06 December 2011

DEFENSE ARGUMENTS FOR PHAM BA HAI IN THE APPEAL COURT OF THE PEOPLE’S SUPREME COURT


At 8 a.m of August 08, 2008

Dear Jury (Panel),

I, lawyer Le Tran Luat, who am approved by the People’s Supreme Court to defend Mr. Pham Ba Hai, the activist for democracy.

The reason I don’t call Mr. Pham Ba Hai the defendant but the activist for democracy is that I do believe that his actions which have just been accused by the first instance level are not guilty if not mean that they will bring lots of good results for the evolution of democracy in Vietnam that a democratic society is the desire of the people of Vietnam and the essence, the goal of the Socialist Republic of Vietnam.

Dear Jury,

First of all, I, together with the Procuracy to elucidate:

1. What is to oppose the Socialist Republic of Vietnam?

I would begin to advocate for Mr. Pham Ba Hai by debate against the Procuracyon the legal concept of “the Socialist Republic of Vietnam” and the so-called “against the Socialist Republic of Vietnam”. I would repeat that I want to have a debate on this concept from the legal point of view. I cannot find any guidelines of the Supreme Court as well as the Congress interpreting legal term, “against the Socialist Republic of Vietnam”, which is expressed with what specific acts and what its content of expression? Needing to remind that one of the factors/elementsthat constitutes crime is the object or known as infringed legal relations. So the Procurary must point outspecifically what social relation or group of social relations Mr. Pham Ba Hai’s actions have infringed according to the Article 88.

Dear Jury,

To further justify Mr. Pham Ba Hai’s actions, I find it necessary to raise how the legal concept of “the Socialist Republic of Vietnam” should be understood thoroughly.

The August 1945 Revolution abolished feudalism, terminating permanently the structure of “hereditary succession” to build a democratic state in which  power belongs to the people through the electoral mechanism, setting criteria of democracy, equality, justice, civilization, comfortable life as goal. With such criteria and aim, the Vietnamese revolutionary leaders were determined to follow the line of thought of the Marxist-Leninist to build a state known as the Socialist Republic of Vietnam. So, first of all, the concept of the socialist state, in general, and the Socialist Republic of Vietnam, in particular, is a system of thought. 


In my opinion, this system of thought is rendered to the objective world in 2 basic contents, namely: political system, system of state apparatus and the operations of these 2 systems. Many instruments of Vietnamese Communist Party Congress have ever acknowledged the shortcomings in the process of mobilizing these systems and necessity for regulation so as to perfect and accord with the objective needs of the Vietnamese people who wish a life of comfort, democracy and happiness. In the movement of these systems, there must be factors/elements which impede the fulfillment of the above-mentioned goals of the Socialist Republic of Vietnam.

Are whether the resistance and protest against those impeding factors/elements against the Socialist Republic of Vietnam or not?

The reason I have raised this argument and requested the Procurary to point out what legal relations have been infringed is simply that the concept of state is an extremely abstract one which I am sure that I and the Procurary have not yet understood thoroughly. On the other hand, the Penal Code of Vietnam’s Article 88 is a deeply indistinct and enigmatic article of law that we don’t have any guidelines of the Supreme Court or Congress on the legal concept of this crime so we will easily fall into the states of subjectivity, attribution and slander.

If the Procurary want to impute Mr. Pham Ba Hai’s actions to then anti-Socialist Republic of Vietnam, then what infringed legal relation has to be pointed out.

Pointing out what legal relation known as the anti-state will clarify whether Mr. Pham Ba Hai’ssense of subjective side is against the State or not, but I will present in the next section.

Next, I am going further into analyzing Mr. Pham Ba Hai’s specific actions and Bach Dang Giang Foundation:

II. Mr. Pham Ba Hai’s actions are not against the Socialist Republic of Vietnam but the factors/elements that have hindered the social progress.

The First Instance trial has accused Mr. Pham Ba Hai of the propaganda against the Socialist Republic of Vietnam based on the following series of actions:
1. Having established Bach Dang Giang Foundation with 4 tasks:

a. Speeding up the propaganda activities; providing the people with the truth of the development of the country. Encouraging, supporting, spreading every movement and thought offree democracy.
b. Supporting the establishment of independent trade union to defend workers’ interests, going to replace the Socialist Republic of Vietnam and building up multi-party pluralism.
c. Providing scholarships to juniors of those who had fled the country but were forced to repatriate and called “the victims of discrimination, differentiation and ill-treatment” by Bach Dang Giang Foundation in order to train and build up a new young generation.
d. Humanitarian activities to encourage physically and materially the disabled puppet soldiers and all the strata and individuals who are victims of the communist tyranny.

2. Having written the followings: “Letter dated March 17, 2005, to Venerable Thich Man Chau in the United States” (The judgment of First Instance considered the letter referring to the issue of “Pham Ba Hai had been expelled from Law school and detained in Thu Duc’s Public Security Department for 06 months” as untrue); “Stigma of Vietnam in the race against Taiwan and Korea”; “Opportunity to overcome was deprived: 1954 – 1975”; “National Unity: Golden chance for development”; “Advancing to the socialism: 10 years for finding the clue of tie”; “What can save today”.

3. Participating in Block 8406
I think that the First Instance Level has not proved that Mr. Pham Ba Hai’s subjective sense was against the Socialist Republic of Vietnam. In my opinion, about subjective side, Mr. Pham Ba Hai only had the sense of resistance and protest against the factors which had blocked the development process of Vietnam.

First of all, I would ask the Procuraryif in the system of the law of Vietnam there is any article that forbids the establishment of organization. If not, I continue my analysis:

1. The establishment of Bach Dang Giang Foundation with 4 tasks listed by the judgment of first instance that I have re-presented above do not have any task which was against the Socialist Republic of Vietnam.

_ It does not make sense if “providing the people with the truth of the development of the country; Encouraging, supporting, spreading every movement and thought of free democracy” are against the Socialist Republic of Vietnam. Thought of free democracy is one of the top assignments which the Socialist Republic of Vietnam is heading. So why is the action of encouraging the thought of free democracy considered as anti-Socialist Republic of Vietnam?
_ Supporting the establishment of independent trade union to defend workers’ interests, going to replace the Socialist Republic of Vietnam and building up pluralistic, multi-party system. First of all, in the original of the objective of Bach Dang Giang Foundation posted publicly at the address www.bachdanggian.org clearly wrting “going to replace the one-party dictatorship” with “free democratic pluralism”, completely not “going to replace the Socialist Republic of Vietnam and building up pluralistic, multi-party system” (Records 0060, 0061). It is obvious that the Procurary have replaced on its own initiative the phrase “going to replace one-part dictatorship” with the other “replace the Socialist Republic of Vietnam”. That is the deliberate fabrication to shift blame onto Mr. Pham Ba Hai and Bach Dang Giang Foundation for the sense against the Socialist Republic of Vietnam.

Back to the issue of Supporting the establishment of independent trade union to defend workers’ interests. I would remind that the Socialist Republic of Vietnam in particular and the State of Socialist Republic in general rely on the base of the working class’s interests. So, the establishment of independent trade unions and defense of the workers’ interests are not against the Socialist Republic of Vietnam but to support her as inferred by First Instance Level.

The call for multi-party pluralism, in my opinion, it is simply a solution for the process of democratizing country. The leaders of our State think that it is enough to be governed by only one communist party and this is also a solution. Raising a solution for a democratic process is not with the aim of being against the Socialist Republic of Vietnam. Needing to remind that when abolishing the feudalism, hereditary succession, our leaders desired to build a democratic society where power belonged to the people through electoral mechanism so that the people executed their power. I don’t criticize whether the issue of multi-party pluralism is right or not but I think that multi-party pluralism is not an illogical solution.

Granting scholarships and supporting disabled veterans are simply the humanitarian activities of an organization and I felt no need for further comment because the Procurary and Jury can realize it easily.

The additional findings numbered 145/ANĐT dated September 12, 2007 of the Department of Public Security’s Security Agencies saying that Mr. Pham Ba Hai’s granting scholarships “with the aim of training young leading generations to replace the leaders of the Vietnamese Communist Party towards the country” was a subjective deduction. It represents the thinking of conservativeness, stagnation, clinging to power and position and counter-science of the Department of Public Security’s Security Agencies. Anyone, including the leaders, must also age and die, “old bamboo shoots grow” is the law of social evolution. If the young generation that Mr. Pham Ba Hai granted scholarships and trained is competent, moral and worth governing the country, then it is a very good thing, joyfulness and happy fate of the Vietnamese people. The goal to build the country of the Vietnamese government is to move towards a fair, democratic and civilized society so the reason why the ones with full competence, morals cannot replace the leaders of the Vietnamese Communist Party to continue governing the country.

Thus, the establishment of Bach Dang Giang Foundation with the above-mentioned tasks, in my opinion, is not to aim at opposing the Socialist Republic of Vietnam but to head to the construction of a fair, democratic society.

2/ The First Instance Level judged that Mr. Pham Ba Hai had written 6 articles and having relied on Mr. Pham Minh Nghiep’s assessment conclusion to conclude that Mr. Pham Ba Hai had had the subjective sense against the Socialist Republic of Vietnam is not satisfactory because:

- Letter written to the Venerable Thich Man Giac as an exchanging one between individual and individual was seized at the private house (or printed from the computer at Mr. Pham Ba Hai’s house, the investigation documents did not specify, Records 0140). This was Mr. Pham Ba Hai’spersonal letter exchanging with the VenearableThich Man Giac, so the writer could write what he liked, even invent many untrue circumstances etc…it doesn’t make sense if a personal letter had to be written correctly pursuant to the lines and policies of the government. I really don’t understand why a personal letter was considered against the state.

- In the remaining 5 articles, there was only article “Stigma of Vietnam in the race against Taiwan and Korea” taken into the case file and appraised and the contents of these articles were not included, not knowing what had been written.In the public questioning at the first instance court, there was no mention of what the contents of these articles were, no elucidation of what had been written wrongly, then what grounds for saying that the contents of them were erroneous?

- In the article “Stigma of Vietnam in the race against Taiwan and Korea”, Mr. Pham Ba Hai claimed that Spratlys Islands, Paracels Islands and Nam Quan Pass were a part of the territory of Vietnam. Mr. Pham Ba Hai felt great anguish when a part of his country had fallen into the hands of other country like you were hurt when having lost a part of your body. It should be recalled that in the history of our combatting aggressors, China was one of the countries that had invaded our country most. Maybe the Procurary is the one who knows this better. Was feeling great anguish when a part of country had fallen into the hands of another considered against the Socialist Republic of Vietnam?

- The remaining 5 articles were not mentioned by the First Instance Level. Therefore, pursuant to the regulation of Item 1, Article 184 of the Code of Criminal Proceedings saying “the verdict is only based on the evidences considered at the hearing”, the aforementioned 5 articles had not been considered at the first instance trial, so they cannot be regarded as evidence to accuse Mr. Pham Ba Hai.

On the other hand, the First Instance Level’s relying on Mr. Nguyen Minh Nghiep’s assessment conclusion numbered 123/KLGĐTP dated October 25, 2006 to accuse Mr. Pham Ba Hai is not objective:

- With regard to the form: This assessment conclusion numbered 123/KLGĐTP is not legal because Mr. Nguyen Minh Nghiep signed it as assessor in charge of assessment without the decision of appointing him to the position of justice assessor of Ho Chi Minh City’s People’s Committee or the confirmation of the assessor’s signature of the People’s Committee of the City, so Mr. Nghiep’s status of assessor cannot be certified. Authenticating the signature of Mr. Nguyen Minh Son (as receiver/deliver) of Inspection Office of Import-Export Cultural Products under the Department of Culture and Information of Ho Chi Minh City was in his capacity as Deputy Manager of Inspection Office of Import-Export Cultural Products, not as assessor. So, the assessment conclusion numbered 123/KLGĐTP has no validity as evidence for accusation (Item 3, Article 9 of the Judicial Assessment Ordinance).

Needing to add that, the Department of Culture and Information of Ho Chi Minh City is a state agency, a component part in the apparatus of the state, then its assessment conclusion on an issue that itself is a subject of being against is clearly not objective. The Department of Public Security’s Security Agencies ought not to have had reverse consultation from the department level downward to the subordinate one as staff of the Department of Culture and Information of Ho Chi Minh City but from the independent individuals, overseas organizations and expertise (Item 2, Article 24 of the Judicial Assessment Ordinance).

- With regard to the content: The assessment conclusion numbered 123/KLGĐTP concluded: “This is a bad document, the articles contain thoughts of incitation, calling with political language which has subversive nature, negative effects to the social stability of the renovation, causing damage to the national security, violating the law of Vietnam. The documents show a dangerous quality of an opposing tendency firmly structured by an organization, a large-scale system having relationship with a foreign reactionary influence practically threatening to the national security and social safety”. Obviously, this is a judgment which has deductive nature according to the subjective intention of Mr. Nguyen Minh Nghiep because he kept repeating the words such as “misrepresenting”, “speaking ill”, “bad documents” etc…but did not point out concretely which sentence “misrepresented”the truth, whatwas “being badl”, what the truth of that issue was, what point was detrimental to the stability of society, what was the result. Mr. Nghiep authorized himself on behalf of the agency to conclude “large-scale system having relationship with an overseas reactionary force” but did not indicate what that overseas reactionary force was. Finally, he only referred generally to violating the law of press and Decree numbered 55/NĐ-CP without pointing out the specific violation of what item, article, and clause of those two documents.

Although the first instance verdict had not cited clearly the article “Stigma of Vietnam in the race against Taiwan and Korea”, it was specified in the additional investigation conclusion so I further analyze:

Article 1: “Opportunity to overcome was deprived: 1954 – 1975”

The proceedings agency thinks that Mr. Pham Ba Hai “distorted the fruit of the national liberation struggle” in the sentence:

“What the Vietnamese Communists’ bellicosity and brutality had caused to the Northerners for 30 years was clearly written in the history. Why the Vietnamese Communists did not let the Southerners, with the same background, give their mind to improving the economic development and competition with Taiwan and Korea. In the first sentence, Mr. Pham Ba Haidid not judge or comment but only stated that the history would acknowledge, so it cannot be infer as “distortion”. In the next sentence, by using the interrogative “why not” Mr. Pham Ba Haiput the supposition about a stage of society and not also affirmed anything, so it could not all the more be attributed the truth distortion to the author.

Article 2: “National Unity – Golden Chance For Development”

Considered as “distorting the economic development, criticizing the leadership of the Party and State” pursuant to the paragraph: “In 1986 the Socialist regime marked the poverty of the people with the hyperinflation reaching the world record, 777,7%. Where were the achievements for building the socialism in the North?”

Maybe the proceedings agency forgot that the First National Congress of the Vietnamese Communist Party’s XI had been considered as the first congress opening the renovation stage for the economy of Vietnam. Why did it have to renovate? Because the economy at that time was in extreme crisis, the state of Vietnam had to choose between 2 ways: dying or renovating? And the 6th congress chose renovation.

The resolution of the 6th Congress judged that “the situation of the socio-economy is facing the severe difficulties such as production increasing slowly; low efficiency in production and investment; distribution and circulation have much confusion; significant unbalances in the economy have slowly been narrowed, some aspect is more severe; socialist production relations are slowly strengthened; the living condition of the labor class still has a lots of difficulties; negative phenomenon happens in many places, some are serious”, “not yet determined to overcome hasty subjectivity, conservativeness and stagnation in the arrangement of economic structure, socialist reform and economic management and committing new and serious mistakesin distribution and circulation”.

Therefore, the resolution of the 6th Congress brought out the directions: “Urgently correcting, implementing the economic policies, especially the ones in material supply, commodity circulation, pricing, tax, credit, wages…in order to encourage the establishments, workers, farmers and craftsmen eagerly to develop production”, “reforming economic management mechanism in order to create motivation to the economic units, labor masses for eagerly developing production, increasing capacity, quality and economic efficiency”.

The above-mentioned quotes from the 6th Congress instrument show that Mr. Pham Ba Hai wrote correctly about the reality of the society of Vietnam in the period of 1986 so the accusation of “distorting the economic development, criticizing the leadership of the Party and State” is groundless.

Article 3: “Advancing to the socialism: 10 years for finding the clue of tie” is reckoned as “distorting the line of the economic development of Vietnam”, having paragraph “The standard of living of the civilians is improved much or little, domineered over or liberated to what extent, the past 30 years and future, depending on the hands of the Vietnamese Communists. Whether or not they have thought this opportunity, though belated, is a great one for the nationality, not misusing the civilians’ force, washing out the interminable insults”. In the first sentence, from “the standard of living of the people” to “the hands of the Vietnamese Communists”, it is a completely sound judgment of Mr. Pham Ba Hai about the actual situation of Vietnam. The Vietnamese Communist Party is leading Vietnam then there is no reason why the people depend on the foreign capitalists but it is right for them to depend on the Vietnamese Communists. In the next sentence, the word “They” is to point at the Communists and the writer put a question that why not “misusing the civilians’ force”? Do not coerce the civilians to do what they are unable to do, it was also the advice of Hung Dao Vuong Tran Quoc Tuan in “Call of Soldiers”. If deducing that the request of “not misusing the civilians’ force” is the distortion of the line so Hung Dao Vuong was also the one who “had distorted the line of the economic development” of the King Tran.

Article 4: “What can save today” is imputed as “backbiting the leading line of the Vietnamese Communist Party” through the sentence: “TV of the Communist has to project their films to satisfy the people’s liking besides the music and fashion etc…The Party’s culture, propaganda films have made the spiritual life of the people crippled, unbalanced. The tragic consequence of that is that there have been tens of thousands of Vietnamese girls who have been daughters-in-law abroad, enduring countless humiliation in Taiwan and Korea”, “thoroughly economic resolution to shorten the different distance, gradually deleting the national humiliation; the thoroughly political resolution to maintain efficiency and bring into play all the national potential. The program of action of the patriotic people today is to follow the call from the democrats, demanding multi-party pluralism and free elections”.

In this quote, the additional investigation conclusion truncated the first sentence “Stigma of the Socialist Republic of Vietnam is inferior and backward, the inferiority has weighed on the conscience of the patriotic intellectuals and the backwardness has closely surrounded the civilians and the poor” but only took the following clause that has made the sentence obscure and misleading the writer’s idea.

“The tens of thousands of the Vietnamese girls who have been daughters-in-law abroad” have had to live as sexual slaves; being beaten and even brutally killed…is an actual situation that no one can deny. Voicing a reality of the society of Vietnam which everyone knows is not “the defamation of the Party”. The fact that is unable to be denied is that our economy cannot be developed as the same as Taiwan and Korea. We are more backward than them and our people are poorer than theirs. Saying that we feel humiliated to the countries with the same conditions and circumstances but they have more developed and civilized than us is totally right. There is no reason why we are proud that our country is more inferior and backward than the other countries.

The Penal Code does not have any offense prescribing the action of “backbiting the leading line of the Communist Party” so “backbiting the leading line of the Vietnamese Communist Party”, if any, is not against the Socialist State.

Considering thoroughly all the articles of Mr. Pham Ba Hai, the facts and figures about the economic situation of Vietnam adduced in them are correct. When evaluating a work, we must evaluate it on the overall and subjective basis and not entitled to cut into pieces of words out of the context of the article then infer wrongly pursuant to the reader’s idea as the assessment conclusion and additional investigation conclusion did.

Therefore, it can be affirmed that the above articles are based on accurate events, expressing the protesting ideas of Mr. Pham Ba Hai towards the factors/elements hindering the social progress and not aiming at opposing the Socialist Republic of Vietnam.

3. Action of participating in the Block 8406:

The Decision numbered 127/2007/QĐ-THS dated July 19, 2007, of Ho Chi Minh City’s People’s Court requested the supply of documents, evidences to prove “how the activities of Block 8406 has opposed the government are” and the additional investigation conclusion of the Department of Public Security’s Security Agencies did not supply any further document or evidence.

In today court, if the Procurary can point out document or evidence showing the conclusion for the Block 8406’s activities are to aim at opposing the Socialist Republic of Vietnam and whether or not the document is publicly proclaimed, if any, I would agree that Mr. Pham Ba Hai purposed to oppose the Socialist Republic of Vietnam. If the Procurary do not provide further new evidences, then this action does not obviously commit the offence of propagandizing the Socialist Republic of Vietnam.

Dear Jury,

From the arguments presented above, I respectfully request the Jury to declare that Mr. Pham Ba Hai is not guilty of propaganda against the Socialist Republic of Vietnam. Together with the Procurary to clarify Mr. Pham Ba Hai’s actions, I summarize 4 key issues to argue:

-       What is to oppose the Socialist Republic of Vietnam?
-       Whether or not the establishment of Bach Dang Giang Foundation and Mr. Pham Ba Hai’s articles have targeted towards opposing the Socialist Republic of Vietnam.
-       Whether or not the action of participating in the Block 8406 has intended for opposing the Socialist Republic of Vietnam.
-       Whether or not the assessment conclusion is objective.

Thank you for listening!

Lawyer Le Tran Luat

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