On June 24, 2015, the Gauteng High Court of South Africa (the Court) ruled in Southern Africa Litigation Centre v. Minister of Justice and Others that South African law required the government to arrest Sudanese President Omar Al-Bashir—who is wanted by the International Criminal Court (ICC) for war crimes, genocide, and crimes against humanity—and that the government could not contravene a prior decision ordering his arrest.  In the previous decision from June 14, 2015, the Court had ruled that the government must take steps to arrest Al-Bashir “and detain him, pending a formal request for his surrender from the International Criminal Court,” while he was in South Africa for an African Union Summit.  In the present case, the Court stated that Al-Bashir had subsequently left South Africa and that “on a common sense approach, there are clear indications that the order of Sunday 14 June 2015 was not complied with.”  The Court went on to note that “[a] democratic State based on the rule of law cannot exist or function, if the government ignores its constitutional obligations and fails to abide by Court orders” and invited the South African National Director of Public Prosecutions “to consider whether criminal proceedings are appropriate.”