuse (i.e., The Winnower), who sieves through all living creations and determines, at every point, which lives in being will be taken out of circulation and should pass on from the natural world, thus wielding the fearsome power of death itself. All three living personifications of Nature are mere expressions and embodiment of the same underlying divinity, the same Nature, following and enacting the same Mandate, but they play different roles, discharge complementary but distinct responsibilities, and most importantly, they work in harmony and in concert with one another. Each of their roles plays a part in shaping how the others play their respective roles.

For example, L'Auteure, by determining the genetic codes of Her creations, influences how well those creatures can adapt to the conditions of the natural environment which are set by La Mouleuse. If She decides, for instance, to bestow upon a group of rabbits genetic variability, giving some the ability to survive the cold, and giving others the ability to survive heat, then when She decides also to place some areas of the Earth under extreme heat and other areas under extreme cold, it will kill off the rabbits ill-disposed to survive such temperatures, based on their genes, while retaining the rabbits pre-disposed to survive such climates. Likewise, it follows that the conditions of the natural environment set by La Mouleuse necessarily influence how La Vanneuse exercises Her power over death itself and which creatures to 'sieve' out from living existence. If, for instance, She decides to inflict a natural disaster over a particular area, by sending a hurricane to afflict a certain town or placing a tsunami over a coastal area, then She likewise will determine, amongst the inhabitants afflicted by that disaster, who will survive and who will perish therefrom. Finally, the way La Vanneuse exercises Her power to 'winnow' through all lives in being will naturally have a knock-on effect on how L'Auteure exercises Her power of creation, since it determines the genetic materials She has available to cultivate new creations therefrom, through natural reproduction. Thus, if She decides to kill off all the baboons in an area with an A and AB blood type, leaving only the baboons with a B blood type, it naturally follows that when She makes new baboons through the process of sexual reproduction, those new baboons will only possess the B blood type and not the A and AB blood types, through the natural process of the heritability of genetic traits. As such, each of these three distinct roles have knock-on consequences on how the other two roles may be exercised. If each of these three deities were distinct and separate beings, with differing wishes and desires, it is easy to envisage the conflicts and frictions that would arise if these three responsibilities were discharged towards incompatible ends. However, because these three deities are mere manifestations and expressions of the same three-in-one 'Trinity Goddess' (La Nature), it follows that they will discharge their roles and responsibilities in a complementary and harmonious fashion which promotes, rather than sabotages, the way the other two in the Trinity discharge their respective roles and responsibilities. All three are therefore united in their common pursuit of the same goals and objectives, which together form the so-called 'Mandate of Nature' which collectively rules over the entire natural realm and every living organism in existence.

As the Mandatum Est religion began to grow in popularity in the late 1990s and throughout the early 2000s, an interesting phenomenon began to take hold amongst its more fervent and devout adherents, however, which took the 'deification' of this non-deific materialistic philosophy a step further still. In a clear demonstration of the syncretistic character of the Mandatum Est faith, many of the devotees of this new religion who enthusiastically bought into the personification of La Nature as a three-in-one 'Trinity Goddess' began to search the annals of Purgation culture for avatars and representatives for each of the three expressions and manifestations of La Nature (L'Auteure; La Mouleuse; La Vanneuse). They found their answer deep in Purgation antiquity, and in the ancient and historic pagan polytheistic religions once believed by the various Frankish, Norman, and Gallo-Romance clans and tribes that once populated the Purgation State's territorial heartland of today, and which have retained their force and relevance as hugely important historical and cultural figures within the modern popular cultural imagination of Purgation society today. Different tribes of the age of classical antiquity (which were the cultural predecessors of, and continental ancestors to, the Anjous peoples) believed in different sets of deities and their mythologies and tales were, naturally, not always entirely aligned or ad idem in their contents.

Broadly speaking, however, the Ancient Anjous (a broad turn of phrase which historians often use to refer to the peoples of the ancient civilisations predating the rise of the warring feudal kingdoms of the 8^th Century CE onwards and beginning with the founding of the Burgondi civilisation in around the 10^th Century BCE following the Bronze Age Collapse of various coastal ancient civilisations like the Vannages), believed in a number of so-called 'common' deities, or gods or goddesses which recur in the mythological tales espoused by the different kingdoms and civilisations that made up the Ancient Anjous (e.g., the Burgondis, the Pérovinnise, the Barrévaïsés, the Amboisaîs, the Lesmonténis, the Rôchémorts, the Çateuilles, etc.). Many historians and archeologists have identified a total of seventeen (17) gods and goddesses which are found in the art, poetry, pottery, sculptures, and temples of different ancient civilisations scattered across the Purgation State's territory of today, all unified by a so-called God-Emperor who reigned over all of humanity and had almighty and supreme power over the face of the Earth, by the name of Seviathane, who was generally characterised as a stern, tough, and somewhat authoritarian ruler who maintained order, harmony, and discipline within nature and society, ruling over humanity with an iron fist from the divine realm of Lucrèçis. The other sixteen (16) gods and goddesses who formed part of the so-called 'Lucrèçisian Pantheon' were all family members of Seviathane, either through blood or through marriage. The ancient mythological tales generally characterised the relationship between Seviathane and his family members as more of a lord-vassal relationship as opposed to the kind of loving and affectionate familial relationship that would be more compatible with modern cultural sensibilities. Seviathane, as the God-Emperor, represented order and discipline in an otherwise chaotic, messy, and disordered universe, and he maintained that order and control within his Imperial Household as much as he maintained it over the natural environment on Earth and all the human societies and civilisations thereupon. Thus, the other gods and goddesses of the 'Lucrèçisian Pantheon' were generally portrayed as loyal, faithful instruments of the divine will of Seviathane, maintaining order and harmony on Earth on his behalf. Hence, Seviathane is never portrayed as directly meddling in humanity's affairs, he never leaves the safety and comfort of the divine realm of Lucrèçis, and it is always the other sixteen (16) gods and goddesses who appear directly in various mythological tales intervening in human affairs, but always on the orders of Seviathane, who plays the role of a rather distant and removed, but all-powerful, deific ruler. Due to the distant portrayal of Seviathane, it is generally these other sixteen (16) deities who possess richer and far more vibrant and dynamic personalities and characterisations within the ancient mythological stories, since they play much bigger roles in the ancient tales featuring wars, hardships, romances, or other such heroic feats, tragic tales, or dramatic epics.

Amongst these sixteen (16) gods and goddesses, therefore, three goddesses in particular were picked out for their broad similarities with the personified La Nature and Her three particular manifestations as L'Auteure, La Mouleuse, and La Vanneuse. The first of these was Karioleur, the mother of Seviathane who thus held the title of Dowager Empress within the Imperial Household of Lucrèçis. Karioleur was the patron goddess of marriage, pregnancy, childbirth, and fertility. In the ancient tales, Karioleur was generally portrayed as nurturing, tender, kind, and an affectionate member of the family. She remained loyal to her son, Seviathane, even after he treacherously murdered his own father, her husband Noëruss, in their marital bed, in his blind lust for power and to seize the divine throne of Lucrèçis. Despite this bloodied betrayal, Karioleur was a loyal Dowager Empress to the God-Emperor Seviathane, and there was never any indication in the mythology that she harboured any resentment against him for causing the death of her husband nor ever plotted to undermine his rule in revenge. While no doubt shocking to modern sensibilities, this origin story reflected a core part of the culture of the Ancient Anjous, which was a strict and uncompromising view of the 'duty of maternal love', the notion that it was a biological mother's overriding imperative to nurture and wean her natural begotten offspring, irrespective of the circumstances. However, the nurturing and affectionate side of Karioleur, shown to her son and other members of her family, stood in stark contrast to the vengeful, cruel, and vindictive attitude she bore to anyone she deemed a threat of any kind to her family and especially to her son. Many of the ancient tales involved Karioleur inflicting terrible cruelty upon humanity for the pettiest of slights against her son Seviathane. In one tale, the king of the city of Myséis boasted that he was a fairer and more equitable sovereign than even Seviathane himself. Outraged by the insult, Karioleur cursed the city by using her powers over fertility to boost the reproductivity of nearby hornets' nests to unusually and unnaturally high levels, effectively raising an army of millions of venomous hornets which descended upon his city and stung every man, woman, child, and livestock until none were left except the king himself, who was cursed with immortality, writhing on the floor of his ruined kingdom in eternal torment and agony, getting stung over and over again by millions of hornets, unable to die throughout. On the other hand, she had a soft spot for young infants and pregnant mothers, in her capacity as a goddess of pregnancy and childbirth. As such, some stories portrayed the gentler side of Karioleur, involving her leaving the safety of Lucrèçis and intervening in human affairs specifically to protect a pregnant woman or a young defenceless infant who was about to suffer imminent death or injury. In one story, when a pregnant woman drowned on the island of Delínis following a flash flood, a horrified Karioleur assumed a human form, came down to Earth, and absorbed the foetus into her own womb, carrying the foetus for another seven months before undergoing the pain and struggle of a natural human birth, to bring the child into being. These competing mythological tales made Karioleur a perfect figure to use as an avatar of L'Auteure - The Author - responsible for the creation of all life, creating and cultivating the genetic constitution and biological materials of every living creature on the face of the Earth. L'Auteure is not a universally kind figure, She cannot be, for while She is responsible for creating life, She must also be responsible for failed attempts at procreation, for all miscarriages and stillborn births, as well as for cursing living creatures with all sorts of traits and characteristics which we might consider negative, including congenital disabilities and genetic diseases. Hence, a complicated and multi-faceted figure like Karioleur was perfect to capture the arbitrariness and capriciousness inherent in the lottery of the creation of biological life and the randomness inhered in that process.

The second of the goddesses chosen to be an avatar for La Nature was Elosthérenée, the goddess of sex, lust, beauty, harvest, seasons, luck, prosperity, and fortune. In the mythologies of the Ancient Anjous, Elosthérenée was one of the goddesses married to Seviathane in his Imperial Harem. While she was not the Consort Empress, she was an Imperial Concubine and generally portrayed as the most favoured spouse and lover of Seviathane, and also, not coincidentally, the most beautiful as well as the most sexually and conventionally attractive of the lot. Having earned the God-Emperor's favour, she had the benefit of being conferred the most coveted domains over humanity's affairs, which generally consisted of the most popular bounties which can be bestowed on human beings - sexual prowess and attractiveness, romance and beauty, a successful harvest, bountiful riches, and vibrant economic prosperity - making her a very popular goddess for the Ancient Anjous to pray to and make sacrifices and offerings for. Despite these beneficent sounding divine remits and the positive connotations generally associated with these blessings, the mythological portrayal of Elosthérenée was surprisingly quite unflattering (or perhaps, on closer reflection, not that surprising when one remembers that the bards, poets, dramatists, and writers did have to logically account in some way for why these blessings were not being richly and generously bestowed upon humanity in much greater abundance). Indeed, in most tales and fables, Elosthérenée often comes off as the most vain, superficial, shallow, arrogant, hubristic, and narcissistic of the 'Lucrèçisian Pantheon', and at the worst of times, she possesses a positively petty, dictatorial, and controlling streak in her personality. In one myth, she cursed a beautiful princess with a facially disfiguring illness and a body odour so nauseating such that all male and female lovers alike would shun her as repugnant simply because the princess's mother delayed the disbursement of funds for the construction of a temple and shrine intended to be dedicated in her honour. In another tale, she cursed a farmer's entire harvest to yield only poisonous crops for the rest of his days because the once-attractive man, who married one of the fairest maidens in the land on account of his once youthful good looks, grew increasingly obese as he aged, even as his wife retained her conventionally attractive looks, an inequality and disparity in appearance which Elosthérenée simply found too revolting to go unpunished. In yet another myth, she destroyed a merchant's entire business and reduced his once-thriving fortune into ruination and bankruptcy because she felt he was insufficiently generous in his offerings and sacrifices in her temple. In another tale, she cursed an infamous playboy and local lothario with erectile dysfunction and shrunken genitals because she was put off by his constant bragging about his good looks and the number of women he'd bedded in his lifetime. However, just as there are myths where Elosthérenée is dishing out curses on humanity, there are also many myths where she is bestowing immensely generous gifts and bounties on the humans she takes a liking to - although, in keeping with her personality, her reasons for favouring particular human beings were nearly always frivolous and superficial. Many of her mythologies involved Elosthérenée taking a liking to the charming appearance of a young peasant boy or girl and elevating them to positions of great fame, power, and fortune, making them kings, queens, generals, wealthy merchants, beloved performers, famed playwrights and composers, and more. In other stories, mortals who had successfully flattered her ego in unique ways were bestowed untold riches, glorious treasures, and bountiful harvests as a reward. In one tale, a young woman praying in her temple told her that she dared not ever marry or even lose her virginity as she had so dedicated herself to learning and studying the ways of Elosthérenée that she had completely lost the will to love or be intimate with another since she could not possibly fathom any encounter with a mortal lover that would not pale in comparison to what the goddess did with her lovers on a regular basis. Immensely flattered, the goddess elevated the young woman into being one of the richest merchants on the continent with a whole fleet of ships under her command, all carrying untold luxuries and exotic treasures, and ensured she would enjoy the company of many young beautiful house-boys in her employ lasting long into her old age. This erratic, unpredictable, frivolous personality of Elosthérenée in the ancient mythos, and the haphazard and illogical way she doled out curses and blessings on mortals for wholly superficial reasons, made her a perfect avatar for La Mouleuse. In the worldview of Mandatum Est, after all, Nature (and by extension La Mouleuse) is illogical, arbitrary, and unpredictable in the gifts She doles out and the things She takes from the world. There is no logical moral explanation for why certain human beings suffer illnesses while others remain unharmed, or why certain human communities suffer tsunamis and hurricanes while others are spared. Nature Herself is capricious in the fortunes and misfortunes She doles out upon humanity, and living creatures on Earth have no choice but to simply make do with that reality of life and make the best of whatever hand is dealt upon them by Her. As such, the capricious and erratic personality of Elosthérenée is an apt representation of the random way in which La Mouleuse determines the relative fortunes and misfortunes of individual living creatures - wholly arbitrarily, and without any rhyme or reason whatsoever.

Finally, the last of the goddesses chosen from the 'Lucrèçisian Pantheon' to represent La Nature was the young Porthiarâté, the feared goddess of war, famine, droughts, calamities, plagues, pestilence, death, and the underworld of Nathyaka. In the divine realm of Lucrèçis, Porthiarâté held the title of Crown Princess within the Imperial Household, as the youngest child of the God-Emperor Seviathane and the only child born to his one and only Consort Empress, Réçavronuelle, thereby making her his one and only legitimate heiress to his throne, and accordingly, his most favoured issue. In the mythos of the Ancient Anjous, Porthiarâté was awarded control by her father over the underworld of Nathyaka to rule over as her personal fiefdom and domain, with total dominion over all the souls of the deceased, be they human or animal or any other living organism. She also wielded power over death itself, and by extension, was responsible for such lethalities as famines, droughts, calamities, plagues, pestilence, and wars. Amongst the Ancient Anjou peoples and their scattered civilisations, Porthiarâté was not a popular deity to worship, but she was an especially feared one, and temples and offerings were often erected in her honour in cities and town squares in order not to attract her ire or attention. However, even to speak her name was considered cursed and a way of attracting her unwanted scrutiny, with worshippers at the time often using vague euphemisms to allude to her such as 'the Imperial Princess', 'the Holy Maiden', or 'the Divine Daughter', amongst others. In the ancient tales, Porthiarâté was the only deity with a genuinely sadistic and almost malicious streak, a personality which practically revelled and delighted in the pain and suffering of her chosen victims, whether out of bloodlust, a lust for power, or some other primordial drive within her, it did not matter much, the point was that the mortals who caught her eye rarely ever met pleasant ends. Two themes feature ubiquitously in the classical tales and myths involving Porthiarâté and the various bouts of suffering she visits upon hapless mortals. First, she is drawn in particular to mortals who have an unusual fear or anxiety about death. In one tale, the governor of the island of Oïvaire spent a huge proportion of the island's budget searching the universe for elixirs of immortality as he was terrified of dying. Porthiarâté, as the goddess of death, was drawn to the governor's fear and appeared to him at night, visiting upon him terrifying images of monstrous personifications of demise and destruction crawling out from every dark corner of his mansion, clawing off his skin and devouring his face whilst he was asleep. When he woke up at the next day, he fell under a curse, whereby every mirror he walked pass or looked into, those monstrous personifications would appear. As he passed through the day, those monstrous personification would appear like sudden mirages in hallways, corners of walkways, or hidden in the crevices of buildings or atop the high ceilings of his home. The fear so gripped him that his body was constantly on high alert, always fearing and anticipating the next appearance of these illusive mirages of death, until the fear and stress got to him so badly that, a few months later, he had a heart attack in his home when the next mirage appeared seemingly out of nowhere from underneath his bed, shocking him into such a fright his skin turned ashen-white, his hair turned gray, and he died writhing on the floor in agony swatting away at imaginary demons which did not exist. Many similar stories existed amongst the Ancient Anjous of mortals cursed to suffer terrible deaths because their fear of death attracted the attention of Porthiarâté. These mythologies reflected the stoic and nihilistic worldview of the culture of the Ancient Anjous, their belief that to fear something as inevitable as death is futile and pointless, and it is better for human beings to embrace the cold reality of their demise and approach the end of their lives with bravery, courage, and mental fortitude. Other tales involved mortals with the opposite flaw - hubristic and arrogant defiance of death or a false belief in their indestructibility. In another myth, a young warrior who was a fearsome fighter on the battlefield had slain countless enemies in numerous battles for his kingdom, until he was the most famed warrior in the land, gifted bountiful riches and honours by the king, with countless maidens flinging themselves at him. The fame and glory got to his head and before every battle he would begin to boast that even death itself was no match for a warrior like him. Such boasts caught the ire and fury of Porthiarâté, who engineered his demise in the next battle, causing a part of his battle armour to rust and slide off in the middle of the fighting. As such, the spear of an enemy fighter caught his shoulder blade, piercing through his skin and vessels, resulting in a bacterially infected wound. The warrior died slowly, agonisingly, and incredibly painfully over the course of many months, from a combination of gangrene, sepsis, and awful necrotising bacteria eating away at his tissue at the wound. Not all of the myths involved a moral of the story or human flaw attracting the attention of Porthiarâté, however; in fact, a key feature of Porthiarâté, as a divine goddess of death, is that the suffering and misery she visits upon mortals is not always an act of divine retribution for a mortal flaw involving a crippling fear of death or hubristic defiance of death. In many cases - as in real life - plagues, pestilence, famines, droughts, calamities, wars, and other forms of terrible destruction are visited upon civilisations and victims who have done nothing to earn or attract such divine retribution, reflecting the randomness and arbitrariness of death and mortality in the world. In fact, when the Bronze Age Collapse of the 11^th Century and 10^th Century BCE saw the sudden destruction and regression of many thriving, prosperous, cultured Bronze Age civilisations, including that along the trade-rich Purgation coastline, the Ancient Anjous bards and dramatists and epic poets wrote many stories about the wanton destruction of these societies, heavily featuring Porthiarâté raining down floods, hailstorms, droughts, pirate attacks, conquests and raids by marauders and looters, terrible plagues and pestilences, which brought once thriving and prosperous kingdoms to terrible ruin and inflicted death on countless innocents, for her sheer sadistic enjoyment and cruel relishing in and gratification from human suffering. Conversely, other portrayals of Porthiarâté were more ambivalent and less overtly negative and terrifying. For instance, throughout the 5^th Century through to the 13^th Century CE of Purgation history, the medieval feudal tribal kingdoms of the Medieval Anjou peoples (who were the cultural successors and descendants of the Ancient Anjous) constantly warred with each other for territory, fiefs, and resources, as well was the sheer glory of battle and conquest. As such, many warriors, generals, and kings often prayed to Porthiarâté and offered her rituals, worship, and sacrifices in the hopes that she would hear their supplications and rain down terrible death, destruction, and suffering upon their enemies, whether in battle or before then. Hence, in heroic folktales of the early medieval age, Porthiarâté would lend assistance to courageous fighters as they launched heroic feats or conquered epic journeys, resulting in her occupying somewhat of an 'antihero' role in such mythologies. Numerous epic tales of noble knights and brave warriors charging into battle would feature Porthiarâté fighting by the side of her favourite heroes and heroines - often those with a courageous and stoically respectful acceptance of their eventual deaths - helping them to strike down their enemies in their paths, ensuring the strikes of their sword are true and the aiming of their bow is steady. Another common source of worship for Porthiarâté was for the purpose of enraged revenge and the seeking of vengeance. Many such worshippers often made sacrifices, performed rituals, and made earnest prayers for Porthiarâté to visit terrible plagues, pestilences, or other tortuous and painful forms of death upon persons they hated or despised for any reason whatsoever. Whether she would answer those prayers was always portrayed in the mythology as being somewhat unpredictable and erratic. The rare myths which depict Porthiarâté in more positive or flattering terms generally involved her inflicting terrible vengeance upon a mortal who had committed awful wrongs upon another mortal. In one particularly memorable myth of the Ancient Anjous, a young knight who had helped his liege lord to invade and occupy a village decided to rape two underage peasant girls after killing their father and tying up their mother. When the army left the village the next morning, the two victims were left traumatised and ended up taking their lives not a week later. Their mother was so distraught and heartbroken by the tragedy visited upon her family that she slowly starved herself to death, lacking the will to live or to even find food for herself. As she wasted away slowly, she would pray every day and every night for Porthiarâté to visit the most terrible vengeance she could possibly conceive of upon the knight responsible for the suffering he had inflicted on her husband and daughters. When the mother finally died a few weeks later, Porthiarâté would answer her prayer. During a jousting tournament, Porthiarâté supernaturally sharpened the lance of the knight's opponent and instigated the knight's horse to suddenly throw the knight onto the ground without warning. The opponent's lance came crashing down onto the knight, as the sharp edge pierced his groin, skewering his testicles and private parts, even as Porthiarâté inflicted a madness upon the horse which caused it, in a frenzy, to stomp all over the knight. As a result, the knight went blind in both eyes as both of them were squished by the horse's shoes. His spine and tailbone were completely shattered, leaving him paralysed from head to toe. The lance tore into his testicles and pierced right into his urethra, causing his male sexual organ to suffer a number of seriously infected wounds. She used her powers to artificially prolong the man's life, ensuring that he would take over a year to die from a mix of his urinary tract infection, various bacterial and fungal bloodstream infections of his wound, and severe and acute meningitis from the inflammation of his male sexual organ. The knight died slowly and in the most terrible and agonising pain imaginable for the rest of his short life. This is the tone that the so-called 'nicer' stories about Porthiarâté would generally take in the mythos of the Ancient Anjous - cold, gruesome, chilling, brutal, horrifying, but perhaps oddly satisfying and cathartic if the reader is of the more vengeful inclination. This conflicting picture of Porthiarâté as a cruel, sadistic, evil goddess whose actions sometimes had positive effects and were, on occasion, desired by her worshippers in certain circumstances, made her a perfect avatar for La Vanneuse, for in the Mandatum Est worldview, the role of La Vanneuse is also complicated in a similar way. While death is never savoury or edifying to think about or imagine, La Vanneuse plays an important even if unpalatable role in maintaining the balance and harmony of Nature, for without death, natural selection would be impossible, no species could ever change or evolve for the better, and the world would become overpopulated with a disproportionately aged and infirm populace and insufficient natural resources to support a halfway decent existence for most organisms. As such, the cruel and complicated character of Porthiarâté accurately captures the complex role of La Vanneuse in discharging the 'Mandate of Nature' - unpleasant, but sometimes very necessary.

It should be noted here that there is no one-to-one equivalency between the religious canon of the old pagan polytheistic pantheon of the Ancient Anjous versus the deification of the contemporary Mandatum Est religion of today. Purgation pagan polytheism is presently a 'dead religion' within the Purgation State's society and was only a major religious force within the Purgation State populace from around the 18^th Century BCE during the Purgation Bronze Age and lasted for over two thousand years until the 9^th Century CE, by which point it was a waning fringe religion on the decline in the face of the rise of Roman Catholicism and the disaffiliated Catholicism of the Burgondi civilisation thereafter. Given the sheer length of time in which pagan polytheism was an entrenched part of the Purgation State's history and heritage, the religious iconography and cultural figures of the pagan mythologies remained core parts of the Purgation State's mainstream popular culture long after the religion had died out, with gods and goddesses frequently being referenced in casual conversation, slang dialogue, and popular television shows, and with allusions to iconic myths being scattered all across modern literature, pop music, and even in many a commercial advertisement. Given that they remained fixtures of the popular Purgation cultural imagination, it is not surprising that when the Mandatum Est religion took off from the late 1980s through the 1990s and 2000s, many Purgations began to draw natural and automatic associations between the personified La Nature and the goddesses Karioleur, Elosthérenée, and Porthiarâté. The fact that there was no one-to-one similarity between the tenets of the Ancient Anjous pagan polytheism and the Mandatum Est religion mattered little since the polytheistic pantheon had become cultural figures as opposed to religious figures by this point in time, lending flexibility and fluidity in terms of how the Purgation populace could invoke their cultural memory and re-purpose it to dress up the grandiosity and aesthetics of a much more contemporary faith.

This 'deification' process was a gradual and organic one. When the Mandatum Est religion grew as a political ideology amongst the Purgation far-right in the late 1980s and early 1990s, such as amongst the far-right Ça Suffit! movement, and under the active encouragement and promotion of far-right governmental figures like High Inquisitor Geneviève de la Fayette, PIGC Director Marin de la Trémouille, and Commandant en Chef Delrico Charlet, there was little attempt made by the Purgation far-right to push for this non-theistic philosophy to become a deified quasi-theistic religion. No attempts were made by the Purgation State through its propaganda efforts, such as its 'Genetic Integrity Education' programme of the 1990s, to push for Purgations to worship a personification of Nature, much less to conceive of Nature as some kind of 'Trinity Goddess' with links to the deities of Purgatio's distant past. It was only once the religion became a deeply rooted part of Purgation culture in the early 2000s onwards and the congregation of Mandatum Est became a truly sizeable and significant proportion of the population that a substantial proportion of such adherents began to speak of the religion in more theistic terms, increasingly so as the religion garnered broader mass appeal. By the turn of the 21^st Century, talk of the Mandate of Nature as a conscious divine will of a thinking and feeling personified deity - La Nature - had become ubiquitous in the way the average follower of the religion spoke about the doctrine with their friends, their family, and especially in anonymous online spaces. When Mandatum Est became an official State religion in 2010, Media and Culture Secretary Marquisa de Taillefer then had the idea to 'lean into' the personification of La Nature in order to play to and actively encourage the passion and zeal that these Purgations had increasingly begun to show for the religion. It was hoped that leaning into the personification of La Nature as a 'Trinity Goddess' and playing up these historical cultural associations with these three pagan goddesses of the Purgation polytheistic pantheon of old would add a sense of mystique and intrigue to the religion, link this new faith to the country's roots and heritage, and hopefully draw in more public interest and attention to the faith's doctrines by casting its teachings and tales in a more entertaining and storied mythological lens.

Hence, in addition to the drier academic texts about eugenics and dysgenics and natural selection and social Darwinism, the Media and Culture Ministry funded the creation of temples, sanctuaries, altars, and holy places, filled with imagery and iconography of La Nature as a three-headed goddess, with images of the nurturing Karioleur bringing life into the world, the dictatorial Elosthérenée holding the fortunes of humanity in her hands, and the cruel and sadistic Porthiarâté wielding the fearsome power of death itself. Huge towering marble statues of the goddesses began to be erected in public spaces, in public parks or around major gardens, beaches, lakes, rivers, recreational areas, thoroughfares, and city districts. Many Mandatum Est libraries included fictional works, both past ancient epic poems and plays and songs about the goddesses but also more modern reimaginings of the three goddesses and their various plottings and schemings in the over one thousand years since the polytheistic religion had died out in Purgation State history. The Purgation State commissioned art work of the goddesses to be erected in national museums, plays and dramas to be written by talented auteurs creatively writing the goddesses into various parts of Purgation history, with Karioleur birthing the future generation of the nation, Elosthérenée blessing the nation with peace and prosperity after the PNL came to power and restored law and order on the Purgation streets and in the inner cities, and with the fearsome Porthiarâté cursing Purgatio's many internal enemies, ruthlessly striking down all her criminals, drug-dealers, terrorists, sexual offenders, gangsters, syndicate bosses, and more, all in service of the harmonious Mandate of La Nature Herself from which they all flowed and emanated as their common point of origin. Festivals and public holidays were christened and declared in honour of the different goddesses. A two-day public holiday for the remembrance and celebration of La Nature and her sacred Mandate was declared for 18-19 February, filled with glorious parades and military spectacles in the public square, replete with huge rallies of Purification Order paramilitaries marching through the streets as PNL rank-and-file party members chant far-right party slogans in unison while waving the Little Blue Book. The Feast of Karioleur was declared for 21 July, intended as a day when people can spend time with their families and have a big grand feast and banquet together with all of their extended relations, in commemoration of the goddess of childbirth, fertility, and pregnancy. The Festival of Elosthérenée was declared for 4 October, a bacchanalian holiday when the country would go wild with parties, drinking and dancing in the streets, with a massive parade in major city centres and music blaring out in public even late into the night, as partygoers revel and lose themselves in an unusual day of decadence and indulgence to celebrate the goddess of romance and fortune. And finally, the Solemnity of Porthiarâté was declared for 27 November, a day of mourning for the brave fallen who had given their lives in defence of the nation and a day of celebration over the death of Purgatio's enemies, as Purgations attend huge rallies and parades where images of certain prominent Purgation Dysfonctionnel - including high-profile GEM terrorist leaders and various prominent terrorists, murderers, rapists, paedophiles, human traffickers, drug kingpins, kidnappers, robbers, and more - are flashed across huge scenes in the public square as a video narrator summarises their gruesome deeds and crimes in vivid excruciating detail while describing the painful and brutal ways they died in the concentration camps via 'liquidation through labour', as the Purgation public will cheer and scream ecstatically in enraptured excitement, praising Porthiarâté for bringing them to a grotesque and agonising end while collectively praying for her to rain down even more horrors and torment on all the other Dysfonctionnel parasites within Purgatio and beyond.

As such, the PNL-controlled Purgation State very effectively transformed the deification and personification of La Nature, and the cultural linkage and association with three ancient goddesses of the Ancient Anjous polytheistic pantheon, into a propaganda victory for the Purgation government, further cementing the cultural power and influence of the Mandatum Est religion within the society and culture of the Purgation populace of today. This ideological and propaganda campaign was successful for a number of reasons. First, the syncretistic character of the Mandatum Est religion melded well with the equally syncretistic character of the Ancient Anjous polytheistic religion of classical antiquity. Ancient Anjous polytheism has always been able to assimilate the doctrines of most other religious faiths and incorporate their belief systems into the existing canon and mythology of the Ancient Anjou peoples. In fact, as the Ancient Anjous met overseas civilisations through trade, navigation, commerce, and diplomacy, they often syncretised their own gods and goddesses with foreign deities by writing foreign myths into the existing body of myths for the 'Lucrèçisian Pantheon'. Famously, throughout history, the God-Emperor Seviathane was 'syncretised' with the Greek god Zeus, the Roman god Jupiter, the Norse god Odin, the Egyptian god Amun, the Phoenician god Baal Hammon, the Taoist deity the Jade Emperor (Yudi), and the Hindu deity Indra. Likewise, historically, Karioleur was 'syncretised' with the Greek goddesses Demeter and Hera, the Roman goddesses Ceres and Juno, the Norse goddess Frigg, the Egyptian goddess Isis, the Phoenician goddesses Kotharat and Atargatis, the Taoist deities Songzi Niangniang and Bixia Yuanjun, and the Hindu deity Parvati. The goddess Elosthérenée was 'syncretised' with the Greek goddesses Tyche and Aphrodite, the Roman goddesses Venus and Fortuna, the Norse goddess Freyja, the Egyptian goddess Hathor, the Phoenician goddesses Astarte and Tanit, the Taoist deities Jiutian Xuannü and Mazu, and the Hindu deities Rati and Lakshmi. Finally, the fearsome and most foreboding Porthiarâté was historically 'syncretised' with the Greek goddess Persephone, the Roman goddess Proserpina, the Norse goddess Hel, the Egyptian goddess Ammit, the Phoenician goddess Anat, the Taoist deity Xiwangmu, and the Hindu deity Kali. Given this history of syncretism, it was relatively easy for the Purgation State to take advantage of the historical syncretism of the Ancient Anjous pagan polytheism to integrate their deities into the new burgeoning religion of Mandatum Est.

Moreover, another factor which helped along this process was the canonical flexibility of Ancient Anjous pagan polytheism, which was historically a very decentralised faith without a centralised institutional clerical class with power to dictate, authoritatively and determinatively, the 'correct' interpretation of the religion. Historically, there was no one 'correct canonical version' of Ancient Anjous polytheism. Different tribes and clans of the Anjou peoples followed different versions of the mythologies, many of them even had disparate deities who were not part of the 'Lucrèçisian Pantheon' and differed from locality to locality. Likewise, the exact contents and details of certain myths would differ between civilisations and societies, and even within a particular kingdom, there was no centralised institution or hierarchical clergymen dictating what the 'correct' or 'wrong' versions of the myths were, and since many of these tales were passed on through oral tradition, even within a particular tribal kingdom, different households or neighbourhoods would hold different beliefs about the same pantheon. The result is that there was no canonical standardisation within the religion, which became doctrinally very decentralised and individualised. This made for 'canonical flexibility' which allowed the religion to be interpreted broadly and widely to fit other religious beliefs or the social and political needs of the time. Hence, the Purgation State was also able to take advantage of this same 'canonical flexibility' to blend the ancient mythos of the 'Lucrèçisian Pantheon' to fit the unique doctrines of the Mandatum Est belief system.

Next, the tendency to 'look backwards' to an ancient age preceding the Purgation State deeply rooted in the nation's history, heritage, and tradition blended nicely into the reactionary outlook promoted by the Purgation far-right and the fascistic PNL political party. A key tenet of any fascist movement - and the PNL fascist movement is no exception - is palingenetic ultranationalism, a promised 'rebirth' and rejuvenation of the nation by looking backwards to return the country to a past glorious nostalgic 'golden age' of the society, grounded in culturally reactionary politics. Given that the Ancient Anjou peoples were the ancient cultural predecessors of the modern Purgation State of today, and existed within a period of classical antiquity lasting from around the 7^th Century BCE until around the 8^th Century CE which is often associated in the minds of many Purgations with a 'cultural golden age' filled with flourishing poetry, dramas, fashions, architectural wonders which are major tourist attractions in Purgatio today, ancient pottery, bronzeware, and silverware, artistic creations which remain important cultural wonders and attractions within all major museums in Purgatio today, it is only natural that implicitly associating the Mandatum Est religion of today with the deities and goddesses of an ancient pantheon associated with an 'artistic golden age' rooted in Purgatio's ancient past and history would provoke a kind of cultural nostalgia and 'harkening back' attitude that would command natural appeal to the fascistic far-right supporters of the PNL party and the Mandatum Est faith.

Additionally, although the doctrines of Ancient Anjous paganism and the modern day Mandatum Est faith are not interchangeable with one another, there are certain aspects of the two religious faiths which are quite similar and compatible with one another, which aided the cultural integration process. For example, Karioleur was often a symbol of maternal love, devotion, and fidelity, given her unyielding loyalty and faithfulness to her natural son, the God-Emperor Seviathane, displaying a nurturing motherly attitude towards him as well as to other members of the Imperial Household (despite his rather distant, removed, and lordly attitude to all of his family members) which stood in stark contrast to the vindictive horrors she would inflict upon the enemies and detractors of Seviathane which were similarly portrayed as bouts of maternal over-protectiveness. This Ancient Anjous notion that mothers had a natural innate tendency to furiously protect their naturally begotten offspring, irrespective of the circumstances, fit nicely into the Mandatum Est worldview that was rooted in social Darwinism and natural selection, the belief that human societies evolved through selection pressures and reproductive success, which would depend in large part upon biological parents protecting and nurturing their biological offspring with whom they shared a blood and genetic connection. Likewise, the myths of Elosthérenée often highlighted the randomness and capriciousness of human prosperity and fortunes, with the goddess bestowing sexual, economic, professional, and political success upon mortals for petty and frivolous reasons like how physically attractive they were or how much they had praised and flattered her, while destroying the same in other mortals for equally petty and frivolous reasons. This 'random lottery' depiction of human fortune blended nicely with the Mandatum Est belief in genetic determinism, the idea that most human attributes and abilities are the product of one's immutable and unchangeable genetic constitution and internal biology, which a person is born with from the very beginning as a result of a pure 'lottery of birth' which is similarly random, arbitrary, and capricious. Most importantly, the Ancient Anjous depiction of Porthiarâté as a terrifying goddess of death who particularly punished mortals who displayed an excess fear of death or a hubristic defiance of death, which demonstrated a nihilistic but respectful acceptance of death as a natural reality of the human existence which should not be feared or shunned, fit neatly into the Mandatum Est worldview of social Darwinism and selection pressures resulting in a 'winnowing' of the human species, promoting the best and the brightest through a natural process of competition for resources and the survival of the fittest, which naturally requires the least fit and least capable to perish along the way, thereby also accepting human deaths as a part of nature which should be embraced and not feared or shunned. Hence, there were clear cultural and ideological similarities between the worldview of the Ancient Anjous and the doctrinal underpinnings of Mandatum Est which aided the integration process.

Finally, the deification of the Mandatum Est religion and the incorporation of the three goddesses Karioleur, Elosthérenée, and Porthiarâté into the personified 'Trinity Goddess' of La Nature allowed the religion to be more comfortingly familiar to the average Purgation at the time by allowing the materialistic and non-theistic religion to develop ceremonial rites and rituals which could imitate and align with the outward aesthetics of many Purgation Catholic rites and rituals which the average Purgation would have been more accustomed to by that point in time. The concept of a 'trinity deity' would have been very familiar to those raised in Purgation Catholic households and brought up to believe in a 'trinity god'. Moreover, Purgation Catholic rites surrounding the worship of the Virgin Mary, Mother of Jesus, Queen of Peace and Queen of Heaven, were very intentionally rewritten and repurposed by the Purgation State in order to adapt the worship of the three goddesses of La Nature into a format that would feel more comfortingly and intimately familiar to the average Purgation, including the erecting of marble statues in holy sanctuaries, the writing of hymns and poems around the goddesses that could be chanted, whispered, or sung, the creating of artwork, murals, and iconography around the goddesses in styles similar to Catholic artistic depictions of the Virgin Mary, the erecting of shrines and holy spaces in honour of the goddesses which worshippers can plan pilgrimages to, and so on. Likewise, in keeping with the Purgation Catholic tradition of the veneration of saints, the Purgation State set aside religious holidays dedicated in honour of La Nature and the three goddesses that were avatars of Her divine essence, similar to how the Catholic Church creates a 'calendar of saints' and sets aside 'feast days' associated with certain particular revered saints. Saints are also ordained by the Church as the 'patron saint' of particular aspects of human life in the same way as each of the three goddesses are said to control a certain 'domain' of human existence and a facet of the natural world in discharge of the Mandate of Nature and the will of La Nature. The Media and Culture Ministry thus intentionally leaned into the deification of the non-deific Mandatum Est religion and designed their rites and rituals around that new religion in such a way that would actively promote a more psychologically seamless religious transition for the average Purgation convert who may have been raised in a Purgation Catholic household and grown up familiar with Catholic rites and rituals and who may not be furiously wedded to the niceties and minute details of Catholic beliefs and doctrines but may still feel more comfortable with a religion which imitates those outward aesthetic ceremonial aspects of the religion that they may implicitly associate with certain positive and nostalgic childhood and familial memories.

All of these reasons contributed to the personification of La Nature as a 'Trinity Goddess', the growing cultural association and 'syncretism' of La Nature with the Ancient Anjous goddesses of Karioleur, Elosthérenée, and Porthiarâté, and further contributed to the growing popularity and mainstream appeal of the Mandatum Est religion amongst the Purgation State populace more broadly, particularly from the 2000s onwards when this personifying and deifying cultural process truly began to take off and accelerate in its pace.

[Purgatio]

Founding Myth of the Burgondis (The Tale of the Vannageux War: Seviathane v Malheuse)

The Tale of the Vannageux War is one of the most culturally significant and enduring of the mythologies originating from Ancient Anjous pagan polytheism, and was immortalised by epic poets who wrote great works from the 7^th to 6^th Centuries BCE, including Abrexia's Fabuler ou Fantasmer, Lascitio's Samorix et Qhorieni, Orbissa's La Guerre des Cieux, and Bossence's Le Grand Siège, amongst other such works which have since entrenched that stirring mythological tale within the cultural landscape of even the modern Purgation State. The story is one of forbidden romance against all odds, of strong and unbreakable family ties enduring across oceans, of friendship and sacrifice, of heavenly wars and a groundbreaking clash of civilisations between two broad 'tribes' of peoples who arguably constitute the critical cultural and historical predecessors to two sovereign states in the world today. Hence, it is no wonder that the story has captured popular imagination and endures to this day even three thousand years after the events took place.

Before one begins to delve into the story of the Vannageux War itself, however, the origins of that conflict cannot be separated from the religious undertones of the mythology. Hence, one has to look into the story of the Ancient Anjous gods Seviathane and Malheuse, and how their never-ending conflict and friction inadvertently brought two civilisations to war with one another. This introduction is prefaced with two disclaimers. First, the Vannageux War is here being contextualised within the specific cultural context of Ancient Anjous pagan polytheism. Given the significance of the event to many cultures and civilisations, however, the Ancient Anjous cultural perspective on the war is not the only one to consider. In particular, the writings of the bards, poets, and writers from the Kurzakriori peoples and their cultural descendants today in, inter alia, Sondestadt, Velstrania, deserve separate consideration on another occasion, as it would be impossible to reconcile the contrasting religious and cultural portrayals of the Vannageux War within the Velstur religion as opposed to the pagan polytheism of the Ancient Anjous. Hence, this introduction is concerned solely with the latter cultural perspective.

Second, as far as historians and anthropologists are aware today, the Vannageux War was a real human conflict between the Vannages civilisation (so-called because the kingdom was centred around the capital city of Vannages) and over 300 independent and loosely affiliated nomadic and sedentary tribes that together fell under the broad cultural umbrella of the Kurzakriori peoples. Based on what can be gleaned from ancient writings and excavations of the historical city of Vannages, experts generally estimate that the conflict took place sometime in the 11^th Century BCE during the Bronze Age and shortly before the historic Bronze Age Collapse in which most literate civilisations in the region were plunged into a literary dark age in which no written works or annals are available, likely attributable to mass societal collapses that swept across the region in that period for the next couple of centuries. As far as historians can tell, what is generally agreed about the conflict, as a real life historical event, is that the Kurzakriori coalition of tribes crossed the Sea of Vasconia and laid siege to the coastal city of Vannages, before eventually conquering and sacking the city following a costly twenty-year-long siege, which destroyed and devastated the Vannages civilisation and left it in ruins. However, the Kurzakriori peoples do not appear to have benefitted from that victory as the Bronze Age Collapse followed soon thereafter, which may suggest that the conflict had negative ripple effects upon the regional economy which devastated all neighbouring civilisations, including the Kurzakriori tribes, or that the conflict depleted the energies and resources of the tribes so badly that it triggered a societal collapse back home, or there may be no cause and effect at all and the occurrence of the Bronze Age Collapse after the Vannageux War may be a mere coincidence of timing. Whatever the case may be, the other more embellished literary aspects of the conflict, including the love story between the characters, the familial ties which triggered a war, the war's inciting incident and catalyst itself, and certainly all of the mythological elements therein, were likely due to epic poets of the time taking artistic licences to dress up and aestheticise a historical event, through their own religious and cultural lens of the time.

With that, one should consider the origin story of the rival deities Seviathane and Malheuse, whose conflict and rivalry would come to set the stage for the Vannageux War. In the beginning, there was only One Realm, a mixed blended singular plane of existence, where the energies of deities and mortals stood side-by-side. The entire universe was shaped and moulded, inadvertently, by a callous and apathetic but almighty god known as Noëruss, whose magical and supernatural energies were so immense that his every waking move moulded the cosmos around him. The result was that existence itself was messy, chaotic, disordered, and in complete disarray. Elements could not take shape in a stable and secure form and were erratic and haphazard in their appearance, movement, conversion, and sudden disappearance. Organic life was shrunken, miserable, and deprived. Demigods and half-immortals would be produced at random, as hapless mortals were raped and the demigod descendants of Noëruss and his kin ravaged the world around them. Weather and climate were unpredictable, storms and hurricanes and floods and tremors and imploding portals and flashes of lightning and whirlpools would suddenly appear and disappear and appear again without warning. Noëruss was a god of a haphazard and somewhat artistic temperament, he would wake up one day and paint messy scrawls on a canvass or make pottery or clay or kick about the dirt and sand simply to entertain himself. It was from these random acts of artistic experimentation that all life came to be created by mistake - other deities, demigods, and all organic life, including humans - but that same chaotic temperament made for a chaotic world. Humans, in particular, lived miserable lives and were little more than cavemen beasts. Food was scarce because the chaotic elements meant the resources of the world changed and moved and shifted constantly. Water and clothes were difficult to come by due to the erratic weather. Demigods ran amok and frequently tormented hapless mortals, and the mortal women who were raped conceived more demigod offspring who would continue to run rampage across the realm, tormenting more humans and animals in the process. To the extent that human life existed, it was short, brutish, and miserable. Humans lived largely as solitary cavemen or, at most, in small groups of nomadic hunter-gatherers, trying to live off the land, fighting each other for scraps for what little food and resources were available to scavenge or forage on a world whose elements and climate were constantly changing and shifting every few seconds. And after their short lives ended, often violently, they would wander the face of this chaotic realm as forever weeping and shrieking wraiths and ghouls, their souls unable to find peace and rest in a realm so engulfed in mayhem and pandemonium as this.

It was in this chaotic and messy world that the future God-Emperor Seviathane would launch a fateful coup d'état that would change the shape of the universe forever. Seviathane was the older son of the almighty god Noëruss and his main consort Karioleur, whom the god forged from clay and plucked from the strings of energy of the cosmos itself. As he witnessed the chaos, misery, mayhem, and pandemonium of the universe, which was haphazardly rocked and ruined inadvertently every day by his almighty father's disordered artistic experimentations to amuse himself, Seviathane decided one day that enough was enough and decisive action was needed to establish a universe of order, balance, and harmony, where life could not only exist, but thrive and flourish to its fullest potential. To achieve this, he planned the first-ever and grandest coup in the world, known to the Ancient Anjous as Effacer l'Ardoise - literally, to wipe the slate clean. Seviathane instructed his younger brother and only full-blooded sibling, Xanthière, a talented forger, metalworker, and blacksmith, to forge a unique and powerful weapon, a blade so sharp that it could slice through the energy of a deity and scatter their energy and matter all across the cosmos. He waited for his father Noëruss to fall soundly asleep in his marital bed, next to his consort (and mother to Seviathane) Karioleur. He used the Blade of Xanthière to slice through his father's body five thousand times over, tearing apart the energy that bound his being together, and scattering his matter in every far-flung corner of the universe. Each swing of the blade was harsh, clean, and thorough, taking minutes each time. The god's body was so enormous, gargantuan, mighty, powerful, and filled with immense magnificent magical energies, that it took a whole week of Seviathane hacking relentlessly at the body of his father, to make certain that his every particle of matter was severed from every other. It did not take long for the siblings and relatives of Noëruss to learn of the vicious treachery of Seviathane and to rush over to exact their revenge. However, the now-widowed Karioleur, who was grieving the death of her husband and lover, the treason of her son, and traumatised at having to bear eyewitness to the first ever murder amongst the gods in history, made a fateful decision that would change the fate of the world forever. Seeing her husband's family rushing to exact their revenge on her son, Karioleur could not stand the thought of watching Seviathane getting hurt by them in any way. Using her supernatural powers over life itself, she caused a huge oak tree to shoot up from the ground, with the thickest and sturdiest trunk ever created, spanning over 10,000 metres in height and 5,000 metres in width, enclosing herself, her son, and her husband's wracked body, in the heart of that tree, allowing Seviathane to finish the job and hack at her own husband's body for a whole week without interruption or disturbance.

When the deed was done, and the essence and matter of Noëruss were scattered to the far ends of the universe, unable to be pieced back together for eons, Karioleur released herself and her son from the Great Oak to face the music. Many gods, goddesses, demigods, and half-immortals were shocked and horrified to learn of what Seviathane had done. Thirteen (13) of them in particular - most of them being the concubines, mistresses, children, and siblings of the slain Noëruss - were enraged at the treachery and demanded justice against Seviathane, his brother Xanthière, and his mother Karioleur, for their acts of treason against their lord and god. Seviathane, however, declared himself the God-Emperor of the World and the Universe, King of all the Gods and Goddesses, and declared that any who dared defy him would be made to suffer a thousand times over for their crimes. The Great Schism came to beset the immortal gods of this realm, some sided with the thirteen (13) deities who made up L'Ancienne Garde du Ciel - the Ancient Guard of Heaven - while a smaller number sided with Seviathane and his allies. Most tried to remain neutral or flee from the fighting, fearful of inviting the wrath of either side. And so began the Great War in history, La Grande Guerre des Colosses, fought primarily between the thirteen loyalists who wanted revenge over the murder of Noëruss and the five (5) gods and goddesses who wished to cement the great coup of Seviathane and entrench his rule over the New World he sought to create. The fighting was difficult, deities were bruised and bloodied, and it dragged on for over a thousand years, but by the end of it, Seviathane and his allies had won - in no small part due to the greater brutality, viciousness, and preparedness of his allies and the comparative decadence of the Ancient Guard deities who had grown lazy, decadent, over-indulged, overly comfortable, and pampered over the eons, having been all-too-reliant and totally dependent on the almighty protection of their lord Noëruss who was now unable to protect them. And so it was that Seviathane would seize the crown of victory and fashion himself into the superior almighty God-Emperor of the World and the Universe and of All Gods and Goddesses forevermore.

The first ever act of Seviathane was to cement his rule forevermore and to partition the One Realm into Five Realms, in a strict hierarchy that would bind each being to their allotted realm, unable to move between realms without his permission. At the very lowest rung, Seviathane would make a momentous decision that would cement his fearsome and tyrannical reputation into history. He carved out the terrible world of Akthûsoirix, a nightmarish realm designed for the sole exclusive purpose of physically and psychologically torturing any gods, goddesses, demigods, and half-immortals who were cursed by him into that realm forevermore. The new inhabitants of Akthûsoirix would be every single god, goddess, demigod, and half-immortal who fought alongside the defeated Ancient Guard of his father, and he threatened that any who dared to defy him would suffer the same fate. Tens of thousands of loyalists were tossed into this new realm, and would for the rest of their immortal lives suffer endlessly and perpetually, their hair would be torn out of their scalps by the sharp branches of magicked trees, only to grow back and be torn out again. Their skulls would be split open by strikes of lightning, heal, and be struck again. Their eyes would be pecked out eternally by vultures, only to heal and be pecked out again. Everywhere they turned, nightmarish apparitions would appear from every corner of this realm and torment and haunt the victims for the rest of their immortal lives. They would be forced to run and run for miles, never stopping or ceasing lest monsters maul their beings and eat away at their flesh. They would be tossed into rivers of blood as piranhas ate away at their flesh and bones only to re-grow and be devoured again. Acid rain would periodically fall from the sky and singe away their skin. Outcroppings of rocks would suddenly shoot up from the ground, so sturdy and sharp it would cut away at their legs, amputating their limbs, and for a brief moment, they would be able to stop running and get a short respite from their unending marathon, until their legs grew back and they would have to start running all over again. It was a tortuous and nightmarish realm. At the start of his reign, Seviathane let all the beings hear the terrible screams, shrieks, pleas, and begs emanating from this horrifying world, which boomed thunderously across all realms, and at once, every single god, goddess, deity, and half-immortal not tossed therein fell before his Imperial Throne, bowed before him, and proclaimed him as their King, their Emperor, their Master, and their Lord forevermore.

That would not be the end of his policy of deterrence, however. He asked his brother, Xanthière, to build a magical net capable of catching and scooping up the scattered energies of his father Noëruss, and all the thirteen members of the Ancient Guard who had been hacked away by his magical almighty blade during the gruelling civil war. He had his brother forge and bind together many huge chains spanning over 40,000 kilometres in length. His father Noëruss and all his relatives who had fought on his side would be re-formed and tied down with these chains right in the centre of his new torture realm of Akthûsoirix. There, they would suffer the terrible brunt of every horror this realm was capable of, which would be at its strongest at the realm's core. All the mindless beasts of this realm would congregate at the centre to break and paralyse the deities' bones, gnaw away at their flesh, gouge out their eyes, peck out their livers, burst and shatter every blood vessel they could find, and as they were immortal, these would re-grow and re-form within minutes and be destroyed all over again. An endless cycle of pain, torment, and agony, which the immortals would suffer for the rest of their existences. Such was to be the punishment for those who defied Seviathane's New World Order. He dubbed this campaign of terror tailler des haies et d'arbustes - to trim the hedges and the shrubs - for in his view, to make a new world that was stable and sustainable, he had to definitively clear out anything and everything from the old world which he had just overthrown, cut it out from the root and stem to ensure they could never grow up ever again, crush it so thoroughly and utterly that the brand new world he planned to make could never, ever be threatened.

With the torture realm of Akthûsoirix out of the way, Seviathane would forge the next two realms, reserved for mortals alone. First, the realm of all dead mortal souls, Nathyaka, intended to be a resting place for all deceased mortal humans and animals to find peace and rest after their demise. The realm was sub-divided into regions, some were paradisiacal and reserved for the noble, the good, the most capable of the humans who had distinguished themselves as lives in being. Others were tortuous - not as tortuous as Akthûsoirix, certainly - but intended to visit condemnation upon the mortal souls who had committed great crimes in their time alive. Most of Nathyaka would be somewhere in between these polar extremes, neither paradisiacal nor hellish, an uneventful resting place for deceased mortals to congregate and find their peace in the afterlife.

However, it is the mortal realm for the living where Seviathane made his most important reforms. He hated the chaos, disorder, and pandemonium under the neglectful watch of his father Noëruss. For years, humanity had suffered as cavemen beasts, unable to progress, form communities, do or achieve anything in their short, brutish, miserable lives, beset by changing elements, shifting weather, unstable environmental conditions, unpredictable natural disasters, demigods and half-immortals who ravaged their lands and raped and impregnated mortal women without warning. He wanted to replace that chaos with a world of order, stability, and harmony. He calmed the weather and the storms and created cycles and schedules for such events to occur, so that whirlpools or typhoons could no longer appear in one second and disappear the next, or self-imploding portals could not suddenly appear in one locale without warning and suck in everything around it in the world. He structured and organised the mortal realm, creating continents, areas for oceans, set the terrain for each part of the world, some mountainous, some deserts, some forested areas, and so on. He created the four seasons and organised times of the year when it would rain more and rain less, be hotter or colder. Most importantly, he calmed the physical elements so that matter would remain constant instead of ever-changing. Under Noëruss, everything from stone, water, fire, food, plants, sand, soil, would appear and disappear without warning, or change shape and element abruptly and suddenly, making it impossible for humans to do anything with these elements. By laying down rules for the physical and natural world, and calming and ordering the corporeal elements, structuring what objects would constitute what elements of matter, creating regulations for when objects could become other objects instead of these changes happening randomly (for example, water freezing into ice in freezing temperatures), humans finally had the stability, permanence, and order to make something of all these elements when they could not have done so before. And thus, Seviathane ushered in the Stone Age of humanity, a period when primitive humans could finally harness the element of stone to make tools for themselves, harness the element of fire to warm themselves at night and cook their food. Instead of humans being primitive beasts hiding away from a terrifying universe, constantly starving and thirsting naked, scared of the elements and the world around them, they finally had the chance to build communities, form hunter-gatherer tribes, eventually settling down roots and forming farming and agricultural communities, tilling and working the soil to grow crops which would have been impossible in the world of Noëruss when soil could turn into something else in a second and seeds and crops could simply disappear without warning. In this way, Seviathane's ordering and structuring of the rules of the physical universe ushered in humanity's development, allowing it to grow and thrive and form societies and civilisations. He christened this new segregated Mortal Realm for all mortal organic life as Impervoillée.

Next, he created the divine realm of Théquoislín, an intermediate realm for all of the other gods, goddesses, demigods, and half-immortals to live, separately and apart from humanity and the other mortals. This segregation would protect the mortal realm from being freely ravaged and destroyed and raped and tormented by deities far more powerful than themselves, while also controlling the population of demigods and half-immortals which had exploded exponentially over the years under Noëruss, in no small part due to out-of-control sexual assaults upon mortal women. Demigods and half-immortals would be able to make their own realm and society in Théquoislín, forming their own magical and fantastical communities therein. If they wanted to leave and join the mortal realm of Impervoillée, they would need leave to do so. Many would receive such leave in order to interact with humans and become part of their society or to help them build great wonders of the world and architectural feats, but even after they had left Théquoislín to mingle amongst the mortals in Impervoillée, they always knew that they acted under the watchful reign of Seviathane. If they did anything to displease him or disrupt the natural order of the universe he had ordained, depending on the severity of the violation, they could be banished back to Théquoislín either temporarily or permanently, or worse of all, they may become a new entrant into the nightmarish torture realm of Akthûsoirix down below.

Finally, at the apex of the hierarchy of the Five Realms stood the divine realm of Lucrèçis, the Imperial Realm, reserved exclusively for the Imperial Household. It was a protected sanctuary for the members of the Imperial Household so that they could pass laws and enact decrees and enforce the divine will of Seviathane upon all other realms without hindrance, molestation, or interference from any of the lesser realms. It was here that Seviathane would erect his Imperial Throne and Imperial Palace, the source of all his power and authority over the universe and existence itself. The only persons who could freely enter and remain in Lucrèçis were the members of the Imperial Household which, at the institution's inception, consisted of a grand total of only nine (9) members. Amongst these were the five (5) gods and goddesses who had fought on the side of Seviathane and his coup-plotters and led his followers and his armies during the last civil war which ripped the One Realm apart. These five were Seviathane himself, his mother Karioleur, his brother Xanthière, his sister-in-law Zhyhéxia, and his nephew Hôthélais. Also included were four (4) former members of the massive harem of Noëruss - consisting of over three thousand consorts, concubines, madames, ladies, and attendants - whom Seviathane had selectively picked out from that huge flock to form his Imperial Harem, which would consist of only four (4) members, his Consort Empress Réçavronuelle, and his three Imperial Concubines Elosthérenée, Côillèorîtha, and Ménuittes. This comparative selectivity was also intended as a symbol of the order, discipline, and rigour of Seviathane. His father Noëruss had bedded thousands upon thousands of women and fathered countless offspring, too many to count. In contrast, while Seviathane would no doubt take many informal lovers and mistresses in numerous mythologies, he would only ever father children from the four (4) members of the Imperial Harem, thereby restricting the size of the Imperial Household and preventing a chaotic situation where numerous inhabitants of Lucrèçis could all fight and squabble over power over that realm and proximity to and influence over his authoritative Imperial Throne. All other deities who were not in the Imperial Household would have to live in the realm of Théquoislín and could generally not enter the Imperial Realm of Lucrèçis except where they received leave from Seviathane to do so. This would be the case for deities and demigods who would serve as servants to the Imperial Household, or informal lovers and mistresses who would serve and service the sexual pleasures of Seviathane (but with whom he would never father children or form long-term relationships as they were not members of his Imperial Harem), and any deities who wished to trade goods or offer votives, sacrifices, and objects of worship to the God-Emperor Seviathane and his Imperial Household. Deities asking for leave to enter Lucrèçis to make supplications and indulge in rituals of effusive praise and adoration for the wonderful God-Emperor of the World and the Universe and of all the Gods and Goddesses and the Five Realms in person before His Blessed Imperial Majesty would, invariably, be granted leave to enter, perform these rites in his superior presence, and then immediately return to Théquoislín from whence they came.

Thus, a strict segregated hierarchy of realms was firmly established, from ascending to descending order of authority and importance, Lucrèçis at the top, Théquoislín next, followed by Impervoillée, then Nathyaka, and lastly Akthûsoirix at the very bottom. Those who resided in higher realms could generally travel (with some restrictions) to the lower realms and back, whereas those in the lower realms could generally never leave and enter into the higher realms except where Seviathane gave permission to do so. On an anthropological note, the distinction between the Imperial Household gods in Lucrèçis and all the other non-imperial deities in Théquoislín has been speculated by academics as having an interesting cultural origin amongst the Ancient Anjous. Due to the decentralised polytheistic nature of their religion, the faith and pantheon differed from city to city, civilisation to civilisation, tribe to tribe. As such, the 'Lucrèçisian Pantheon' consists of the gods and goddesses who are common in the mythos of all the Ancient Anjous peoples, whereas those deities who only existed in some localities and not others - and were consequently of lesser cultural importance to the region as a whole - were relegated within the world-building of their mythos to the hierarchically lower intermediate realm of Théquoislín instead.

Accordingly, Seviathane, qua God-Emperor of the World, the Five Realms, and all Gods and Deities, represents law, authority, order, hierarchy, and all structure, discipline, organisation, and harmony that exists throughout the divine, human, and natural universes, responsible for every rule and regulation that enables planned organised living and any stable, secure, and predictable form of existence. This mythology of Seviathane also demonstrates the cultural relevance of the polytheistic faith which doubled as a useful tool of social control and indoctrination, as kings and governors and military leaders across classical antiquity would justify their own rule on the same basis, and that the social harmony and organisation they provided was ordained by, and indeed flowed from, the God-Emperor Seviathane himself. Every literary protagonist needs a foil and antagonist, however, and within the Ancient Anjous religion that foil was the god Malheuse, an agent of mischief, trickery, scheming, and a somewhat subversive force for chaos, mayhem, and general disorder. It is important to note here, however, that Malheuse was never portrayed in an outright evil or malicious fashion, nor was he ever a villainous or wholly malignant force. He was an uncle of Seviathane, a younger brother of Noëruss (with 'brother' being a very loose turn of phrase here, as Noëruss and his siblings were all primarily birthed from the exact same consciousness-less energies and magical forces of the cosmos themselves), who was neutral and did not fight for either side during the last divine civil war of La Grande Guerre des Colosses. Hence, after the war was over, he, like all the other neutral deities, were placed in the intermediate realm of Théquoislín. He gathered quite a following there, becoming a minor lord over many of the deities there, due to his charisma and gregarious, magnetic personality. In the Ancient Anjous polytheistic religion, Malheuse was portrayed as the exact opposite of Seviathane in every way - chaotic, disordered, messy, haphazard, disorganised, impulsive, spontaneous, and a massive party-goer and party-planner, throwing huge raves and bacchanalian balls in the realm of Théquoislín, with flowing libations and alcohol in abundance. Malheuse was also notoriously independent and did not take well to following orders - hence, unique amongst the gods and goddesses in Théquoislín, he alone was not afraid to speak freely about how brutal and excessive, in his view, the actions of his nephew Seviathane were in the last civil war and his treatment of the defeated old guard loyalists in the aftermath. While most of the other minor deities and demigods were terrified of the God-Emperor and his torture realm of Akthûsoirix to say anything negative or critical about him, Malheuse frequently made such criticisms rather vocally at his many parties, nighttime raves, and mass social gatherings in Théquoislín.

It is crucial to note here, however, that while Malheuse was a foil to Seviathane, in terms of his character, beliefs, and personality, the Ancient Anjous mythologies never portrayed their relationship as a simple black-and-white 'good vs evil' conflict between the forces of virtue and the forces of malice. This is a common misconception borne out from cultural projection, as Abrahamic faiths and the Zoroastrian religion before them pioneered this relatively modern concept of a cosmic dualistic struggle between good and evil which would have been totally alien to most religious faiths which preceded them. Seviathane and Malheuse were never portrayed as black-and-white antagonistic rivalrous forces of good and evil, vice and virtue. Instead, it was more of a 'yin and yang' complementary relationship, with the strictness, order, and authoritarian tendencies of Seviathane being balanced against the freer, more liberal, more mischievous, fun, and impulsive personality of Malheuse, with the former representing order and harmony and the latter representing chaos and mayhem.

Hence, this also explains how Malheuse eventually became a member of the Imperial Household, notwithstanding his vocal criticisms of the actions of his nephew the God-Emperor Seviathane. The story goes that as Malheuse began to gather quite a following of increasingly disgruntled deities down in Théquoislín, who were drawn to his vocal remarks about the authoritarian and dictatorial tendencies of Seviathane and his brutal treatment of his former enemies down in Akthûsoirix, as he spoke aloud the words they were afraid to express, word reached Seviathane about this movement and he became increasingly concerned. In fact, while reluctant to consider it, Seviathane even contemplated the idea of tossing Malheuse down into the torture realm of Akthûsoirix as a deterrent warning to his followers to get in line - and when he did, this idea was actively supported and vocally championed by many members of the Imperial Household, including the brutal Crown Princess Porthiarâté (daughter of the Consort Empress Réçavronuelle and now the Queen of Nathyaka), the sycophantic and manipulative Imperial Concubine Elosthérenée, her youngest son the Imperial Prince Léodyrieux (notorious god of revenge, vengeance, retribution, and punitive justice, ennobled by his father into the Imperial Governor of Akthûsoirix empowered with total autocratic powers over that nightmarish realm and free to devise whatever sadistic tortures he pleased over all the inhabitants condemned thereto), and the Dowager Empress Karioleur (mother of the God-Emperor Seviathane and utterly devoted and loyal to her son and to the maintenance of his rule through any means whatsoever).

Others in the Imperial Household urged restraint, however, and feared that tossing his own uncle into Akthûsoirix could provoke a full-scale rebellion. The God-Emperor's brutalities in the immediate aftermath of the divine civil war could be overlooked by many deities, however discomfiting, because a millennium-long war had just been fought brutally, yielding a difficult victory and an unstable regime that needed to be secured. Tossing his uncle into the torture realm in a time of relative peace and stability, merely for espousing critical views of his methods, would be far more difficult for the gods to swallow. This view was championed by a smaller subset of the Imperial Household. The first detractor was Valéréteur, an Imperial Prince and the only son and child of the Imperial Concubine Côillèorîtha, god of music, poetry, prophecy, and the expressive arts, who was mainly concerned about the impact such a course of action would have on his father's image. The second set of dissenters were the God-Emperor's younger brother, Xanthière, the Grand Prince Royal and the god of architecture, engineering, ceramics, metallurgy, and forging, together with his son Hôthélais, the Grand Duke Royal and the messenger god of youth, friendship, joie de vivre, marathons, and athletic competition, both of whom disagreed largely for sentimental reasons, as both had had positive memories interacting with their uncle and grand-uncle Malheuse in the many years prior to the God-Emperor's coup d'état and did not want to see him suffer in pain and agony for the rest of his eternal immortal life.

The most vocal and persuasive detractor, however, was the God-Emperor's very own Consort Empress Réçavronuelle, who was the goddess of peace, justice, fairness, equity, harmony, and amity, a perfect match with her husband. In the Ancient Anjous religion, both Seviathane and Réçavronuelle represented a peaceful, stable, secure, and socially ordered and well-organised society and civilisation, but while Seviathane represented the more brutal and harsher side of the law, the punitive and deterrent side of a civilised order needed to keep dissenters and subversives in line, Récavronuelle represented the gentler and softer side of the law, rules to maintain justice and fairness, social cooperation with others to maintain peace and harmony between differing factions of a society, amity and concord rather than war, division, and internal infighting. Together, they complemented each other. Seviathane threatened seditious elements and would-be diversionary fifth columns with the brute force of the stick while Réçavronuelle presented the more tantalising carrot as an incentive for social cooperation. It was the Ancient Anjous belief that both sides were necessary for a stable society, they were simply two sides of the same coin of social harmony and cooperation, and so one could not function well without the other; hence, this is why Réçavronuelle was the one and only Consort Empress to the God-Emperor Seviathane, standing in a sort of 'yin-yang' complementary relationship with each other. She urged her husband to make peace with Malheuse, to strike a compromise with him and to bring him into the fold, as a stabler and securer means of maintaining his grip on the Imperial Throne through mollification rather than simple brunt force.

Seviathane was eventually persuaded and talked around by his Consort Empress, and over the objections of many members of the Imperial Household, he invited Malheuse up into the realm of Lucrèçis for a marathon round of negotiations and discussions. Eventually, a great peace deal was struck between the two deities. Seviathane would invite Malheuse to become the last and final addition to the Imperial Household, which grew to a total maximum size of seventeen (17) gods and goddesses in the 'Lucrèçisian Pantheon'. He would be given the title of Prince of the Blood and Imperial Governor of the realm of Théquoislín, ruling over that realm in the God-Emperor's stead, keeping its inhabitants happy, mollified, and appeased under his rule with parties, revelry, and debauchery. In return, Malheuse agreed to temper his criticisms of the God-Emperor, cooperate with and follow his rules, and abide by the traditions and conventions of the Imperial Household. He would be permitted free reign to vocally express his honest opinions about the God-Emperor to his face and in his presence in Lucrèçis itself, but not to the rabble down below in Théquoislín, lest he incite a riot, rebellion, or full-scale insurrection. Thus, Malheuse agreed to these terms and was formally accepted into the Imperial Household by Seviathane as an uncle to the God-Emperor and a Prince of the Blood.

The relationship between the two deities up in Lucrèçis was always a difficult and rocky one, but it was never portrayed as the vicious or embittered existential struggle between, for example, God and the Devil in Christianity, or between Ahura Mazda and Angra Mainyu in the older Zoroastrian religion. It was more of a rocky avuncular 'love-hate relationship' between two polar opposite personalities, with the playful, spontaneous, impish, and mischievous prankster Malheuse often grating on the nerves of his stern, serious, no-nonsense, impatient, easily angered nephew Seviathane. However, there was no bad blood between the two and the pranks of Malheuse were always forgiven by the other members of the Imperial Household at the end of the day, although naturally he got on better with some members of the family and less so with others. In one tale, Malheuse created a mirage and illusion of the Imperial Throne, causing Seviathane to sit down on the illusion and crash onto the floor with a thunderous boom so loud it caused earthquakes and tremors across the face of the mortal realm in Impervoillée. In another tale, he replaced the famous celestial dessert red wines of the Lucrèçis elite with a similar looking blended slush of red hot chilli peppers grounded into a liquid pulp, causing many members of the Imperial Household to unknowingly gulp down the spicy makeshift beverage at a party and spit fire at the dinner table which burnt down the Imperial Palace and caused volcanic eruptions that covered the human world of Impervoillée in soot and ash. These mischievous pranks were generally embarrassing and harmless - at least, for the godly denizens of Lucrèçis, less so for the mortals in Impervoillée - and were generally forgiven by the God-Emperor Seviathane eventually, although he would often be reprimanded and punished with a brief exile back to the lower realm of Théquoislín or, if the act was severe enough, even down to the mortal realm of Impervoillée instead. Nevertheless, it never permanently damaged his relationship with his nephew Seviathane, and at most caused annoyance and irritation as opposed to hatred and contempt.

There was one pivotal bout of mischief by Malheuse, however, that would inadvertently spark the onset of the devastating Vannageux War that would topple the first of a row of dominos leading, eventually, to the downfall and destruction of two great human civilisations in the Bronze Age. In this myth, the God-Emperor Seviathane invited all the top socialites, celebrities, politicians, vassals, and minor lords of Théquoislín 'high society' into the highest realm of Lucrèçis for the Imperial Ball - an annual celebration of the Imperial Household's greatness and an excuse for partying, dancing, and drinking away between all the crème de la crème of the immortal world. As usual, Malheuse was placed in charge of planning the event, arranging the music, the raunchy entertainment, and the free-flowing libations. To amuse himself, however, he wanted to cause some drama and commotion at the event itself. He learnt from an ally down in Théquoislín that a minor half-faery half-immortal called Deimois had his eye on the ravishingly beautiful Imperial Princess Iseulde, the only daughter of the equally beautiful and alluring Imperial Concubine Elosthérenée. The young Iseulde was known to have particular and exquisite tastes, as the patron goddess of fashion, perfumes, jewellery, spices, silks, trades, antiques, all visual and graphic art forms, and all maritime trading more generally as the goddess of the oceans and the high seas. Malheuse disguised himself as a gossip-monger and went down to Théquoislín, and began circulating a rumour that eventually reached the ear of Deimois that the Imperial Princess Iseulde was looking for an extremely rare and exotic Anatolian perfume known as Zidantilar, said to have been invented by a Hittite artisan who made no more than five bottles of this particular brand, only one of which was imported into the world of the immortals by a demigod lover he gifted the bottle to. All of these were lies and a complete fabrication, but the story was vivid and captivating enough that all in Théquoislín believed the enchanting tale, including the smitten Deimois who decided he had to find this famed Hittite perfume of Ancient Anatolia.

He eventually tracked it down to a small shop in a crowded marketplace in Théquoislín, manned by a shopkeeper who was a friend of Malheuse, which the mischievous Prince of the Blood planted for this purpose and led the unwitting lover to her with a string of deliberate rumours like a trail of breadcrumbs. Deimois bought the perfume for practically half his fortune and gift-wrapped it nicely, sending it upwards to the realm of Lucrèçis with a love note attached thereto, signed off by the half-faery half-immortal Deimois. Although Iseulde was not actually looking for an Ancient Anatolian perfume, she did find the perfume very fragrant, contained in a beautiful and exquisite looking bottle, hence she kept it and decided to wear it as and when she pleased.

Although the perfume was indeed fragrant and aromatic, it was also enchanted by Malheuse. He knew that the vain and discerning Imperial Princess had an extremely special dress that was in the works and intended to be reserved for a very special occasion - namely, the upcoming Imperial Ball. Indeed, she went down to the mortal realm of Impervoillée and seduced the king of the royal Shan Dynasty, and persuaded him to order over a hundred of the royal seamstresses to work for years and years designing, planning, and sewing together one of the softest, finest, and most elegant silk gown they had ever produced, which would be ready only on the date of the Imperial Ball itself. The beautiful Iseulde wanted to have the most exotic, unique, and elegant look and appearance at the Imperial Ball that no other deity or goddess would be able to compare herself to. When the date of the Imperial Ball came, Iseulde had the dress delivered up to Lucrèçis by a number of huli jing fox spirits in Ancient Ruanyang, hiding the silks so none would see the dress until Iseulde herself debuted it in all its exquisite glory before all of godly high society at the Imperial Ball. It is said that when she saw the silk dress unveiled for her in her dressing room, she wept with joy, overcome by the exquisite beauty of what she saw before her, flowing gossamer-thin silks so fine and so gentle they were softer and smoother than any fabric she had ever seen or felt before, with creative patterns sewn in by hand with an artist's careful eye. She put on the dress an hour before the ball began, doing up her hair into a magnificent coif, and finally, the enchanted perfume.

Once the perfume was sprayed all over her body, the energies spread all over her skin, her body, and finally, the woven fabrics of her long silken dress. It copied, reproduced, and memorised every intricate sewing and weaving of the dress, and invisible to the eye of Iseulde, it floated off of her dress into the air, forming into a magical scarab that whizzed out of her room and approached its master, Malheuse. The scarab fed him all the information it had obtained about the secretive dress of Iseulde, and the mischievous god was pleased to hear all the pieces of his prank were falling nicely into place. When the Imperial Ball began, all the members of the Imperial Household came out in style, showing off their outfits or grand entrances. Last to arrive would be the God-Emperor Seviathane and his Consort Empress Réçavronuelle, but the Imperial Princess Iseulde negotiated with her imperial father for her to be the second-to-last entrant who would arrive with her stunningly exotic dress just before them. Before she arrived, several other members of the Imperial Household would come before her, including the Dowager Empress Karioleur, the Imperial Concubine Côillèorîtha, and the Imperial Princess (daughter of the Imperial Concubine Ménuittes) Mireisgôt, each of them stunning and beautiful in their own way, with their specially tailored dresses. Then came the time for Iseulde's grand entrance, but just as she entered onto the stage for all of godly high society to behold her stunning and special dress, Malheuse sent out his scarabs to cast an enchantment upon the goddesses Karioleur, Côillèorîtha, and Mireisgôt, and behold, each of their dresses transformed before the eyes of all into exact copies and replicas of the stunning dress of Iseulde, and all of them applauded and cheered for the silk dress's gorgeous and exquisite appearance, before Iseulde could make her entrance.

Once she realised she had been upstaged and saw the replica dresses, she broke down into tears in utter humiliation, crushed and devastated at having had the big moment she had been dreaming of for months shattered before her eyes in one fell swoop. She ran to her dressing room, tore her beautiful dress into tattered pieces, and screamed long into the night for the whole party, distraught, and refusing to leave no matter how many times her family pleaded for her to calm down and step out. Before she left for her room, she screamed at the three goddesses who were wearing replicas of her dress, calling them liars, cheats, and filthy pathetic plagiarists who 'stole' her dress and her idea because they had 'not a single original thought in your empty wooly little heads'. Her mother, the vain and narcissistic Imperial Concubine Elosthérenée, and her over-protective older brother, Vélmuzaïs, god of war, carnage, and bloodshed on the battlefield, were enraged at what had been done to Iseulde, and as they were unable to coax her out of her room, their rage grew and grew, and naturally they lay the blame at the three goddesses who had copied and plagiarised her silk dress and stolen her idea to steal her big moment. They returned to the Imperial Ball below, and Elosthérenée cursed Mireisgôt with a contorted and distorted facial appearance and a bloated belly, until all her hair greyed and fell off in clumps and she looked like an ugly old hag on such a grandiose night, while an enraged Vélmuzaïs whipped out his sword and sliced off Côillèorîtha clean into two by her torso, and approached the Dowager Empress Karioleur, swinging his sword in the air and threatening to decapitate her for her wicked scheme. The Dowager Empress quickly dissipated to escape and warn her son of the commotion, while the Imperial Concubine Ménuittes and her son the Imperial Prince Brésivaît (twin brother of the cursed Mireisgôt) immediately intervened, as Ménuittes threw a couple of well-aimed magical bolts right at the enraged warrior Vélmuzaïs when he was not facing her, knocking him out unconscious. The hot-headed Brésivaît, however, was the fuming mad and easily enraged god of the sun and of fire itself, and he let out a stream of all-consuming heavenly fire which burnt and singed off the skin of both Elosthérenée and her son Vélmuzaïs, and could not and would not stop until the flames grew so big they began spreading across the Imperial Palace, burning up thousands upon thousands of the deities, demigods, and half-immortals present, until the throne room was left in utter chaos, mayhem, and pandemonium, and gods and goddesses were screaming their heads off desperately tripping over each other and shoving others out of their way, desperately trying to escape the room before the growing flames consumed their bodies and burnt away their flesh.

The pandemonium only ended when the God-Emperor Seviathane arrived at the scene with his Consort Empress Réçavronuelle and the Dowager Empress Karioleur, who went to warn her son of the commotion so he could arrive just in the nick of time. He used his powers to put out the flames immediately, heal all the damaged and injured gods and goddesses, undo whatever curses and spells had been inflicted in the meantime, and cancelled the festivities of the Imperial Ball, sending all the lesser deities back down to Théquoislín so he could sort out the mess amongst the Imperial Household alone. When the God-Emperor spotted his impish and mischievous uncle Malheuse sniggering under his breath in the corner of the room, witnessing the pandemonium play out before his eyes more chaotically and messily than he had imagined, he immediately suspected that he was to blame. He had his younger brother the Grand Prince Royal Xanthière tie up Malheuse in magicked chains that weakened him and drained him of his powers and had him dragged before his Imperial Throne to face judgment. He gave Malheuse a chance to confess his crimes, and when he did not, he questioned the Imperial Princess Iseulde and asked her to describe all the events leading up to her wearing of her Shan dynasty silk dress. The moment she mentioned the mysterious Anatolian perfume she received from Théquoislín, the God-Emperor grew instantly suspicious and demanded that she bring the perfume to him. The Consort Empress Réçavronuelle performed a tracking spell on the perfume and immediately detected her uncle-in-law's magical signature all over the perfume's enchantments. Now caught, Malheuse revealed his scheme from beginning to end, and the ire of the entire Imperial Household was now upon him for his prank which, in the family's view, had clearly gone too far and caused immense damage to so many of them.

As the patron god of law, discipline, and order, the God-Emperor Seviathane immediately began doling out his punishments. The Imperial Concubine Ménuittes had knocked the Imperial Prince Vélmuzaïs unconscious with her spells. However, the God-Emperor found her innocent of all wrongdoing as she was only trying to defend the family and prevent him from doing further harm. No punishment was inflicted on her. As for her son, however, the Imperial Prince Brésivaït, he may have been trying to avenge the curse that had befallen upon his twin sister Mireisgôt, but he went way too far in starting a magical fire that burnt away the courtyard and living room of the Imperial Palace and left so many of their guests charred and incinerated. In light of the extenuating circumstances, the God-Emperor ruled that he would be suspended from the Imperial Household and stripped of his titles for twenty-seven years, three months, and fourteen days. He would be allowed to remain living in Lucrèçis in that period but only on the God-Emperor's leave, for as he was not in the Imperial Household in that time, he had lost his automatic right to remain in that realm. As for the Imperial Concubine Elosthérenée, for inflicting a disfiguring curse upon the Imperial Princess Miresgôt that resulted in the distortion and mutilated alteration of her appearance into an ugly form, the God-Emperor suspended her from the Imperial Household, stripped her of her titles throughout that suspension, and temporarily exiled her from Lucrèçis to the lesser realm of Théquoislín for thirty-eight years, ten months, and eleven days. Her son, the Imperial Prince Vélmuzaïs, however, had gone even further, slicing off the Imperial Concubine Côillèorîtha by her torso clean into two and threatening to decapitate the Dowager Empress Karioleur with his sword before she swiftly fled his blow. For that abhorrent crime, he too would be suspended from the Imperial Household, stripped of his titles during his suspension, and temporarily exiled from both divine realms of Lucrèçis and Théquoislín, thus having to live in the mortal realm of Impervoillée for sixty-six years, eleven months, and twenty-eight days.

Of course, the most culpable of them all was Malheuse himself, who had been responsible for the whole mess to begin with. A vocal minority of the Imperial Household called for the worst possible punishment for him - permanent condemnation to the torture realm of Akthûsoirix for the rest of his immortal life. The God-Emperor did not go that far. Instead, Malheuse would be suspended from the Imperial Household, stripped of his royal titles in that time, and temporarily exiled from Lucrèçis and Théquoislín for a very long period of time: three hundred and eighty-seven years, ten months, twenty-two days, and nineteen hours. In addition, for that entire stretch of time, Malheuse would be condemned to perform an unending community service on the deserted barren archipelago of Kaal-zerney, a series of backwater islands in the Sea of Vasconia devoid of any natural resources and cursed with a particularly inhospitable climate, constantly beset by numerous storms, floods, and torrential rains, with only a small handful of scattered hunter-gatherer tribes who would now be under the protection and watch of Malheuse. It would be the job of Malheuse to atone for his crimes by safeguarding and assisting the tribes on Kaal-zerney however he could, and he was sternly warned that if he failed to dutifully perform his community service well to the best of his ability, his exile and suspension would only keep growing in duration.

Over the next two centuries or so, Malheuse would use his magical powers to gradually build up the Kaal-zerney archipelago as a safe haven for pirates and looting and plundering on the high seas by corsairs from both the native inhabitants of the Kaal-zerney isles and talented seafarers from all over the world eager to rob and hijack the wealth and riches of regional maritime trading. Small but thriving 'pirate states' began to emerge on Kaal-zerney under the careful watch and stewardship of the mischievous and impish Malheuse, and across the Sea of Vasconia pirates would attack merchant ships at random, loot and plunder them for their valuable riches and goods, torture any soldiers or bodyguards that attempted to resist or fight back, and sell all the ship's inhabitants into slavery, before fleeing back into the 'pirate havens' of the Kaal-zerney archipelago. The Kaal-zerney pirates became incredibly rich from their lucrative looting on the high seas, and they would strike abject fear and terror into all merchants and traders due to their famed barbarity and infamous cruelty in the extreme lengths they would resort to in torturing their victims to deter any resistance, including pulling out the tongues of their captives, chopping off the hands and feet of their victims, and even boiling some of them alive, but the biggest source of wealth for them was the growing slave trade, which was a highly profitable enterprise at the time. The Kaal-zerney pirates would raid merchant ships and conduct slave raids on coastal towns and cities along the Sea of Vasconia, abducting as many hapless civilians as they could get their hands on to sell them into slavery all over the world. These slaves suffered a number of terrible fates. Some would become galley slaves tied down and forced to row on merchant or military vessels for the rest of their short miserable lives. Others would be sold into plantation slavery in the decadent and highly-feudalised and stagnating Asphenium Empire. Others would become slave soldiers and warrior thralls within the expansionist and militaristic Cyanean Ascendancy. Others - especially women, girls, and underage boys, whom the pirates deemed conventionally attractive - would be sold into sexual slavery, forced into the huge Royal Harem of the Great Shah of the Izmirian Shahdom. Still others would find themselves being castrated and sold as eunuchs into the Ruanyang Imperial Paramountcy or forced into the enslaved armies of the various princely rajas warring away with each other in the decentralised, ever-divided Vasumitran Maharajahnate.

[Purgatio]

The coastal cities and towns of the continent of Valsorkenyi (on which the modern nation of Velstrania may be found), Sonoratia (on which the modern nations of Woodstovia and Celeria are situated), and the continent of Villalmeyda (on which the modern nation of the Purgation State and her Occupied Territories are located) which face the Sea of Vasconia became particularly attractive and frequent targets of these Kaal-zerney pirate slave raids, and the inhabitants lived their lives consumed by fear of the ever-looming threat of falling victim to the senseless terror and kidnapping of merciless pirates who cared little for the suffering of their captives and cared only about their ability to profit from the burgeoning regional slave trade. One of these infamous pirates' raids was on the coastal city of Leikaia, in which the eldest son of a Kurzakriori chieftess, the young Qhorieni, happened to be sojourning through the town and staying at a small inn whilst he was on the way back home to his family from his recreational travels across the major towns and cities of the Valsorkenyi continent, consumed by his inquisitive spirit and the endless wanderlust in his heart. The wide-eyed and ever-curious young man was caught up in the Kaal-zerney pirates' raid on the town, and while he took up his sword and he fought valiantly to try and defend the innocent townspeople of Leikaia, it all came to naught when the pirates quickly overwhelmed the town's minimal defences, burned the entire locality to the ground, torching homes and shops as they slaughtered over 360 men in the fighting, and proceeded to capture and enslave the entire town's population of over 3,000 inhabitants - including the young Qhorieni.

When Malheuse learnt that the eldest son of the Kurzakriori chieftess Nirsiinae, the famed chief of the militant warrior tribe of the Berjasli and one of the most fearsome, powerful, and capable warriors and fighters amongst all the hundreds of Kurzakriori tribes, had been kidnapped and enslaved by the Kaal-zerney pirates, he spied an opportunity to concoct more mayhem and pandemonium in the mortal realm of Impervoillée, and practically leapt at the opportunity to sow more chaos and discord in the region and watch the drama unfold. He appeared to one of the few runaways who had managed to escape the sacking and looting of Leikaia and induced her to flee into the heartland of the Valsorkenyi continent, until she stumbled upon the territories held by the various Kurzakriori peoples, commonly known as the Kurzakziortrenya region - roughly proximate to the modern day locality of Nuie-Velstur. There, the runaway began to seek refuge in various inns and taverns, and began spreading the word that one of the victims captured in the raid on her hometown of Leikaia was none other than the young Qhorieni, eldest son of the warrior chieftess and the famed and valiant fighter Nirsiinae. Word quickly reached the ear of the chieftess Nirsiinae, who grew incandescent with rage and utterly consumed with grief, having not seen her son for years and already fearing the worst for his safety, her worst fears were now confirmed, and within her soul warred the conflicting urges to rescue her boy and also to inflict terrible vengeance upon the ones who had kidnapped him. Malheuse conspired to stoke those flames further. He found a young girl amongst the Kurzakriori peoples who was also his demigod daughter, Zankruvil, who was born to an ordinary tavern wench in Kurzakziortrenya when he took the disguise of a bull and reproduced with that mortal woman through trickery and subterfuge (under less than entirely consensual circumstances). Zankruvil was only a young teenager at this time and worked as a waitress in a local inn, but she was very bright, politically savvy, talented, charismatic, and very persuasive. She was also a brilliant fighter and swordsman and was very skilled with a spear on the battlefield. When her divine father Malheuse appeared to her in a dream, he prophesied that she would found a great warrior tribe and become the head of a mighty and powerful clan in Kurzakziortrenya one day and her name would be immortalised into history forever. To do so, she would have to unite over 300 of the scattered Kurzakriori tribes into one great coalition of fighters and warriors to embark on a military adventure that would bring great glory and honour to them all. The young and ambitious Zankruvil found herself drawn to the allure of her divine father's prophecy, and within her stirred a great passion and dream to find some event or catalyst for a great alliance of the Kurzakriori tribes for such a grand purpose, whatever that purpose may be.

Meanwhile, Malheuse would implement the next step of his plan, by creating a mirage and apparition which drew the Kaal-zerney pirates who had kidnapped the young Qhorieni and the over 3,000 new slaves looted from Leikaia over to the huge and thriving ancient civilisation of Vannages, situated along the coastline of Villalmeyda, in modern day Purgatio. Vannages was one of the wealthiest cities in the region and had become the royal capital of a great kingdom due to the wealth it generated from being an epicentre of maritime trade around the Sea of Vasconia. Exotic gooods like fine silks from the Ruanyang Imperial Paramountcy, spices from the Vasumitran Maharajahnate, rugs and pearls from the Izmirian Shahdom, flowed into Villalmeyda to the south and to the east of Vannages, flowed into the city overland and were exported overseas from the great ports of Vannages. Likewise, ships with fine goods and exotic wares headed to and fro the great civilisations across the Sea of Vasconia, like the Cyanean Ascendancy to the south, the Asphenium Empire to the north, and the Celasvarii feudal clans of the northwest, docked at the ports of Vannages to load and unload goods, repair their ships and resupply for the maritime journey ahead. The great navy of the Vannages royal family protected merchants in the general area from pirate attacks and hijacking within Vannageux maritime waters. In exchange, merchants paid taxes and customs duties to the Vannages royals in exchange for their protection, and so the royal coffers of the Vannageux civilisation flowed richly with gold, silver, and great treasures from abroad. Malheuse cast a spell on the spires of the royal palace in Vannages, which glittered and glimmered like gold, drawing the greedy eye of the Kaal-zerney pirates. As they sailed closer to the coastal city, their hearts sank at the sight of the city's huge protective walls, massive fortifications, and the royal navy patrolling the shores. However, Malheuse whispered poisoned barbs of temptation into the pirates' ears at night, persuading them that they stood a better chance of profiting from the city's massive wealth if they sold their slaves to the Vannageux royal family instead of trying to raid the ports and harbours thereat.

The pirates agreed, and as they sailed into Vannages, they requested an audience with representatives of the Vannages royal family under the dynasty of Axtrolena which had reigned over the Vannageux civilisation for centuries. Upon meeting the Axtrolena royal envoy, the pirates sold over 300 captured slaves to the Vannages royal family - including their prized prisoner, the young and handsome chieftess's son Qhorieni - for the Vannageux court to prepare an upcoming festival in honour of the patron goddess of the city of Vannages, i.e., Porthiarâté, the Lucrèçisian goddess of death and destruction. The Vannageux civilisation believed, in accordance with the pagan polytheism of the time, that Porthiarâté was a cruel and sadistic goddess, but could be fiercely loyal and protective over those mortals whom she favoured and considered to be under her wing. As she was the goddess of drought, famine, plagues, pestilence, and war, Porthiarâté was believed to hold incredible power over death itself, which could be rained down upon the enemies of her followers while sparing those she considered to be on her side. Hence, the city of Vannages held an annual festival in her honour, which featured ritualistic sacrifices, including animal sacrifices, the disembowelment and dismemberment of livestock, human sacrifices, ritualistic abortions, non-lethal cutting and bloodletting, the bloodied flaying and whipping of prisoners, and perhaps the most eye-catching part of the ceremony to modern historians, the altar sacrifice of babies and infants. The sources of the Vannageux human sacrifices were varied, some were prisoners and convicted criminals, others were vagabonds, wanderers, or indigent vagrants and layabouts who failed to pay their debts or their taxes to the royal family or their enforcers and tax-collectors in the nobility, others were captured prisoners of war, and of course, a substantial proportion of the human sacrifices - especially the infants and young children - were slaves purchased from pirates and slave-raiders. It was believed that the healthier and fitter the sacrifices were, the more it would please and gratify the city's cold and cruel patron goddess Porthiarâté, who would look even more favourably upon their city as a result, allowing the trade and wealth of the city to keep on flowing unhindered by her death, destruction, and demise.

The chieftess's son Qhorieni would avoid that terrible fate, however, by a sudden stroke of luck. The young princess in the Axtrolena dynasty, Princess Samorix of Vannages, noticed the fair, delicate, and handsome features of the young man the moment the priests and clerics brought the purchased slaves into the royal palace to be locked away in storage facilities in the altar room, in preparation for the next festival to Porthiarâté. She was smitten by the young man's charming face, flowing hair, and elegant good looks, and would sneak into the altar every night when her family were unaware to ask the young man questions about his life, his family, where he came from and how he ended up in the city of Vannages. Princess Samorix came to care for him and fall head over heels for the young Qhorieni. In the Ancient Anjous literary works of great epic poets like Abrexia and Lascitio, their stories generally depict a whirlwind epic romance between Qhorieni and Samorix, with both young people falling for each other and yearning and pining for each other despite their cultural differences and the difficulties of their circumstances. In contrast, amongst the Ancient Velsturmanyi writers, the picture is more mixed, with some depicting the couple as being in love and others depicting Qhorieni as a helpless victim, a captive and a prisoner with no control over his circumstances and no reciprocated feelings for the Vannageux Princess.

Whatever the case may be, the Princess Samorix told her parents, King Erenn and Queen Genoseza of the Axtrolena royal family, of her desire to wed the young Qhorieni. Her parents were scandalised at the idea, and her older brother, Prince Carmanos, was outraged both at the idea of his sister marrying a foreign tribesman from across the Sea of Vasconia and also the sacrilege of marrying a man intended to be sacrificed to the terrifying goddess of death, destruction, and the underworld, the cold, pitiless, unforgiving Porthiarâté. The royal family had the young Qhorieni brought up to the throne room, and both King Erenn and Queen Genoseza were impressed with the young man's beauty and good looks and wondered if he would make a good addition to the royal family. However, in order to not anger the goddess Porthiarâté, they ordered the clergy in her cult to slaughter ten beggars and ten street prostitutes in their temple to seek the permission of the goddess to proceed with the plan, and also brought a prophetess and soothsayer from her holy temple to be present during the ceremony and intercede on the goddess's behalf.

It was here that Malheuse is said to have played a terrible trick upon the Axtrolena royal family. Wishing to cause more mayhem and pandemonium as the god of mischief and chaos, and also seeking to get revenge on his nephew the God-Emperor Seviathane for banishing from the divine realms and cursing him to an extended exile in the mortal world by playing a prank on his youngest and most favourite child, the one and only Crown Princess Porthiarâté, Malheuse believed it would be funny if the Crown Princess were somehow tricked and deceived into unwittingly contributing to the downfall of her favourite mortal city and civilisation, Vannages, home to the highest quantity and quality of human sacrifices made in her honour. To achieve this, he impersonated the form of a demon and snuck into the underworld of Nathyaka, which Porthiarâté ruled over as the Queen of Nathyaka. In disguise, he pretended to be a messenger and a courier delivering a message to the Queen, claiming to be passing along a holy prophecy from her father, the God-Emperor Seviathane, which had to be relayed to the Axtrolena royals in Vannages, otherwise the Vannageux civilisation will face swift and sudden destruction and the downfall of their entire society. Porthiarâté was eager to avert the downfall of a royal dynasty so dedicated to her worship, praise, and adoration; thus, she swiftly delivered the prophecy she believed to be from her father over to the prophetess in the Vannageux royal court. To speak a prophecy is a holy and sacrosanct act, rendering it impossible for a faithful and dutiful prophet to truthfully speak a prophecy during a religious ceremony that will not come true. Hence, Malheuse had to word the prophecy in such a way that it was both technically true but also liable to mislead the Axtrolena royals. Thus, the prophetess opened her mouth and prophesied as such: The heart of Samorix doth pine for most fair locks and looks divine; but lo, an ancient foe shalt rise to snatch her prize from her bosom blessed. Where lovers' lips caress and nuptial vows doth profess none other, the Divine Daughter's grandest city shalt for all eternity endureth! But hark ye all, avert thine eyes whence clasped young palms canst be untwined, wherein those high great walls of fine and fair Vannages shalt be no more! No more, no more, no more, mere ash and dirt and soot forevermore!

King Erenn and Queen Genoseza both interpreted the soothsayer's prophecy in the most intuitive way - namely, that it meant that if Princess Samorix were separated from her lover, Qhorieni, the Vannageux civilisation would fall and be destroyed, whereas if the young lovers were kept together, the Vannageux civilisation would endure and remain. With that, the royal couple approved the wedding, and even the Prince Carmanos reluctantly and begrudgingly approved the match, still unhappy about the new entrant into the royal family but not wishing to defy the declared will of the gods. Accounts differ on what happened next. In most of the Ancient Anjous accounts, Qhorieni was freed and emancipated from his enslaved state, given Vannageux citizenship, and married Princess Samorix in a grand royal wedding ceremony that enthralled the whole city of Vannages in a huge celebratory affair, effectively becoming a full-fledged member of the Vannageux royal family. Many Ancient Velsturmanyi poets and dramatists portray the story quite differently, with some depicting Qhorieni as holding the legal status of a chattel slave and being forced to marry the Princess Samorix against his will. Others depict Qhorieni as being only a second-class or inferior member of the royal family, still others go further and write that instead of marrying Princess Samorix, he was simply gifted over to her as her new property and chattel, becoming an effective sex slave for her benefit whilst she went on to wed a Vannageux nobleman while keeping Qhorieni in her possession to toy with on the side, while others write that he was freed and emancipated in name only but for all practical purposes still retained his subordinate and subservient role as being under the thumb and complete control of the Axtrolena dynasty and therefore in no real position to refuse their order to marry the Princess Samorix. Whatever the circumstances may have been, most (although not all) literary accounts are generally agreed that Qhorieni and Samorix did indeed wed and become husband and wife.

Back across the Sea of Vasconia, on the continent of Valsorkenyi, the news would reach the ears of the great chieftess Nirsiinae that the Princess Samorix of Vannages married a new man, a foreign stranger from across the Sea of Vasconia, a young Kurzakriori man by the name of Qhorieni, and she would fly into an even greater incandescent rage than before. To her mind, this was confirmation that her son was a captive, a prisoner, and a slave being forcibly betrothed to the Vannageux princess against his will. Another in the Berjasli tribe, however, would be outraged by the news. He was a young and handsome Kurzakriori tribal warrior by the name of Rolinavasa, and one of the most skilled and competent fighters and warriors in Nirsiinae's fearsome army. In some accounts, Rolinavasa is a cousin of Qhorieni, in others he is a close childhood friend who grew up with Qhorieni and had a close relationship with him, and in others Rolinavasa is portrayed as a lover who had been in a sexual and romantic relationship with Qhorieni before he was kidnapped and disappeared, hence his distressed reaction to the news in such versions of the tale doubled as a heartbroken reaction as well. Both Rolinavasa and Nirsiinae swore a holy oath that they would do whatever it took to sail across the dangerous and treacherous Sea of Vasconia to rescue young Qhorieni and bring him back to his family and people. However, to do that, they would need a much larger army in order to defeat the great Vannageux civilisation, lay siege to such a rich maritime city, and tear down their high walls and military fortifications, as there were over 300 different and distinct Kurzakriori tribes living in Kurzakziortrenya, and the Berjasli people alone only commanded under 10,000 warriors. Thus, they set out plotting to form a 'grand coalition' of as many Kurzakriori tribes as they could possibly rally and amass together to fight as one and set sail for the city of Vannages as one.

To do this, they would need the help of divine intervention, given that the different Kurzakriori tribes had warred and battled with each other for centuries over land, resources, martial glory, and other inter-tribal rivalries. Thus, Malheuse would take the form of a wise old sage and appear in Kurzakziortrenya, appearing to his demigod daughter Zankruvil to urge her to fulfil her destiny as a future head of a mighty clan whose name would be immortalised in her people's history. To achieve this, he prophesied that she would need to carve out her name in glorious battle and combat on the continent of Villalmeyda, spilling blood on Vannageux soil by waging war upon one of the richest and greatest civilisations in the region, taking down and looting the thriving maritime port city of Vannages which would cement her reputation as a powerful and fearsome warrior. He urged her to join the army of the Berjasli chieftess Nirsiinae and help her to unite over 300 tribes to fight as one against the Vannageux, and promised to help her along the way through his godly divine intervention. With that, Zankruvil would demonstrate her fighting prowess to the chieftess Nirsiinae, impressing her sufficiently with her combat skills and adeptness with a sword and spear, thereby joining the ranks of the Berjasli army. Over the next three or four years, Nirsiinae, Rolinavasa, and Zankruvil would approach the head of the other Kurzakriori tribes, and through a combination of diplomacy, negotiation, threats, intimidation, and promises of gold and glory, 316 other tribal chiefs would pledge their armies in support of the military effort. It was an inherently difficult bargain to persuade the other tribes to sign onto. The Berjasli chieftess was the only one with a direct personal interest in the war, given it was her son Qhorieni who had been sold as a slave to the Vannageux royal family. The journey across the Sea of Vasconia was a notoriously treacherous one, spanning over 500 kilometres from coast-to-coast. Given the state of nautical technology at the time, the risks of such a maritime journey were grave, soldiers could die at sea from any combination of causes, including inclement weather, terrible thunderstorms, looting and hijacking by pirates, being marooned on islands, getting lost at sea due to the poor state of navigational technology causing soldiers to die slowly and waste away from starvation and dehydration. Not to mention, it would take years for the soldiers to make the maritime journey alone to the coastal city of Vannages. The city's great wealth also meant that it would be defended by its own massive army, would have the benefit of regional allies on the continent who were trading partners of the Vannageux, and worst of all, the royal capital city would be shielded behind high walls and massive impenetrable fortifications, making a siege difficult. Even if the Kurzakriori tribes won the war, they would have to be away from home and from their families for years, possibly decades. They would be cut off from the Valsorkenyi continent for the whole period of the war, unable to receive reinforcements or to resupply and thus having to depend on whatever resources they could loot or pillage in Villalmeyda itself.

All in all, it was a difficult sell, but not an impossible one. Indeed, while the factors dissuading the tribes from signing onto the war effort were great, the factors incentivising them to join the war were just as great if not greater. Vannages was one of the richest trading ports and epicentres in the region. Looting and sacking the city would allow the warriors to access great wealth, famed treasures and valuable jewels and riches which had become the stuff of legend in the region. Taking down the Vannageux civilisation would also undoubtedly bring great glory and honour to many of the Kurzakriori warriors and fighters, and given the martial culture of many of the tribes, wanting to die gloriously on the battlefield in one of the greatest wars ever that would live on in human history for eons thereafter was an alluring prospect that was incredibly difficult for many warriors to turn down. In addition to the promise of gold and glory, however, there was also the promise of revenge. While the chieftess Nirsiinae may have been the only one with an immediate direct personal grudge against the Vannageux, in the present, it did not detract from the fact that, in the past, many Kurzakriori would have lost loved ones due to pirate slave raids which had been fuelled, in great part, by the slave purchases made by the rich Vannageux civilisation, and especially the slave purchases of the Axtrolena royal dynasty. The Axtrolenas were one of the most infamous slaveholders within the region, the wealth of their trading empire allowed them to buy massive numbers of slaves in bulk from pirates and corsairs on the high seas, and they had an incredibly brutal reputation for sacrificing many of their 'purchased chattel' in massive festivals and cult ceremonies to the patron goddess of Vannages, the feared and cruel Porthiarâté. Many Kurzakriori had friends and family who had fallen victim to pirate slave raids, and while it was rare for them to know for certain what happened to those loved ones thereafter, it was not at all incredible to speculate that some of them were probably sold to the Vannageux, perhaps even to the Axtrolena royal family themselves, and a good proportion of those slaves would have been sacrificed on altars in honour of the goddess Porthiarâté. As such, there were personal and cultural reasons to want to go to war against the Vannageux, for revenge, to destroy a slaveholding civilisation whose trading wealth had contributed in large part to fuelling and growing the regional slave trade and, by extension, increasing the scale of the pirate slave raids on coastal cities in Valsorkenyi which had claimed so many of their brethren. There was also a historical and traditional aspect to this battle. The Kurzakriori were, themselves, descended from slaves, and their enslaved history had played a big part in forging their cultural identity as a tribe and people. Several centuries before this point in time, the Kurzakziortrenya were once a colony occupied by the armies of the fearsome Cyanean Ascendancy, located to the southeast of the Valsorkenyi continent. Historians estimate that the region was under Cyanean occupation for roughly 100-200 years, during which time it functioned as a slave colony, with the natives being used to perform dangerous and backbreaking labour in the mines, quarries, factories, and farms. The Cyaneans also used their overseas colonies as de facto 'slave farms', forcing slaves to breed with each other and kidnapping selected newborns to be 'exported' back to the home territory, presumably to be put to other enslaved uses in the Cyanean territorial heartland. The enslaved population were defiant and over the course of 100-200 years of colonial rule they launched a huge number of slave rebellions, historians have estimated that the locals launched at least 50-60 slave revolts against their colonial masters in their period, each one being put down with brutal retaliation and reprisals thereafter, but wearing down the strength of the empire over time, until finally one slave revolution was successful and all the Cyanean slaveholders and enforcers were slaughtered in a massacre so brutal and complete it frightened the Cyaneans who never attempted to establish colonies in Kurzakziortrenya ever again. The self-liberated once-enslaved peoples became independent, and eventually became the autonomous and self-governing Kurzakriori tribes and peoples. The Kurzakriori wore their formerly enslaved status, and the fact that they were descended from ancestors who had bravely defied all odds to rise up against a slaving empire and defeat them in glorious battle for their own freedom, as a badge of pride and a defining part of their cultural identity as a people. Hence, the allure of looting, plundering, and destroying a notorious slaveholding empire within the region would have also appealed to that aspect of the Kurzakriori cultural identity.

The aid of Malheuse as a trickster illusionist was also immensely helpful in facilitating this campaign of unifying the tribes into a martial 'grand coalition' army. He conjured up images of glorious battle, great riches waiting to be looted and plundered, bards and poets singing the praises of brave warriors who fought in the greatest war in human history and whose names came to be remembered for generations thereafter, which tugged at the heartstrings of many tribal warriors and peoples and compelled them to sign up for the war effort. He also helped to 'power up' his daughter Zankruvil, enabling her to perform impossible and supernatural feats in battle before the other chieftains and chieftesses, impressing them by being able to win seemingly impossible duels against multiple opponents at once, with the aid of her own natural talent and the divine intervention of her father, which only inspired more tribal warriors to sign up for the upcoming battle to carve out their names in glory on the battlefield.

The divine intervention of Malheuse, however, had increasingly begun to attract the attention of the gods and goddesses up in Lucrèçis. In particular, the Dowager Empress Karioleur had been keeping a very close eye on Malheuse, having borne an immense grudge against the trickster god after his last prank in the divine realm nearly resulted in her being decapitated by an angry Vélmuzaïs at the Imperial Ball. When she learnt from her spies in the mortal realm that Malheuse had managed to rally the peoples of Kurzakziortrenya into a 'grand coalition' army the likes of which had never been seen before, she grew instantly suspicious at what the mischievous god was planning now. She went to her son, the God-Emperor Seviathane, asking him for permission to intervene to break up the coalition. The God-Emperor refused permission, ruling that it was not for the gods to change the course of history for mortals, and they would have to see how the upcoming war played out before their eyes. However, he did give the Dowager Empress permission not to stop the war per se, but influence its outcome. With that blessing in hand, Karioleur was now determined to engineer the downfall of the Kurzakriori peoples out of spite and a desire for petty revenge, still harbouring a grudge against Malheuse and seeing the favour he had begun to bestow upon these tribes. She recruited Elosthérenée to her cause for revenge, since they both shared a common interest in getting revenge against Malheuse. Elosthérenée had been temporarily stripped of her imperial titles and suspended from the Imperial Household over a fight which she blamed entirely on the prank of Malheuse; thus, she held him responsible for her predicament as well. Both would begin to plot and scheme, trying to devise a way to engineer the destruction of the Kurzakriori civilisation without outright stopping the upcoming Vannageux War and defying the God-Emperor's orders.

Eventually, they both took a ploy out of the playbook of Malheuse and decided to indulge in a similar bout of trickery that he had used on the Vannageux civilisation. The goddesses sent a number of half-immortal - including elves, dwarves, gnomes, faeries, and giants - down to the mortal world of Impervoillée and to the region of Kurzakziortrenya more specifically to serve as holy men, shaman, and soothsayers, telling great tales and prophecies to enthral the local mortals. Knowing the Kurzakriori people to be a martial culture with warriors who were immensely proud of their status as warriors and desirous of carving out their name in glorious battle, they planted a prophecy that would rouse and arouse the spirits of the Kurzakriori warriors and brave fighters - Behold and rejoice with glee, ye whose hearts are filled with joy at the demise of oppressors, for that once great city of enslavers and mass slaughterers shall soon be no more, their rich coffers stuffed with ancient gold and glimmering treasures shall be drained to naught, their civilisation crumbling before an almighty horde of liberating warriors, whose formidable bravery and hardened valiance, well-tested by the bloodied crucible of battle, shall be remembered and immortalised by the bards and poets of tomorrow for all time!

It was an immensely seductive prophecy, and also (in accordance with the mandatory divine laws) entirely truthful and correct in its predictions. However, it was intentionally designed to be selectively truthful, for the goddesses deliberately left out a critical portion of the story - it would take ten long years for the warriors to find their way from Valsorkenyi to the city of Vannages, and the city would not fall for another twenty years thereafter. All the men and women who signed up for the conflict would be separated from their families, friends, and their homeland for the overwhelming majority of their lives. In addition, another terrible truth was deliberately hidden from the Kurzakriori warriors - while they would eventually win the Vannageux War, nearly every single warrior who signed up for the war would die, they would die on the way over to Vannages, they would die during the twenty-year-long siege and during the fighting itself, or they would die on the way back home to Valsorkenyi making that dangerous maritime journey across the treacherous Sea of Vasconia. Fewer than 100 Kurzakriori warriors and fighters would actually end up surviving the Vannageux War.

The goddesses Karioleur and Elosthérenée hid these terrible truths from the Kurzakriori in a deliberate attempt to tell a half-truth that would bring about the demise of their civilisation. They knew that the Kurzakriori would not be able to pass up the chance of fighting in such a glorious battle, and the divine and holy promise of ultimate military victory over the Vannageux would make signing up for the war impossible for the warriors to refuse. As such, over 90-95% of the military aged men and women in the Kurzakriori tribes would sign up for the chieftess Nirsiinae's proposed 'grand coalition' army - a devastating choice, since nearly all of them would come to be wiped out in the Vannageux War, viciously devastating the numbers of the Kurzakriori and plunging their people into a terrible and brutal 'dark age' of embittered civil war, economic deprivation, cultural regression, and desperate infighting which the Kurzakriori would not recover from until many centuries later when they eventually became the Velsturmanyi people, permanently reforged as a people through war and hardship. Their fate and destiny had now been written into stone. The Vannageux civilisation would crumble into ruination, but the Kurzakriori civilisation would now also be destroyed and devastated along with it. The goddesses were immensely pleased, as their plot for petty revenge against Malheuse was now complete, both spitefully content with having engineered the ruin and downfall of his favourite new human civilisation.

And so the 'grand coalition' of Kurzakriori tribal warriors and fighters would set sail, led by the chieftess Nirsiinae, the largest army the region had ever seen, numbering over 1.1 million fighting men and women from over 310 different tribes in more than 180 vessels set to cross the Sea of Vasconia on a treacherous and dangerous journey, especially given the technology of the time. The warriors had to count on the winds to be in their favour, and so prayed to their gods and interceded with their shaman and soothsayers for the gods to show their favour to the warriors and bless them with favourable winds to bring their ships quickly across the seas. Alas, that would not be the case. Porthiarâté was outraged at the sight of such a massive army of tribal warriors trying to lay waste to her favourite city to tear down a royal dynasty that were her most loyal and devoted worshippers. She left the realm of Nathyaka up to the divine realm of Lucrèçis, prostrated herself before the Imperial Throne of her father, the God-Emperor Seviathane, and prayed desperately for him to curse the journey of the Kurzakriori to ensure they would never set foot on Vannages. As Porthiarâté was the only legitimate heir to his Imperial Throne, the only child of his one and only Consort Empress, she was the God-Emperor's most favourite issue and daughter upon whom he lavished much praise and adoration. He thus granted her wish and set the winds themselves against the Kurzakriori, ensuring they would blow harshly and strongly against their vessels, back in the direction of the continent of Valsorkenyi. The oarmen and rowers of the Kurzakriori army were fit, strong, and many in number, they would row and row their galleys as much and as hard as they could, but even their mighty strength was no match for the sheer intensity of the powerful gusts of wind blowing against their vessels. Years would past by and the warriors were still stuck somewhere in the middle of the Sea of Vasconia, lost on the high seas, with the coastline and shoreline of the Villalmeyda continent nowhere in sight. Their supplies of food were quickly running out, and warriors began to starve. It looked as if the whole army of the region's most fearsome and able-bodied warriors would all be slowly wiped out through starvation alone, suffering the indignity of a most inglorious death indeed before they ever had the chance to battle their enemies.

The army would be saved, once again, through the divine intervention of Malheuse, who answered the desperate prayer of his demigod daughter, Zankruvil, who pleaded for the gods not to forsake her and her people. As the original patron god of the Kaal-zerney pirates, Malheuse had earned the trust of the pirate clans and navies, which he now planned to betray and exploit to buttress his new favourite tribe of mortals, the plucky and courageous Kurzakriori, for as an agent of chaos and mischief, Malheuse favoured whichever mortal faction had the greatest potential to stir up the most trouble and disruption in the affairs of the mortal realm of Impervoillée. He would whisper honeyed words of temptation into the ears of the Kaal-zerney pirate captains, luring them towards the huge Kurzakriori navy with false promises of great victory in battle over a numerous but tired and exhausted army of tribal warriors just waiting to be plundered and enslaved. Pirate army after army attempted to ambush and hijack the Kurzakriori warriors. In truth, these were divine gifts from Malheuse, for he knew the Kurzakriori were fearsome and ferocious warriors, and they would prevail over the pirates who attempted to board their vessels and hijack their ships. Once a wave of pirates was fended off and killed, the Kurzakiori would board their vessels and ransack all of their supplies, restocking their pantries with food and treats galore. So it was that, despite the winds being against them, and despite the maritime journey taking many years longer than anticipated, the Kurzakriori would have enough food and supplies to last the journey, for every time their stocks began to run low, Malheuse would tempt and lure another unwitting band of pirates to attack their vessels. The brave oarmen of the Kurzakriori would have to bear the arduous and exhausting task of rowing their galleys all the way across the Sea of Vasconia with the winds against them, but by the end of the decade-long journey, the crew wept with joy and celebrated with they finally saw the shoreline of Villalmeyda in sight, and beheld before their eyes the rich, flourishing, thriving port city of Vannages, with all the luxurious merchant vessels, high walls, archers and soldiers with gold-plated and silver-plated armour, and the beautiful, regal, elegant palace of the Axtrolena royal dynasty, spires towering high up into the sky, boasting the immense wealth and prestige of this trading civilisation. The tribal chieftains practically salivated at the chance of plundering and ransacking such a wealthy city and at once the thoroughly demoralised army began to feel their spirits lift once more.

For the next twenty-years, Vannages would be besieged by a massive army of more than 1.1 million Kurzakriori warriors and fighters. The standing armies garrisoned within Vannages numbered only 630,000 at most, hence they were nearly outnumbered two-to-one by their enemies. However, Vannages had the benefit of fighting on home ground. The Vannageux soldiers were protected behind their high walls and thick military fortifications, from which their archers would rain down arrows on their enemies from behind the safety of their defenses, and their catapults could rain down boulders from on high. Moreover, as they were fighting on home soil, they were able to count on trading partners and regional allies to send reinforcements and additional supplies whenever the city's own stocks ran low, whereas the Kurzakriori were cut off and isolated from their allies back home, separated by a vast and immense ocean. At the outset of the war, it was not clear which side would prevail. The numbers and battle experience favoured the Kurzakriori, but the resources and home ground advantage favoured Vannages. That added to the drama and intensity of the battle, and given the slow speed of communication at the time, news of each new development of the war would travel slowly across continents and oceans to drama-hungry and gossip-mongering readers in the Asphenium Empire, the Celasvarii feudal clans, the Kurzakriori tribesmen back home, and the other pre-antiquity predecessors of the Ancient Anjous on the Villalmeyda continent that were farther away from the coastline, including the Phylianians, the Ceçanians, the Druvírians, the Nakdôrians, the Théolians, and the Galligans. It was basically the biggest unfolding drama of the century that the region was hooked on, and every new update from the frontlines was awaited with bated breaths and much anticipation indeed.

An interesting feature of the Vannageux War, however, is its place within the Ancient Anjous pagan mythologies, because the depiction of the war during the period of classical antiquity amongst the Ancient Anjous peoples demonstrates how the actions of the pagan gods and goddesses were so deeply intertwined with fundamental historical events and the historical trajectory of mere mortals within the worldview of the Ancient Anjous. Gods and goddesses from the Lucrèçisian Pantheon would intervene to change the tide of specific events during the Vannageux War itself. On the side of the Kurzakriori tribal warriors was, of course, Malheuse, the god of mischief, chaos, and disorder, who found himself growingly and increasingly fond of the tribal warriors and the chaos and mayhem they had begun to unleash upon the region as a whole. On the side of Vannages, however, fought Porthiarâté, famed goddess of death and destruction, desirous of protecting and defending her favourite city which was responsible for so much worship, adoration, and ritual sacrifices in her honour. Moreover, Karioleur and Elosthérenée would also frequently intervene and come down to the mortal world to assist the Vannageux warriors and soldiers in individual battles given the petty grudge they continued to harbour against Malheuse for his prank at the Imperial Ball. Most importantly, however, the God-Emperor Seviathane stayed out of the war and the fighting entirely, believing it was his role to remain above the fray as the ruler of the entire world and universe, and also considering it to be uncouth and also beneath the dignity of the gods to meddle so directly in the affairs of mortals or attempt to singlehandedly mastermind the flow and trajectory of mortal affairs without permitting them to develop the general arc of their universe. As such, the most powerful deity in the universe did not intervene to influence the overall direction of the war in either direction. Thus, while Malheuse and Porthiarâté would meddle in smaller ways to turn the tide of a single battle or assist their favourite warrior in combat, whether by sabotaging a warrior on the other side or lending a supernatural power-up to a warrior on their side, they never intervened in huge and monumental ways to single-handedly change the course of the entire war itself. Instead, the fate of the war would remain in the hands of human warriors, and so the Vannageux War became a mythology that allowed poets, bards, and dramatists to wax lyrical about the heroic feats and self-sacrificial antics of brave valiant warriors on both sides of the conflict. On the side of the Kurzakriori, bards sang tales of the mighty heroics of the chieftess Nirmiinae, the brutal fearsome fighter Rolinavasa, and the talented swordswoman Zankruvil. On the side of the city of Vannages, epic poems were written about the feats of the warrior King Erenn and his eldest son Prince Carmanos, who both fought valiantly to protect their homeland. In versions of the tale where the love story between Qhorieni and Samorix is portrayed as a mutual and reciprocal romance, Qhorieni is also depicted as a skilled archer fighting on the side of the Vannageux, helping to defend his new homeland from behind the tall protective towers and high defensive walls shielding the city of Vannages from all around.

The twenty-year-long siege of the city of Vannages featured many dramatic twists and turns and ups and downs throughout the course of that conflict. Some attempts were made to avert the conflict, including diplomatic envoys sent by the chieftess Nirsiinae offering to end the war if her son Qhorieni were returned to her unharmed, but with the Axtrolena royal dynasty rebuffing the offer in exchange for allowing the chieftess to speak to her son Qhorieni to confirm that he was remaining in Vannages on his own volition. Attempts were made also to send Qhorieni to speak with his mother Nirsiinae and his childhood friend Rolinavasa in the hopes of appeasing the Kurzakriori and inducing them to end the conflict, but all these attempts were likewise rejected as cynical attempts to disguise the fact that Qhorieni was a hostage and a captive of the Vannageux who was only living in Vannages entirely under their guard and control. As such, these diplomatic efforts all came to naught. During the fighting, both the chieftess Nirsiinae and the Prince Carmanos would die valiantly and gloriously in various dramatic battles. The cheiftess Nirsiinae would perish on the battlefield when she entered into a duel with Prince Carmanos and he successfully managed to defeat her in combat, partially through the divine intervention of Porthiarâté who induced a shift in the rocks beneath her feet to trip her off balance, allowing the Prince Carmanos to strike the finishing blow. In response, in the next battle, an enraged Rolinavasa swore to avenge the death of the woman who had been a quasi-maternal figure to him in his youth, and in another duel with Prince Carmanos, Rolinavasa would slay the young prince when Malheuse now intervened to blow a gust of wind into his face which temporarily blocked out his sight and filled his eyes with sand and dirt, permitting Rolinavasa to quickly slice a lethal cut across his throat, ending the prince's life. In the final year of the war, the demigod daughter of Malheuse, Zankruvil, would slay the last main hero on the Vannageux side of the war when she fought the King Erenn of Vannages and managed to triumph over him, despite him being a skilled swordsman and duellist, due in no small part to her divine powers, using her magic to fire a bolt of supernatural energy from her spear which knocked the king off his feet, allowing her to rush to the king and decapitate him before he recovered.

At that point, it did seem somewhat inevitable that the Vannageux civilisation would lose the war, now that all of their main heroes were lost. However, the gods and goddesses on the side of Vannages would make several last ditch attempts to save the ailing and besieged city. Karioleur used her powers over life and birth to raise an army of parasitic worms which infected the food supplies of the Kurzakriori warriors, causing tens of thousands of them to die from asphyxiation when the parasites infected their lungs resulting in airway obstruction. Others suffered from pain on the field of battle from parasitical infections, which allowed the Vannageux warriors to cut them down where they stood. Not to be outdone, Elosthérenée would use her powers over resources and fortunes to protect siege runners who snuck in critical resources into the city of Vannages, breaking the Kurzakriori siege of the city, while infecting the food supplies of the Kurzakriori warriors, causing many of them to die from starvation and malnutrition. In other incidents of battle, Elosthérenée sent huge gales of wind to beset the area with strong hailstorms and typhoons, which decimated the military tents and encampments of the Kurzakriori warriors while the Vannageux were relatively insulated behind the tall high walls of their city gates, causing thousands of warriors to die from exposure to the elements or succumbing to the frostbite of winter when Elosthérenée sent a cold wave to follow such disasters. The greatest numbers of lethalities inflicted upon the warriors, however, would come from the feared and dreaded Porthiarâté, growing increasingly desperate to save her favourite city and avenge the deaths of two Vannageux warriors belonging to a very faithful and devoted royal family. Whenever Kurzakriori warriors were stabbed on the battlefield, Porthiarâté used her frightful powers over death to ensure the wounds would become infected and inflamed, dying painfully from preventable yeast or bacterial infections. She poisoned the nearest streams of water so that warriors passed away from illnesses when they drank. She sent down terrible plagues and pestilences which beset the camps of the Kurzakriori causing tens if not hundreds of thousands of warriors to die from smallpox, rickets, malaria, and the bubonic plague. She sent droughts to dry up nearby streams at critical points of the war and blotted out the rainclouds from the sky until the Kurzakriori camps ran dry from water, leading tens of thousands of warriors to pass away from dehydration and kidney failure, while protecting the shipments of water from siege runners being smuggled into Vannages from her regional trading allies. And when the warriors of Vannages and Kurzakziortrenya clashed on the battlefield, she fought directly alongside the Vannageux generals and military leaders, ensuring arrows and blades always struck true, hitting the most vulnerable and sensitive parts of the bodies of their enemies.

By the final year of the war, the Vannageux were down to fewer than 120,000 soldiers in their precious city, and had become increasingly restrained and conservative in their battle tactics, desperate to conserve the last of their armies, huddled up in their city behind the walls of Vannages, unwilling to leave the safety of their defensive fortifications to meet the Kurzakriori fighters on the battlefield. However, the warriors from Kurzakziortrenya were not faring much better, their numbers had been whittled down from the more than 1.1 million that arrived on Villalmeydan soil to just over 350,000 left. Their chieftess Nirsiinae had been slain in battle, and most of the top tribal chieftains and most talented and experienced warriors had been killed from battles, plagues, or natural disasters. Morale was low on both sides of the war, and both of their strategic positions appeared increasingly unstable and precarious. It was only a matter of seeing which side would collapse in on themselves first, whether Vannages would be starved into submission from the long and protracted siege until their dwindling army was no more, or the desperate and precarious Kurzakriori warriors would run out of supplies, as their numbers kept on dwindling to health problems and the elements until they would no longer be in any fit physical condition to raid and loot neighbouring towns and cities for resources and to keep 'living off the land', separated from their homeland in a foreign and hostile place with no supply lines in sight. Consequently, despite the very heavy losses sustained by both sides, it was still unclear which side would ultimately prevail at this point.

What would finally tip the scales in favour of the Kurzakriori side was, of course, divine intervention, this time from the god of chaos, disorder, and disarray, the ever-mischievous trickster deity Malheuse. He appeared in a dream to his demigod daughter Zankruvil, and revealed the location of a secretive tunnel through which food and water was being smuggled into Vannages by foreign merchants and siege runners who were sneaking through their blockade, keeping the city of Vannages fed and maintained on its last legs with very critical resources. Led by Zankruvil, the Kurzakriori warriors blocked up the smugglers' tunnels and began to guard the mouth of the tunnel, taking hostage any merchants' caravans attempting to furtively cross or sneak into the city under the cover of darkness, simultaneously seizing much-needed supplies for their own army. As the city of Vannages began to slowly starve and its civilian population became increasingly desperate due to an absence of food and water, the numerically smaller army of the Vannageux was eventually forced to leave the safety of the city's high protective walls to engage the Kurzakriori in battle in order to free and liberate the smugglers' tunnels and protect the flow of their food and water supplies into the city. The two armies met at the fertile delta region of the River Vistuli for one last and final dramatic battle of the war known as the Battle of the Vistulian Delta. The two armies set up camp on opposite sides of the river, over 100,000 Vannageux soldiers on one side, closer to the city, with over 300,000 Kurzakriori soldiers on the opposite embankment of the river, on the side that was farther away from the city walls. For several days, the armies would engage in small skirmishes, but the Vannageux forces would use 'hit and run' tactics to gradually wear down the army and 'feint and retreat' manoeuvres to ensure that their numerically smaller army would not have to face their much more numerous foes in a direct confrontational clash for an all-out head-to-head battle that would engulf and overwhelm them. The two armies were thus stuck in a stalemate for about a week, with Porthiarâté occasionally intervening on several occasions to tilt the scales marginally in favour of the Vannageux, sending down plagues and pestilences upon various segments of the Kurzakriori army at critical moments to weaken their forces and so prevent their army from charging head-on against the defenders of Vannages, or sending heat waves at critical moments to afflict the Kurzakriori soldiers with heat strokes, allowing the Vannageux army a brief reprieve and sufficient time to retreat behind the city walls, regroup and resupply, before exiting the city to face their foes in the heat of battle once more. In versions of the story that portray a mutual reciprocal love affair between Qhorieni and Samorix, the brave young warrior Qhorieni would also join his companions in battle on the frontlines, fighting on the Vannageux side, as his wife and lover the Princess Samorix would watch the battle unfold before her eyes from the city walls' ramparts, her heart leaping up into her heart in fear and panic whenever her husband's life was close to being endangered or jeopardised by their enemies.

[Purgatio]

Finally, the stalemate was broken through the mischievous intervention of the trickster god Malheuse, who decided to sow the seeds of discord and dissension into the hearts of the serfs and peasants of the countryside in the immediate radius of the city of Vannages, who had been harassed and pestered endlessly by the looting and plundering of the Kurzakriori warriors, whose farmlands had been burnt and livestocks robbed and stolen by the invaders, and whose crops and grain harvests were still being requisitioned on the regular by royal soldiers to restock the granaries of the royal capital of Vannages to weather the siege, even as enslaved serfs were forced to keep on tilling the land to produce more grain and food for the city's royalty and nobility. Malheuse would whisper seditious words into the ears of the serfs and agricultural servants, he would appear to them in their dreams with apparitions and illusions of rioting and disorderly conduct, he would fill their hearts with frustration, dissension, and discontent, engineering the perfect moment for their rebellion and insurgency. At long last, after a week of vicious embittered fighting between the Vannageux and Kurzakriorian armies, the serfs and peasants began to angrily revolt and riot, and the violent riotous mob descended en masse upon the armies, first attacking the royalist soldiers of Vannages from behind until they were completely sandwiched and caught between the Kurzakriorian invaders on one side and violently revolting serfs on the other. Malheuse, the god of chaos, mayhem, disorder, and pandemonium rejoiced and cheered at the messy violence and disarray he had caused, laughing as Vannageux soldiers were cut down on both sides and forced into a retreat behind the protective high walls of Vannages.

The city was besieged once more, with all supply routes and smugglers' tunnels into the city blocked up and guarded at night by the ever-vigilant and motivated Zankruvil, more eager than ever now to see the city fall so that she could sack it and write her name into the history books as one of the most glorious warriors of all time. Victory was so close and she and the Kurzakriori warriors knew it. The soldiers of Vannages had dwindled drastically to fewer than 50,000 now, while the armies of the Kurzakriori still stood strong at just under 200,000 men and women. All she had to do was to somehow get her army into Vannages, past its high walls and defensive fortifications, and the city's population would be defenceless and vulnerable sitting ducks before her mighty and superior warriors. She would finally get her long-awaited opportunity when Malheuse began to whisper the same tempting words of chaos, dissension, and discontent into the ears and hearts of the enslaved population of Vannages, toiling away arduously in the sewers, the aqueducts, the roads, the tunnels, the drainage systems, the once-thriving ports and harbours and crowded warehouses, instigating a full-on slave revolt that engulfed the city in inner turmoil and turbulence. As mobs of angry slaves rushed out into the streets of Vannages, destroying and burning down buildings and killing and slaughtering as many Vannageux citizens they could get their hands on, more and more of the impoverished citizenry began to riot as well, over the absence of food and water in the city due to the twenty-year-long siege. The entire city of Vannages was torn apart from within with slave revolts and rioting and rebellion from the city's poorest, and the city soon fell apart in infighting and internal dissension. It was complete mayhem, pandemonium, and disarray at a scale and level that made the god Malheuse blush with pride and admiration. The city's royalty and nobility barricaded themselves behind the royal palace in fear and trembling, as the slaves took over the streets, killing the city's guards and watchmen to open the gates and lower the portcullis, allowing the Kurzakriorian invaders to freely enter the city. In many Ancient Velsturmanyi versions of the story, the Kurzakriori warriors embraced the formerly enslaved denizens of Vannages as their brethren-in-arms, welcoming them into the fold as they looted and pillaged the rich city together. In most Ancient Anjous versions of the tale, however, the Kurzakriori immediately betrayed the slaves who let them into the city, proceeding to rape, slaughter, murder, and cannibalise every single resident of Vannages indiscriminately slaughtering slave, worker, peasant, merchant, artisan, soldier, and noble alike without fear, favour, or distinction whatsoever, as they looted and pillaged the city and ran rampage throughout the streets, ripping clothes off of carcasses, ransacking homes for any chattels they could find, burning whatever could not be carted off or carried away, and surrounding the royal palace to slaughter every single noble, royal, and household servant they could find, stabbing and ripping apart babies, raping any women and child they came across, butchering and mutilating every man they could get their hands on, until the messy dirty streets of Vannages ran red with blood, the bodies were piled on high with thick heaps of the bloodied mutilated carcasses of many hapless civilians murdered and slaughtered in the rampaging warriors' wake, and every building was destroyed or set on fire, with the great magnificent palace of the Axtrolena royal dynasty, that had stood for over half a millennium, set aflame, burning away all its inhabitants with it until nothing was left. Every precious jewel, treasure, and priceless object that the warriors could find in the palace and the grandiose residences of the city's richest nobles and merchants was stolen and robbed from them, while their homes were burnt and reduced to nothing but charred remnants and rubble. In one fell swoop, in one vicious and devastating sack, the once-great and magnificent city of Vannages that had been the envy of the region for hundreds upon hundreds of years was now nothing more than a burning heap of soot, ash, and rubble.

The fate of the lovers Qhorieni and Samorix likewise differs between different retellings of the Vannageux War mythology. In many of the Ancient Anjous versions of the tale, the Princess Samorix was either slaughtered by Kurzakriorian warriors or gang-raped and sexually assaulted or burnt alive in the palace along with the rest of the Axtrolena royal family or had her body butchered mutilated and cannibalised by the Kurzakriorian invaders who were trashing and sacking the palace for its many treasures. In others, she was captured by the Kurzakriorian invaders as a prisoner of war or enslaved as a sex slave for the Kurzakriorian tribal leaders along with all the women and girls in the Axtrolena dynasty. In some Ancient Anjous versions, Qhorieni comes to her defense when the Kurzakriorians enter the royal palace, and is either defeated in combat before his wife the Princess Samorix is attacked or assaulted or killed in the process. In other versions, Qhorieni is slaughtered by his own people, either in the course of him trying to defend his wife and children, or intentionally as payback or revenge for betraying the Kurzakriori and for his treason in fighting for, and marrying into, an enemy people. Many Ancient Velsturmanyi poets and dramatists have generally portrayed the ending of Qhorieni and Samorix's story in many comparatively sympathetic fashions, although even then there is a broad divergence from writer to writer. In some Ancient Velsturmanyi versions, Qhorieni is rescued by his childhood friend Rolinavasa and separated from his wife the Princess Samorix. In others, he returns to his former lover Rolinavasa and the two hug, kiss, and embrace at their reunification. In other versions, the Vannageux are keeping Qhorieni under lock and key in the dungeons as their prisoner and hostage, and the Axtrolena royals and their enforcers are slaughtered and Qhorieni is rescued by either his childhood friend (or lover) Rolinavasa or the demigod hero of the Kurzakriori Zankruvil or by both. The final fate of the Princess Samorix likewise differs between the Ancient Velsturmanyi retellings. In some versions, she is killed during the sack of the city of Vannages. In others, she is arrested by the Kurzakriori along with her royal family to stand trial back home in Kurzakziortrenya for their crimes of slavery and ritual sacrifice perpetrated against the Kurzakriori people. In other versions, she is brought back with the Kurzakriori people to live with them back in their homeland as a guest or migrant, coming to embrace their culture and way of life. In a small minority of retellings by some Ancient Velsturmanyi poets, she even becomes a side-lover to both Rolinavasa and Qhorieni even as the two men marry and are reunited.

In all of the above retellings, however, the one commonality remains that the marital relations between Qhorieni and Samorix are ended when the Kurzakriorians invade the Axtrolena royal palace, sack and plunder it for all its treasures and riches, and take Qhorieni away from the Princess Samorix. Thus, the prophecy was fulfilled - the city of Vannages would only come to burn to soot and ash when the matrimonial relationship of Qhorieni and Samorix had been formally ended, by whatever means.

In the Ancient Anjous mythology, the aftermath of the Vannageux War is taken up largely by the 'Lucrèçisian Pantheon' debating and discussing how to respond to the monumental events of that conflict, and the destruction of an important epicentre of regional maritime trade in the Sea of Vasconia, linking so many of the world's major economies at the time. In real life, the looting and burning of the city of Vannages triggered a regional economic collapse which likely contributed, in substantial part, to the great Bronze Age Collapse when civilisations all over the region collapsed into a state of illiteracy when no written records or annals are available for centuries, possibly due to these societies becoming engulfed by societal and cultural regression due to economic disaster, civil war and unrest, and becoming consumed with internal infighting. Thus, in real life, both the Kurzakriori tribes as well as the societies of Vannages and her regional allies (from Nakdôria, to Théolis, to Gallige, to Druvírí, to Phylian, to Ceçania and beyond) all suffered from a societal collapse lasting from around the 11^th Century BCE to around the 7^th Century BCE, during which time civilisations fell and new civilisations arose. Historians and cultural anthropologists therefore theorise that the ending and aftermath of the Vannageux War is intended, in many ways, to provide a post hoc explanation for these societal shifts and radical changes in regional geopolitics at the time, through the unique cultural lenses of the time. Before these mythologies were written down into textual poems and dramas in the 7^th Century BCE onwards, many of these myths were likely disaggregated and scattered piecemeal stories spread through unwritten oral tradition which were later combined and consolidated into larger tomes and written works, told and passed down from generation to generation during the centuries of the Bronze Age Collapse. As such, they provide a useful insight into how the peoples living at the time explained and understood the catastrophic events of the regional Bronze Age Collapse, and their own views as to how such a regional apocalypse could have occurred or taken place.

This provides the historical context for the aftermath of the Vannageux War in the Ancient Anjous version of the mythos. The Crown Princess Porthiarâté was enraged at the sacking and looting of her prized and favoured city of Vannages by the Kurzakriori warriors. The city was her city, it made sacrifices and offerings in her honour, there were temples, shrines, holy places, and altars all over the city, all of which were desecrated, destroyed, and burned to ashes by the pillaging warriors. As such, as Queen of Nathyaka, controller of the underworld, she wrote each and every Kurzakriorian tribal warrior's name into her Royal Book of the Damned, promising that when those souls entered her domain, she would cast them into the condemned regions of Nathyaka, where evildoers' souls are punished for their crimes whilst they were lives in being. However, she was eager for their divine retribution to begin sooner rather than later. Thus, she appeared before her father's Imperial Throne in Lucrèçis and demanded swift and immediate retribution for the destruction of Vannages. She wanted the Kurzakriori to suffer for the destruction of the city and the holy spaces consecrated in her honour. She framed the destruction as a sacrilege and blasphemy against her, the Crown Princess, which in turn was a seditious affront against the God-Emperor Seviathane as well. This was an argument which appealed greatly to the God-Emperor. He agreed the Kurzakriori people should suffer for what was done in Vannages. However, the Crown Princess Porthiarâté, the Imperial Concubine Elosthérenée, and the Dowager Empress Karioleur, all of whom had played some role helping the Vannageux side of the recent conflict, wanted the God-Emperor to punish his uncle the Prince of the Blood Malheuse as well for his role in the fighting. They asked for Malheuse and his demigod daughter Zankruvil to be condemned to the torture realm of Akthûsoirix for all eternity. The Consort Empress Réçavronuelle feared that such an approach would risk a civil war that would tear the divine cosmos apart and destabilise the rule and reign of the Imperial Household. The God-Emperor agreed and decided that this dispute had to be settled within the Imperial Household as a whole. He invited all members of the Imperial Household, including those banished to the other realms, like Malheuse, up to Lucrèçis to express their views on the subject and to be held accountable for any role they may have played in the destruction of Vannages. He made clear to all, however, that he wanted consequences to follow for the city's recent ruination.

Malheuse understood the severity of the situation, especially as many members of the Imperial Household were calling for his eternal condemnation to Akthûsoirix. He gave a full accounting of the situation and his role in the conflict, from the pirate raids of the Kaal-zerney pirates all the way up to the Kurzakriori invasion of Vannages and his assistance in their successful besieging of the city. He argued that it was fair's play as other members of the Imperial Household had lent their assistance to the Vannageux side of the war. The God-Emperor disagreed. Malheuse had sown the seeds of the destruction of the region through chaos and infighting, whereas other members of the Imperial Household had only attempted to preserve the stability and harmony of an existing civilisation. In the view of the God-Emperor - who, in the Ancient Anjous mythos, was a representative of order, discipline, harmony, and social organisation in a chaotic and unstable universe - the two aims were not equal or comparable to one another. He made clear that Malheuse would be punished for his crimes, but offered him a choice - he could share his punishment with his daughter Zankruvil, or he could spare Zankruvil but worsen the severity of the punishment he inflicted on Malheuse instead. Malheuse bravely decided to take on a harsher punishment to spare his daughter, telling the God-Emperor that his daughter Zankruvil had only acted on his orders and instructions throughout and knew not of his wider schemes and plots or the real implications and consequences of her actions. She carried out his will blindly and unthinkingly like a faithful daughter should, all the while completely ignorant of the role she was playing and executing within his broader plan for the region, and for the Vannageux in particular.

The God-Emperor agreed with his uncle on that point, and with that, he rendered his fearsome and terrible verdict. His uncle's punishment would fall short of eternal condemnation in Akthûsoirix but it would still be a terrible one in its own right. He had his brother Xanthière create a device - a divine plow of sorts - which could carve and hollow out souls, spirits, and consciousnesses. The consciousness and essence of Malheuse would be hollowed out from his divine form and being. His soul would be imprisoned in his divine daughter's underworld realm of Nathyaka for a grand total of four hundred and eighty-nine years, two months, one week, three days, five hours, and forty-four minutes. He would be shackled down in the lowest depths of Nathyaka where there was nothing but void and oblivion - thus, he would be driven mad not by active physical torture but simply by sheer nothingness and total inactivity for a very long period of time. As for the divine body of Malheuse, it would now become little more than a hollow shell of what it once was, a mindless unthinking unfeeling ghoul to be unleashed upon humanity, an agent of chaos, mayhem, and pandemonium - but this time, an aimless one that inflicted chaos and disorder in a blind and random fashion. It was intended by the God-Emperor as a cruelly ironic contrapasso punishment. He would unleash the mindless being of Malheuse upon the region of Kurzakziortrenya first of all. In that way, his favourite mortals, the Kurzakriori, would ironically suffer from the chaotic destruction and disorder Malheuse had inflicted on Vannages. Thus, while he was chained and imprisoned in Nathyaka under lock and key by Porthiarâté, Malheuse would have the distinct displeasure of witnessing with his own eyes his own divine body and being unleashed upon Kurzakziortrenya as it ravaged, destroyed, and demolished the entire Kurzakriori civilisation, razing it to the ground through the same powers of chaos and disorder he had used in Vannages - including, upon his own daughter Zankruvil, and his other demigod and half-immortal sons and daughters scattered throughout the Kurzakriori peoples, as they got caught up in the violent mayhem and unruly pandemonium of the Kurzakriorian dark ages, wherein looting, banditry, and brigandage ran unchecked and amok.

For the next couple of centuries, therefore, Kurzakziortrenya would be engulfed in a perpetual civil war, as the civilians left behind on that continent by the warriors who set sail across the Sea of Vasconia and their descendants battled and duked it out constantly, fighting and tearing each other apart as the civilisation fell to infighting, disorder, and a society-wide apocalypse that would not end until centuries later when the Velsturmanyi people were birthed from its ashes. As for the warriors who sacked and destroyed the city of Vannages, the God-Emperor ordered that all of them should die from their journey back to the continent of Valsorkenyi. While over 1.1 million Kurzakriorian warriors had crossed the Sea of Vasconia thirty years ago, by the end of the Sack of Vannages only less than 120,000 of them were left. The God-Emperor ordered his daughter, the Imperial Princess Iseulde, who controlled the seas and the waves, to engineer a huge storm and tidal wave that would engulf and drown all of the warriors as they tried to cross the Sea of Vasconia and return back home. Iseulde was only all too happy to oblige. She still held a grudge against the Prince of the Blood Malheuse for the terribly humiliating prank he had engineered upon her during the Imperial Ball and had no intention to forgive him for what he had done to her. Knowing of the liking that Malheuse had taken to the Kurzakriori people, she regarded the destruction of their tribes and civilisation as just desserts and a fair way to exact her petty revenge from Malheuse for his prank. The wholesale destruction of their warriors would all but guarantee the societal collapse of the Kurzakriori back home, with a huge proportion of their workforce and military strength sapped and destroyed into nothingness. To that end, she shut herself away in her room, day and night, for months, concentrating her magical energies to create the greatest, largest, most terrifying thunderstorm the world had ever seen and would ever witness on the high seas, consisting not just of a huge storm, thunder, lightning, and rocky waves, but also a massive tidal wave and a fearsome whirlpool which would guarantee the drowning and destruction of all the Kurzakriorian warriors who were trying to return home safely with their loot, their plundered riches, and their spoils of war. Following the God-Emperor's orders to her, the only people who would survive that terrible destruction were Zankruvil, the demigod daughter of Malheuse, in honour of the God-Emperor's promise to Malheuse spare his daughter from his wrath, and the childhood friends (or lovers) Qhorieni and Rolinavasa. In the versions where the Princess Samorix is part of their entourage, whether as a prisoner or otherwise, she too survives the storm. The reason for their lives being spared by the God-Emperor Seviathane differs from account to account, but generally follows the view that the God-Emperor considered them to be innocent of the blasphemies committed in Vannages, as Qhorieni and Samorix were not involved in the Sack of Vannages, and Rolinavasa is generally portrayed in all accounts as a very honourable Kurzakriori warrior who, unlike the other Kurzakriorians, did not participate in the burning, looting, and raping of the city, and had a laser-focussed single-minded aim that was exclusively geared towards rescuing Qhorieni and bringing him home. Thus, only these three (or four) persons would survive the terrible flood or storm that would consume the 120,000 strong army of Kurzakriorians who committed the sacrilegious Sack of Vannages. The rest would drown and perish somewhere in the Sea of Vasconia and proceed to suffer for all eternity under the sadistic watch of Porthiarâté down in Nathyaka, all of them forever damned in her eyes for their role in the destruction of her city - at least, that was their ending in the Ancient Anjou retelling of the tale. The Ancient Velsturmanyi writers generally portrayed the Kurzakriorian warriors in a more noble and honourable light, omitting the tales of their rapes, their brutalities, and their cannibalisation of the hapless civilians of the city of Vannages, and while they would be cursed to drown in the storms of the Sea of Vasconia, they would forever enjoy eternal happiness in a paradisiacal afterlife, as a reward for their bravery and valour on the battlefield against the enslaving and tyrannical Vannageux civilisation. All accounts of the Vannageux War, however, agree that the great majority of the Kurzakriorian contingent that participated in the war would either die on the battlefield in Vannages or drown in the Sea of Vasconia on the way back to their homeland. And thus, the Kurzakriorians' prophecy would also come to be fulfilled - indeed, Vannages would fall and burn at their hands, but their whole civilisation would be destroyed along with it.

Likewise, the prophecy that was told to Zankruvil by her godly father Malheuse - that she would found a great warrior tribe in Kurzakziortrenya and her name would be immortalised forever in history - would also come to pass. After a great thunderstorm beset what was left of the Kurzakriorian armies that were en route back to Valsorkenyi, it would capsize all the vessels and kill and wipe out all persons onboard, save only for a handful who, miraculously, would somehow wash up ashore on Valsorkenyi, alive and well. Those survivors were Zankruvil, Rolinavasa, Qhorieni, and in the versions where she is brought back with the Kurzakriori - whether willingly or unwillingly - the Princess Samorix as well. They would return back to the region of Kurzakziotrenya to find a land engulfed in utter chaos, plunged back into a dark age of warring tribes, endless civil war, burnt and destroyed villages, the ruthless slaughter of innocents by angry warlords and opportunistic bandits, as the Kurzakriori had reverted and regressed in the Bronze Age Collapse that had engulfed the region in infighting and civil war following a massive economic collapse that left most in the region unable to make ends meet or access the basic necessities of life. Rolinavasa and Qhorieni would attempt, to no avail, to rebuild or reorganise the remnants of Nirsiinae's former tribe, the Berjasli people, but would realise soon enough that the tribe was no more and had become engulfed in the same warring and infighting that had overtaken the entire region. In the end, Rolinavasa and Qhorieni (along with the Princess Samorix, in versions where she is brought with them) would make their own life elsewhere in a small hamlet, defending themselves from bandits as and when they can, living off the land, and carving out a peaceful but obscure life for themselves, away from the chaos and infighting of their homeland. Zankruvil, on the other hand, would carve her name out in glory on the battlefield, using a combination of her martial prowess and supernatural powers to defeat multiple warrior tribes and warlords to assert her dominance over them, gathering a loyal following around her as she established a domain under her control as the leader of a mighty and fearsome warrior clan. They would eventually go on to become the Zankruvian Tribe, one of the founding 36 tribes of Nuie-Velstur who would eventually come to unite and make peace in the new city of Sondestadt centuries later, formally putting an end to the Bronze Age Collapse and the dark ages of the warring Kurzakriorian people. Zankruvil would also have the honour of being the only demigod founder of a Velsturmanyi tribe who had fought gloriously on the battlefields of Vannages. According to the Ancient Velsturmanyi bards and writers, the remaining 35 Velsturmanyi tribes would all go on to be founded by other demigod children of Malheuse who were mere infants or young children when the Vannageux War began, and while they would go on to enjoy glorious fates and destinies back home in Kurzakziortrenya as great warriors and leaders in their own right, only Zankruvil alone would have the distinction of being both a demigod child of Malheuse, as well as a famed heroine of the Vannageux War who miraculously managed to survive the perilous journey back home. Thus, the glorious promise made to her by Malheuse was fulfilled, and her name would be immortalised forever within Velsturmanyi history.

Meanwhile, back on the continent of Villalmeyda, the collapse of the rich thriving trade city of Vannages had devastating ripple effects on the regional economy, as thriving neighbouring civilisations totally collapsed in the wake of the destruction of the Vannageux civilisation. What was once a thriving flourishing economy, which traded with her neighbours and propped up the economies of so many others in their proximity, was set aflame and left in ruins, now utterly destroyed beyond recognition. The destruction of Vannages is generally estimated by historians today as occurring sometime in the 11^th Century BCE, as verified through the carbon dating of votives, pottery, and other artefacts excavated from the ancient ruins of the modern day city of Vannages, which has been preserved as a World Heritage Site and a very popular tourist destination today. From the 11th Century to 9th Century BCE, various other ancient civilisations in the region would suffer their own downfalls and decline, as a regional economic collapse led to other civilisations surrounding Vannages being engulfed by internal civil war and infighting or going to war with one another for resources and sapping their strength and energies in the process, as the region completely collapsed to the same forces of chaos, banditry, and brigandage of the Bronze Age Collapse that had beset the Kurzakriori in Valsorkenyi. Meanwhile, the Sack of Vannages was so thorough and the destruction of the city so complete that there was no hope whatsoever for recovery. According to the mythos of the Ancient Anjous, a tiny entourage of 150-250 loyalists to the Axtrolena royal dynasty managed to hide from the Kurzakriorian invaders during the great sacking of the city, either by hiding away in the smugglers' tunnels, the ancient catacombs, or by playing dead. When the sack was over and the warriors had left the burning city to return home, the small band of surviving loyalists formed an entourage to protect the last surviving member of the Axtrolena royal family they were able to hide away - a young baby girl, less than one year old, the youngest child of the slain Prince Carmanos, and the only descendant of the Axtrolena dynasty left alive and on Villalmeydan soil, the infant Princess Magueria. The rest of the royal family was gone, either captured and enslaved by the enemy, imprisoned and brought back with the Kurzakriorians to Valsorkenyi to stand trial for their supposed crimes, or raped, killed, mutilated, and cannibalised by the Kurzakriori during their sacking of the royal capital city of Vannages. Only the Princess Magueria was left, hidden away and kept safely concealed by loyal servants of the Axtrolena crown. That small band of loyalist nobles, warriors, and household servants wrapped the infant princess in a blanket and left the ruined and burning city of Vannages behind, venturing out into the cold uncaring wilderness of the vast continent of Villalmeyda.

At first, they wished to travel to the neighbouring allies of the Vannageux in the hopes that some of them would be willing to take them in and grant them refuge and protection. However, once they left Vannages, they were horrified at the chaos and destruction of the world around them. All of the great ancient allies of the Vannageux were no more, engulfed by a dark age of societal collapse and cultural regression. Whether it was the Phylianians, the Ceçanians, the Druvírians, the Nakdôrians, the Théolians, and the Galligans, once great civilisations were now little more than mindless barbarian hordes, their societies engulfed by internal infighting, slave rebellions and peasant revolts, their capitals were aflame, their lands and holdings overtaken by warlordism, banditry and brigandage, the looting of great treasures by opportunistic forces, and piracy run amok as they ravaged coastal cities and once-wealthy and well-defended maritime ports. The Axtrolena loyalists found themselves marooned in an unfamiliar and hostile land, a continent they once called home but was now scary, alien, and utterly unrecognisable to them, reshaped by the forces of chaos and destruction into something frightfully new and barbaric in their eyes. Their morale was low as they wondered to themselves how they could possibly protect themselves in this strange new land of barbarians, warlords, and highwaymen. It seemed to the loyalist entourage that they had defended and hidden away the young Princess Magueria for naught, that she would inevitably fall victim to the lawless and predatory forces that had taken over a once-tamed, once-civilised continent, now left in ruins in the wake of the destruction of the Vannageux civilisation, the greatest civilisation that had ever been built on the continent that was now no more.

The precarious state of this tiny delegation of the Vannageux remnant did not escape the notice of the great gods and goddesses up in Lucrèçis. The God-Emperor Seviathane, as a god of order, law, and discipline, was still upset over the general chaos and mayhem unleashed upon the continent of Villalmeyda through the mischievous machinations of his uncle Malheuse, who was still being punished and held in captivity under lock and key down in the netherworld of Nathyaka. Nonetheless, that penalty did not fix the present state of affairs, which was that the face of Villalmeyda, once filled with ordered and organised civilisations, had now regressed into a barbarous dark age of warlordism, warring tribes, anarchy and lawlessness throughout. He wanted the continent to eventually return to the orderly, peaceful, and prosperous state that once existed under the watchful governance of the rich city of Vannages which was now no more. Therefore, he noticed the existence of the Vannageux remnant of loyalist nobles, warriors, and servants, guarding the infant Princess Magueria, and saw in them the promise of the rebirth of the Vannageux civilisation one day. To achieve that, however, they needed to be protected. He ordered his mother, the Dowager Empress Karioleur, to see to it that the infant princess was safeguarded and properly defended, that her life would be watched over properly, and she would live to adulthood, to bring about a promised rebirth of the great city of Vannages. The ever-loyal, ever-faithful Karioleur bowed before the Imperial Throne in humble submission, and promised to her son and God-Emperor that his will would be done and the Princess Magueria would be safe and secure under her watchful eye and divine protection. She appeared down in the mortal realm of Impervoillée, to the small delegation of the Vannageux remnant, and told all the servants to not be afraid, and to have courage, for the gods and goddesses were watching over them, and while the journey throughout the wild and primal lands of Villalmeyda would be treacherous and dangerous, and not all of them would survive it unscathed, she promised that the young Princess Magueria would survive throughout, and through her, the once-great prosperous Vannageux civilisation would come to be reborn and revived through her royal lineage. This lifted the spirits and morale of the plucky Vannageux remnant, who were inspired at the thought that the destroyed civilisation of Vannages would live on one day, and thus their rescuing and harbouring of the infant princess was not in vain or for naught at all. With that, they guarded the baby girl with their life, and fought bravely against any bandits and robbers in the countryside or on public roads that they encountered throughout their travels, journeying deeper into the heart of the Villalmeydan continent, farther away from the coastal areas that were beset by piracy and maritime slavery, away from the ruined civilisations near the Sea of Vasconia, deeper and further inland. They travelled frequently, living off the land, forming a little village or small rural community as and when they could, but never staying in one place for too long, escaping barbarian invaders and raiders and deftly dodging warlords and warrior tribes through their best efforts and evasive, elusive travels. Each time the young Magueria came closer to being slaughtered, slain, killed, or kidnapped, the fearsome and terrifying Karioleur would appear from thin air or came down from the divine realm to smite the attacker, blind them or strike them dead where they stand, before the child could come to any harm, for she was under her divine watch and godly protection, and thus no harm could befall her.

Many years would pass, and decades later, the infant princess would grow into a beautiful adult woman, hardened by the rugged circumstances of her birth and upbringing, having had a rough and unsheltered childhood under the prevailing state of affairs. The adult Princess Magueria was now a hardened wanderer and traveller, a natural born leader and fighter, and highly impassioned and inspired to remake the glorious dynasty she had once been a part of and to found a new city and civilisation that would recapture the glories and grandiosities of the civilisation which had just been destroyed. She sent out scouts to scope out neighbouring towns, cities, hamlets, and villages, to gain more intelligence about them. She sweet-talked and charmed any villagers the loyalist entourage came into contact with, rallying any former citizens of the Vannageux civilisation and her neighbours, seducing them with her dream of remaking the Vannageux civilisation once more, playing to their lost pride and waning nostalgia, growing her following in the process. She gathered resources, stowing away foraged food and rainwater when it poured, in preparation for the worst-case scenario, living off the land and rationing critical supplies amongst her flock. Finally, she learnt from her spies and sentries that, within their general proximity, there were no fewer than 50 towns and hamlets founded by former runaway slaves of the Vannageux civilisation. She had been taught by the loyalist Vannageux delegation that one of the key causes for the downfall of her family's legacy had been the sudden uprising of chattel slaves within the city of Vannages and the violent riots of bonded serfs in the surrounding countryside, which forced the Vannageux army to fight on two fronts, engulfing them between the rebellious slaves and the Kurzakriorian invaders. She found herself filled with hatred, bitterness, and resentment for the subversion and sedition of the disloyal and treacherous within her family's mighty civilisation, whose selfishness had brought a great civilising force to destruction and ruination for their own ends, eating and cannibalising a productive society from within. Her heart burnt with anger and a lust for revenge against those she felt had been responsible for the death of so many innocent Vannageux civilians, who had perfidiously surrendered their city to the raping barbarian horde, who had destroyed everything her ancestors had worked so hard to make, build, and cultivate as a people. When she discovered that those very same treacherous slaves and serfs, and their children and families, were living freely and happily in scattered hamlets and localities around them, she hatched a plot to exact her family's revenge, the vengeance of an Axtrolena come to haunt the treasonous, the faithless, and the disloyal.

The adult Princess Magueria had been raised by the loyal nobles, warriors, and household servants in the ancient traditions of her family, including their faithfulness and devotion to the gods and goddesses of the divine realm of Lucrèçis. She prayed day and night to the gods - especially to the goddess Porthiarâté, who had always been a favourite patron goddess of her family and her ancestors - that she may see her family's vengeance enacted and exacted upon the perfidious slaves and serfs responsible for the destruction of her people's proud legacy and heritage. The goddess Porthiarâté, ruling down below in Nathyaka as its Queen, was only all too happy to oblige. She too had been enraged and angered at how Malheuse had manipulated the lower classes into a short-sighted and perfidious rebellion, dooming the city of Vannages into chaos and pandemonium that surrendered it to the invading horde that destroyed and ruined it from both within and without. She too believed that a fitting punishment had to be devised for what had been done to her favourite city of devoted worshippers who had faithfully sacrificed so many on altars in her honour. She appeared in an apparition before the Princess Magueria and promised her that she would see the death, demise, and suffering of every former slave and serf in the area and all their children and families, who would all pay the fatal price of blood for their treason and sedition. The next morning, the Princess Magueria gathered up her retinue of soldiers, preparing them to raid and destroy the neighbouring villages to exact their bloodied revenge. She told them that the goddess Porthiarâté had appeared to her in a dream and prophesied that she would bring about a rebirth of the destroyed and ruined Vannageux civilisation. She would be responsible for destroying all of the scattered towns and hamlets filled with the treasonous blood and stock of rebellious and destructive slaves, replacing them with her loyal and faithful following, the devoted and diligent Vannageux remnant, the last remains of their glorious and thriving civilisation, which would be reborn in fire, blood, and ashes.

To do so, however, she would make one sacrifice to the goddess Porthiarâté - herself. The Princess Magueria was impregnated by her husband, a young nobleman from one of the Vannageux patriciate, and through him she came to conceive a beautiful baby boy, whom she named the infant Prince Elantius, the last heir to the Axtrolena royal dynasty, who would rebuild the Vannageux civilisation once more. She lay on a bed of flowers, surrounded by her following in a birthing ceremony, praying day and night as the goddess of childbirth and pregnancy Karioleur appeared before all her loyal followers, watching over the labouring Princess Magueria as she gave birth to her son, healing her wounds, protecting her infant, cradling him as he left her body. As the Princess Magueria lay on the floor, heaving in exhaustion, she held her son to her bosom, crying as she whispered her last few prayers over her son, and whispered into his ear that, in her mind's eye, she saw a second city of Vannages on a beautiful celestial plain, shining the torch of civilisation as it touched every edge and corner of the wild and untamed wilderness, filled with men no better than beasts, gnashing their teeth and baring their chests at each other, building and creating nothing, preserving little, destroying much in their wake, but through his veins and blood ran the stock and lineage of leaders, builders, and cultivators, and through him order and civilisation would return to the wild and rowdy plains of Villalmeyda, teeming with foul savages and primitives and the broken descendants of rebelliously violent slaves who together could build nothing. With that, she returned her infant boy to the goddess Karioleur and prayed for the goddess to watch over her boy as she watched over her in her infancy, to ensure no harm came upon him, until he came of age to remake the Vannageux civilisation back into what it once was. Then, she made her prayer to the goddess Elosthérenée, beseeching her to bless her people with wealth, with prosperity, with good fortune. Finally, she asked the goddess Porthiarâté to accept her sacrifice of blood, the ultimate sacrifice of her life, and in exchange, she asked the goddess to curse every former slave and former serf, all their spouses, all their children, all their livestock, everything and everyone they loved and cherished and held dear, that they may die a most terrible, painful death, and suffer for all eternity in the most tortuous depths of her realm of Nathyaka, that they would all suffer and pay dearly for the chaos and suffering they inflicted upon the Vannageux, the raping and mutilation and brutalisation her people and her family had suffered at the hands of the Kurzakriori due to their treason, that the pain of every raped and butchered civilian in the Sack of Vannages would be multiplied by a thousandfold and cast and inflicted upon all her enemies, that the screaming would be great and their shrieks of agony would echo hauntingly about for eons, never to be forgotten for millennia. Her following gathered around her as the brave Princess Magueria picked up a dagger and prepared to plunge it into her heart. They wept tears of both loss and joy, commending the bravery and valiance of their leader, cursing their enemies, chanting for the death, destruction, and tortuous agony of the formerly enslaved and the rebellious serfs in their vicinity, and the fearsome goddess Porthiarâté appeared before the crowd, behind the Princess Magueria, wearing a cruel smile on her face, with much malice glinting in her eyes, moved by the princess's acceptance of death and sacrifice of her life, and she solemnly pronounced that it would be done. With that promise, the Princess Magueria plunged the dagger into her heart, sacrificing herself to Porthiarâté with a huge beaming smile on her face, imagining the death of all her enemies at the goddess's hand, content in the knowledge that she had avenged her family and exacted her vengeance upon all who wronged the Axtrolena dynasty. Her blood fell from the gash in her chest from the dagger, scarlet blood dripped down her body, pooling underneath her corpse on the grassy fields upon which she lay. In the wake of the trails of blood, flowers began to blossom from the dirt below, a delicate and elegant purple flower, which even Purgations today still call the Magueria, in her honour.

In the next few weeks, the goddess Porthiarâté would fulfil her solemn promise. The blessed soul of the Princess Magueria was transported down to the realm of Nathyaka and was laid peacefully to rest in Les Jardins Empyrées, the most elysian and paradisiacal region of the underworld, reserved by the Queen of Nathyaka for those she considered the bravest, most valiant, most courageous and honourable in their lifetimes. In honour of her noble sacrifice, she held to her word and inflicted terrible plagues and pestilences upon all 50 or so towns, hamlets, and communities that had sprung up in the area, founded by former slaves and former serfs who rebelled during the Vannageux War. Huge boils broke out amongst the inhabitants, afflicted with gruesome pathogens and disfiguring diseases, beset by terrible fevers and constipation, festering wounds, infected bloodstreams, illnesses that left their victims scarred, blinded, or permanently disabled or incapacitated. The screaming was terrible and the shrieking was haunting, lasting all throughout the nights, and all the Vannageux remnant could hear their enemies screaming out their lungs until they coughed up blood from their trachea from the excruciating pain and agony of the grotesque diseases that had afflicted them, crying out for a mercy that would never come to them. The Vannageux remnant desisted from attacking their enemies, considering death to be a mercy to them and an insufficient penalty for inflicting a terrible downfall upon such a great and prosperous civilisation as theirs once was. Instead, they purposefully laid down their arms, and simply prayed to the goddess Porthiarâté day and night, chanting for her to prolong their victims' lives, to keep their enemies alive just to suffer in their beds from their plagues, their blights, their illnesses, to keep their screaming constant and unending, to keep such villains twisting and turning and squirming like worms in their little huts shrieking helplessly in torment and agony for as long as they kept praying, with many of the followers even devotedly slitting their wrists to water the grassy fields in blood in sacrifice to the goddess in the hopes that she would answer their prayers.

She obliged. Porthiarâté ensured that the formerly enslaved and the rebellious serfs would toss and turn and scream and squirm and grit and gnash their teeth for over two years in endless and constant pain, never permitting death to intervene to end their suffering, for as long as the Vannageux remnant prayed and prostrated themselves before her and made blood sacrifices in her honour, until the royal infant Prince Elantius was now a toddler, attaining around two and a half years of age, and the faithful Vannageux loyalists declared as one that they were finally ready to inflict their awful vengeance. They picked up their swords, sharpening them against stones, waiting for darkness to arrive, and under the cloak of the night sky, they would raid each village surreptitiously in darkness, one-by-one, they torched their homes and slaughtered everyone in their beds, taking each victim by surprise, stabbing, skewering, and butchering every man, woman, and child in the villages they could find, going door-to-door in a systematic fashion to ensure no former slave or serf or their families would survive or escape their view, tossing all of their bodies into a singular thick and burning heap which they then set alight and aflame, watching the glorious fires reach terrible heights, the flame rising up and towering like a magnificent beast upwards into the night sky, as the loyal noble warriors danced and chanted away in unison, collectively celebrating the demise of their enemies as the bloodied bodies pilled up higher and higher still, burning them on a funeral pyre surrounded by traditional votive offerings in honour of the goddess Porthiarâté, who found herself terribly delighted and cruelly pleased at the mounting and ever-growing pile of human sacrifices whose blood now watered the fields and grasses of Villalmeyda, and all of which had been done in veneration and worship of her holy and divine name. At long last, the Vannageux remnant had exacted their revenge upon those who had wronged them and stabbed their civilisation in the back. At long last, the Vannageux loyalist had inflicted their vengeance upon all of the evildoers and saboteurs who had been responsible, by virtue of their insurgency and insurrection, weakening Vannages from within, for the deaths of hundreds of thousands of innocents in Vannages. Many of the Vannageux warriors had lost family and friends during the Sack of Vannages, they had seen great treasures looted and plundered, watched their own children smashed to death against rocks by Kurzakriorian warriors, women brutalised and gang-raped by Kurzakriori invaders, seen bodies of fellow countrymen mutilated and cannibalised in the streets by the tribes from across the Sea of Vasconia, as their city burnt in the background. All of that misery, suffering, barbarity, savagery, cruelty, and torment, made possible only because of the actions of the seditious traitors and their loved ones who had fled and set up and erected new communities further inland. Now, they paid what was, in the eyes of the Vannageux loyalists, a most fitting and well-deserved punishment for their behaviour. When all was said and done, the infamously bloodied Massacres of Desvilles-sous-Clertien saw over 20,000 slaughtered, taken in the night whilst struck by the goddess's illness. And in the afterlife, as their souls were seized by the sadistically cruel Porthiarâté, she would condemn all former inhabitants of the new accursed townships and villages of the formerly enslaved to a hellish region of Nathyaka, L'Abîme Abadonnien, where they would suffer continually and perpetually in the afterlife every single murder, rape, torture, brutalisation, mutilation, and cannibalisation that the Kurzakriori warriors had inflicted on all those countless innocents in the merciless and barbarous Sack of Vannages, suffering for all eternity the scars and wounds they had condemned the Vannageux people to by their selfish and reprobate actions. And the sadistic Queen of Nathyaka could not have been more pleased by the arrival of so many new victims into a dominion that was under her absolute control.

When the killings were over and the massacres were complete, the Vannageux remnant now had to do the difficult work of rebuilding their civilisation in the charred remains of the villages and townships they had levelled and destroyed so completely. They began by paying tribute to the gods and goddesses on high, and in particular erected a huge statue to the fearsome goddess, the Imperial Princess Porthiarâté of Lucrèçis, in honour of the Imperial Household and in a show of gratitude for her assistance in clearing the fields and wiping the slate clean in these lands so that a new, better, more peaceable and honourable civilisation could be founded in its newly-emptied wake. The contingent of the Vannageux remnant worked day and night to erect a huge white marble statue of the fearsome goddess Porthiarâté, which they surrounded and cordoned with by planting rose bushes and making a small lake to surround her statue as a separate 'holy place' and quiet sanctuary for worshippers and cultists to pay homage to the goddess and make sacrifices in her honour. In addition to the goddess Porthiarâté, the Vannageux remnant worshipped the goddess Karioleur and expressed their gratitude for her protection and preservation of the life of their founder, the Princess Magueria, allowing her to give birth to the last heir and descendant of the Axtrolena royal bloodline, the young boy Prince Elantius, who was made the first-ever King of their brand-new city. Moreover, the contingent prayed to and made sacrifices in honour of the goddess Elosthérenée, praying to her for her to grant them peace, prosperity, wealth, and good fortune as the new city navigated a dangerous and chaotic geopolitical landscape during the Bronze Age Collapse. According to the Ancient Anjous writers, Elosthérenée would indeed bless the new city, if for no other reason than pettiness and spite. She continued to bear a huge grudge and resentment against the mischievous trickster god Malheuse for the prank he played during the Imperial Ball which she still blamed for her eventual suspension and temporary banishment from the divine realm of Lucrèçis. Unable or unwilling to forgive him for that, and knowing that Malheuse had engineered the Sack of Vannages and the downfall of the Vannageux civilisation, she wanted to bless the new civilisation founded by the Vannageux remnant simply to spite the god Malheuse and frustrate and derail the enterprise he had embarked on. Thus, she blessed the new city with many, many years of good harvests and prosperous flourishing trade with new neighbours, as well as peace and security from her enemies, working together with the goddess Porthiarâté to protect the city from raiders and looters, allowing the city guards to beat back the tribesmen in the general area who attempted to harass or plunder the city on the regular. This is the famous founding myth of the Burgondi civilisation. The Vannageux remnant christened themselves the 'Burgondi people', they called their new civilisation the 'Burgondi civilisation', they called their ruler King Elantius the 'Great King of Burgondes', and their civilisation would soon become known to all within the region, as they grew, prospered, and flourished throughout the centuries, as the new 'Burgondi civilisation', self-proclaimed successor to the Vanageux civilisation that preceded it. It is generally estimated by historians and archeologists - based on the carbon dating of artefacts excavated from the ruins of the city of Burgondes within the modern day District of Burgundy, Purgation State, situated roughly 50-60 kilometres from the present day capital city of Auxiliora - that the 'Burgondi civilisation' was founded sometime in or around the 10^th Century BCE, during the Bronze Age Collapse period of Purgation history.

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Many of the mythological and fantastical elements of the founding mythos of the 'Burgondi civilisation' had, of course, been the literary embellishments of the Ancient Anjous writers immortalised in their grandiose epic poems, but the founding of the 'Burgondi people' was certainly a real-life historical event. In fact, it is a historical event of immense historic and cultural significance to the modern Purgation State of today. To understand why, one needs to appreciate how the 'Burgondi civilisation' played an indelible role in the eventual formation of the predecessor of the Purgation State of today - i.e., the Holy Kingdom of Purgatio or Le Saint-Royaume de la Purgatio, which was officially founded on 4 March 1218 by the first-ever Le Saint-Roi François I. Very briefly, the modern day continental heartland of the Purgation State used to be inhabited by the Ancient Anjou peoples during the so-called Ancient Period of 'classical antiquity', defined by what Marxist theorists and historical materialists would call the 'ancient mode of production' (i.e., a system of chattel slavery propping up such sectors as rudimentary agriculture, trading networks, and smaller-scale less-efficient manufacturing of man-made goods). They were called the Ancient Anjous simply because the general region was often called the région anjousse or secteur anjousse, which was in turn described as such due to the name given to the mountainous region which separated the modern day Purgation State's continental heartland from her neighbours to the east and south on the continent of Villalmeyda - viz., the Anjous Mountains or Les Montagnes Anjousses. That period of classical antiquity lasted from around the 7^th Century BCE to around the 8^th Century CE. During this time, the Ancient Anjous consisted of numerous ancient classical civilisations, mostly slave states consisting of a centralised capital city in which the power of the ruling class (often consisting of a warrior king and their aligned warlords and loyal generals) was concentrated, and a large outlying countryside of mines, quarries, fields, mills, estates, trading networks, and plantations, over which the ruling classes exercised differing degrees of control and authority, depending on such factors as proximity to the capital, relative domestic stability, and the general success or failure of their military conflicts with their neighbours over resources and security interests. Over 100-200 different slave states and slaving kingdoms warred with each other for slaves and for resources and for control over prosperous trading networks during this centuries-long era of Purgation history. Amongst these kingdoms, a very dominant civilisation and player in the region was the ancient 'Burgondi civilisation', centred around the capital city of Burgondes, forming a great empire which grew in size and ballooned into a powerful force on the continent a handful of centuries after its founding, when the powerful conqueror and military prodigy King Tanilios II led his armies into battle and vastly expanded the size and influence of his civilisation sometime in the mid-to-late 6^th Century BCE - hence, his historical moniker as 'Tanilios the Glorious'.

The 'Burgondi civilisation' would last for over a millennia thereafter but the empire would eventually break apart and disintegrate into numerous warring provinces in the Great Age of Disunion, which began in the beginning of the 5^th Century CE and ended with the formation of a new medieval kingdom - Le Règne de la Burgondes - in the early-to-mid 7th Century CE, under the first Le Roi-Regnant Burgondais Hilaire I (descended from one of the former warlords of the ancient Burgondi empire), who carved out a massive fiefdom under his control and exerted his power and authority in a feudal system based on a hierarchy of liege lords and vassals that allowed for the most cost-efficient and effective organisation of conquered lands and the maintenance of his continued control over annexed territories, ruling from his new royal capital city of Auxiliora through an army of knights and vassals whose continued loyalty to his throne was assured through the promise of fiefs and fiefdoms under their control. This dovetailed the transition in Purgation State history from the age of 'classical antiquity' - lasting from the 7^th Century BCE to the 8^th Century CE - to the so-called Medieval Age or age of 'warring feudal states' which lasted from around the 8^th Century CE to the 19^th Century CE, characterised by what Marxist theorists and historical materialists would call the 'feudal mode of production', in which a more advanced and cost-efficient system of agricultural production was a hugely dominant part of the economy, and economic production was organised into a strict feudal hierarchy of serfs, fiefs, vassals, and superior lords ruling above them, with an absolute monarch sitting at the very apex of the hierarchy as the ultimate paramount liege lord, to which all other lesser nobles and vassals swore their oaths of fealty and allegiance. While the rise of feudal structures certainly predated the so-called Medieval Age - and indeed, that feudal economic structure had already begun to wane and fade away several centuries before the onset of the Purgation Revolution of 1823 - a convenient starting point for the Medieval Age is the Bretagne Conference of 4 March 1218 in which 21 feudal kingdoms of the Medieval Anjou peoples met in the city of Bretagne and agreed on rough borders and spheres of influence for their various fiefdoms, the vassals under their authority and the fiefs and serfs under the control and ownership of their vassals. While the Bretagne Conference certainly did not end all wars and fighting between the 21 Anjous kingdoms, it is significant because the dominant player at that conference was Le Règne de la Burgondes, given its large and efficient military and the greater size of the fertile lands and territories under its control. Thus, it was La Reine-Regnante Burgondaise Lorraine I who would have the privilege of issuing the royal edict declaring the existence of the loose association of feudal kingdoms which she christened Les Domaines et Règnes Anjousses, a clear symbol that the Burgondi feudal kingdom - with the territory of the various interconnected fiefdoms under its control largely coinciding with the large and fertile agricultural farmlands of the District of Burgundy of today - was to be the dominant partner of that highly-decentralised and loose alliance of feudal kingdoms.

Over time, that decentralised alliance would morph into a singular kingdom founded on the Catholic faith and unified by the authority and legitimacy of the Church - Le Saint-Royaume de la Purgatio - which arose from the Burgondi kingdom's takeover of the other feudal kingdoms and their incorporation into its feudal domain through a combination of conquest, persuasion, inter-marriages, diplomacy, religious conversions of neighbouring nobles and civilians, and other forms of such pressure applied to their royal families over the next few centuries. It would thus be the Burgondi monarchy that would eventually become the ultimate liege lord or lord paramount to which all of the other monarchs would come to swear their seigneurial oaths of fealty and allegiance, in exchange for maintaining their own largely-autonomous and relatively-undisturbed control over their respective feudal domains. Likewise, the disaffiliated and caesaropapist Burgondi Catholic Church, formed in 1013 CE, would eventually become the national Purgation Catholic Church, formed in 1218 CE, at the very same time when the new Holy Kingdom of Purgatio was born. All of this is to say that the founding of the Burgondi civilisation in or around the 10^th Century BCE is often viewed and perceived by many modern-day Purgations of today as a symbolic representation of the founding of the Purgation civilisation itself, given the subsequent course of history thereafter. Thus, in many ways, the self-sacrifice of the Princess Magueria, following her birth of her one and only child, and the crowning of Prince Elantius as the first-ever 'Great King of Burgondes', is often similarly perceived as a mythological representation of the birth of the Purgation people and the fountainhead of modern-day Purgation nationhood itself, with the Princess Magueria often being idolised in culture as a quasi-divine 'Mother of the Purgation Nation', a figure of reverence and veneration, to the extent that when the Purgation State eventually became a Catholic nation under the Holy Kingdom of Purgatio, it was not uncommon for artistic depictions of the Virgin Mary to mirror earlier artistic depictions of the Princess Magueria during the Medieval Age. And much in a similar vein, many artists, painters, musicians, and poets during the age of the Holy Kingdom of Purgatio often immortalised the mythology of the Princess Magueria's birth of her son Prince Elantius, followed by her honourable self-sacrifice of her own life to the goddess Porthiarâté in exchange for her raining down vengeance upon the enemies of the Vannageux remnant, in order to avenge her family and people while securing the founding of a new civilisation with her baby boy as its king, in light of the immense cultural significance that that mythological tale has had in shaping the very concept of Purgation national identity and the essential sense of what it means to be Purgation, fundamentally at its core, and the foundational origins of the Purgations as a distinct and definable folk, tribe, and people, as understood within the national consciousness of Purgations living today. Consequently, the myth of the Vannageux War plays an equally important role in shaping the Purgation national identity and cultural heritage of the modern era, and in many ways constitutes the essential 'founding myth' or 'founding story' of the Purgation civilisation itself, thus its historic and cultural importance to the Purgation State and to Purgation national identity cannot be overstated.

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Social and Cultural Conservatism (Key Socio-Cultural Stigmas of the Purgation Community)

The modern culture of the Purgation State is - relatively speaking, at least - generally considered to be a socially conservative culture, rooted in traditional concepts of 'family values', the maintenance of traditional social structures, and rooted in a more moralistic and somewhat puritanical conception of the idealised social and political life. Many comparatively liberal societies have thus often stereotyped the culture of the Purgation State - and that of her people - as dogmatic, close-minded, exclusionary, discriminatory, prejudiced, and bigoted in their ways of life and thinking. However, understanding the relatively socially conservative culture of the Purgation State, its history and origins, and in particular, the critical socio-cultural stigmas which are shunned and abhorred by its people, is fundamental not only to making sense of how the far-right PNL one-party regime came to power and subsequently held onto it in the decades thereafter, but more importantly, enables an outsider to better navigate the society and culture of the Purgation State without causing needless offence and outrage amongst her people.

The modern day socio-cultural values of the Purgation State have been irrevocably shaped by her cultural history. That history includes, inter alia, the modern day eugenical and genetically discriminatory precepts of the religion of Mandatum Est, but also the religion of Purgation Catholicism, a caesaropapist breakaway offshoot of the Roman Catholic religion that preceded it. The religious history of the Purgation State, however, is best viewed as a series of evolutions, instead of as clinically isolated periods of history. In other words, each previously dominant religious faith in Purgation cultural life inevitably had an impact in shaping the worldview of future successively dominant religions. This is because a religion does not take root within a populace in a vacuum, it moulds and evolves to fit the cultural sensibilities of the adherents who are receiving and accepting it. Thus, what results from a sudden period of mass religious conversions into a new faith is a discursive compromise between doctrine and culture, and the eventual faith which arises from that process is not a strict, cookie-cutter, doctrinaire religious worldview based on some unquestioningly and logically consistent applications of religious principles and rules, but a more flexible and synergistic combination of old cultural practices and beliefs vis-à-vis the incoming religious faith, wherein a previously held worldview comes to be superimposed upon, and thereby shapes and influences, general public perception and reception of the new religious faith now being embraced en masse by a new population of fresh adherents. Hence, in the same way as aspects of Purgation Catholicism came to influence the development of the Mandatum Est faith, inevitably, when Roman Catholicism first arrived on the continent of Villalmeyda sometime in the early 2^nd Century CE - from which Burgondi Catholicism would branch-off in the 11^th Century CE, and Purgation Catholicism would later emerge therefrom in the 13^th Century CE - the way the Catholic faith was embraced and implemented, in practice, by its Purgation adherents would naturally be influenced and shaped by the ideals of Ancient Anjous paganism as expressed in its pre-existing polytheistic theology, which would have shaped the development of Purgation societies and civilisations for over two thousand years before Roman Catholicism ever arrived on the continent. This had an impact on what aspects of the Catholic doctrine came to be emphasised and focussed or hyper-fixated upon by its new Purgation adherents, while also explaining why other aspects of the faith may have been downplayed or diminished in cultural significance and relatively societal emphasis within the Purgation State. Hence, when explaining each socio-cultural stigma of the modern Purgation State of today, it is vital to appreciate how that stigma was reconciled with, and in turn came to be reinforced by, the religious worldview of Ancient Anjous pagan polytheism, which bled into Purgation Catholic religious life thereafter, whose ideals and principles would eventually evolve into the more materialistic philosophy of the Mandatum Est ideology of today.

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RESERVED (Socio-Cultural Conservatism/Traditionalism in Purgatio)