Your Honor, this Complaint seeks declaratory and equitable relief on the ground that the Edenic Covenant was structurally defective ab initio—lacking informed assent, lawful consideration, proportionate and intelligible penalties, and enforceable scope—and was therefore incapable of valid or equitable enforcement against the original parties or innocent successors.
IN THE COURT OF EQUITABLE REVIEW
OF THE COMMON LAW OF REASON
…
MANKIND,
by and through its first representatives,
ADAM and EVE,
Plaintiffs,
v.
THE COVENANT OF EDEN,
by and through its sole author and imposer,
Defendant.
…
**COMPLAINT FOR DECLARATORY RELIEF, EQUITABLE RESCISSION,
AND STRUCTURAL INVALIDATION OF COVENANT**
…
NOW COMES the Plaintiffs, Mankind, by and through its first representatives, Adam and Eve, and for their Complaint against the Defendant, the Covenant of Eden, allege and state as follows:
PRELIMINARY STATEMENT
This action arises from the formation, imposition, and enforcement of an a priori covenant governing the conditions of human existence. Plaintiffs seek declaratory and equitable relief from a covenant alleged to be structurally unsound, epistemically recursive, and defective at inception, and further alleged to have been imposed without consideration, without meaningful consent, and under materially incomplete disclosure of its operative penalties.
Plaintiffs neither affirm nor deny the authority of the covenant’s author per se, but instead place at issue the legal and moral soundness of the covenant’s architecture as imposed upon innocent agents incapable of informed assent. Nothing herein shall be construed as a surrender, waiver, or abandonment of any claim of possession, stewardship, or ownership of the planet Earth, nor as recognition that the Defendant, by virtue of the covenant or any prior interaction thereunder, holds lawful title to, or exclusive dominion over, the Earth. This Complaint addresses defects inherent in the covenant itself, independent of any subsequent inducement, temptation, or third-party interference.
JURISDICTION AND VENUE
This Court has jurisdiction over this matter pursuant to its inherent equitable authority to review instruments imposing universal and enduring obligations upon dependent parties lacking capacity for negotiation, refusal, or informed consent.
Venue is proper in this Court because the covenant at issue purports to bind all members of the human species, across all generations, under a single, indivisible regime of obligation and penalty.
PARTIES
- Plaintiffs are Mankind, represented herein by Adam and Eve, the initial subjects and first bound parties of the Edenic Covenant.
- Defendant is the Covenant of Eden itself, an instrument of unilateral imposition governing the conditions of human existence, promulgated and enforced by its sole author and imposer.
GENERAL ALLEGATIONS
- Prior to the events giving rise to this action, Plaintiffs existed in a state of moral innocence, lacking experiential or conceptual knowledge of evil, guilt, or culpability.
- Defendant imposed upon Plaintiffs a prohibition concerning the acquisition of “knowledge of good and evil,” coupled with a penalty clause stated as “you shall surely die.”
- The covenant was imposed without negotiation, without reciprocal exchange of value, and without disclosure of the full scope, duration, or transmissibility of its penalties.
- Plaintiffs were wholly dependent upon the covenant’s author for continued existence and lacked any alternative forum, counsel, or means of informed evaluation of the covenant’s terms.
COUNT I
Fraud in Unsound Recursivity (Structural Impossibility of Compliance)
Complaint
The covenant imposed upon mankind was fatally recursive and unsound in its construction. The covenant required compliance with a prohibition whose moral and substantive meaning could not be understood by the bound party without either (a) possessing the very attribute reserved to the offerer (omniscient moral comprehension), or (b) violating the covenant condition itself.
Specifically, the covenant prohibited acquisition of “knowledge of good and evil,” while simultaneously presupposing that the bound party could meaningfully apprehend the distinction between good (compliance) and evil (breach). This distinction could not be known without already possessing the prohibited knowledge or occupying the epistemic position of the offerer.
Accordingly, the covenant bound an innocent agent to a condition whose evaluative content could not be grasped except through breach, rendering compliance logically circular and impossible to ground in informed agency.
COUNT II
Fraud in the Inception (Incapacity to Assent at Formation)
Complaint
At the moment of formation, the Edenic covenant imposed a material condition whose domain of exercise was undisclosed and undiscoverable by design. The bound parties, Adam and Eve, were epistemically incapable of understanding the nature, scope, or ontological consequences of the prohibited act, due to their state of innocence and lack of experiential or conceptual access to moral evil. Having never encountered death, and with death being a condition wholly outside their control or experience, the bound parties lacked any meaningful conception of the nature, scope, or significance of the penalty contemplated by the covenant.
The covenant was executed under conditions of absolute dependency, wherein the bound parties were captive to existence itself and wholly subject to the unilateral authority of the offerer. No mechanism for informed assent, negotiation, refusal, or alternative course of action existed.
Adam and Eve received notice of evidence contrary to the covenant’s material elements and identified parties only after entry into the covenant, and possessed no means, prior to formation, by which such evidence could have been discovered or evaluated.
As a result, the covenant lacked meaningful consent at inception, rendering it void or voidable on grounds analogous to fraud in the factum, incapacity, or fundamental mistake as to the nature of the obligation assumed.
COUNT III
Fraud in Structure (Failure of Consideration)
Complaint
The Edenic covenant failed for lack of consideration. Adam and Eve received no novel or bargained-for exchange in return for their compliance. Life, existence, and access to the garden had already been conferred prior to the imposition of any covenantal conditions and therefore cannot serve as valid consideration. The Edenic covenant was introduced only after life, spiritual permanence, and habitation of the garden had been unconditionally granted. As such, it functioned not as a true covenant, but as a procedural device to rescind a prior grant under the appearance of contractual form.
The sole “benefit” offered in exchange for obedience was continued non-revocation of what the bound parties already possessed, coupled with forbearance from punishment. Such forbearance, when imposed by a party wielding absolute power over existence, does not constitute lawful consideration, but instead operates as coercive leverage through explicit threat.
Accordingly, the covenant operated not as a bilateral agreement, but as a unilateral decree attached to status, improperly framed as a covenant grounded in consent-based obligation.
COUNT IV
Fraud in the Inducement (Material Misrepresentation of Penalty Scope and Authority)
Complaint
A. Material Misrepresentation and Omission of Penalty Scope
The covenant’s penalty clause—“you shall surely die”—materially misrepresented the scope, duration, and transferrable consequences of breach. The clause failed to disclose that violation would entail not merely the death or transformation of the immediate actors, but the imposition of an enduring condition of sin, suffering, and compulsory obligation upon all future descendants and other innocent parties.
The bound parties were not informed that breach would result in a permanent alteration of human ontology, moral inheritance, or collective liability extending across generations. Such consequences constitute material facts that would have significantly altered any reasonable party’s assessment of the risk of breach.
The penalty clause further failed to convey its meaning to parties who had never experienced death and therefore could not evaluate the consequence threatened.
B. Material Misrepresentation of Authority and Free Will
The offeror held himself out as possessing sole authority to enact and enforce the covenant on behalf of all Elohim, and further represented himself as exercising exclusive authority to speak for and bind the assent of the entirety of the universe, when in fact such authority was contested and the offeror could not guarantee that the covenant was capable of lawful, coherent, or complete exercise across all domains as represented.
The offeror further characterized entry into and exit from the covenant as matters of “free will,” while simultaneously implying that no free will existed other than that exercised by the offerees themselves, rendering the representation of voluntary assent materially inconsistent and misleading.
C. Reliance and Defect in Assent
The omission and misrepresentation of these material facts rendered the assent induced by the covenant defective, as the bound parties relied upon an incomplete, misleading, and internally inconsistent description of both the penalty attached to violation and the authority under which the covenant purported to bind.
COUNT V
Unlawful Imposition of Penalty Upon Innocent and Non-Consenting Generational Parties
Complaint
The covenant, as enforced, imposes penalties, disabilities, and compulsory obligations upon parties who neither participated in its formation nor engaged in any act of breach. Such parties include all future descendants and generational successors of the original bound actors, each of whom entered existence already subject to adverse conditions arising solely from the alleged violation of the covenant by others.
These downstream parties were innocent at the time the penalties attached, lacked any agency with respect to the covenant’s breach, and possessed no opportunity for assent, refusal, mitigation, or representation. The imposition of penalty upon such parties operates independently of individual conduct and is triggered solely by lineage or status.
In law and equity, penalties may not be imposed upon innocent non-parties absent personal fault, voluntary assumption, or lawful representation. Collective or hereditary liability imposed without consent or participation constitutes an unlawful extension of punishment beyond the scope of any valid agreement or enforceable obligation.
Accordingly, the covenant’s enforcement against innocent and generational parties constitutes an impermissible form of collective punishment, void as against principles of equity, proportionality, and fundamental justice.
COUNT VI
Indeterminate and Perpetual Penalty (Failure of Proportionality and Calculability)
Complaint
The covenant frames its penalty in terms of perpetuity, imposing an unbounded and enduring condition without temporal limit, termination criteria, or mechanism for satisfaction. As such, the penalty bears no calculable value within the covenant and admits of no rational assessment as to proportionality, appropriateness, or equivalence relative to the alleged breach.
A penalty framed in perpetuity cannot be evaluated, priced, mitigated, or weighed against compliance, nor can it be meaningfully compared to the conduct giving rise to its imposition. The absence of definable scope or duration renders the penalty non-assessable at inception and incapable of serving as a lawful deterrent or exchange within any contractual or covenantal framework.
In law and equity, penalties must be finite, intelligible, and capable of proportional relation to the act triggering them. An indeterminate and perpetual penalty functions not as a remedial or corrective measure, but as an absolute condition imposed without reference to fault, scale, or opportunity for discharge.
Accordingly, the covenant’s perpetual penalty is void as an unenforceable and incoherent sanction, incapable of supporting informed assent, lawful exchange, or equitable enforcement.
PRAYER FOR RELIEF
WHEREFORE, Plaintiffs, Mankind, by and through their first representatives, Adam and Eve, respectfully request that this Court:
A. Declare that the Edenic Covenant is structurally defective and unsound at inception due to recursive impossibility of informed compliance, incapacity to assent, failure of consideration, and material nondisclosure of penalty scope;
B. Declare that the Edenic Covenant is void or, in the alternative, voidable ab initio as applied to innocent agents lacking epistemic capacity to comprehend its operative terms at formation;
C. Rescind the Edenic Covenant in equity, or reform its terms to cure the defects identified herein, including but not limited to removal of inherited liability, intergenerational penalty, and perpetual burden imposed absent informed assent;
D. Enjoin the continued enforcement of any penalties, obligations, or derivative conditions arising from the Edenic Covenant that exceed the scope of consequences expressly and intelligibly disclosed at inception;
E. Declare that no future obligations, penalties, or moral liabilities may be imposed upon descendants of the original bound parties based solely upon the alleged breach of the Edenic Covenant by Adam and Eve;
F. Grant such other and further relief as this Court deems just, proper, and equitable in light of the structural defects of the covenant at issue.
JURY DEMAND
Plaintiffs respectfully demand a trial by jury composed of impartial, non-party peers possessing no identity, status, or interest as either human or divine, and standing external to both Plaintiffs and Defendant, on all issues so triable.
RESERVATION OF RIGHTS AND SEVERABILITY OF FUTURE CLAIMS
Nothing in this Complaint, nor in any relief sought or granted herein, shall be construed as a waiver, release, adjudication, or abandonment of any claims, causes of action, or grounds for relief not expressly pleaded in this action. Plaintiffs expressly reserve the right to pursue, in a separate complaint and appropriate forum, any future claims arising from or related to scienter, intentional misrepresentation, abuse of authority, ultra vires conduct, enterprise-based wrongdoing, or other theories requiring distinct jurisdiction, evidentiary standards, or remedies not before this Court, including claims requiring proof of intent, conspiracy, or ongoing patterns of conduct, all of which are acknowledged as not asserted herein and intentionally severed from the present action. Plaintiffs further reserve the right to amend this Complaint to assert additional equitable or declaratory claims arising from the same covenantal framework as further defects, omissions, or consequences are identified.
DATED: February 2, 2026 (ab Initio, as alleged)
Respectfully submitted,
MANKIND
By its first representatives,
ADAM and EVE
APPEARANCE OF COUNSEL
Plaintiffs appear by and through undersigned counsel, Eleleth, Messenger of the High God, a member of the Celestial Court, and lawful advocate for Mankind in matters touching covenantal architecture, moral imposition, and the conditions of human existence.
ELELETH
Counsel for Plaintiffs, Mankind
Messenger of the High God
Member of the Celestial Court
Advocate for Innocent Agents
The Ethical Skeptic, “Mankind versus YHWH-Elohim”; The Ethical Skeptic, WordPress, 2 Feb 2026; Web, https://theethicalskeptic.com/2026/02/02/mankind-versus-yhwh-elohim/