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By Ido Rosenzweig and Yuval Shany

Introduction

The ICC's Jurisdiction over the PNA (photo)
On 3 May 2010, the Office of the Prosecutor of the International Criminal Court (ICC) published a summary report on the initial submissions it received regarding the Palestinian National Authority’s (PNA) request that the court exercise jurisdiction over the West Bank and the Gaza Strip following the events of "Operation Cast Lead".

The Office of the Prosecutor grouped the arguments into the following general categories: questions concerning the interpretation of Article 12(3); the exercise of criminal jurisdiction; statehood in international law; and historical considerations. The report is informative and does not express the views of the Office of the Prosecutor regarding the submissions.

This article in the IDI's Terrorism and Democracy Newsletter presents a summary and brief discussion of the report as part of its coverage of "Operation Cast Lead", Israel’s major counter-terrorism operation in Gaza (Dec. 2008-Jan. 2009), and the response thereto of international judicial bodies.

Background

On 21 January 2009, following the conclusion of "Operation Cast Lead" [1],   the Minister of Justice of the Palestinian National Authority submitted a declaration to the International Criminal Court (ICC) [2], in accordance with Article 12(3) of the Rome Statute of the ICC [3], which enables a state that is not party to the statute to accept the jurisdiction of the Court over crimes that occurred in their territory or were committed by their nationals.

Following that declaration, the Office of the Prosecutor initiated a preliminary examination to determine whether there is a reasonable basis to proceed with an investigation of the situation in Palestinian territory, taking into consideration the jurisdiction of the Court, admissibility, and the interests of justice. In order to facilitate such an examination, the Office of the Prosecutor reviewed more than 380 documents alleging crimes committed during "Operation Cast Lead", and met with relevant figures – such as diplomats and members of the Arab League's Fact Finding Committee on Gaza – and a number of Palestinian and Israeli NGOs. Moreover, the Office of the Prosecutor received several submissions from different organizations, NGOs, and scholars concerning this legal question. [4]

On 3 May 2010, the Office of the Prosecutor published a report summarizing the relevant issues and questions raised in the preliminary examination.

The Report

According to the report, the Office of the Prosecutor grouped the arguments that were submitted into four general categories – the interpretation of Article 12(3), the exercise of criminal jurisdiction, statehood in international law, and historical considerations.

Interpretation of Article 12(3) – According to the report, the main question that relates to the interpretation of Article 12(3) is whether the Palestinian Authority can be regarded as a "state" not party to the Statute. This interpretation should be undertaken in accordance with Article 31(1) of the Vienna Convention on the Law of Treaties, which calls for the interpretation of conventions in good faith, in light of the text, context, and the treaty's objective and purpose.

The first line of arguments in favor of the Palestinian request rests on a teleological basis. According to these arguments, the term "state" does not have a clear set of defining variables and should be interpreted in accordance with the main objective and purpose of the Rome Statute, which is to ensure that the most serious international crimes do not go unpunished. Moreover, the meaning of the term "state" in the context of Article 12(3) may differ from the interpretation of statehood under general international law. Therefore, the ICC can restrict its decision concerning the PNA’s fulfillment of the requirements of Article 12(3), without determining thereby the general question of Palestinian statehood.

An opposing set of arguments urging the Prosecutor to reject the Palestinian request focuses on the literal interpretation of Article 12(3). According to this interpretation, the United Nations does not recognize the Palestinian state and the ICC lacks both explicit and implicit powers to recognize the validity of declarations made by a non-state organization. The claim is also made that the acceptance of the Palestinian request and the application of the ICC's jurisdiction could interfere with Israel's rights according to the Oslo Accords, and would infringe Israel's sovereignty claims with respect to the Palestinian territories. Furthermore, it was claimed that the de facto acknowledgement of the statehood of the PNA would compromise the ICC by creating perceptions of the politicization of the Court and would also open a Pandora’s box vis-à-vis other potential non-state claimants before the ICC.

The exercise of criminal jurisdiction – Some of the submissions argue that the entity issuing a request under Article 12(3) must exercise sovereign criminal jurisdiction in order to delegate it to the ICC. The core of the arguments in favor of and against the acceptance of the Palestinian request lies in the Oslo Accords, which invests the PNA with only some powers of criminal jurisdiction.

The arguments in favor of accepting the Palestinian referral claim that although the Oslo Accords bar the PNA from exercising criminal jurisdiction over Israeli citizens, it still has inherent criminal jurisdiction over the territories. The Oslo Accords only provide for a temporary waiver of jurisdiction over Israeli nationals, which does not represent a denial of Palestinian sovereignty.

On the other hand, some submissions claim that all the powers and responsibilities that were not transferred to the PNA were retained by Israel. Since the PNA cannot exercise jurisdiction over Israeli nationals in the West Bank and the Gaza Strip, it cannot delegate authority that it does not possess. According to this claim, at most, the PNA can only transfer criminal jurisdiction over the conduct of its own nationals or of non-Israelis.

Statehood in international law – This category of arguments examines the Palestinian declaration in light of the general rules of recognition of statehood under the Montevideo Convention of 1933 (i.e., permanent population, defined territory, government, and the capacity to enter into relations with other states). [5]

There are different arguments for and against the recognition of Palestinian statehood. The arguments in favor of the declaration note that Palestine has already been recognized by 97 states and 29 states recognize its passports. The opposing arguments note that a significant portion of the international community has not recognized Palestinian statehood, and the national case law of several countries has held that the PNA falls short of one or more of the Montevideo Convention's requirements.

While all the submissions agree that the PNA has a permanent population, in accordance with criteria of the Montevideo Convention, there are different legal opinions and interpretations concerning the fulfillment of the rest of the relevant aforementioned criteria.

Historical considerations – The last group of arguments refers to the situation in the area before 1948, during the Ottoman area, and during the period of the League of Nations Mandate. While some submissions suggest that Palestinian statehood was recognized under the League of Nations Mandate and the UN Partition Plan in 1947, other submissions claim that according to the relevant historical documents, there was never any formal recognition of Palestinian statehood.

Conclusions

This report serves as an interim summary of the arguments that were brought before the Office of the Prosecutor to date, and does not express the opinion of the Office of the Prosecutor regarding the outcome of the preliminary examination. Moreover, as the report noted, more submissions are still pending and the Office of the Prosecutor should ensure that all the relevant parties (including the State of Israel) have the opportunity to express their opinions before it reaches a decision.

The declaration of the PNA raises many legal, diplomatic, and historical questions concerning the status, powers, and jurisdiction of the PNA, and the area in general. It also raises broader theoretical and political issues related to the ICC’s ability to address sensitive and high profile international conflicts.

In any event, the shadow of the ICC currently looms over the counter-terrorism policies of Israel. Even if the Prosecutor decides ultimately to reject the Palestinian declaration, the current plans for establishing a Palestinian State in 2011 could lead to greater involvement by the ICC in future military conflicts in the region. Israel’s long-term ability to fend-off ICC prosecutions may, therefore, rely more on its ability to project complementarity – i.e., conduct genuine and effective investigations of alleged crimes – than on formal arguments that address the interpretation of the ICC Statute.