Last Updated 19/10/2025 published 19/10/2025 by Hans Smedema

The Documentary as Redress: A Legal and Financial Analysis for Inclusion in the Smedema v. The Netherlands Damages Claim

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I. Executive Summary

 

This report presents a comprehensive legal and financial analysis supporting the inclusion of production costs for a feature-length investigative documentary within the damages claim of Ing. Hans Smedema against the Kingdom of the Netherlands. The central thesis of this analysis is that this claim is not for an ancillary or speculative damage, but for the quantifiable cost of a specific, non-monetary remedy mandated by international human rights law. The proposed documentary serves as a direct, proportionate, and necessary countermeasure to the extraordinary non-pecuniary harm inflicted by the State: a decades-long, systemic campaign of institutional invalidation and reputational destruction, designed to frame the claimant as “delusional”.1

The legal basis for this claim is firmly established in Article 14 of the United Nations Convention Against Torture (UNCAT), as authoritatively interpreted by the Committee Against Torture. This framework mandates that “redress” for victims must be comprehensive, extending beyond mere monetary compensation to include measures of “satisfaction” and “guarantees of non-repetition”.2 The documentary is precisely such a measure, uniquely capable of achieving the “full and public disclosure of the truth” and “restoring the dignity, the reputation and the rights of the victim” required under the principle of satisfaction.4 Furthermore, its educational function directly serves as a guarantee of non-repetition by preserving the historical memory of this instance of systemic state failure and providing public access to the truth.4

This approach is further supported by the State’s positive obligations under Article 8 of the European Convention on Human Rights (ECHR) to protect an individual’s reputation, and by the principles of rectification under Dutch civil law.5 When a State not only fails in its duty to provide these remedies but is the architect of the harm itself, it becomes liable for the reasonable costs incurred by the victim to procure that remedy independently.

This report concludes by presenting a detailed, itemized production budget, transforming the legal entitlement into a concrete and defensible financial claim. The estimated cost of €850,000 for a professional, broadcast-quality documentary is justified as a necessary and proportionate expense to reverse the profound and calculated reputational damage sustained by the claimant.

 

II. The Legal Foundation for Non-Monetary Reparations

 

The proposal to include the costs of a documentary in a damages claim is an innovative application of established legal principles. The argument is not that the claimant is entitled to funds for a creative project, but that the State is legally obligated to provide a specific form of non-monetary redress which it has failed to deliver. The cost of commissioning this remedy thus becomes a quantifiable head of damage.

 

A. The Comprehensive Scope of “Redress” under UNCAT Article 14

 

The foundation of the claim rests on Article 14 of the UN Convention Against Torture, which obligates each State Party to “ensure in its legal system that the victim of an act of torture obtains redress and has an enforceable right to fair and adequate compensation, including the means for as full rehabilitation as possible”.7 While the term “compensation” is often interpreted in purely monetary terms, the controlling concept is the broader term “redress.”

The UN Committee Against Torture, in its General Comment No. 3 (2012), provides the authoritative interpretation of Article 14.3 This comment clarifies that “the term ‘redress’ in article 14 encompasses the concepts of ‘effective remedy’ and ‘reparation'”.2 It explicitly states that this comprehensive concept entails five distinct forms of reparation: (1) Restitution, (2) Compensation, (3) Rehabilitation, (4) Satisfaction, and (5) Guarantees of Non-Repetition.2 This framework establishes that monetary compensation is only one component of the State’s reparative obligations and, critically, that it “may not be sufficient redress for a victim of torture and ill-treatment” on its own.3

This legal architecture allows for a crucial strategic re-characterization of the claim. The request is not an “addition to the damages” in the sense of seeking more compensation for past harm. Rather, it is a claim for the cost of procuring a future remedy that the State is obligated, yet has failed, to provide. The State has a direct, positive obligation to provide non-monetary remedies aimed at restoring the victim’s dignity and preventing future violations. The documented history of the Smedema case demonstrates not merely a failure to provide these remedies, but an active, decades-long campaign to achieve the opposite.1 Therefore, the legal claim is transformed: it is not “provide compensation for the harm, which will be used to fund a film,” but rather, “the State is legally obligated to provide the remedy of ‘satisfaction’ through public disclosure of the truth. It has refused. Therefore, the State is liable for the full cost for the victim to commission this remedy himself.” This reframes the claim from a request for damages into an enforcement of a specific, unfulfilled legal duty.

 

B. The Documentary as a Measure of “Satisfaction”

 

The concept of “satisfaction” under General Comment No. 3 is specifically designed to address harms to dignity and reputation that money alone cannot repair. The remedies listed under this heading are directly relevant to the Smedema case and include:

• “verification of the facts and full and public disclosure of the truth“;
• “an official declaration or judicial decision restoring the dignity, the reputation and the rights of the victim and of persons closely connected with the victim”; and
• “public apologies, including acknowledgement of the facts and acceptance of responsibility”.2

A feature-length documentary is arguably the most effective, and perhaps the only, means of achieving these specific remedies in this case. The State’s wrongdoing was not a single defamatory act but a systemic, multi-decade “smear campaign” 1 and a process of “Institutional Gaslighting” 1 designed to methodically destroy the claimant’s credibility. The official psychiatric diagnosis of a “delusional disorder,” upheld by a medical tribunal, served as a powerful tool to invalidate the claimant and perpetuate the obstruction of justice.1

Given this context, a simple court judgment or a printed rectification in a newspaper would be wholly inadequate. Such remedies lack the narrative power to deconstruct a complex, decades-long history of obstruction and manipulation. They cannot effectively convey the “Kafkaesque trap” 1 in which the claimant was placed, where every attempt to access domestic remedies was blocked, only for international courts to then reject his claim for “failure to exhaust” those same remedies.1 A documentary, through its unique ability to combine interviews, archival documents, expert analysis, and narrative storytelling, is the only medium capable of achieving a “full and public disclosure of the truth” and truly “restoring the dignity [and] reputation” of the victim in a manner that is both publicly accessible and compelling.

 

C. The Documentary as a “Guarantee of Non-Repetition”

 

The claimant’s second stated goal for the documentary—to “prevent other people specific unaware girls to walk into the same ‘mind control’ trap”—aligns perfectly with the fifth form of redress under UNCAT: “Guarantees of Non-Repetition.” This component of redress moves beyond the individual victim to address the systemic failures that allowed the violation to occur, with the aim of preventing its recurrence.

The remedies specified in General Comment No. 3 include:

• “education and training on the prohibition against torture and ill-treatment for all officials”;
• “measures aimed at preserving historical memory of torture and ill-treatment”; and
• providing “public access to the truth regarding such past violations, including through the establishment of truth commissions”.4

The proposed documentary directly serves these preventive functions. It acts as a powerful tool for public education, raising awareness of the documented systemic vulnerabilities within the Dutch justice system, such as the “culture of fear” seen in the Demmink affair and the “systemic indifference” of the Toeslagenaffaire (Childcare Benefits Scandal).1 By creating a detailed public record and “preserving the historical memory” of this specific case, the film serves as a potent warning and a deterrent against future institutional misconduct. It fulfills the State’s obligation to ensure public access to the truth about its own failings.

 

D. Corroborating Principles in European and Dutch Law

 

The claim for the documentary’s costs is not legally radical but represents an innovative application of principles that converge across international, European, and domestic legal frameworks.

First, under the European Convention on Human Rights (ECHR), the European Court of Human Rights has consistently affirmed that “the right to protection of reputation is a right which is protected by Article 8 of the Convention as part of the right to respect for private life”.5 Importantly, this right entails not just negative obligations (a duty not to interfere) but also positive obligations on the State to take active measures to secure these rights.14 The Dutch State’s creation and perpetuation of a defamatory narrative, and its subsequent failure to correct it, constitutes a clear breach of this positive duty.

Second, under Dutch Civil Law, defamation is an unlawful act (onrechtmatige daad) pursuant to Article 6:162 of the Civil Code.6 The available remedies are not confined to monetary damages. Dutch courts can, and frequently do, order non-monetary relief, most notably rectification (rectificatie), which compels the defaming party to publicly issue a correction and acknowledge the falsity of their prior statements.6 While the historical remedy of a court-ordered apology (amende honorable) is no longer explicit in the code, the underlying principle of restoring a victim’s honour through a public corrective act remains a cornerstone of the legal system.18

These legal frameworks create a powerful synergy. Dutch law establishes the principle of court-ordered public correction. The ECHR imposes a positive duty on the State to protect and restore reputation. UNCAT provides the specific mechanisms for doing so in complex cases involving torture or other cruel, inhuman, or degrading treatment. The facts of the Smedema case—a decades-long, state-sponsored psychological attack—represent an extreme scenario where a standard Dutch rectification would be manifestly insufficient. Therefore, the documentary should be framed not as a new type of remedy, but as a proportionate scaling-up of the established principle of rectification. It is the only remedy that fits the scale of the wrong, is necessary to fulfill the State’s positive duties under the ECHR, and can be executed through the specific mechanisms of “satisfaction” and “guarantees of non-repetition” provided by UNCAT.

 

III. Strategic Justification for Quantifying the Claim

 

Moving from legal theory to litigation strategy, the next step is to construct a compelling argument for why the court should award the full production cost of the documentary as a quantifiable component of damages. This requires demonstrating how an unfulfilled state obligation translates into a pecuniary loss and pre-emptively neutralizing the State’s inevitable counterarguments.

 

A. From In-Kind Remedy to Quantifiable Damage

 

The core strategic argument is straightforward: when a State has a positive legal duty to provide a specific form of non-monetary redress (e.g., public disclosure of the truth) and fails or refuses to do so, the victim is entitled to claim the full, reasonable costs of commissioning that redress independently. This legal logic transforms an unfulfilled state obligation into a quantifiable pecuniary loss, making it a legitimate head of damage.

The situation is analogous to a breach of contract for services. If a party contracts for a service, and the provider fails to perform, the injured party is entitled to damages equivalent to the cost of hiring a third party to complete the contracted work. Here, international and domestic law impose an obligation on the State to perform the “service” of restoring the claimant’s reputation and ensuring public access to the truth. The State has not only failed to perform this service but has actively done the opposite for decades. Therefore, the reasonable cost of commissioning an independent party—a professional documentary production team—to perform this service is a direct and foreseeable financial loss for which the State is liable.

 

B. The Argument for Necessity and Proportionality

 

To succeed, the claim must demonstrate that the documentary is both a necessary and a proportionate remedy.

The necessity of an independent production stems directly from the State’s own conduct. The claimant’s legal filings document an irrefutable “paper trail of obstruction created by the State itself”.1 This includes police being ordered not to file a report, a court explicitly refusing to hear the complainant, and the National Ombudsman repeatedly refusing to investigate.1 This systemic blockade proves that no official state channel can be trusted to produce a fair, impartial, and complete account of the facts. An independent production, free from state influence, is therefore the only necessary means to achieve the “full” disclosure of the truth mandated by UNCAT.

The proportionality of the remedy is established by the nature of the harm. The damage to the claimant’s reputation was not the result of a single defamatory article but a systemic, multi-decade “smear campaign” involving the police, the Ministry of Justice, and the judiciary.1 A remedy must be proportionate to this sustained and complex institutional attack. A feature-length documentary is the only medium with the depth and narrative capacity to weave together the extensive timeline of events, the documentary evidence, expert testimony, and historical context. It is the only communication tool that can proportionately counter the powerful and pervasive official narrative that the State has meticulously constructed and maintained for over two decades.

 

C. Pre-empting and Neutralizing State Counterarguments

 

The State will undoubtedly raise several objections to this claim. A robust strategy must anticipate and neutralize them in advance.

• State Argument 1: “This is an unprecedented and unrecognized form of damages.”

• Counterargument: This claim is not for a novel type of damage. It is a novel quantification of a long-recognized form of redress—”satisfaction”—that is explicitly provided for under binding international law (UNCAT) to which the Netherlands is a party.2 The claim is fully consistent with the principles of state liability, which require making the victim whole, and the positive obligations under the ECHR to restore reputation.5 It is an application of existing principles to an extraordinary set of facts.

• State Argument 2: “The cost is speculative, subjective, and excessive.”

• Counterargument: The cost is not speculative. As detailed in the following section, it is based on a granular, itemized budget derived from established film industry standards and practices.19 The cost is not excessive; it is proportionate to the immense and prolonged reputational harm inflicted by the State itself. The State, as the wrongdoer, does not have the standing to argue that the cost of undoing the harm it caused is too high.

• State Argument 3: “A court cannot order the funding of a specific creative work, as this would infringe on freedom of expression or amount to compelled speech.”

• Counterargument: This mischaracterizes the claim. The court is not being asked to commission a film, approve a script, or compel the State to apologize. It is being asked to award damages equivalent to the cost of a necessary reparative measure that the State was obligated to provide but failed to. The content of the documentary would be the responsibility of the claimant and an independent production team, who would be bound by journalistic and ethical standards. This is functionally no different from a court awarding damages for the cost of future medical care; the court does not dictate the specific doctor or treatment plan but provides the funds for the victim to obtain the necessary care. The award is for the means of redress, not the content of the redress itself.

 

IV. Financial Analysis: Budget for a Feature-Length Investigative Documentary

 

To transform the legal argument into a concrete financial claim, a detailed, credible, and defensible cost projection is required. This budget serves not only as a calculation of damages but as evidence of the serious, professional, and non-speculative nature of the proposed remedy.

 

A. Establishing the Production Standard and Overall Budget

 

The documentary’s effectiveness as a tool of “satisfaction” is contingent on its credibility. To reverse a decades-long, state-sponsored narrative, the production cannot be an amateur effort. It requires the technical quality, journalistic rigor, and narrative sophistication of a professional, broadcast-quality, feature-length (approximately 90-minute) investigative documentary suitable for international film festivals and broadcast.

Common industry rules of thumb, such as a “$1,000 per finished minute” estimate, are wholly inadequate for a project of this complexity and are often outdated.21 A more realistic benchmark for a professional independent feature documentary, particularly one involving archival research and international elements, falls within the range of $250,000 to over $1 million.19 The International Documentary Association (IDA), for example, notes that feature project budgets typically range from $250,000 to $1 million.23

Given the specific requirements of this case—including filming in at least three countries (the Netherlands, the United States, and Spain), extensive archival research to substantiate the “paper trail of obstruction,” the need for high-level legal and expert consultants, and the overall sensitivity and complexity of the subject matter—a budget in the mid-to-high end of this range is necessary. This analysis proposes and justifies a total production budget of €850,000 (approximately $925,000 USD). This figure is sufficient to ensure the required professional standard and global reach, while remaining a defensible and proportionate claim relative to the multi-decade harm and the US$100 million benchmark valuation of the total case.1

 

B. Itemized Budget Breakdown

 

Presenting a highly detailed, multi-phase budget is a strategic imperative. It demonstrates meticulous planning and transforms the claim from an abstract concept into a series of concrete, defensible line items. This shifts the legal debate from a philosophical one about the nature of damages to a practical, financial one about the reasonable costs of production, placing the burden on the State to challenge specific, industry-standard expenses.

The following table provides a top-sheet summary and detailed breakdown of the proposed €850,000 budget.

Table 1: Proposed Budget for “The Smedema Case” Documentary

 

Phase and Category	Estimated Cost (€)	Description / Justification
Phase 1: Development & Pre-Production	€120,000	Foundational stage for research, planning, and securing rights.
Story Rights & Development	€35,000	Fees for an experienced writer/researcher to structure the complex narrative and timeline; initial legal consultation on story rights.19
Initial Research & Archival Sourcing	€30,000	Travel for preliminary interviews in NL/USA/ES; costs for accessing and screening materials from state and private archives.19
Producer & Director Fees (Dev. Phase)	€30,000	Compensation for key creative personnel during the intensive 6-8 month development period.20
Fundraising/Pitch Materials	€15,000	Production of a short proof-of-concept trailer to demonstrate the film’s viability and approach.20
Legal (Production Counsel)	€10,000	Drafting crew contracts, location releases, and initial clearance reviews.19
Phase 2: Production	€350,000	The principal photography stage, involving crew, equipment, and travel.
Producer & Director Fees (Prod. Phase)	€75,000	Fees for key creative leadership during the production period.20
Core Crew Salaries	€120,000	Based on industry rates for a Director of Photography, Sound Recordist, and Production Manager for an estimated 40 shoot days.19
Equipment Rental	€60,000	Rental of a professional 4K cinema camera package, lighting, grip, and sound equipment.19
Travel & Accommodation	€70,000	Airfare, ground transport, hotels, and per diems for a small crew for shoots in the Netherlands, USA, and Spain.19
Location Fees & Permits	€5,000	Securing necessary permits and fees for filming locations.19
Production Insurance	€20,000	Essential coverage including General Liability and Errors & Omissions (E&O) insurance.19
Phase 3: Post-Production	€250,000	The editing and finishing stage where the story is constructed.
Editor & Assistant Editor Salaries	€80,000	Based on a 28-week post-production schedule for a feature documentary.22
Edit Suite Rental / Facility	€25,000	Cost of a professional editing facility and necessary hardware/software.26
Archival Footage & Stills Licensing	€50,000	A significant and crucial cost for an investigative film requiring extensive third-party material to prove its case.19
Music (Composition & Licensing)	€30,000	Fee for an original score composer and licensing of 2-3 pre-existing music tracks.19
Graphics & Animation	€20,000	Essential for visualizing complex legal timelines, document trails, and abstract concepts like “institutional gaslighting”.19
Sound Design & Mix	€20,000	Professional sound editing, design, and final mix to meet broadcast standards.19
Color Correction & Mastering	€15,000	Professional color grading and creation of final delivery masters.27
Narration	€10,000	Fee for a professional voiceover artist to guide the narrative.19
Phase 4: Administration & Contingency	€130,000	Overhead, legal finalization, and essential risk mitigation funds.
Office & Administrative Overhead	€30,000	Bookkeeping, communication, office supplies, and other general expenses over the project’s lifecycle.24
Legal (Clearance & E&O Review)	€10,000	Final legal review of the film to secure E&O insurance.
Contingency	€90,000	A standard and non-negotiable 10-15% of the subtotal to cover unforeseen costs, essential for the unpredictable nature of documentary filmmaking.24
Phase 5: Distribution & Marketing	(Integral to Remedy)	Costs for public disclosure are part of the remedy itself.
Note on Distribution	N/A	Basic distribution costs (e.g., film festival submission fees, creation of a press kit, public screening costs) are considered an integral part of achieving the “public disclosure of the truth” mandated by the remedy of “satisfaction.” They are accounted for within the main budget lines and are not claimed as a separate commercial expense. The goal is public vindication, not commercial profit.
TOTAL ESTIMATED BUDGET	€850,000

 

V. Conclusion and Strategic Recommendations

 

The evidence and analysis presented in this report lead to the unequivocal conclusion that a claim for the full production costs of a feature-length investigative documentary is legally sound, strategically robust, and financially quantifiable. This claim is not an ancillary request for compensation but a direct demand for the means to procure a specific form of redress—”satisfaction” and “guarantees of non-repetition”—mandated by the State’s binding obligations under the UN Convention Against Torture. The documentary is the only remedy that is truly proportionate to the unique, prolonged, and profound harm of state-sponsored institutional gaslighting and reputational destruction.

Based on this conclusion, the following strategic recommendations are provided for the claimant’s legal counsel:

1. Integrate the Claim as a Specific Head of Damage: The €850,000 claim should be formally integrated into the statement of damages. It must be presented not as an undifferentiated component of “non-pecuniary loss,” but as a distinct, quantified head of damage for the “Cost of Procuring Redress under UNCAT Article 14.” This precise legal framing is critical.
2. Submit this Report as Expert Opinion: This report, or a formalized version thereof, should be annexed to the legal filings. It serves as a comprehensive expert opinion that substantiates both the novel legal theory grounding the claim and the detailed financial calculation justifying the amount.
3. Frame the Narrative in Court: The legal argument should consistently employ the language of “satisfaction,” “guarantees of non-repetition,” and the State’s “unfulfilled positive obligations” under the ECHR. This framing reinforces that the claim is not a mere request for money, but a demand for justice in a form that international and domestic law explicitly provide for, and which only the claimant can now reliably execute.
4. Leverage in Settlement Negotiations: This claim should be used as a powerful lever in any potential settlement discussions. It highlights the State’s ongoing failure to meet its international human rights obligations and underscores the profound nature of the harm that requires such a comprehensive and public remedy. It transforms a private dispute into a matter of public record and institutional accountability, increasing the pressure on the State to seek a meaningful resolution.

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