41. The Applicant argues further that "the goal of demanding advance notice of withdrawal is to discourage opportunistic defections that may cause treatybased cooperation to unravel." The Applicant cites the examples of the European Convention on Human Rights and the American Convention on Human Rights which provide for notice periods of six months and one year, respectively. The Applicant requests the Court to consider these comparative treaties and apply their principles by analogy. 42. The Applicant takes the view that the Respondent's withdrawal has no effect on pending cases based on the principle of non-retroactivity. The Applicant argues further that allowing the Respondent to withdraw from proceedings before the Court at this stage would offend the principle of legality. In support of this argument, the Applicant cites Article 70(1)(b} of the Vienna Convention which provides that the termination of a treaty, unless otherwise agreed, does not affect any preexisting obligation or legal situation. The Applicant states that complaints submitted after the withdrawal would still be admissible to the extent that they address State action during the period when the State was still bound by the convention. V. 43. Submission of the Coalition The Coalition focused on two issues, namely: whether the Respondent was entitled to withdraw its declaration and the legal effects on pending proceedings of such withdrawal. The Coalition is of the view that in the absence of express provisions for withdrawal of declarations in the Protocol, the provisions of Article 56 of the Vienna Convention may apply. The Coalition asserts that the rules that govern treaties also apply to the acceptance of the jurisdiction of courts, and as such, the Court should interpret the Respondent's withdrawal in light of the provisions of the Vienna Convention. 10

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