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by Ido Rosenzweig and Yuval Shany

Introduction

Update – Universal Jurisdiction: Spanish Court's Inquiry of the Targeted Killing of Salah Shehadeh

The third issue of the Terrorism and Democracy Newsletter (March 2009) discusses the decision reached by the Central Magistrates Court Number Four of the High Court in Madrid on January 29, 2009, in the preliminary proceedings of a criminal case regarding a complaint lodged by the families of some of the civilian casualties of an IDF targeted killing operation, which was directed against Salah Shehadeh, the commander of the Hamas military wing, on July 23, 2002.

This decision led to legal and diplomatic discussions between Israel and the Spanish prosecution in an attempt by the latter to halt the proceedings in Spain.

This is an update on the developments in the case since March 2009.

Background

On July 23, 2002, Israel executed a targeted killing operation directed at the commander of the Hamas military wing in Gaza, Salah Shehadeh, causing the death of Shehadeh and 14 other people and the injury of 150 persons. Pursuant to that attack and the Israeli High Court's recommendation, Israel has established a special committee to examine the killing of Shehadeh and the collateral damage that it caused, the justification for the operation, and the possibility of recourse to alternative measures at the time.

On January 29, 2009, the Central Magistrates Court Number Four of the High Court in Madrid, issued a decision in the preliminary proceedings[1] regarding a criminal case against several high-ranking Israeli officials. Judge Fernando Andreu determined that "the events may and must be investigated by the Spanish courts" and ordered the initiation of an official inquiry. On January 30, 2009, as a result of that decision and of Israeli diplomatic efforts, the Spanish Foreign Minister announced that the Spanish government plans to change Spanish law in order to limit the court's jurisdiction over cases such as the Shehadeh case in the future.[2]  However, on February 27, 2009, the Spanish court announced its decision to continue the investigation in this case.[3] 

Follow-Up

On April 2, 2009, the Spanish prosecutors submitted a request with a Madrid court asking to halt the investigation in the Shehadeh case. The prosecutors' position was that the Spanish universal jurisdiction can be apply only upon the inexistence of any judicial investigative proceeding for the matters complained of in Israeli territory. Therefore,  the probe should be dismissed due to a parallel investigation by Israel.[4] 

However, on May 4, 2009, Judge Andreu held that no such  criminal investigation was being conducted and declared, moreover, that even if such an investigation was underway, the Spanish judiciary could simultaneously investigate the incident since it could be classified as a war crime.[5]

On May 6, 2009, the Spanish prosecutors appealed Judge Andreu's decision and requested to revoke the  investigation[6] emphasizing the fact that Israel has the closest jurisdictional link to the events and therefore must have preference and priority over the jurisdiction of Spain and any other State without links to the events or parties affected.[7] Moreover, the prosecutors disagreed with Judge Andreu's opinion about the nature of the investigation being conducted in Israel. The prosecutors said that the investigation was initiated as a result of a judicial order by the Israeli Supreme Court, and since it can issue operative conclusions and determine whether there are grounds to find that a crime had been committed, it is clearly a judicial investigation.[8]

On May 20, 2009, the Spanish government proposed new legislation that would limit the universal jurisdiction of the Spanish courts to cases involving offences which have a direct connection to Spain.[9] It is unclear however, how such legislation would affect ongoing proceedings such as those pending in the Shehadeh case.

Notes

[1] Preliminary proceedings 157/2008 Central Magistrates Court Number Four of the High Court. Non-official translation available at http://www.pchrgaza.org/files/PressR/English/2008/admission_order_propery.pdf

[2] http://www.ynetnews.com/articles/0,7340,L-3664375,00.html

[3] https://www.haaretz.co.il/hasen/spages/1067502.html

[4] http://www.israelnationalnews.com/News/News.aspx/130740

[5] http://news.yahoo.com/s/ap/20090504/ap_on_re_eu/eu_spain_israel_probe

[6] http://uk.news.yahoo.com/18/20090506/twl-spanish-prosecutors-renew-gaza-raid-3cd7efd_2.html

[7] This principle was expressly recognized in Resolution 3074 of the UN General Assembly, 3/12/1973, relative to the principles of international cooperation in the identification, detention, extradition and punishment of those guilty of war crimes or crimes against humanity, as well as in Article 17 of the Statute of the International Criminal Court of 1998

[8] The prosecutors even went as far as suggesting that the investigating Judge holds a misleading conception that a criminal investigation which is not conducted by an independent investigating magistrate, would not be recognized as a sufficient and genuine criminal investigation

[9] www.ynetnews.com/articles/0,7340,L-3718976,00.html