botswana/namibia - Cour international de Justice

421. This photograph is part of a series flown by the South African Defence Authorities in
June 1977, in accordance with a survey plan, copy of which has been obtained from the
Directorate of General Surveys, South Africa, and appears in the Botswana Supplementary
Atlas to this Counter-Memorial. to be used in the production of the 1978 Joint Air
Reconnaissance Intelligence Centre map (The JARIC map) (See the Botswana Atlas, Map
22).
422. As the photography was required for reconnaissance mapping, the scale of the original
series was very small; (1:150,000 or 1 cm = 1.5 kms.).
423. Even at this scale it is quite evident that the eastern and southern channel is very much
smaller than the western and northern channel, almost disappearing near the Headquarters of
the Chobe National Park and around the Sediment Spit marked 'A'. It is probably for this
reason that the military cartographers showed the southern channel as an inlet on the JARIC
map and not as a through channel.
424. This 1977 JARIC aerial photograph is shown in Figure 13 of the Second Opinion of
Professor Sefe, Appendix 2 to the Counter-Memorial, p.53. It was scanned at high resolution
and false colour applied to the resulting image. The contrast between the northern and
southern channel is revealing, showing the southern channel to be shallower than the northern
channel. The southern channel between the 'lagoon' sector and its confluence with the
northern channel and in the bend of the meander loop has the same colour tone as the Kasai
channel, indicating that both are of shallower depth than the northern channel.
The June 1997 Photographs (Scale 1;20,000 and 1:17,000) taken on 5 June 1997 (Photo K).
Reproduced with labels at page 187.
425. This photography was undertaken as the high-flood waters were receding to illustrate the
present-day situation around Kasikili/Sedudu Island and is the first official air-photograph
taken in this area since 1985. The surface of the island is still partially covered by shallow
water as is the central sections of the sediment spit marked 'B' in the southern channel.
G92 - July 1997 aerial photograph
G35 - June 1997 aerial photograph with labels
426. The Namibian Memorial refers to "the existence of ..sandbars and the changes in their
position and shape over the years" as indicative of active river flow (Namibian Memorial,
p.56,para.155) and Professor Alexander purports to identify such sandbars on Diagram 5 of
sheet 18 (Namibian Memorial, Vol.VI,Part 2, and see also Part 1, p.23, para.8.13) and cites
this as evidence that the southern channel is active and is therefore the main channel.
427. Reference to this photograph at the points marked 'B' and 'C', clearly reveals these same
sediment bars in essentially the same size, shape and location, as on the 1925 photograph
(photo 'A') and indeed on all the intervening photographs in the series.
428. This is visual proof that these features are permanent surface features over a period of 72
years and are in no way 'active'. This fact therefore completely contradicts the Professor
Alexander's theory that they are proof of an active channel.