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Two drafts of the oral submissions to be made by Timothy Otty on behalf of the applicants in the Elçi and others cases at the 2 December 1996 case hearing, and English translations of the complaints made to the Diyarbakır State Security Court Investigating Judge on 10 December 1993 by the detained applicants.

Photocopy and fax copy of the draft of the oral submissions to be made by Timothy Otty on behalf of the applicants in the Elçi and others cases at the 2 December 1996 case hearing. The drafts have been faxed by Otty to Aisling Reidy. The text on the fax copy of the draft is heavily faded but legible.

Applicant's pleadings on the merits of the Mahmut Kaya application, restating the claims of the applicant. The applicant 'submits that the attitude of the authorities to the Kurdish civilian population is such that they treat all civilians as PKK supporters and PKK sympathisers... ...the State has taken no steps to differentiate between the PKK and the civilian Kurdish population.'

Applicant's pleadings on the merits of the Nasır İlhan application, restating the claims of the applicant and his brother and asking for just satisfaction for their losses. Attached is radiologist Alan Kermond's expert report on Abdüllatif İlhan's brain injury.

Final pleadings of the applicant in the Mehmet Haran case submitted to the European Commission of Human Rights. The applicant 'submits that the attitude of the authorities to the Kurdish civilian population is such that they treat all civilians as PKK supporters and PKK sympathisers... ...As such civilians killed are 'legitimate' casualties of the fight against the PKK, on the basis of their ethnic origin.' The applicant submits that he has established beyond reasonable doubt that the violations claimed under the European Convention on Human Rights have occurred. Attached are statements (in Turkish with English translation) from June 1997 of Mehmet Haran and Meyase Haran regarding the harassment of their family by security forces pertaining both to this case and to the Nesime Haran case (A44/43/1/35).

Françoise Hampson's reply to the Turkish Government's observations on the applicant's proposal for a friendly settlement in the Dulaş case.

Reply of the applicant to the observations of the Turkish Government on the Cemil Kılıç application. The reply maintains the applicant's claims that available domestic remedies are ineffective and asks the Commission to declare his application admissible. The reply also states that the Government has not shown that it has conducted a genuine investigation into finding the identity of Kemal Kılıç's killers or the possibility of undercover state forces having been responsible.

1) Reply of the applicant to the observations of the Turkish Government on the Mahmut Kaya application. The reply asks for the application to be declared admissible and states that the Government has not produced any evidence to show that it is genuinely investigating the allegations of statement involvement in the killings of Mahmut Kaya and Metin Can, and has failed to show that domestic remedies are effective (2 August 1994, 12pp); 2) Supplementary statement of Mahmut Kaya to the European Commission of Human Rights noting that 6 separate petitions to Turkish authorities have been made during 1993 and 1994 regarding the Kaya-Can murders and yet no statements have been taken from any of the victims' relatives (20 July 1994, 2pp).

Replies of the applicants to the observations of the Turkish Government in the Ovat and Şahin cases submitted during February 1995, and the pleading of the applicants on the merits of the joined applications submitted 23 August 1996. The applicants note that the Government's allegations that the application are not genuine is a practice which they have raised in numerous applications and that they have not introduced any evidence to substantiate their claims. The applicants state that the destruction of Pecar (Güldiken) by security forces, the beating of men, and the forced evacuation of villagers has been established and that 'The complaints of all the applicants must therefore be considered as having been substantiated'. Appendices attached to the replies include statements, reports, and media clippings documenting village evacuations and destructions in Turkey during 1993.

Reply of the applicant to the documents and observations submitted by the Turkish Government in the Yaşa case between April and July 1995 and to questions posed by the European Commission of Human Rights with pertinence . The first reply, submitted 7 September 1995, states that the Government's evidence confirms that the attack on Eşref Yaşa was aprt of a pattern of attack on Kurds who are considered to by sympathetic to Kurdish issues, and that the Government refuses to investigate the possibility that State agent committed the attack. The reply concluded by asking the Commission to continue its investigation and fact-finding in the case. The second reply, submitted 21 September 1995, states that there is a pattern of attacks targeted against journalists, vendors, and distributors of Özgür Gündem and that the State has an obligation to address this pattern, which it has failed to do. Attached are appendices containing articles and statements regarding harassment of Özgür Gündem personnel, including a detailed list of incidents of harassment and violance against said personnel during 1993.