Temple of Preah Vihear Case (AQA, 1962) PDF

Treaty law: Temple of Preah Vihear Case (Cambodia v. Thailand, ICJ 1962): Who Owns the Temple? What was the dispute about? Background: The case was about a disagreement between Cambodia and Thailand over who owned the land around the Temple of Preah Vihear, an ancient and culturally...

Treaty law: Temple of Preah Vihear Case (Cambodia v. Thailand, ICJ 1962): Who Owns the Temple? What was the dispute about? Background: The case was about a disagreement between Cambodia and Thailand over who owned the land around the Temple of Preah Vihear, an ancient and culturally important site. The disagreement started because of different interpretations of a treaty signed in 1904 between France (on behalf of Cambodia) and Siam (now Thailand). The treaty said the border should follow the watershed line (the highest points dividing rivers). A map made after the treaty, called the "Annex I Map," showed the temple on Cambodia’s side. Thailand later argued the map was wrong and didn’t match the treaty’s terms because it didn’t follow the watershed line. Cambodia said Thailand had occupied the temple unlawfully since 1954 and asked the International Court of Justice (ICJ) to decide who had sovereignty and to order Thailand’s troops to leave. Area of Law: The case was about land ownership, treaty interpretation, and whether maps can be used as evidence to define borders. Thailand claimed there was an "error" in the map, referring to Article 48 of the Vienna Convention on the Law of Treaties, which allows treaties to be invalidated if there was a mistake. Why could the ICJ decide on this case? Both Cambodia and Thailand agreed to let the ICJ settle their dispute. The ICJ’s job was to interpret the 1904 treaty, the Annex I Map, and the actions of both countries over time. What did the two sides argue? Cambodia’s Argument: 1. The Annex I Map correctly reflected the 1904 treaty and placed the temple in Cambodia. 2. Thailand had accepted the map for decades without objecting, which meant it had agreed to the boundary. 3. By remaining silent and acting as though the map was correct, Thailand had effectively recognized the border. Thailand’s Argument: 1. The map was wrong because it didn’t follow the watershed line, as stated in the treaty. 2. Thailand only accepted the map because of a mistake. Under Article 48 of the Vienna Convention, a mistake like this could invalidate the map. What did the ICJ decide (and why does it matter)? The Decision: The ICJ ruled in favor of Cambodia, confirming its ownership of the Temple of Preah Vihear and ordering Thailand to remove its troops. Thailand’s argument about a mistake in the map was rejected because: 1. Thailand’s officials had been involved in creating the map and should have noticed the error. 2. Thailand didn’t object to the map for decades, so it couldn’t suddenly claim it was wrong. 3. Thailand’s actions over the years showed it accepted the map as correct. Why It Matters: 1. Mistakes in Treaties: o The ICJ clarified that a country can’t claim a treaty or map is invalid because of a mistake if it contributed to the mistake, failed to notice it, or acted like it agreed with the terms. 2. Maps as Evidence: o Maps attached to treaties can be strong evidence of borders, especially if both sides have accepted and followed them for a long time. 3. Treaty Stability: o This case showed the importance of keeping treaties reliable and discouraging countries from challenging them years later without good reason. What can we learn from this case? 1. Mistakes and Treaties: o A country must show it didn’t cause or notice the mistake to claim a treaty or map is invalid. Acting like the terms are correct for many years weakens such claims. 2. Actions Speak Louder Than Words: o If a country accepts a treaty or map for a long time without objecting, it may lose the right to challenge it later. 3. Respecting Agreements: o Treaties and maps provide stability, and countries are expected to act carefully and responsibly when making agreements. Why is this case still important today? The Temple of Preah Vihear Case is a key example of how international courts handle land disputes and interpret treaties. It highlights the importance of accepting and respecting agreements, especially when evidence like maps has been relied on for decades. It also shows how international law promotes stability and fairness between countries. Customary law: Nicaragua Case (ICJ 1986): U.S. Military and Paramilitary Actions Against Nicaragua What was the dispute about? Background: From 1981 to 1984, the U.S. gave financial and military support to the Contra rebels in Nicaragua, who were fighting the Sandinista government. The U.S. also carried out military actions like mining Nicaragua’s harbors and attacking oil facilities and naval bases. Nicaragua claimed these actions violated international law, particularly the rules against using force and interfering in another country’s internal affairs. What was Nicaragua’s claim? Nicaragua argued that the U.S. violated its sovereignty and the international rules prohibiting: 1. The use of force. 2. Intervening in another state’s domestic matters. What legal principles were involved? Customary International Law: The ICJ applied customary international law because the U.S. had excluded ICJ jurisdiction over disputes involving treaties, like the UN Charter, through the "Vandenberg reservation." Key principles of customary law included: 1. Prohibition on the Use of Force: A fundamental rule of international law, recognized as universally binding (jus cogens). 2. Non-Intervention: States cannot interfere in the internal affairs of other countries. How is Customary International Law formed?  1. Opinio juris: The belief that a practice is legally required. 2. General state practice: Widespread and consistent actions by states. What were the main arguments of the parties? Nicaragua’s Argument: The U.S. broke international rules by: o Mining Nicaragua’s harbors. o Attacking its infrastructure. o Supporting armed rebels (the Contras). U.S. Argument: The U.S. claimed its actions were lawful because: 1. It was acting in collective self-defense under customary law. 2. The ICJ didn’t have jurisdiction to decide the case because of the treaty reservation. How did the ICJ handle the case? Customary Law vs. Treaties: The ICJ ruled that customary international law could still be applied, even though the U.S. excluded treaty-based jurisdiction. This allowed the Court to evaluate whether the U.S.’s actions violated the principles of customary international law. Key Points on Customary Law: 1. General Practice: For a rule to count as customary law, states don’t need to follow it perfectly. Even when a state violates a rule, the violation is seen as a breach, not a sign that the rule no longer exists. 2. Opinio juris: A state shows it believes in a legal obligation if it acknowledges the rule, even if it doesn’t always follow it. 3. Non-Intervention: The Court confirmed that the principle of non-intervention remained valid, even if some states occasionally broke it. What was the ICJ’s decision (and why is this case important)? The Decision:  The ICJ ruled in favor of Nicaragua, finding that the U.S.: 1. Violated the rule against using force. 2. Broke the principle of non-intervention. The Court ordered the U.S. to stop its actions and pay reparations, but the U.S. refused to comply. Why It Matters: 1. Customary Law vs. Treaties: o The case showed that customary law applies even if a state excludes treaty-based jurisdiction. 2. Strength of Customary Law: o The ICJ emphasized that customary rules remain valid if states publicly accept them, even if their actions sometimes don’t align. 3. International Justice: o The Court demonstrated its ability to uphold international law despite challenges from powerful states like the U.S. What are the broader lessons for international law? 1. Prohibition of Force: o This case confirmed the rule against using force as a universal and non-negotiable principle (jus cogens). 2. How Customary Law is Formed: o Customary law depends on widespread practice and the belief that the rule is legally binding, even if violations occur. 3. Challenges in Enforcement: o The case highlighted the difficulty of enforcing international law against powerful states unwilling to follow ICJ rulings. 4. Modern View of Customary Law: o The ICJ took a flexible approach, focusing on preserving the strength of international rules rather than strict adherence to state actions. Why is this case still relevant today? The Nicaragua Case remains important because it reinforced key principles of international law, like the prohibition on the use of force and non-intervention. It also demonstrated the enduring power of customary law, even when treaty obligations are excluded, and highlighted the challenges of enforcing international justice in a world of unequal power dynamics.  Statehood: Sealand Case (1978): Can Sealand Be a Country? – German federal administrative court What was the dispute about? Background: The case was about whether the "Principality of Sealand," a self-declared state, should be recognized as a real country under international law. A German citizen, who claimed to be Sealand’s "Foreign Secretary" and a citizen of Sealand, argued that he had lost his German citizenship by adopting Sealand nationality. German authorities disagreed, saying Sealand wasn’t a real country, so the man was still a German citizen. The case went to the German Federal Administrative Court (Bundesverwaltungsgericht). What is Sealand? In 1967, Roy Bates, a British man, took over an abandoned WWII sea fort in the North Sea called Roughs Tower and declared it the "Principality of Sealand." Sealand acted like a country by issuing passports, creating a constitution, and claiming sovereignty. However, it was just a small platform with a handful of people, mostly Bates’ family. What did the plaintiff want? He wanted the court to recognize Sealand as a country, which would mean his Sealand citizenship replaced his German citizenship. What legal principles did the court use? The court used the Montevideo Convention (1933) to decide if Sealand qualified as a country. According to the convention, a state must have: 1. Defined Territory: A specific area of land it controls. 2. Permanent Population: A group of people living there permanently. 3. Government: A functioning system of authority. 4. Capacity to Enter Relations with Other States: The ability to interact with and be recognized by other countries. Focus on Three Criteria: The court focused only on the first three criteria (territory, population, and government) because Sealand already failed these. Without meeting the basics, it couldn’t have relationships with other states. What did both sides argue? Plaintiff’s Argument: Sealand met the requirements of a state under international law. Its government, which issued passports and controlled the platform, proved it was sovereign. German Authorities’ Argument: Sealand didn’t meet the requirements for statehood: 1. Territory: Territory must consist in a natural segment of the earth’s surface. An artificial island, albeit connected to the earth’s surface, did not satisfy this criterion. 2. Population: Whilst size was irrelevant, in order to constitute a people the group of persons in question must form a cohesive vibrant community. An association whose common purpose covered merely commercial and tax affairs was insufficient.” 3. Government: Sealand’s "government" wasn’t capable of running a real state or being independent. How did the court decide? The court applied the Montevideo criteria and found: 1. Territory: Sealand didn’t qualify because it was an artificial structure, not a natural part of the earth. 2. Population: A permanent population requires more than a small group or family living together for convenience. Sealand didn’t have a real, settled community. 3. Government: Sealand’s "government" lacked the ability to control the platform effectively or act as a proper authority. Decision: The court ruled that Sealand wasn’t a country under international law, so the plaintiff’s claim to Sealand citizenship was rejected. Why is this case important? 1. Montevideo Criteria: It reinforced the rules for deciding what makes a country under international law. 2. Artificial Structures: The court made it clear that artificial platforms like Sealand cannot be used to claim sovereignty.  3. Micronations: The case showed that self-declared "micronations" without proper land, population, or government won’t be recognized as countries. Broader Lessons for International Law 1. Strict Statehood Requirements: The Montevideo criteria are applied strictly, ensuring that only entities meeting these rules can claim to be states. 2. Recognition Matters: Without recognition by other states, entities like Sealand cannot gain sovereignty, even if they act like a country. 3. No Sovereignty for Platforms: The ruling set a clear precedent that artificial structures in international waters cannot form the basis for claiming statehood. Why does this case still matter? The Sealand Case highlights how international law distinguishes between real states and self- declared micronations. It ensures that statehood is reserved for entities with land, people, and functioning governments, preventing artificial claims from undermining international rules. State responsability: Analysis of the Rainbow Warrior Case in the Context of State Responsibility What was the dispute about? Background: On July 10, 1985, French intelligence agents bombed the Greenpeace ship Rainbow Warrior in Auckland Harbour, New Zealand. This act aimed to stop Greenpeace’s protests against French nuclear tests. The bombing led to the death of Fernando Pereira, a Dutch photographer. New Zealand authorities arrested two French agents, Alain Mafart and Dominique Prieur, who pleaded guilty to manslaughter and causing willful damage. Under international pressure, France and New Zealand reached a 1986 agreement mediated by the UN Secretary-General. It stated that Mafart and Prieur would be sent to a French military base on Hao, a remote island in French Polynesia, for at least three years. They could not leave without mutual consent. In December 1987, France unilaterally repatriated Mafart to Paris, citing medical reasons. New Zealand objected, claiming this violated their agreement. France argued that the decision was necessary due to humanitarian reasons (force majeure). Key Legal Issues 1. State Responsibility for Wrongful Acts: o The bombing violated New Zealand’s sovereignty and international law. France, as the orchestrator, bore full responsibility for the act. 2. Breach of International Agreement: o France broke the 1986 agreement by transferring Mafart without New Zealand’s consent, ignoring the clear treaty terms. 3. Use of Force Majeure: o France justified its breach by claiming force majeure, arguing that Mafart’s medical condition required urgent action. However, the validity of this defense was questioned as the situation did not meet the high threshold required under international law. Legal Principles Applied 1. State Responsibility: o A state is accountable for the actions of its agents, especially when those actions breach international law or agreements. 2. Good Faith in Treaties: o States must act in good faith when fulfilling treaty obligations. France's failure to consult New Zealand before moving Mafart violated this principle. 3. Force Majeure as a Defense: o Force majeure can only excuse a breach if it is caused by an unforeseen, unavoidable emergency. In this case, the medical condition cited did not reach that level of urgency. Assessment of the Parties’ Arguments New Zealand’s Arguments: France’s unilateral transfer of Mafart was a clear violation of the 1986 agreement and New Zealand’s sovereign rights. Alternative solutions, such as allowing medical personnel to treat Mafart on Hao, were dismissed by France, showing bad faith. France’s Arguments: Mafart’s health condition justified immediate action, which was unavailable on Hao. France cooperated afterward by allowing a New Zealand doctor to examine Mafart in Paris, though this was too late to mitigate the breach. Tribunal Decision and Its Importance The Decision: The arbitral tribunal found France guilty of breaching the 1986 agreement. France’s justification (force majeure) was rejected because Mafart’s medical condition was not an immediate or unavoidable emergency. France was held responsible and required to provide assurances of compliance with the agreement. Why It’s Important: 1. Respect for Treaties: o The decision emphasized that states must honor their treaty obligations, even during challenging circumstances. 2. Limits on Force Majeure: o The case clarified that the defense of force majeure has strict limits and cannot be used to justify avoidable breaches. 3. Good Faith and Cooperation: o The case underlined the importance of acting in good faith when resolving international disputes. Broader Implications for International Law 1. State Accountability: o States are responsible for the actions of their agents and breaches of international law. 2. Strengthening Treaty Obligations: o The case reinforced the idea that international treaties must be strictly adhered to, preserving the trust and order in international relations. 3. Limits on Justifications for Breaches: o The tribunal’s decision showed the rigorous standards required for invoking defenses like force majeure, ensuring they aren’t misused to escape responsibility. Why This Case Matters Today The Rainbow Warrior Case is a landmark in international law, illustrating: The importance of holding states accountable for wrongful acts. The necessity of honoring international agreements. The rigorous standards for justifying breaches, safeguarding fairness and trust in international relations. It remains a crucial example of how states must balance their actions with their obligations under international law. Title to Territory: Island of Palmas Case (Netherlands v. United States, 1928): Sovereignty and Territorial Title What was the dispute about? Factual Background: The Island of Palmas (Miangas), located between Mindanao (Philippines) and the Dutch East Indies, was claimed by both the United States and the Netherlands. Following the Spanish-American War (1898), Spain ceded the Philippines to the U.S. under the Treaty of Paris. A U.S. official later discovered that the Dutch flag was flying on the island, triggering the dispute. Area of International Law / Legal Principles: The case revolved around sovereignty over territory and the rules governing effective occupation. Key principles discussed include discovery, contiguity, and the doctrine of inter-temporal law. What was the basis of the tribunal’s jurisdiction? The case was submitted to arbitration under an agreement between the United States and the Netherlands to resolve the territorial dispute. What were the main contentions of the parties? United States’ Argument: The U.S. claimed sovereignty based on: The Treaty of Paris, asserting Spain’s original title through discovery. Palmas’ proximity to the Philippines, arguing that contiguity implied inclusion within ceded territories. The island was terra nullius when Spain discovered it. Netherlands’ Argument: The Netherlands argued it had exercised continuous and peaceful sovereignty over the island since 1677.  Evidence included treaties negotiated by the Dutch East India Company with local rulers and consistent administrative activities. Contested the U.S. claim that Spain had included Palmas within its administration of the Philippines. Which side of the main argument do you personally find more convincing and why? The Netherlands’ argument is more convincing because: Effective Occupation: The Netherlands demonstrated continuous and peaceful exercise of sovereignty, a stronger basis for title than mere discovery or contiguity. Inter-temporal Law: At the time of the dispute, effective sovereignty carried more weight in international law than discovery, which is considered only a provisional title. How did the tribunal decide (and why is this case important)? Decision: The arbitrator, Max Huber, ruled in favor of the Netherlands, finding that: Discovery provides only a provisional title, which must be solidified through effective occupation. The Netherlands had exercised effective and continuous sovereignty over Palmas, while Spain (and later the U.S.) had not. Geographical proximity does not establish sovereignty in international law. Significance: Reinforced the principle of effective occupation: Continuous and peaceful exercise of sovereignty prevails over competing claims based on discovery or geographical proximity. Highlighted the doctrine of inter-temporal law, which states that the legality of territorial claims must be evaluated based on the rules of law applicable at the time of the relevant acts. Established that sovereignty requires tangible acts of governance, not mere nominal claims. Broader Takeaways for International Law: Effective Occupation: Sovereignty over territory depends on the actual, continuous, and peaceful exercise of state authority.  Provisional Title: Discovery alone does not confer full title unless followed by effective occupation. Contiguity: Geographical proximity is not a sufficient basis for sovereignty. Inter-temporal Law: Claims to territory must be evaluated based on the legal norms prevailing at the time of the claim. State Jurisdiction: Eichmann Case (Israel v. Eichmann, 1960–1962): State Jurisdiction and Universal Justice What was the dispute about? Factual Background: Adolf Eichmann, a senior Nazi official and one of the principal architects of the Holocaust, fled to Argentina after World War II and lived under an assumed identity. In 1960, Israeli intelligence (Mossad) abducted Eichmann in Argentina and brought him to Israel to stand trial under the Nazis and Nazi Collaborators (Punishment) Law, 5710-1950. He faced 15 counts of crimes, including: Crimes against the Jewish People. Crimes against Humanity. War Crimes. Membership in enemy organizations (e.g., the SS, SD, and Gestapo). Legal Issue: Did Israel have jurisdiction to prosecute Eichmann for crimes committed outside its territory and before its existence as a state in 1948? What was the basis of Israel’s jurisdiction? Universal Jurisdiction: Israel argued that Eichmann’s crimes constituted atrocities of such magnitude (e.g., genocide, crimes against humanity) that they could be prosecuted under universal jurisdiction, regardless of where they were committed or the nationality of the perpetrator or victims. Article 6 of the Genocide Convention was cited as a key legal basis. Protective Principle:  Eichmann’s crimes targeted the Jewish people, many of whom later became citizens of Israel. The state had an inherent right to protect its national interests. Lotus Principle Reference: Israel invoked the Lotus case principle that "any argument against a state’s power to try crimes must point to a specific rule in international law which negates that power." What were the main contentions of the parties? Eichmann’s Defense: Challenged Israel’s jurisdiction on the grounds that: He was not an Israeli citizen. His crimes were committed outside Israel, before its establishment as a state. The Nazis and Nazi Collaborators (Punishment) Law was enacted after his crimes, making its application retroactive and thus illegal under international law. Opposition to the Trial: Eichmann’s defense also argued that his abduction from Argentina violated international law and the sovereignty of Argentina. Israeli Prosecution: Emphasized the universality of the crimes and argued that the gravity of Eichmann’s actions transcended territorial boundaries. Cited international norms established during the Nuremberg Trials, rejecting Eichmann’s claim that he was merely following orders (“superior orders defense”). Which side of the main argument do you personally find more convincing and why? Israel’s Argument: The principle of universal jurisdiction is compelling, especially for prosecuting crimes that shock the conscience of humanity. The defense’s reliance on Eichmann’s abduction is less persuasive, as established international law holds that the legality of an arrest does not preclude prosecution for grave offenses. How did the courts decide (and why is this case important)? District Court of Jerusalem: Found Eichmann guilty on all counts and sentenced him to death. Israeli Supreme Court:  Upheld the conviction, reaffirming: The validity of universal jurisdiction for prosecuting international crimes. The principle that superior orders are not a valid defense for atrocities. States may enact retrospective criminal legislation for crimes under international law, given their universal and timeless nature. Significance: The Eichmann trial was a landmark in establishing universal jurisdiction as a tool for justice. It reinforced norms of accountability for international crimes, such as genocide and crimes against humanity. It clarified that procedural violations (e.g., Eichmann’s abduction) do not invalidate jurisdiction over grave crimes. Broader Takeaways for International Law: Universal Jurisdiction: The case solidified universal jurisdiction as a legitimate basis for prosecuting atrocities, regardless of where they were committed or the nationality of those involved. State Sovereignty and Accountability: Highlighted the balance between state sovereignty (Argentina’s protest over Eichmann’s abduction) and the imperative to prosecute international crimes. Legacy: Inspired subsequent prosecutions of international criminals, influencing cases like those in the International Criminal Tribunals for Rwanda and Yugoslavia. Controversial Elements: The abduction of Eichmann remains debated in terms of its legality under international law. The use of the death penalty in this case, while legal at the time, is considered inconsistent with modern human rights principles. Why is this case significant today? The Eichmann case reaffirmed the principle of accountability, ensuring that no individual—regardless of rank or geography—can escape justice for crimes that harm humanity. It remains a cornerstone in discussions of extraterritorial jurisdiction and the development of international criminal law. Immunity: Arrest Warrant Case (Democratic Republic of Congo v. Belgium, ICJ 2002): Jurisdiction and Immunity What was the dispute about? Factual Background: In April 2000, a Belgian investigating judge issued an international arrest warrant against Abdulaye Yerodia Ndombasi, the Minister for Foreign Affairs of the Democratic Republic of the Congo (DRC), for grave breaches of the Geneva Conventions and crimes against humanity. The alleged acts occurred outside Belgian territory, involved no Belgian nationals, and Mr. Yerodia was neither a Belgian national nor in Belgium at the time of the arrest warrant. Key Legal Issue: Did Belgium’s issuance of the arrest warrant violate international law, particularly the principles of state immunity and sovereignty? What was the basis of Belgium’s jurisdiction? Belgium relied on its 1993 Law on Grave Breaches of International Humanitarian Law, later amended in 1999, which granted universal jurisdiction to Belgian courts for serious violations of international humanitarian law, regardless of where they occurred or the nationality of the accused or victims. Article 7 of this law extended jurisdiction “wheresoever [the acts] may have been committed.” What were the main contentions of the parties? DRC’s Argument: The issuance of the arrest warrant violated the principle of immunity ratione personae, which protects foreign ministers from criminal prosecution in foreign courts. Belgium breached DRC’s sovereign equality and the norms of diplomatic immunity under international law. Belgium’s Argument:  Universal jurisdiction applies to grave breaches of international law, particularly crimes against humanity and war crimes. Immunity ratione personae is procedural and does not exempt officials from substantive criminal responsibility under international law. Which side of the main argument do you personally find more convincing and why? The DRC’s argument is more convincing because: International law upholds the immunity of sitting foreign ministers under customary law to ensure the effective performance of their duties (e.g., Article 21(2) of the New York Convention on Special Missions). The ICJ correctly distinguished between immunity (a procedural bar to jurisdiction) and impunity(lack of accountability), emphasizing that immunity does not prevent accountability in other circumstances, such as domestic or international courts. How did the ICJ decide (and why is this case important)? Decision: The ICJ ruled in favor of the DRC, finding that: Immunity ratione personae protects sitting foreign ministers from the jurisdiction of foreign national courts, even for serious international crimes. Belgium violated DRC’s sovereignty by issuing the arrest warrant against Yerodia while he was in office as Minister for Foreign Affairs. International law upholds the immunity of sitting foreign ministers under customary law to ensure the effective performance of their duties (e.g., Article 21(2) of the New York Convention on Special Missions). The ICJ correctly distinguished between immunity (a procedural bar to jurisdiction) and impunity (lack of accountability), emphasizing that immunity does not prevent accountability in other circumstances, such as domestic or international courts Significance: Reaffirmed the principle that immunity is procedural, shielding officials from prosecution in foreign national courts but not from accountability  in their own state, once they leave office, or before international criminal tribunals. Highlighted that the application of universal jurisdiction must respect international norms of immunity and sovereignty. Broader Takeaways for International Law: Immunity vs. Impunity: The ICJ clarified that immunity protects state officials only while they are in office and does not equate to impunity for international crimes. Four exceptions to immunity ratione personae: Prosecution in their own state. Waiver of immunity by the state. Prosecution after leaving office for acts committed outside their official period. Prosecution by international criminal tribunals with proper jurisdiction. Limits of Universal Jurisdiction: States exercising universal jurisdiction must consider international norms, particularly those governing immunity for high-ranking officials. Sovereign Equality: Reaffirmed the importance of respecting the sovereignty and equality of states in international law. Why is this case significant today? The Arrest Warrant case serves as a critical precedent in balancing universal jurisdiction with the principles of immunity and sovereignty. It underscores the need for international mechanisms (e.g., the ICC) to prosecute serious international crimes when procedural immunity shields perpetrators in domestic or foreign courts. This case remains a cornerstone for discussions on the tension between state sovereignty, diplomatic immunity, and accountability for international crimes. 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