International Law in Brief


International Law in Brief (ILIB) is a forum that provides updates on current developments in international law from the editors of ASIL's International Legal Materials.
ICC Appeals Chamber Upholds Article 18(1) Decision in the Palestine Situation
| By: Özge Karsu : December 24, 2025 |

Photo by Roel Wijnants (CC BY-NC 2.0)

On December 15, 2025, the Appeals Chamber of the International Criminal Court (ICC), by majority, confirmed Pre-Trial Chamber I’s decision rejecting Israel’s request for an order requiring the Prosecutor to issue a new notification under Article 18(1) of the Rome Statute in the Situation in the State of Palestine.

The appeal was submitted by Israel, as a challenge to the Prosecutor’s ongoing investigation. Israel argued that the events following October 7, 2023, together with referrals submitted by seven state parties in 2023 and...

ICC Sentences Abd-Al-Rahman to 20 Years’ Imprisonment for Darfur Crimes
| By: Özge Karsu : December 24, 2025 |

Photo by Tony Webster (CC BY 2.0)

On December 9, 2025, Trial Chamber I of the International Criminal Court (ICC) issued a sentencing judgment in Prosecutor v. Ali Muhammad Ali Abd-Al-Rahman (“Ali Kushayb”). The sentencing judgment followed Abd-Al-Rahman’s conviction on October 6, 2025, on 27 counts of crimes against humanity and war crimes committed in Darfur, Sudan, between August 2003 and April 2004.

The Chamber imposed a sentence of 20 years of imprisonment. Pursuant to Article 78(2) of the Rome Statute, the period of Abd-Al-Rahman’s detention since June 9, 2020,...

Security Council Renews MINURSO Mandate
| By: Ylian Gassmi : December 19, 2025 |

Image generated by AI

On October 31, 2025, the United Nations Security Council adopted Resolution 2797, extending the mandate of the United Nations Mission for the Referendum in Western Sahara (MINURSO) until October 31, 2026. The resolution was adopted by 11 votes in favour, with abstentions from China, the Russian Federation, and Pakistan.

The resolution, drafted by the United States, reiterates full support for the efforts of the Secretary-General and his Personal Envoy, Staffan de Mistura, to advance negotiations among the parties (Morocco, the Frente POLISARIO,...

ECtHR Finds Excessive Use of Force in Georgia Demonstration
| By: Özge Karsu : December 19, 2025 |

Photo by Adrian Grycuk (CC BY-SA 3.0 PL)

On December 11, 2025, the Grand Chamber of the European Court of Human Rights (ECtHR) delivered its judgment in Tsaava and Others v. Georgia, concerning the dispersal of a large-scale demonstration that took place outside the Georgian Parliament on June 20-21, 2019. The applicants, who included the demonstrators and journalists, alleged that law enforcement authorities used excessive force through the use of kinetic impact projectiles and that the subsequent investigations were ineffective. The case concerned Article 3 (prohibition...

States and the EU Sign Convention Establishing International Claims Commission for Ukraine
| By: Özge Karsu : December 19, 2025 |

Photo by Wanderherr (CC BY 3.0)

On December 16, 2025, the European Union (EU) and thirty-four states signed the “Convention establishing an International Claims Commission for Ukraine.” The Convention establishes the International Claims Commission as an independent administrative body within the institutional framework of the Council of Europe. The Commission possesses international legal personality and is mandated to review, assess, and decide claims for compensation arising from damage caused by internationally wrongful acts committed by the Russian Federation in or...

ICC Takes Custody of Libyan Prison Official Accused of War Crimes
| By: Brianne Blain : December 18, 2025 |

Photo by Tony Webster (CC BY 2.0)

The International Criminal Court (ICC) has confirmed the transfer of Khaled Mohamed Ali El Hishri, a Libyan war crimes suspect, from Germany to its custody in The Hague, marking a significant development in efforts to hold perpetrators of atrocities in Libya accountable.

El Hishri is alleged to have been a senior official at Mitiga Prison in Libya, where thousands of people were detained for extended periods. The Office of the Prosecutor say he committed, ordered, or oversaw crimes against humanity and war crimes between February...

UN Launches Fact-Finding Mission Amid Sudan Crisis
| By: Brianne Blain : December 18, 2025 |

Photo by FCDO / Russell Watkins (CC BY 2.0)

The UN Human Rights Council (HRC) adopted a resolution directing an independent fact-finding mission to investigate reports of human rights violations including mass killings in El Fasher, North Darfur. The Council’s held its 38th special session to address the concerns over crimes against humanity and the potential risk of genocide in Sudan.

In its resolution (A/HRC/S-38/L.1), the Council condemned RSF and allied forces for killings, torture, executions, and widespread sexual and gender-based violence. UN experts reported...

ICC Pre-Trial Chamber Confirms 39 Charges Against Joseph Kony
| By: Özge Karsu : December 11, 2025 |

Photo by Tony Webster, CC BY 2.0

On November 6, 2025, Pre-Trial Chamber III of the International Criminal Court (ICC) issued a decision confirming 39 charges brought by the Office of the Prosecutor against Joseph Kony, founder and leader of the Lord’s Resistance Army (LRA) in Uganda.

The Chamber found substantial grounds to believe that Kony is responsible for crimes against humanity and war crimes allegedly committed between at least July 1, 2002, and December 31, 2005, in northern Uganda. It determined the existence of a non-international armed conflict during the...

Germany Establishes Arbitral Tribunal for Nazi-Looted Art
| By: Özge Karsu : December 11, 2025 |

On March 26, 2025, Germany’s federal government, the states, and the leading municipal associations signed an administrative agreement creating a new arbitral tribunal for Nazi-looted art. The agreement states the foundation for transforming the former Advisory Commission into a legally binding dispute-resolution body and strengthens Germany’s implementation of the Washington Principles.

Beginning December 1, 2025, victims of Nazi persecution and their heirs may unilaterally initiate proceedings before the tribunal, provided the cultural heritage institution has issued a standing...

ICC ASP Opens Multi-Year Review of Aggression Amendments
| By: Özge Karsu : December 11, 2025 |

Photo by OPCW, CC BY 2.0

On July 9, 2025, the Assembly of States Parties of the International Criminal Court adopted by consensus Resolution ICC-ASP/S-1/Res.1, initiating a multi-year process to review the amendments to the Rome Statute on the crime of aggression.

The resolution noted that, although 49 of 125 states parties have ratified the Kampala Amendments, no investigation into the crime of aggression has been conducted since the Court’s jurisdiction was activated. It also acknowledges that states parties remain divided: some view the current framework as...

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