Lawsuit: In Session Sovereign Kingdom Party v. Crown, Case 9 (Ch. 2025)

[Ibney0]

Sovereign Kingdom Party

v.

The Crown of the Kingdom of Alexandria​

I. Jurisdictional Statement
This Court has jurisdiction over this suit through Alex. Const. Part III Sec. 15. Specifically, Sec. 15 describes this Court has exclusive jurisdiction over constitutional questions.

II. Parties

1. The Sovereign Kingdom Party is a duly registered party within the Kingdom of Alexandria, governed by her laws, and subject to regulations regarding elections.
2. The Crown of the Kingdom of Alexandria is the legal body recognized for proper service of suits alleging constitutional violations. See Reallmza v. The Crown, Case 1 (Ch. 2025) (Where this Court dismissed plaintiffs suit, but not before determining that plaintiff had proper standing to challenge the crown).

III. Factual Allegations

1. On April 8, 2025, the Ministry of Internal Affairs promulgated the Party Policy document.
2. Within the Party Policy document, the ministry of internal affairs listed the requirements for maintaining party registration. That list required the Party Secretary to respond to their registration thread with the following: 1) Total party membership, 2) party leadership, 3) the number of members currently in parliament, 4) the number of members who hold an Alexandrian government job, 5) the updated Party Mainfesto, 6) the party corporation, 7) the estimated amount of donations and expenditures of the party corporation, 8) and a brief statement of the previous month's activities in the party's thread on the forums
3. The same policy listed this must be done "during the first 7 days of each month to be considered a registered party."
4. The same policy listed that "parties who do not complete this will be unregistered and must wait until the 15th of the month to apply to become a registered party."
5. The same policy listed that players could register their political parties "at any point in April."
6. On May 7, 2025, the Labour Party, the Alexandria's Public Service Party, and the United Central Party all failed to properly maintain their registration as described within the party policy requirements. See Exhibit D; Exhibit E; Exhibit F.
7. On May 9, 2025 (UTC), the Ministry of Internal Affairs announced that parties would be able to maintain their registration until May 15, 2025, and silently updated the Party Policy document to reflect these changes. See Exhibit A; Exhibit B; Exhibit C.
8. On May 9, 2025 (UTC), the Sovereign Kingdom Party, a political entity lawfully incorporated and properly maintaining its registration with the Ministry of Internal Affairs noticed this announcement and brought forth this lawsuit.

IV. First Claim for Relief - Unconstitutional Regulations

1. The timeline for party registration concluded, and parties at that point were deregistered. As a result, they no longer existed as political entities which may oppose the Sovereign Kingdom Party in free and fair elections.
2. In order to prevent this, the Ministry of Internal Affairs took steps to arbitrarily change their policy documents in order to allow these parties to run in the election.
3. This arbitrary change treats parties which properly registered in time and followed all applicable laws and regulations substantially differently from parties which failed to properly meet their deadlines.
4. Under Alex. Const. Part V, Sec. 22, Sub. 10, all players are "equal before and under the law."
5. Because the Sovereign Kingdom Party was treated substantially differently from all other parties, and because the Ministry of Internal Affairs acted to purposefully grant additional time to parties other than the Sovereign Kingdom Party, the Ministry of Internal Affairs has treated the deregistered parties substantially unequally leading to harm against the Sovereign Kingdom Party.
6. Additionally, the Ministry of Internal Affairs silently changed the month requirement for party registration from April to at any point.
7. This change resulted in the ability for parties to register a mere 7 days from the election, despite longstanding guidance on the issue dating back at least a month.
8. As a result, any party that would be delisted may register despite this longstanding guidance at any point up to and including into the election.

Prayer for Relief
Therefore, because the Ministry of Internal Affairs acted to unfairly discriminate against the Sovereign Kingdom Party, the plaintiff requests that this Honorable Court strike down the current party policy document and revert it back to the May 8, 2025 version. Additionally, the Sovereign Kingdom Party requests this Honorable Court instruct the Ministry of Internal Affairs to deregister the Labour Party, the Alexandria's Public Service Party, and the United Central Party until such time they comply with the law. We ask this Court issue declaratory relief that the Labour Party, the Alexandria's Public Service Party, and the United Central Party were not registered during the previous policies required time period, and thus were not properly registered for the May Elections.

Respectfully Submitted,

Joseph Ibney
General Counsel
Sovereign Kingdom Party

 

[Ibney0]

IN THE CHANCERY OF THE KINGDOM OF ALEXANDRIAENTREATY FOR EMERGENCY INJUNCTION

The Ministry of Internal Affairs has modified the Party Policy in order to favor political parties who failed to follow the rules that were previously set out under the law. This unfair treatment of parties who failed to follow the rules causes immediate and irreparable harm by ruining the sanctity and fairness of Alexandria’s very first Parliamentary election. This Emergency Injunction requests:- The Ministry of Internal Affairs’ “Party Policy” be reverted to its state prior to the unconstitutional change;- The Ministry of Internal Affairs be barred from updating the policy for the duration of this lawsuit​

 

[Ibney0]

Your honors,


Proof of representation.

Respectfully submitted,

Joseph Ibney
General Counsel
Sovereign Kingdom Party

 

[Smallfries]

IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
WRIT OF SUMMONS


The Crown's rightfully appointed Counsel is commanded to appear before the court within seventy-two hours.

​

 

[ko531]

The Crown is present

 

[Smallfries]

The Crown shall have seventy-two hours to respond with their Answer.

 

[ko531]

Answer to Complaint​

IN THE CHANCERY OF THE KINGDOM OF ALEXANDRIA
ANSWER TO COMPLAINT

Sovereign Kingdom Party
Plaintiff

v.

The Crown
Defendant

I. ANSWER TO COMPLAINT

1. The Defense Affirms On April 8, 2025, the Ministry of Internal Affairs promulgated the Party Policy document.
2. The Defense Affirms Within the Party Policy document, the ministry of internal affairs listed the requirements for maintaining party registration. That list required the Party Secretary to respond to their registration thread with the following: 1) Total party membership, 2) party leadership, 3) the number of members currently in parliament, 4) the number of members who hold an Alexandrian government job, 5) the updated Party Mainfesto, 6) the party corporation, 7) the estimated amount of donations and expenditures of the party corporation, 8) and a brief statement of the previous month's activities in the party's thread on the forums
3. The Defense Affirms The same policy listed this must be done "during the first 7 days of each month to be considered a registered party."
4. The Defense Affirms The same policy listed that "parties who do not complete this will be unregistered and must wait until the 15th of the month to apply to become a registered party."
5. The Defense Affirms The same policy listed that players could register their political parties "at any point in April."
6. The Defense Denies On May 7, 2025, the Labour Party, the Alexandria's Public Service Party, and the United Central Party all failed to properly maintain their registration as described within the party policy requirements. See Exhibit D; Exhibit E; Exhibit F.
7. The Defense Affirms On May 9, 2025 (UTC), the Ministry of Internal Affairs announced that parties would be able to maintain their registration until May 15, 2025, and silently updated the Party Policy document to reflect these changes. See Exhibit A; Exhibit B; Exhibit C.
8. The Defense Neither Confirms nor denies On May 9, 2025 (UTC), the Sovereign Kingdom Party, a political entity lawfully incorporated and properly maintaining its registration with the Ministry of Internal Affairs noticed this announcement and brought forth this lawsuit.

II. DEFENCES
1. The Plaintiff in recounting the alleged violation of the law brings up that all players are "equal before and under the law" which the Crown agrees but their argument is confusing Equality with Equity. The policy was applied uniformly and for the benefit and use of all parties which would be the "equal before and under the law" standard as no party was treated differently. What the defense is alleging is Equity before and under the law as they feel that even though every party was granted the same extension, the parties already able to maintain their registration status should receive special treatment and consideration.

2. The crown is confused as to what the end goal of the SKP in this case is. Even if the parties were to be deregistered, they could register again on the 15th and declare when declarations open on the same day. No party would lose their ability to run. The SKPs end goal in this case is to mildly inconvenience the 3 parties mentioned by having they register on the 15th instead of earlier. It is also possible that this case finishes after the 15th by which the time for action would have been over leading to nothing happening even if the SKP wins.


By making this submission, I agree I understand the penalties of lying in court and the fact that I am subject to perjury should I knowingly make a false statement in court.

DATED: The 10th day of May 2025

 

[Ibney0]

Your honors, I ask for a ruling on the merits of the preliminary injunction at this time. The deadline for a response from the defence has passed.

 

[Smallfries]

IN THE CHANCERY OF THE KINGDOM OF ALEXANDRIAENTREATY FOR EMERGENCY INJUNCTION

The Ministry of Internal Affairs has modified the Party Policy in order to favor political parties who failed to follow the rules that were previously set out under the law. This unfair treatment of parties who failed to follow the rules causes immediate and irreparable harm by ruining the sanctity and fairness of Alexandria’s very first Parliamentary election. This Emergency Injunction requests:- The Ministry of Internal Affairs’ “Party Policy” be reverted to its state prior to the unconstitutional change;- The Ministry of Internal Affairs be barred from updating the policy for the duration of this lawsuit​

IN THE CHANCERY OF
THE KINGDOM OF ALEXANDRIA
RESPONSE TO WRIT
​

Claimant asks the Chancery to rule that a policy the Government has made be illicit, and bar them from changing the law until the time of the upcoming election has passed. The Chancery has mulled this issue for several days, and have come to the following conclusion as to this Entreaty for Emergency Relief:

The First Parliamentary Elections are slated to begin (at least insofar as proceedings may begin) on the fifteenth of this month of May, two-thousand twenty-five. This is both a momentous and exciting occasion, and one that fills many with dread and worry. The Elections, thus far, have been plagued with controversy and instability as frantic policy makers work to construct a make-shift bridge to hastily get the subjects of this nascent Kingdom across the chaotic chasm below. The Chancery has boldly decided to take the first steps, and is cautiously holding a hand for others to join.

However, we strongly advise caution. This bridge, metaphorical as it is (if only barely) perhaps is the only route our nation has to stability, and it would be foolish to uncritically rip it apart. The Government created a policy, which they later rescinded. The former benefited the Claimant, and the latter removed that benefit. The Claimant now seeks to preserve that benefit. As to this instant action, we refuse to grant a Writ of Emergency Relief.

This is not a decision we make lightly. To ask the Chancery to, in effect, ban three parties days before the first election is a massive ask that we are not comfortable granting. To grant a Writ of Emergency Relief, a Claimant must show that they suffer some great harm that is intolerable for a reasonable person to bear under the circumstances. We do not think a party being deprived of a benefit by the entity (in this case, the Government) that granted such benefit rises to this level of intolerability.

Were the Claimant a party suffering from such a policy, we could perhaps entertain this motion. As it stands, however, we are extraordinarily hesitant to grant this sort of relief, which in effect would rule in favor for the Claimant without allowing the Defense a chance to make their case. We are bound by the Constitution, and as the Claimant points out: to ensure that all players are equal before and under the Law.

We do not rule as to any merits of this case at this time, and nothing in this Response should be considered as binding Opinion except that we refuse this Writ. This is an extraordinary case at an extraordinary time, and we attempt tonight to do the best we can with what the Government and the Constitution have given us to work with.

So ordered.

 

[Ibney0]

Your honors,

In light of this Courts ruling, we ask for leave to amend the complaint as to Sec. V to add the following sentence:

"We ask this Court issue declaratory relief that the Labour Party, the Alexandria's Public Service Party, and the United Central Party were not registered during the previous policies required time period, and thus were not properly registered for the May Elections."

With that, we submit for discovery and are ready to proceed.

 

[Smallfries]

Your honors,

In light of this Courts ruling, we ask for leave to amend the complaint as to Sec. V to add the following sentence:

"We ask this Court issue declaratory relief that the Labour Party, the Alexandria's Public Service Party, and the United Central Party were not registered during the previous policies required time period, and thus were not properly registered for the May Elections."

With that, we submit for discovery and are ready to proceed.

Discovery will begin at this point, and last for seventy-two hours. Parties may consent to abbreviate discovery or may motion to extend it.

The General Court Rules and Procedures dictate that any amendments must be declared and explained. To that, please explain for what reason you would like to make this amendment.

 

[Ibney0]

Discovery will begin at this point, and last for seventy-two hours. Parties may consent to abbreviate discovery or may motion to extend it.

The General Court Rules and Procedures dictate that any amendments must be declared and explained. To that, please explain for what reason you would like to make this amendment.

Yes, your honors.

Under the current Constitution, this Court may hear disputes from "the interpretation and application of the Constitution, as well as disputed returns arising from elections, including challenges to election results and qualifications of elected members of Parliament." Alex. Const. Part III, Sec. 15. From documents submitted to this Court by His Majesty's Government show, the Government intends to assert there is no prejudice from their actions, and that even if the Sovereign Kingdom Party prevails in these proceedings, it will have accomplished nothing:

2. The crown is confused as to what the end goal of the SKP in this case is. Even if the parties were to be deregistered, they could register again on the 15th and declare when declarations open on the same day. No party would lose their ability to run. The SKPs end goal in this case is to mildly inconvenience the 3 parties mentioned by having they register on the 15th instead of earlier. It is also possible that this case finishes after the 15th by which the time for action would have been over leading to nothing happening even if the SKP wins.

Answer, Part II, Sec. 2.

The Sovereign Kingdom Party sought to prevent the registration of the parties at issue in this case due to the breach by the Government with its original complaint. Claimant attempted to do so through their application for Extraordinary Writ. However, as that Writ was denied by this Honorable Court, Claimant now seeks to preserve its claim for additional litigation after the election.

Because our attempt to prevent injury failed, we now attempt to preserve the issue of qualifications for appeal should we succeed. As such, we ask under this Court's liberal amendment standard to allow for amendment.

Respectfully submitted,

Joseph Ibney
General Counsel
Sovereign Kingdom Party

 

[kaiserin]

Your honors,

In light of this Courts ruling, we ask for leave to amend the complaint as to Sec. V to add the following sentence:

"We ask this Court issue declaratory relief that the Labour Party, the Alexandria's Public Service Party, and the United Central Party were not registered during the previous policies required time period, and thus were not properly registered for the May Elections."

With that, we submit for discovery and are ready to proceed.

The Chancery hereby grants this request from Claimant to amend their Complaint. Please edit the initial filing accordingly.

 

[Ibney0]

Your honors,

We submit the following exhibit for discovery as Exhibit G.


Additionally, We tender @winterwolf as a witness in this case.

 

[kaiserin]

Discovery has now ended. The Claimant shall present their Opening Statements within seventy-two hours.

 

[Ibney0]

Opening Statement for the Plaintiff​

Your honors,

This case is about the arbitrary actions of the Ministry of Internal Affairs ("Ministry"). On May 7, 2025, the Labour Party, United Central Party, and the Alexandrian Public Servants Party all failed to submit mandatory reports with the Ministry. On May 9, 2025, the Ministry of Internal Affairs ("Ministry") announced that parties would nevertheless be able to maintain their registration until May 15, 2025. Importantly, this change came after all three parties were actively deregistered under the Ministry's own policies.

The Sovereign Kingdom Party ("SKP") noticed this issue and filed suit against the Ministry for its failure to treat its members "equal before and under the law." The SKP is a political party duly registered under the Ministry, and is made up of players whose rights are subject to protections under Alexandria's constitution. By granting all parties additional time to follow Ministry Policy and maintain registration, the Ministry has unequally applied the law to the offending parties. While appearing facially neutral, the rule only serves to assist the offending parties. The SKP receives no benefit from the policy change, and instead must now face parties which did not even properly comply with the rules as written.

Because all three parties were actively deregistered once the May 7th deadline passed, the parties themselves needed to wait until the 15th of the month to reregister. However, it was also impossible under the Ministry's own guidance to register on the 15th of May. The same ministry guidance specifies that "parties may register any time in April 2025," and "players may register their political party at any point in April." The Ministry only listed April as the month a party may register. This language gives guidance to the application period for parties to register, and additionally restricts parties by implication from registering in May.

You're going to hear from @winterwolf. They're the Minister of Internal Affairs. We expect they will testify that because the policy said they could register "on the 15th" that there was no prejudice in the actions taken by the ministry, and it was simply to just move up the timeline of events. However, you will notice they failed to take into account the April deadline self imposed by the Ministry. As this is a civil case, we bear the burden of proof. We must prove by a balance of the probabilities the actions undertaken by the Ministry were unequal. This means we merely must prove it is more likely than not those actions are unequal. We will meet that burden. Based on all available evidence, we will show more likely than not that the deadline was May 7th, and that registering on the 15th was impossible due to the April restrictions.

A government of laws can not function if the laws are not followed. It is imperative that the Ministry not be allowed to change its mind to help out parties who refuse to follow their own rules. Because of this, the SKP asks this honorable Court to strike down the current party policy document and revert it back to the May 8, 2025 version. Additionally, the Sovereign Kingdom Party requests this Honorable Court instruct the Ministry of Internal Affairs to deregister the Labour Party, the Alexandria's Public Service Party, and the United Central Party until such time they comply with the law. We ask this Court issue declaratory relief that the Labour Party, the Alexandria's Public Service Party, and the United Central Party were not registered during the previous policies required time period, and thus were not properly registered for the May Elections.

Thank you.

 

[Smallfries]

The Crown will have seventy-two hours to give their opening statement.