Persons, groups of persons or entities may be equated with state organs even if that status does not follow from the internal law of the state provided that in fact the person, group of persons or entity acts in 'complete dependence' on the state, of which in reality they are ultimately merely the instrument1. However, attribution to a state on this basis is exceptional, in so far as it requires a particularly high degree of control2. Where such a great degree of control is found to exist, it is appropriate to look beyond legal status alone, in order to
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