Friday 19 February 2010

International Criminal Law Services has completed a study on how the International Criminal Court can learn from the experiences of other hybrid and international criminal courts.


The International Criminal Court and the experience of other International and Hybrid Criminal Courts25 Jan 2010
International Criminal Law Services (ICLS) has published its recent study, “Suggestions for Future Lessons-Learned Studies: The Experience of Other International and Hybrid Criminal Courts of Relevance to the International Criminal Court.”
This report is especially timely, given the upcoming ICC Review Conference of the Rome Statute in May/June, 2010.  The report asks whether there are lessons yet to be learned in relation to other international and hybrid criminal courts that could help the ICC meet its key challenges more proficiently and efficiently.  It is based on a combination of a review of over 200 articles, books, reports and court documents, and interviews with senior officials from the ICC and other international courts, ASP representatives, and experts on the ICC from civil society.

It concludes that, although the ICC has realised some remarkable achievements to date, there may be lessons from other tribunals that is has yet to learn.

According to the report, areas in which the ECCC, ICTR, ICTY, SCSL and STL may still hold lessons for the ICC include: governance of the court and ASP and the proper relationship between these bodies; case selection by the prosecution; defence issues and self-representation; victim and witness issues; field offices and investigations; and support and cooperation, implementing legislation, complementarity and related issues.

ICLS hopes that the report will spur closer scrutiny of lessons the ICC has yet to learn, as well as comprehensive studies learning lessons from other international and hybrid criminal courts in areas found to be of potential relevance to the ICC.

Download the report here.

The Future of International Criminal Justice


Title:  The Future of International Criminal Justice 09 Oct 2009
Author: Stahn, Carsten
I. The Status Quo

Earlier this year, at the June 2009 Inter-sessional Meeting of the Crimes against Humanity Initiative,1 Hague Prize Winner Cherif Bassiouni made a striking observation on international justice. He said: “In five years, we will mainly have the International Criminal Court (ICC) in the landscape of international institutions. The two ad hoc tribunals for the former Yugoslavia and Rwanda will close down and perhaps deal with some outstanding transitional issues. Other institutions will be completing their mandates.” 

What does this mean for the future of international justice? Does it mean that there is no real future, except for the ICC? Or is the future of international justice ‘domestic’, as predicted by International Relations scholar Anne-Marie Slaughter, who argued a couple of years ago, in an article in the Harvard Journal of International law, that the entire ‘Future of International Law is domestic’.2

The actual picture appears to be more nuanced. The realities of conflict make it unlikely that international justice will lose its relevance. Current institutions are struggling to cope with the load of existing situations and cases. The experience of the first years of the ICC defeats any scepticism against international adjudication.
The first ICC practice, with self-referrals from the Democratic Republic of Congo, Uganda, the Central African Republic, and the acceptance of jurisdiction by the Ivory Coast, is vivid testimony that many domestic governments are very eager - some would perhaps even say too eager - in their ambition to devolve responsibilities and to have major cases investigated and prosecuted internationally, rather than domestically.

It is well known that African Union countries have remained critical towards the warrant of arrest against Sudanese President Al-Bashir. Yet, their statement in relation to Al-Bashir3 was accompanied by a whole-hearted pledge of support for the engagement of the Court in relation to existing and potentially new situations, such as Kenya.

We are thus de facto still very far from the idealist vision which ICC Prosecutor Moreno-Ocampo outlined in 2003 when taking office, namely: the dream of an International Criminal Court that has to deal with no cases because of the effective functioning of domestic judiciaries.4

Where is international justice today? It appears to be in a stage of transition. It has been a remarkable success story since the end of the Cold War, but the idealism and faith in multilateralism that prevailed in the 1990s is fading. There is continuing commitment to the cause of international justice, but also an increasing look to alternative responses, and a growing debate about its effectiveness.
In 2004, former UN Assistant Secretary-General Ralph Zacklin claimed that the ad hoc tribunals exemplify an “approach that is no longer politically or financially viable”.5 Some features of international trials have come under fire. The typical criticisms are: International tribunals cost too much – the ad hoctribunals cost 10% of the UN’s annual budget. They deliver too little. They are removed from the scene of the crime.

Not all of these criticisms are justified. They need to be put into perspective. It would be misleading to assess the record of international criminal courts merely by the quantity of cases and the number of trials. In fact, a Hague District Court decides more cases in a year than all of the international tribunals together.

But the categories of crimes; war crimes, crimes against humanity and genocide, are particular in the sense that they are atrocity-related and linked to a longer history of conflict. This makes investigations and prosecutions more complex than in classical domestic proceedings, in terms of the actors involved, the gathering and selection of evidence. Moreover, the effects of justice cannot be measured only by what is actually going on in the Court room, but by their impact internationally and domestically.

Yet, I would argue that the time has come to undertake a more nuanced assessment of the actual strengths and limits of international justice.

Thus far, international justice is largely founded upon the assumption that it produces beneficial effects by enhancing accountability and promoting the “creation of an international rule of law”. This claim is still in many respects a hypothesis, rather than an empirically proven reality.
In most contexts, international justice is part and parcel of a broader peace-building process. Studies on the short-term and long-term effects of justice are still very much an exception. The ad hoc tribunals are only slowly embarking on this exercise in the context of their own completion strategy.
In my view, the main challenge of the coming decades is two-fold.

Firstly, we need to examine more carefully what international justice can realistically achieve, and what impact it has on perpetrators, victims and affected societies. This foundational exercise is necessary in order to maintain the very credibility of the discipline, and to draw a proper balance between universal, regional and alternative approaches to justice. This effort goes widely beyond The Hague, but it must be part and parcel of legal engineering and our thought-processes here.

Secondly, it is fundamental to explore how international justice can interrelate better and more effectively with domestic justice systems.

Effects of justice are only sustainable if they are embedded and followed by consecutive domestic action.6

If international criminal courts wish to leave a ‘lasting footprint’ on domestic societies, they must develop strategies to empower domestic institutions. This requires fresh thinking as to how international courts and tribunals interact with domestic jurisdictions in individual situations, in terms of mutual legal assistance and cooperation and sharing of responsibilities.

II. From 'Faith-based' to 'Fact-based' Justice
Empirical research has shown that there has been an exponential increase of international and domestic human rights trials over the past two decades.7 The core question is: what do these trials achieve?

Human rights research typically provides three answers.
International trials are (i) said to have a certain “alert effect”. They draw attention to facts and crimes and cause a “social alarm”. (ii) They are credited for their “demonstration effect”. Justice is “seen to be done”. Moreover, they (iii) enhance accountability and enforcement, by – as Judge Buergenthal put it - providing “teeth” to the enforcement of human rights obligations.8

These general answers may be satisfactory from a human rights perspective. But they hardly suffice to satisfy the needs of victims of crime and international criminal law as a discipline. The fundamental questions are:
(i) How and to what extent can investigation or prosecution contribute to deterrence in and beyond communities affected by conflict?
(ii) To what extent does international justice contribute not only to “retribution”, but also to broader “incapacitation” of perpetrators and the removal of root causes of conflict?
(iii) How do prosecutions interrelate with the interests of the victims of crime specifically, or victims of conflict?
(iv) To what extent do they communicate a sense of fairness or even facilitate societal reconciliation?
These questions have long been on the ‘back-seat’ of international justice. International justice has been focused on the ‘move towards institutions’, rather than an exploration of its specific benefits and limits.
Issues of impact and legacy are now gradually addressed as part of the completion strategy of the ad hoc tribunals. The Tribunals are most advanced in devoting attention to their mission and place in history. In the Presidency, a specific post has been created with the job title ‘legacy officer’.
But the ‘horse’ needs to be placed back again in front of the wagon. The inquiry as to the proper goals and effects of international trials should be at the forefront and focus of all institutional responses. This requires new methods and approaches.9

In continental Europe, lawyers are often criticized for their lack of method and commitment to empirical research. One of the major challenges of international criminal law as a discipline is to engage more strongly with empirical research and social scientists to develop a conceptual framework to link goals of criminal justice to indicators, and to develop a methodology to assess impact.
What does this mean concretely? I would argue that, with the growing diversification of justice institutions and the development of alternative justice mechanisms, it is vital to inquire as to what each institution can deliver, and to what extent the international justice system as a whole is ready to meet its objectives.
We have witnessed this differentiation of roles and mandates of courts over centuries at the domestic level. It is now time to extend it to the arena of international justice. I will illustrate this with some examples.

Deterrence and Prevention
Major responses to mass atrocities, such as Nuremberg, the Genocide Convention, the Chambers in Cambodia or the response to Darfur all came after the facts. When the UN advisors drafted the Statute of the ad hoc tribunals at the beginning of the 1990s, the focus was clearly on criminal adjudication. This approach contrasts with state duties to prevent crime under human rights law and the Genocide Convention.

Recently, Yale Professor Michael Reisman highlighted this dilemma. He suggested that “acting to prevent before the fact, as opposed to acting to punish after the fact” should be the ‘primary technique of international law for dealing with mass murder”.10

He argued that “acting before victims become victims” should be the core task of international justice.
This poses the delicate question: what contribution can international justice realistically make to deterrence?
Deterrence poses special problems. It operates on the assumption that actors in conflict make their decisions on the basis of a rational cost-benefit analysis. This assumption is often a fiction, in light of the underlying political context of the conflict.

International crimes are mostly linked to ideology. If you interview ‘clients’ in the detention centre in Scheveningen, they will reply: “we are not ordinary ‘perpetrators’, we act by true conviction”. This means that there is a risk that they are immune against deterrence, because they act no matter what price they will have to pay for the implementation of their cause.

Moreover, in order for deterrence to work, the perpetrator must identify the action as potentially wrong and be aware of the possibility of sanction. This is a particular challenge.

In the case of Uganda, a team of lawyers has actually managed to track down Joseph Kony in Garamba Park in the Congo and explain the charges to the Lord’s Resistance Army. But this is very much the exception. People are normally aware of the national legal system, because they are confronted with it on a daily basis. They are less familiar with international norms and they do not always understand them properly.

Joseph Kony is again a case in point. He allegedly argued that the warrants were not legitimate because he was not heard prior to their issuance, and because there was no true distinction between innocent ‘civilians’ and legitimate targets in the conflict in North Uganda.

It does not come as a surprise that an expert study prepared by the Open Justice Initiative in 2008 came to a conclusion of non liquet when assessing the deterrent effect of the Tribunal.11 It acknowledged that one “can[not] reach reliable conclusions about the ICTY’s general deterrent impact”.

It said: “[W]e know some things with sobering certainty: as has often been noted, the creation of the ICTY did not by itself end atrocities in the Balkans. The 1995 genocide in Srebrenica occurred two years after the ICTY was created, while atrocities in Kosovo surged during 1998–99”. It is a sad historical reality that some defendants were already in the docket, and that fourteen suspects who had been indicted when the Srebrenica massacre took place.

Deterrence has also played a role in the context of the current ICC situations. It has been claimed that the threat of ICC prosecutions prevented a further escalation of conflict in the Ivory Coast.12 It has further been alleged that the ICC intervention in Uganda reduced the level of violence.

The development of peace negotiations has illustrated the fragility of the deterrence argument:

When the peace negotiations were ongoing, deterrence was praised as one of the factors that prompted the engagement in negotiations. But when the Lord’s Resistance Army refused to sign and abide by the accountability agreement, the argument was turned around. It was claimed that the very engagement in peace talks was mainly a pretext by Joseph Kony to gain time and force to re-arm.

Logically, only one of these two narratives can be true. If the peace negotiations were only a pretext, it cannot be said that the warrants actually produced a meaningful deterrent effect in the first place.

This means: We therefore need more reliable tools and instruments to determine how, and under what circumstances international criminal tribunals can produce a lasting deterrent effect.

Incapacitation
Can international justice make a contribution to incapacitation?

Some examples provide evidence to that effect. Most prominently, Mr. Karadžić was prevented from participating in the 1995 Dayton Peace Talks, because of the indictment brought against him by the ICTY.

The 2008 expert study on the impact of the ICTY came to the conclusion that the most important contribution of the ICTY was its de-legitimating effect in politics. The report found that the proceedings and evidence adduced in The Hague has significantly “shrunk the public space” in which political leaders can credibly deny key facts about notorious atrocities. One example is the clarification of the number of victims killed in Srebrenica. And, consequently, the entire report was called ‘Shrinking the space for denial’.13

But further clarity is needed. The theory is simple: the public condemnation of atrocities and the demonstration of wrongfulness of actions will help to de-legitimize former political elites and national ‘heroes’.

But there are often compromising side-effects. There are conflicting views as to whether the physical removal of Milosevic and Serbian Radical Party leader Seselj from the region to The Hague had only positive effects. Some argue that the transfer to The Hague actually helped to ‘mystify’ them.

Moreover, it is difficult to establish a clear line of causation. The de-legitimization of political elites can rarely be ascribed to the impact of justice alone, nor does it occur on the spot. It is often a gradual process which is tied to a bundle of rationales, such as socio-economic benefits. In this plurality of causes, the individual contribution of justice is difficult to locate.  There is further an inherent risk that ‘dependency’ on international tribunals and donor activities constrains or conditions domestic justice efforts.

Reconciliation
Whether and to what extent international criminal justice can successfully contribute to reconciliation is probably the most difficult question to answer.

There is an increasing trend in comparative criminal procedure to support victim participation in criminal proceedings and their right of access to justice. Proponents of restorative justice point to the benefits of participation: Victims can overcome trauma if the injustice done to them has been recognized publicly, if they receive an opportunity to make their personal story known and if they themselves learn about the details of what has happened.

But the reality is more complex. ‘Victims’ have a wide range of divergent interests. The interests of immediate ‘victims of crime’ do not necessarily coincide with the interests of the broader ‘victims of the situation’. Both constituencies may, in fact, have conflicting prerogatives. The first proceedings at the ICC demonstrate this. Accountability is often a priority for the former, but of less immediate concern for the latter. This is vividly illustrated by the practice in the situation in Darfur. In this situation, different groups of victims have presented motions for and against the issuance of warrants of arrest before the Court.14 This adds a new dimension to criminal proceedings, and requires judges to adjudicate issues which are situated at the borderline of peace and justice.

Investigations and prosecutions of international courts and tribunals typically focus on leadership accountability. Immediate victims of crime, however, often wish to see their neighbour tried, as much as they seek accountability for core leaders.15 The question as to why leadership accountability is to be given preference is typically not explained to them, nor made subject to their choice. This consideration is largely driven by prosecutorial strategy which is determined by motives of deterrence and incapacitation, in addition victims’ interests.

Moreover, collective impact pre-supposes that each group has a willingness to inquire to what extent it bears collective responsibility through the actions of its members, and in particular its leadership. There is no guarantee that such a process will indeed effectively take place. Examples of Germany or Serbia show that society often takes a very long time to recognize the moral wrong committed and to condemn its own involvement in it.

Many experts argue, therefore, rightly that the role and impact of international trials on reconciliation is a modest one,16 and that there should be adequate space for additional legal and institutional responses.

III. Empowering Domestic Legal Systems
This leads me to the second major challenge for the future of international justice, namely the relationship with domestic legal systems.

For a long time, there has been a disconnect between international and domestic justice.17 International and domestic justice have been perceived as opposing forces, like ying and yang; two autonomous systems.

Today, the two systems work increasingly in tandem. The principle of complementarity18 is gradually anchored in the exercise of domestic jurisdiction.  Domestic jurisdiction is increasingly exercised, when the State in which the crimes have been committed, or the State of nationality of the perpetrator, is either unwilling or unable to act.

Internationalized tribunals have tended to argue that they are ‘international’ rather than ‘domestic’ because this qualification enables them to strengthen the efficient adjudication of crimes in terms of immunity and cooperation.19 But it is gradually recognized that what makes international criminal justice a success is ultimately its catalytic effect and its impact on domestic justice systems.
Courts, such as the Yugoslavia tribunal or the Special Court for Sierra Leone, have started to embrace the idea that justice is not only a tool to fill justice gaps at the domestic level, but an instrument to strengthen domestic justice efforts.
In the ad hoc tribunals, this move was born out of necessity. It resulted from the need to deal with a backlog of cases involving lower level perpetrators. All three organs of the tribunals agreed to create mechanisms to transfer cases back from the international to domestic courts, subject to fair trial safeguards.20 This process is gradually taking off. The Yugoslavia Tribunal has by now referred 10 cases to the newly created Bosnian War Crimes Chamber. Rwanda abolished the death penalty, in order to be eligible to receive cases.

But there are paradoxes and curiosities. The rule on transfer of cases from the ad hoc tribunals provides that only cases involving medium- and low-level perpetrators may be transferred to Bosnia or Serbia. Some of the defendants before the ICTY have been in detention for a considerable amount of time or preferred to be tried in The Hague, rather than domestically. In order to avoid transfer, they have argued before the tribunal that they were actually not small fish, but persons bearing great responsibility.
The Rome Statute contains a more systemic turn towards interaction between international and the domestic legal systems: it not only creates a Court, but it establishes a new system of justice.21 It regulates the interplay between the Court and the role of domestic jurisdictions in the fight against impunity.

More than 10 years ago, the provisions of the Statute were drafted. It is timely to inquire whether the interpreters of the Statute are faithful to the intent of the drafters, or whether we are going in new directions.

Some argue that the “secrets” of the Statute and its complexity have not yet been fully brought to life.22 We should thus focus on revealing the true ‘meaning’ of Article 17, or analyse more closely how complementarity has been treated in the past, and what misperceptions prevail in its current perception. Others would argue that we need to go in new directions, and critically examine the provisions of the Statute in light of its objectives.
But we are facing a paradigm shift: in the future, international justice will not be measured by its own performance, but by its actual ability to solve problems. It will be judged by whether, and to what extent, it is able to make domestic jurisdictions work.  Some call this ‘positive complementarity’. It is - in fact - ‘problem-solving’.
What the tribunals are facing in the completion stage is relevant to each single situation of the ICC. This requires new creativity.
It means that it is not enough to stand still and deplore the lack of cooperation by a defiant regime. It is the task of the Rome system of justice to develop strategies to overcome this unwillingness.
Likewise, it is too simple to merely recognize international jurisdiction on the basis of the inability of a domestic State. Ultimately, the task of the Court is to help overcome domestic inability.  None of this is in the textbooks.  It requires creative interpretation and criminal policies in the future.

IV. Conclusion

I have tried to outline that justice in The Hague is no longer a one-way street – it is a dialogue among international institutions and jurisdictions and, most of all, a dialogue with domestic jurisdictions.

Does this mean the future of international justice is domestic? At the moment, the answer is: not quite yet. It will take, at least, another generation to find definite answers.
But we are at an important turning point in the history of international justice. Critical analysis of what international justice can achieve realistically, and how it interrelates with domestic constituencies, must be at the forefront of our contemporary thinking.

 
*Dr. jur., LL.M. (NYU), LL.M. (Cologne-Paris), Associate Professor of International Criminal Law, Leiden University, Programme Director, Grotius Centre for International Legal Studies. These remarks are based on the Opening of the Academic Year at Campus Den Haag, Leiden University.  Thanks are owed to Ms. Ruth Shaikh for her editorial assistance.


1 For further information on this initiative, see the information athttp://law.wustl.edu/crimesagainsthumanity/index.asp?id=7111 .
2 See Anne-Marie Slaughter & William Burke-White, The Future of International Law is Domestic (or, The European Way of Law, Harvard Journal of International Law, Vol. 47 (2006), 327.
3 See African Union, Decision on the Meeting of African States Parties to the Rome Statute of the International Criminal Court, 19 July 2009, Available here.
4 See Election of the Prosecutor, Statement by Mr Luis Moreno-Ocampo, New York, 22 April 2003, ICC-OTP-20030502-10: “The efficiency of the International Criminal Court should not be measured by the number of cases that reach the Court or by the content of its decisions. Quite on the contrary, because of the exceptional character of this institution, the absence of trials led by this Court as a consequence of the regular functioning of national institutions, would be a major success”.
5 See Ralph Zacklin, The Failings of the Ad Hoc Tribunals, Journal of International Criminal Justice, Vol. 2 (2004), 641.
6 This is a lesson learned from decades of UN experiences in peace-building. See e.g., Report of the Secretary-General on the Rule of Law and transitional justice in conflict and post-conflict societies, 3 August 2004 (“Ultimately, no rule of law reform, justice reconstruction, or transitional justice initiative imposed from the outside can hope to be successful or sustainable. The role of the United Nations and the international community should be solidarity, not substitution […] The most important role we can play is to facilitate the processes through which various stakeholders debate and outline the elements of their country’s plan to address the injustices of the past and to secure sustainable justice for the future, in accordance with international standards, domestic legal traditions and national aspirations. In doing so, we must learn better how to respect and support local ownership, local leadership and a local constituency for reform, while at the same time remaining faithful to United Nations norms and standards”).
7 See e.g., Phuong Pham & Patrick Vinck, Empirical Research and the Development and Assessment of Transitional Justice Mechanisms, International Journal of Transitional Justice, Vol. 1 (2007), 231; Hunjoon Kim, Why and when do countries seek to address past human rights violations after transition? An event history analysis of 100 countries covering 1980-2004, International Studies Association, Chicago (2007); Oskar N. T. Thoms, James Ron & Roland Paris, Does Transitional Justice Work? Perspectives from Empirical Social Science (2008), SSRN Working Paper,http://ssrn.com/abstract=1302084.
8 See Thomas Buergenthal, The Contemporary Significance of International Human Rights Law, Leiden Journal of International Law, Vol. 22 (2009), 217.
9 See also the NWO Research Project on ‘Post-Conflict Justice and Local Ownership’, athttp://www.grotiuscentre.org/com/doc.asp?DocID=436.
10 See W. Michael Reisman, Acting Before Victims Become Victims: Preventing and Arresting Mass Murder, Case Western Reserve Journal of International Law, Vol. 40 (2008), 57, at 59.
11 Open Justice Initiative, Shrinking the Space for Denial: The Impact of the ICTY in Serbia, (2008). In its first annual report to the UN Security Council, the President of the ICTY still noted: “One of the main aims of the Security Council [in establishing the ICTY] was to establish a judicial process capable of dissuading the parties to the conflict from perpetrating further crimes. It was hoped that, by bringing to justice those accused of massacres and similar egregious violations of international humanitarian law, both belligerents and civilians would be discouraged from committing further atrocities. In short, the Tribunal is intended to act as a powerful deterrent to all parties against continued participation in inhuman acts”.
12 The Prosecutor defended the feasibility of ICC action in Ivory Coast on the basis of its preventive effect on hate crime more generally. He made this link expressly in his Nuremberg address, where he noted: “[T]he  beneficial  impact  of  the  ICC,  the  value  of  the  law  to  prevent  recurring  violence  is  clear: Deterrence has started to show  its  effect  as  in  the  case  of  Cote d’Ivoire where  the  prospect of prosecution  of  prosecution of those using hate speech is deemed is  deemed  to  have  kept  the  main  actors  under  some  level  of control”. See Building a Future on Peace and Justice, Address. Nuremberg, 24/25 June 2007, Available here
13 See Open Justice Initiative, Shrinking the Space for Denial: The Impact of the ICTY in Serbia, (2008).
14 See ICC, Application on behalf of Citizens’ Organisation of The Sudan in relation to the Prosecutor’s Applications for Arrest Warrants of 14 July 2008 and 20 November 2008, Pre-Trial Chamber I, No: ICC-02/05-170  (11 January 2009).
15 See Eric Stover & Harvey Weinstein, My Neighbour, My Enemy, Cambridge University Press, 2005.
16 See Laurel E. Fletcher & Harvey M. Weinstein, Violence and Social Repair: Rethinking the Contribution of Justice to Reconciliation, Human Rights Quarterly Vol. 24 (2002), 573; . Victor Peskin, International Justice in Rwanda and the Balkans, Cambridge University Press (2008), 243 et seq; David Mendelhoff, Truth-Seeking, Truth Telling, and Postconflict Peacebuilding: Curb the Enthusiasm?, International Studies Review, Vol. 6 (2004), 355.
17 In his Rights of War and Peace (1625), Grotius contemplated an early form of the principle “aut dedere aut judicare” (either extradite or prosecute). He argued that perpetrators of certain categories of offences should be either tried by the State which has custody over the person or by the injured party.
18 For information, see the Research Project The International Criminal Court and Complementarity: From Theory to Practice, athttp://www.grotiuscentre.org/com/doc.asp?DocID=460.
19 See e,g, SCSL, Appeals Chamber, Prosecutor v. C. Taylor, Decision on Immunity from Jurisdiction, 31 May 2004, paras. 37 et seq.
20 See the – by now - famous Rule 11 bis of the ICTY Rules of Procedure and Evidence.
21 For a discussion, see Carsten Stahn, Complementarity: A Tale of Two Notions, Criminal Law Forum, Vol. 19 (2008), 87 -113.
22 See the recent decision of the ICC Appeals Chamber in Katanga, Judgment on the Appeal of Mr. Germain Katanga against the Oral Decision of Trial Chamber II of 12 June 2009 on the Admissibility of the Case, 25 September 2009, ICC-01/04-01/07-1497, paras 75 e seq., Available here.

Thursday 4 February 2010

Compensation and Immunity: Germany v. Italy at the ICJ

Compensation and Immunity: Germany v. Italy at the ICJ
JURIST Guest Columnist and German human rights lawyer Stefan Kirchner, a member of the American Society of International Law and the Faculty of Law at Georg-August-University in Gottingen, says that new litigation between Germany and Italy in the International Court of Justice over Italian courts' awarding of compensation to relatives of civilians killed by German Nazi soldiers in the Italian town of Civitella during World War II gives the ICJ the opportunity to elaborate on the relationship between the modern position of the individual under international law and the concept of jurisdictional immunity derived from the fundamental principle of state sovereignty ...


The recently undertaken case between Germany and Italy at the International Court of Justice at The Hague concerns claims by victims of violations of International Humanitarian Law for compensation for the alleged acts of German soldiers in the Italian town of Civitella during World War II. In recent years, Italian courts, including the Corte di Cassazione, have granted a number of applications directed against Germany, thereby infringing upon Germany's right to jurisdictional immunity (the landmark Ferrini decision has been translated and reprinted in 128 ILR 659 as has been commented on by Bianchi in 99 AJIL (2005) 242).


That such claims are possible appears clear from international treaty law: Art. 91 of the First Additional Protocol to the Geneva Conventions (AP I) states that violations of provisions of the Geneva Conventions or the Additional Protocols lead to the liability of the "party to the conflict which violates the provisions of the Conventions or of this Protocol" - liable to pay compensation and that it "shall be responsible for all acts committed by persons forming part of its armed forces."

Art. 3 of the Fourth Hague Convention (Laws and Customs of War on Land) (Hague IV) also requires that "[a] belligerent party which violates the provisions of the said Regulations shall, if the case demands, be liable to pay compensation It shall be responsible for all acts committed by persons forming part of its armed forces."

Art. 3 Hague IV has become part of the law of the land of the Federal Republic of Germany by virtue of Art. 25 of Germany's Federal Constitution (the Grundgesetz) and both Hague IV and the AP I have been ratified by Germany. While Hague IV dates from 1907, the AP I only dates from 1977. Of course only Hague IV applies to World War II.

Only states as parties can bring such claims under AP I and Hague IV because these conventions do not provide for compensation claims by individual victims. The wording of Art. 3 Hague IV and Art. 91 AP I emphasizes the obligation of a party to provide compensation in case of a breach of an obligation under the treaty in question. Back then such obligations were meant to be between the states which are parties to an international treaty. Although a lot has changed between 1907 and 1977 with regard to the position of the individual under international law, the choice of the virtually identical wording in Hague IV and AP I indicates that the drafters of AP I did not want to create rights for the individual, despite the fact that by 1977 there existed already rights of individuals outside human rights treaties, for example in Art. 36 of the Vienna Convention on Consular Relations which dates back to 1963. Individuals therefore cannot sue directly under Art. 91 AP I or Art. 3 Hague IV – and states in general don't do so. The fact that these rules are rarely resorted to by states does not mean that there is customary international law to the contrary and that these rules have become the object of desuetudo. As a matter of fact, states which want to defend themselves against such claims have resorted to a kind of act of state doctrine, as Japan has done until recently, or relied on the principle of jurisdictional immunity. The latter is at stake here.

Jurisdictional immunity

Is a fundamental consequence of the principle of state sovereignty, which in turn is the very cornerstone of the Westphalian international legal order, that one state cannot adjudicate over another state in matters related to the second state's activities as a state (as opposed to, say, as a commercial actor). Therefore plaintiffs will find it hard to obtain reparations for violations of the laws of war before national courts of a state other than the perpetrators' state. This is the problem at the core of the case currently pending between Germany and Italy.

The Distomo case from several year ago provides a good explanation of the principle of jurisdictional immunity.

The plaintiffs in Distomo were relatives and descendants of the victims of a 1944 massacre by German SS-Forces, which at that point had been integrated into the regular German Army, in the Greek village of Distomo in the Provice of Böotia. The plaintiffs sued the Federal Republic of Germany both based on rights inherited from their deceased family members and on their own rights: claims have been brought forward related to the destruction of family homes and family businesses as well as in relation to damage caused to the plaintiffs' health and other damages. In earlier proceedings, the plaintiffs requested compensation for damages under Tort Law or, in the alternative, compensation for loss of property. After lower courts had rejected their claims, the plaintiffs brought the case before the Bundesgerichtshof, which also rejected their claims on the basis of jurisdictional immunity.

Already in 1997 the District Court in Livadeia, Greece, had awarded the plaintiffs approx. 240,000,000 Greek Drachmas, almost the equivalent of 29,000,000 EUR. The German government, claiming state immunity under international law, appealed the ruling and requested a cassation of this judgment by the Areopag, Greece's Supreme Court. In April 1999 the Areopag rejected Germany's appeal. The Areopag's judgment made headline news in Germany as well when the plaintiffs attempted to enforce the judgment against Germany and asked the Greek authorities to seize property of the Federal Republic, in particular the buildings housing the renowned Goethe-Institute in Athens, for that purpose. (Essentially the same is happening now in Italy with a German-Italian cultural center, the Villa Vigoni, which has been placed under a ipoteca giudiziale, a judicial mortgage.)

Under Greek Law, a judgment can only be enforced against foreign property located in Greece if the Greek government agrees to this enforcement (unlike the legal situation in a number of other countries, in which it is required that there is a connection between the state property to be seized and the subject matter of the proceedings). Yet especially in cases of tort it is unlikely that any prior commitment of the resources of the respondent state located in the state (in this case the Goethe Institute's assets) in which the proceedings take place have been used for tortious activities before, see also Letelier v. Republic of Chile, 748 F.2d (2nd Cir 1984) at p. 793; 63 ILR 378. The Greek government however refused to give this permission, causing the Greek plaintiffs to bring the case before the European Court of Human Rights in Strasbourg. Some Distomo plaintiffs also found their way to Italian courts which declared some Greek judgments enforceable in favor of the Greek applicants.

In Strasbourg the plaintiffs asserted, based on the ECtHR's earlier decision in David and Ada Hornsby v. Greece, that the Greek rule requiring consent of the government to the enforcement of the Areopag's judgment was incompatible with Art. 6 (1) ECHR and with Art. 1 of the 1st Additional Protocol to the ECHR. The ECtHR held that the application was inadmissible (European Court of Human Rights, Decision on admissibility of individual complaint no. 59021 / 00, Aikaterini Kalogeropoulou et al. v. Greece and Germany, 12 December 2002. The decision is only available in French. An unofficial German translation is provided by the German Federal Ministry of Justice on the Court's website athttp://www.coe.int/T/D/Menschenrechtsgerichtshof/Dokumente_auf_Deutsch/Volltext/Entscheidungen/20021212_Kalogeropoulou%20u.a."20_E.asp) since at that time, it was, not generally accepted that states lose their state immunity guaranteed by international law in relation to cases involving compensation claims made abroad concerning crimes against humanity (cf. also European Court of Human Rights, Judgment, Al-adsani v. United Kingdom of Great Britain and Northern Ireland, Case no. 35763 / 97 EGMR 2001 – XI). Consequently, so the Strasbourg-based Court said, the plaintiffs de lege lata cannot force the Greek government to violate the rule of international law providing for state immunity. Nevertheless wanted the ECtHR to leave open a door for future developments, e.g. through a change in customary international law (European Court of Human Rights as quoted by the Bundesgerichtshof in its judgment of 26 June 2003, Case no. III ZR 245 / 98, pp. 11 et seq.). The BGH in its decision in the Distomo case agreed with this view.

Finally Greece's Special Supreme Court (which is comprised of all Senates of Greece's High Courts and usually only becomes involved in proceedings if two Greek High Courts disagree on a legal question) ruled in favor of the principle of jurisdictional immunity. The Special Supreme Court was called together by Judge Stephanos Matthias, the presiding judge in the Areopag's decision, who had voted against the majority opinion in the ruling which rejected the appeal of the German Government against the already mentioned judgment by the Livadeia District Court, despite the fact that the most important requirement to do so - a dispute between two Greek High Courts - was not met. Accordingly, Ioannis Stamoulis, a former prefect of the province of Böotia and former member of the European Parliament who happened to be the attorney for the plaintiffs, accused Judge Matthias of breaking the Greek Constitution. Nevertheless did the Special Supreme Court remain seized of the matter and decided in September 2002 that, albeit the plaintiffs had valid claims against Germany, the judgment issued in their favor could not be enforced due to the principle of jurisdictional immunity.

Conclusions

Unfortunately, Italy has chosen to follow the line of reasoning of the Livadeia court rather than that shared by the Areopag, the Greek Special Supreme Court, theBundesgerichtshof and the European Court of Human Rights. The International Court of Justice will in all likelihood rule in Germany's favor.

As the European Court of Justice left an opening in Kalogeropoulou by concluding that there was no customary law contrary to the concept of jurisdictional immunity, the International Court of Justice now has the opportunity to elaborate on the relationship between the modern position of the individual under international law and the concept of jurisdictional immunity which is a direct consequence of the fundamental principle of state sovereignty.

This case teaches us that international law is not yet as post-Westphalian as many (including many lawyers) want it to be and the law applicable in this case is fundamentally Westphalian. That means that states can only be sued if the state in question in principle agreed to possibly being sued.

Fortunately, the international legal order also contains post-Westphalian elements, allowing individuals to sue states directly. Violations of International Humanitarian Law will often also constitute violations of regional human rights documents, such as the European Convention on Human Rights (ECHR), which provides for compensation for victims of human rights violations. Accordingly the European Court of Human Rights in Strasbourg has received a substantial number of cases related to the situation in Turkish Kurdistan and Chechnya and already has elaborated on the applicability of the ECHR to (military) activities outside the territory of the parties to the convention in Bankovic and Loizidou. Under the Statute of the permanent International Criminal Court in The Hague, individual perpetrators can now also be held liable for the damages caused by their actions. The law is developing, but slowly. Most of the world still lacks the compensation possibility afforded to Europeans by the ECHR and the number of cases before the ICC is still too small to make any predictions as to its effectivity, but the ICC of course was never intended to be an international court of tort law.

State sovereignty will remain the cornerstone of Public International Law for some time. But states should become aware of the fact that this will have a price, or in other words "with great power comes great responsibility". States cannot be sued against their will, i.e. unless they have agreed to the possibility of being sued. Given that states are reluctant to sue each other over violations of International Humanitarian Law, they should provide effective avenues for victims of their violations of international law to be compensated. Nothing less is their obligation under Art. 91 AP I and Art. 3 Hague IV.

Because most armed conflicts today involve at least one non-state actor and non-state actors such as Hamas, Hezbollah or Al Qaida deliberately terrorize civilians by targeting them or at least violating the distinction principle, states should have an interest in creating a rule of customary international law to the effect that victims of violations of the laws of war can sue the perpetrator in person as well as the organization behind the perpetrator, regardless of the nature or identity of this organization, be it a state, an international organization or a terror group (on damages owed by state sponsors of terrorism cf. also 7 German Law Journal (2006) 777). So far, their own reluctance to pay their victims or to sue other states, including state sponsors of terrorism (the Lockerbie case being a notable exemption), has prevented the emergence of such a rule. It is up to the states as the fundamental unit of international legal relations to act upon the responsibility which comes with this position.



A member of the American Society of International Law (ASIL), the Lieber Society and the German Red Cross Expert Pool on International Humanitarian Law, Stefan Kirchner is admitted to the bar in Germany (Rechtsanwalt) and mainly handles cases concerning human and civil rights, in particular before the European Court of Human Rights and the German Federal Constitutional Court. He teaches at the Faculty of Law at Georg-August-University in Göttingen while finishing his doctoral thesis at Justus-Liebig-University in Giessen. Email: kirchnerlaw@yahoo.com.

January 09, 2009

Comments:
Dear Stefan Kirchner,

In response to your well-founded article posted in jurist, I would like to comment on two aspects:
1. You seem to be basing your article on the view that state immunity derives from the concept of national sovereignty, a hypothesis not entirely false. However, in supporting this view you do not seem to take into serious consideration two quite important factors that are into play in the issue at hand: a) the fact that sovereignty applies to acts of a state that are conducted in its domestic sphere (to which a foreign state should not have any power to influence), while state immunity -especially in the instance of the Greek and the Italian cases- is not applied to purely internal matters but rather to acts that were conducted by a state outside its territory where it enjoys its sovereignty. This may
have serious legal implications as it is a contradiction to suggest that a state is to be sovereign (by applying state immunity as a result of its sovereignty) inside the borders of another sovereign state! More importantly though, even if one is to adopt this line of reasoning, ie that state immunity equals state sovereignty, it has to be taken into account that current international law, as it has especially evolved post-WWII, places serious restrictions on state sovereignty, which are mainly contained in the body of human rights and humanitarian law. If therefore, human rights law and humanitarian law limit state sovereignty since they hold the state accountable towards individuals, why shouldn't they limit the scope and application of state immunity in national courts as well?

2. Furthermore, you seem to suggest that the Italian courts reasoning follows the same line as the Greek Courts (...Italy has chosen to follow the line of reasoning of the Livadeia court..). However, in respect to this statement I have to mention that the reasoning adopted by the two courts differs substantially. The Greek courts adopted the so-called normative hierarchical theory by suggesting that an unlawful act of a state is not to be considered as jure imperii and therefore, falls outside the scope of state immunity. On the contrary, the Italian Courts adopted a much well founded and complete approach by , declaring that “a waiver cannot…be envisaged in the abstract, but only encountered in the concrete” and by establishing their jurisdiction using the rules of international criminal law.

As a final word, I have to say that I cannot myself simply guess the decision of the ICJ, but I am sure that it will be quite elaborated and it won't be 100% in the lines of the one side or of the other. In any case though, I surely do not hope that is in favour of Germany and in favour of impunity of the atrocities that its armed forces committed during WWII' atrocities which have not yet been redressed.

Alexandros-Ioannis Kargopoulos
Attorney at law-Greece, LLB (Kent), LLM (UCL),
January 10, 2009

This is a very interesting article by Prof. Kirchner, followed by an equally interesting comment by colleague Mr. Kargopoulos. Mr. Kargopoulos rightly argues that human rights law and humanitarian law limit state sovereignty since they hold the state accountable for their acts towards individuals and, accordingly, poses the logical question: if that is so, why shouldn't such a position limit the application of state immunity in national courts? This position has the ring of the ICJ reasoning in The Barcelona Traction Case where the Court stated that a clear distinction should be made between the obligations that states have vis-a-vis another state and obligations states have towards the international community as a whole. To respect human right law and humanitarian law is certainly an obligation states have towards the international community as a whole.

Consequently, the ICJ should take the clear position on whether the notion of state immunity before the national courts is an absolute privilege, or the right to invoke the state immunity argument should be limited when a state acting outside its borders violates human rights law or humanitarian law on the territory of another state. It can be argued that in such a situation nationals of a state in which the breach took place should be able to sue before the national courts.

Goran Cvetic, LL.M. (LSE)
Advocate
Belgrade
February 20, 2009

Monday 1 February 2010

Why the legal debates about Iraq will never end


January 31, 2010

Why the legal debates about Iraq will never end

What have we learnt so far from the Iraq inquiry with regard to international law? At one level, we have heard views that international law is uncertain, international lawyers dogmatic, and that lawyers who are not international lawyers are not international lawyers and thus cannot, by implication, deal with arguments in that field.
The question of the legal justification for the use of force against Iraq in March 2003 has been long and ferociously debated. Most international lawyers regard the action as illegal, but not all. All are agreed that the justifications of self-defence and humanitarian intervention (itself controversial) were not relevant at that time and that regime change as such is illegal.
So all turned on whether it could be said that the invasion was sanctioned by the United Nations security council. This involves complex questions as to the interpretation of phrases that were deliberately rendered ambiguous in the security council’s resolution 1441 in order to achieve a political consensus.
All states and the security council accepted that Iraq was in material breach of a whole series of resolutions including the key resolution (687) that ended the 1990-1 Gulf war, in which the ceasefire was subject to conditions such as the destruction of weapons of mass destruction. Resolution 1441, passed in November 2002, gave Iraq a “final opportunity” to comply, introduced an enhanced weapons inspection regime and warned of “serious consequences” for Iraq for continued violations.
But could force be used as a result of Iraq’s continuing violations without a further definitive resolution? This was a big step and it was one vigorously disputed as a matter of close interpretation of the resolution by the relevant government lawyers, taking into account pertinent background and negotiating materials.
One interesting question is whether the standard required to demonstrate a legal justification for force is that of “a reasonable case” or something higher. The use of force in Kosovo in 1999 demonstrates that while a vast majority of international lawyers regarded this at the time as unlawful (although some have since changed their minds), at no time could it really have been said that any standard higher than a reasonable or credible case was either accepted or posited.
The testimony last week by the two former most senior Foreign Office international lawyers — one of whom drolly dismissed Jack Straw, the legally trained former foreign secretary, as “not an international lawyer” — and by Lord Goldsmith, inset, the attorney-general at the time, also revealed an institutional flaw.
While the Foreign Office lawyers take the lead on issues of international law with regard to the usual run of business of government, it is the attorney-general who is the senior law officer of government. He is the person to whom the government will turn for the definitive legal view.
However, in the case of the Iraq war, Goldsmith does not appear to have been involved as of right in key activities leading up to the point at which decisions needed to be taken. He told the inquiry that, until relatively late in the day, his involvement was not requested, but it was from time to time provided as he felt necessary.
This can hardly be the most effective or indeed the correct way for international legal advice to be provided to the government at the very highest level. The attorney-general should be provided with further international law specialists, and there should be a mechanism for him to provide advice in a regular and timely fashion. In any event, once the question of legality is dealt with, the next, and perhaps equally critical issue is whether the proposed action is right.
Professor Malcolm N Shaw QC is the Sir Robert Jennings professor of international law at the University of Leicester