Legality of the 2022 Russian invasion of Ukraine

From Wikipedia, the free encyclopedia
Jump to navigation Jump to search

The 2022 Russian invasion of Ukraine violated international law and the Charter of the United Nations, and constitutes a crime of aggression in international criminal law.[8][9][10][11][12] The invasion has also been called unlawful under some countries' domestic criminal codes—including those of Ukraine and Russia—although there are procedural obstacles to prosecutions under these laws.[13][14] This article discusses the international and domestic legal provisions Russia is said to have violated, as well as Russia's legal justifications for the invasion and the responses of legal experts to those justifications. The legality of the Russian invasion per se is a distinct subject from whether individual political officials or combatants have engaged in war crimes or crimes against humanity.

Background[edit]

Main article: 2022 Russian invasion of Ukraine

War in Donbas[edit]

Main article: War in Donbas

In March 2014, Russia annexed Crimea from Ukraine.[15][16] Around the same time, protests by pro-Russian separatist groups took place in the Donetsk and Luhansk oblasts of Ukraine, collectively called the Donbas.[17] Russia took advantage of these protests to launch a coordinated political and military campaign against Ukraine.[18] These events led to an ongoing military conflict between Russian-backed separatists and Ukrainian forces in the Donbass, during which the separatist-controlled areas were organized into two quasi-states: the Luhansk People's Republic and Donetsk People's Republic. These self-declared governments were not recognized by any governments other than Russia and its ally Syria.[19]

Leadup to Russian military action[edit]

Russia's invasion of Ukraine in 2022 was preceded by a massive military buildup. Russia began increasing its military presence near its border with Ukraine in March and April 2021.[20] Although the Russian government repeatedly denied that it intended to invade Ukraine, the US government released intelligence of Russian invasion plans in December 2021, including satellite photographs showing Russian troops and equipment near the Ukrainian border.[21] As these events unfolded, Russian officials accused Ukraine of inciting tensions, Russophobia, and repression of Russian speakers, while also making multiple security demands of Ukraine, NATO, and non-NATO EU allies.[22][23]

On 21 February 2022, Russian President Vladimir Putin gave a televised speech questioning the legitimacy of Ukraine's statehood and indicating that he intended to immediately recognize the independence of Donetsk and Luhansk.[24][25]

Start of and justifications for invasion[edit]

See also: On conducting a special military operation

On 24 February, Putin gave another speech announcing a "special military operation" in Ukraine. Putin claimed that Russian military intervention in Ukraine was necessary to "protect people who have been subjected to abuse and genocide" by the Ukrainian government and to "protect Russia and our people." Putin also said that the Donetsk and Luhansk People's Republics—which the Russian government had formally recognized only two days before Putin's speech—had requested assistance in their fight against the Ukrainian government. The stated aims of Russia's "special military operation" included "the demilitarisation and denazification of Ukraine."[26] Scholars decried Putin's allegations of genocide and comparison of Ukraine to a Nazi state as baseless.[27]

Shortly after Putin's speech, the Ukrainian government reported airstrikes and artillery attacks in Kyiv, Kharkiv, and Dnipro, as well as on the border with Russia. Ukrainian President Volodymyr Zelenskyy declared martial law and called for a general mobilization.[28] The conflict remains ongoing.[29]

United Nations charter[edit]

See also: Russia and the United Nations and Jus ad bellum

Russia has been a member of the United Nations (UN) since December 1991, when it took over the seat of the recently defunct USSR.[30] The 1945 UN Charter sets out the conditions under which UN member states may legally resort to war or the use of armed force in general (a concept referred to as jus ad bellum).[31]

Legality of Russia's use of force against Ukraine[edit]

Article 2(4) of the UN Charter provides that all members of the UN "shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state, or in any other manner inconsistent with the Purposes of the United Nations." Along similar lines, Article 2(3) of the Charter requires all member states to "settle their international disputes by peaceful means in such a manner that international peace and security, and justice, are not endangered."[32]

Many experts on international law and foreign affairs have opined that the Russian invasion of Ukraine violated these principles, namely Article 2(4)'s prohibition on the "use of force" against other states.[33] As detailed below, they have also generally rejected the Russian government's official legal justifications for the invasion of Ukraine.

Self-defense justification[edit]

Russia has argued that its use of force against Ukraine is lawful under Article 51 of the UN Charter, which preserves the rights of UN member states to defend themselves against "an armed attack" and to engage in "collective self-defense." Specifically, Russia has claimed that it may use force against Ukraine in order to defend the Donetsk People's Republic and the Luhansk People's Republic, which Russia recognizes as independent states. International law and foreign policy experts such as John B. Bellinger III, Gabriella Blum, Naz Modirzadeh, and Anthony Dworkin have criticized this argument.[2][4][6]

Bellinger and Dworkin have explained that Russia cannot rely on a self-defense justification because Ukraine has not threatened or attacked any other nation.[2][6] All four scholars have also suggested that even if Ukraine were planning an attack against Donetsk or Luhansk, Russia could not invoke Article 51's collective self-defense provision because these regions are not recognized as separate states under international law.[2][4][6] Allen Weiner of Stanford Law School has made a similar argument, likening Russia's collective self-defense arguments to a hypothetical situation where an entity calling itself the independent "Republic of Texas" invited a foreign government to send troops to fight against the United States.[5]

Genocide/humanitarian intervention justification[edit]

See also: Ukraine v. Russian Federation (2022)

Likewise, experts have been unpersuaded by Russia's argument that its invasion is justified on humanitarian grounds to protect Russian-speakers in eastern Ukraine, namely the Donbass. Some commentators have questioned whether international law (including the UN Charter and the Genocide Convention) even allows nations to use force against another country to remedy genocide or human rights violations, as the legality of humanitarian intervention is heavily disputed.[2][5] In any event, many have characterized Russia's humanitarian justifications for the invasion as a pretext and unsupported by the facts, saying there is no evidence that Ukraine is committing any acts against Russians in Donetsk and Luhansk that would amount to genocide.[36]

Comparisons to Western interventions in other countries[edit]

Russia has also tried to justify its invasion of Ukraine by comparing its actions to interventions by the United States and its allies during the Kosovo War, the Iraq War, the Libyan Crisis, and the Syrian civil war.[citation needed]

One response to these comparisons has been to dismiss them as irrelevant because one illegal act does not make a different act legal.[1][4][7] For example, Professors Blum and Modirzadeh have remarked that "these arguments would carry little weight in any court of law" because "even if [they were] true, one illegal use of force does not justify another."[4] Professor Ingrid Wuerth has likewise said that Russia's arguments go "nowhere in terms of a legal or moral justification for Russia's own actions," although she agrees with Russia "that other powerful countries have undermined international law's prohibition on the use of force and protections of territorial integrity."[1]

Most experts agree that the US-led invasion of Iraq was illegal,[37] and there have also been debates about the legality of NATO's actions in Kosovo[38] and Libya.[39]

UN responses to Russian invasion[edit]

See also: Reactions to the 2022 Russian invasion of Ukraine § Intergovernmental and international organizations, United Nations Security Council Resolution 2623, and United Nations General Assembly Resolution ES-11/1

On 26 February 2022, Russia vetoed a UN Security Council resolution that would have called for Russia to immediately cease its attack on Ukraine. China, India, and the United Arab Emirates abstained from the vote; the 11 remaining members of the Security Council voted in favor of the resolution.[40][41] Days later, a UN General Assembly resolution condemning the Russian invasion was passed with an overwhelming 141-5 vote majority, with 35 nations abstaining.[42]

Crimes of aggression[edit]

Because it violates the UN Charter, and is more than a minor border incursion,[43] Russia's military intervention in Ukraine also qualifies as a crime of aggression under Article 8bis(1) of the Rome Statute, which is defined as "an act of aggression which, by its character, gravity and scale, constitutes a manifest violation of the Charter of the United Nations."[44][45] However, the Rome Statute also specifies that "in respect of a State that is not a party to this Statute, the Court shall not exercise its jurisdiction over the crime of aggression when committed by that State’s nationals or on its territory". Russia is not a party of the Rome Statute.[46][47] A Security Council referral to the International Criminal Court is inconceivable under the current system given Russia's veto power and its ties with others on the Council, including China.[46][47] Therefore, at present the crime of aggression could only be persecuted at state level, in countries that have universal jurisdiction related to aggression and that allow trials in absentia.[48]

Legality of invasion under domestic criminal codes[edit]

Some commentators have stated that in addition to violating international law, the invasion of Ukraine violated some countries' domestic criminal codes, including those of Russia, Ukraine, Belarus, and Poland.[13][14] For example, Article 353 of the Russian Criminal Code prohibits planning, preparing, unleashing, or waging an aggressive war.[49] The criminal codes of Ukraine (article 437), Belarus (article 122), and Poland (article 117) have similar prohibitions. Any country seeking to begin a prosecution under its national laws would need to either have territorial jurisdiction over crimes arising out of the invasion of Ukraine or allow for universal jurisdiction. State immunity doctrines would be another obstacle to prosecution.[13]

Ongoing legal proceedings[edit]

See also: Reactions to the 2022 Russian invasion of Ukraine § Intergovernmental and international organizations

International Court of Justice[edit]

Main article: Ukraine v. Russian Federation (2022)

In late February 2022, Ukraine sued Russia in the International Court of Justice (ICJ). The lawsuit rejects Russia's claims that Ukraine was engaging in a genocide in Donbass and requests a court order requiring Russia to immediately halt its military operations in Ukraine.[50][51] It also accuses Russia of "engag[ing] in a military invasion of Ukraine involving grave and widespread violations of the human rights of the Ukrainian people."[50] Ukraine is represented by the law firm Covington & Burling in the lawsuit.[52]

Russia boycotted an initial hearing held in the case on 7 March 2022,[53] and later said it did not send anyone to attend because of the "absurdity" of Ukraine's lawsuit.[54] At the end of the hearing, the ICJ indicated that it would decide Ukraine's application for an emergency order calling for a halt to hostilities "as soon as possible."[55]

On 16 March 2022, the court ruled that Russia must "immediately suspend the military operations that it commenced on 24 February 2022 in the territory of Ukraine."[56] The court split 13-2 in the decision, with Judges Kirill Gevorgian of Russia and Xue Hanqin of China dissenting.[57] Ukrainian President Volodymyr Zelenskyy hailed the ruling as a complete victory for his country,[57] saying that ignoring the order would further isolate Russia.[58]

International Criminal Court[edit]

Main article: International Criminal Court investigation in Ukraine

On 28 February 2022, the International Criminal Court (ICC) announced its intent to investigate alleged war crimes and crimes against humanity taking place in Ukraine since 21 November 2013.[59][60] A formal ICC investigation began that same week. Although ICC prosecutors normally have to go through an approval process to begin an investigation—a process that can take months—the Ukraine investigation was fast-tracked following an unprecedented number of requests by ICC member states to begin the proceedings.[61]

Jurisdiction[edit]

The ICC has jurisdiction over crimes of aggression as well as three other crimes (genocide, crimes against humanity, and war crimes). In general, it can prosecute these crimes if they were committed by a national of an ICC member state, in the territory of a member state, or in a state that has consented to ICC jurisdiction. The ICC can also prosecute crimes referred to it by the UN Security Council.[62] Neither Ukraine nor Russia are members of the ICC, but the ICC's head prosecutor has said the ICC still has jurisdiction to investigate because Ukraine signed two declarations consenting to ICC jurisdiction over crimes committed on its territory beginning in November 2013.[59][63][64]

Obstacles to prosecuting crime of aggression[edit]

However, there are at least two potential obstacles to putting Russian political or military leaders on trial for crimes of aggression. First, the ICC does not try defendants in absentia, which means that a way must be found to bring leaders accused of crimes to The Hague.[65] Second, unlike the other crimes over which the ICC has jurisdiction, crimes of aggression can only be prosecuted against leaders from states that are members of the ICC unless the UN Security Council makes a referral.[43] Russia is not an ICC member and has the permanent power to veto resolutions of the Security Council.

One way to circumvent this second limitation might be to constitute a special international tribunal to deal specifically with crimes of aggression against Ukraine.[45] However, some have questioned the utility of such a tribunal.[66] Another alternative that would overcome both limitations would be to put leaders on trial in the domestic court systems of the approximately 20 countries that allow both universal jurisdiction over crimes of aggression and trials in absentia.[43]

See also[edit]

References[edit]

  1. ^ a b c d Wuerth, Ingrid (2022-02-22). "International Law and the Russian Invasion of Ukraine". Lawfare. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  2. ^ a b c d e f g Bellinger III, John B. (2022-02-28). "How Russia's Invasion of Ukraine Violates International Law". Council on Foreign Relations. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  3. ^ a b Hannum, Hurst. "International law says Putin's war against Ukraine is illegal. Does that matter?". The Conversation. Archived from the original on 2022-03-07. Retrieved 2022-03-08.
  4. ^ a b c d e f g Neal, Jeff (2022-03-02). "The Ukraine conflict and international law". Harvard Law Today. Interviewees: Blum, Gabriella & Modirzadeh, Naz. Archived from the original on 2022-03-05. Retrieved 2022-03-10.
  5. ^ a b c d e Weiner, Allen S. (2022-02-24). "Stanford's Allen Weiner on the Russian Invasion of Ukraine". Stanford Law School Blogs. Q&A with Driscoll, Sharon. Archived from the original on 2022-03-08. Retrieved 2022-03-08.
  6. ^ a b c d e Dworkin, Anthony (2022-02-25). "International law and the invasion of Ukraine". European Council on Foreign Relations. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  7. ^ a b c Wilmhurst, Elizabeth (2022-02-24). "Ukraine: Debunking Russia's legal justifications". Chatham House. Archived from the original on 2022-03-01. Retrieved 2022-03-10.
  8. ^ Attributed to multiple references: [1][2][3][4][5][6][7]
  9. ^ Ranjan, Prabhash & Anil, Achyuth (2022-03-01). "Debunking Russia's international law justifications". The Hindu.{{cite news}}: CS1 maint: multiple names: authors list (link)
  10. ^ Troconis, Jesus Eduardo (2022-02-24). "Rusia está fuera de la ley internacional". Cambio16.
  11. ^ Gross, Judah Ari (2022-02-27). "Israeli legal experts condemn Ukraine invasion, say it's illegal under international law". Times of Israel.
  12. ^ McIntyre, Juliette; Guilfoyle, Douglas; & Paige, Tamsin Phillipa (2022-02-24). "Is international law powerless against Russian aggression in Ukraine? No, but it's complicated". The Conversation.{{cite news}}: CS1 maint: multiple names: authors list (link)
  13. ^ a b c "Mechanisms for Criminal Prosecution of Russia's Aggression Against Ukraine". Just Security. Retrieved 2022-03-14.
  14. ^ a b Colangelo, Anthony J. (2022-03-04). "Putin can be prosecuted for crimes of aggression — but likely not any time soon". The Hill.
  15. ^ How Russia Took Crimea Archived 2021-01-22 at the Wayback Machine Macias, Amanda (2015). Business Insider. Retrieved 2017-08-01.
  16. ^ Putin Admits Russian Forces Were Deployed to Crimea Archived 2014-04-19 at the Wayback Machine Reuters (2014). Retrieved 2017-08-01.
  17. ^ Grytsenko, Oksana (2014-04-12). "Armed pro-Russian insurgents in Luhansk say they are ready for police raid". Kyiv Post. Archived from the original on 2014-04-12.
  18. ^ Kofman, Michael; Migacheva, Katya; Nichiporuk, Brian; Radin, Andrew; Tkacheva, Olesya; Oberholtzer, Jenny (2017). Lessons from Russia's Operations in Crimea and Eastern Ukraine (PDF) (Report). Santa Monica, USA: RAND Corporation. pp. 33–34. Archived (PDF) from the original on 2022-02-17. Retrieved 2022-03-10.
  19. ^ Qiblawi, Tamara; Hodge, Nathan; Lister, Tim; Kottasová, Ivana (2022-02-21). "Why Donbas is at the heart of the Ukraine crisis". CNN. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  20. ^ Schogol, Jeff (2022-02-22). "Here's what those mysterious white 'Z' markings on Russian military equipment may mean Archived 2022-03-09 at the Wayback Machine". Task & Purpose. North Equity. Archived from the original on 2022-02-27. Retrieved 2022-02-27.
  21. ^ Lister, Tim; Mezzofiore, Gianluca (2022-02-11). "New satellite images show continuing Russian military buildup on three sides of Ukraine". CNN. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  22. ^ Merchant, Normaan (2022-02-25). "US intel predicted Russia's invasion plans. Did it matter? Archived 2022-03-04 at the Wayback Machine". AP News. Photographs by Alexei Alexandrov and Alex Brandon (AP Photo). Washington D.C.: Associated Press. Associated Press. Archived from the original on 2022-03-01. Retrieved 2022-02-28.
  23. ^ Li, David K.; Allen, Jonathan; Siemaszko, Corky (2022-02-24). "Putin using false 'Nazi' narrative to justify Russia's attack on Ukraine, experts say Archived 2022-02-25 at the Wayback Machine". NBC News. Archived from the original on 2022-02-25. Retrieved 2022-02-24.
  24. ^ "Extracts from Putin's speech on Ukraine". Reuters. 2022-02-21. Archived from the original on 2022-02-27. Retrieved 2022-03-10.
  25. ^ Hopkins, Valerie (2022-02-21). "Highlights from Putin's address on breakaway regions in Ukraine". New York Times. Archived from the original on 2022-03-11. Retrieved 2022-03-10.
  26. ^ Staff (2022-02-24). "'No other option': Excerpts of Putin's speech declaring war". Al Jazeera. Archived from the original on 2022-03-01. Retrieved 2022-03-10.
  27. ^ Treisman, Rachel (2022-03-01). "Putin's claim of fighting against Ukraine 'neo-Nazis' distorts history, scholars say". NPR. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  28. ^ Sheftalovich, Zoya (2022-02-24). "Battles flare across Ukraine after Putin declares war". Politico. Archived from the original on 2022-02-24. Retrieved 2022-03-10.
  29. ^ "Latest Russia-Ukraine War News: Live Updates". Washington Post. Archived from the original on 2022-03-09. Retrieved 2022-03-09.
  30. ^ "Russian Federation". United Nations. Archived from the original on 2022-03-08. Retrieved 2022-03-08.
  31. ^ "What are jus ad bellum and jus in bello?". International Committee of the Red Cross. 2015-01-22.
  32. ^ "United Nations Charter, Chapter I: Purposes and Principles". United Nations. Archived from the original on 2022-03-06. Retrieved 2022-03-08.
  33. ^ Attributed to multiple references: [1][2][3][4][5][6][7]
  34. ^ Kerr, Victoria (2022-08-03). "De-bunking the Role of International Law in the Ukrainian Conflict". Opinion Juris. Archived from the original on 2022-03-08. Retrieved 2022-03-10.
  35. ^ Hinton, Alexander (2022-02-25). "Putin's claims that Ukraine is committing genocide are baseless, but not unprecedented". The Conversation. Archived from the original on 2022-02-26. Retrieved 2022-03-10.
  36. ^ Attributed to multiple references: [2][4][5][34][35]
  37. ^ Knox, Robert (2021). "International law, politics and opposition to the Iraq War". London Review of International Law. 9 (2): 169–195. doi:10.1093/lril/lrab014.
  38. ^ Wippman, David (2001). "Kosovo and the Limits of International Law". Fordham International Law Journal. 25.
  39. ^ Ulfstein, Geir; & Christiansen, Hege Føsund (2013-01-30). "The Legality of the NATO Bombing in Libya". International & Comparative Law Quarterly. 62: 159–171 – via Cambridge University Press.{{cite journal}}: CS1 maint: multiple names: authors list (link)
  40. ^ "Russia blocks Security Council action on Ukraine". UN News. 2022-02-26. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  41. ^ Romo, Vanessa (2022-02-25). "Russia vetoes UN Security Council resolution that denounces its invasion of Ukraine". NPR. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  42. ^ Borger, Julian (2022-03-02). "UN votes to condemn Russia's invasion of Ukraine and calls for withdrawal". The Guardian. Archived from the original on 2022-03-02. Retrieved 2022-03-10.
  43. ^ a b c Trahan, Jennifer (2022-02-04). "A Reminder of the Importance of the Crime of Aggression: Considering the Situation of Russia and Ukraine". Opinio Juris. Archived from the original on 2022-02-25. Retrieved 2022-03-10.
  44. ^ "Russia/Ukraine: Invasion of Ukraine is an act of aggression and human rights catastrophe". Amnesty International. 2022-03-01. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  45. ^ a b Peskin, Victor; Boduszyński, Mieczysław P. (2022-03-05). "Op-Ed: Putin's crime of aggression in Ukraine and the International Criminal Court". Los Angeles Times. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  46. ^ a b Dannenbaum, Tom (2022-03-10). "Mechanisms for Criminal Prosecution of Russia's Aggression Against Ukraine". Just Security. Just Security. Retrieved 2022-03-21.
  47. ^ a b "Could the international criminal court bring Putin to justice over Ukraine?". the Guardian. 2022-03-02. Retrieved 2022-03-21.
  48. ^ "A Reminder of the Importance of the Crime of Aggression: Considering the Situation of Russia and Ukraine". Opinio Juris. 2022-02-04. Retrieved 2022-03-21.
  49. ^ "Article 353" (PDF). The Criminal Code Of The Russian Federation. Retrieved 2022-03-14.
  50. ^ a b Application Instituting Proceedings Archived 2022-03-01 at the Wayback Machine, Dispute Relating to Allegations of Genocide (Ukraine v. Russian Federation), I.C.J. 2022-02-27
  51. ^ Deutsch, Anthony; Sterling, Tony (2022-02-27). "Ukraine rejects Russia's genocide claim, asks U.N. court to halt invasion". Reuters. Archived from the original on 2022-02-27. Retrieved 2022-03-10.
  52. ^ Thomsen, Jacqueline (2022-03-01). "Ukraine taps U.S. law firm Covington to press Russia claim at U.N. court". Reuters. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  53. ^ Noack, Ricj; DeYoung, Karen; Birnbaum, Michael (2022-03-07). "Ukraine takes Russia to court, but Moscow's representatives are a no-show". Washington Post. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  54. ^ "Russia skips Ukraine suit before World Court, cites 'absurdity'". The Hill. Archived from the original on 2022-03-09. Retrieved 2022-03-09.
  55. ^ Wintour, Patrick (2022-03-07). "International court of justice to fast-track ruling on Russian invasion". The Guardian. Archived from the original on 2022-03-07. Retrieved 2022-03-10.
  56. ^ "Allegations of Genocide under the Convention on the Prevention and Punishment of the Crime of Genocide (Ukraine v. Russian Federation): The Court indicates provisional measures" (PDF) (Press release). International Court of Justice. 2022-03-16. Retrieved 2022-03-16.
  57. ^ a b Quell, Molly (2022-03-16). "International Court of Justice orders Russia to cease hostilities in Ukraine". The Globe and Mail. Retrieved 2022-03-16.
  58. ^ Borger, Julian (2022-03-16). "UN international court of justice orders Russia to halt invasion of Ukraine". The Guardian. Retrieved 2022-03-16.
  59. ^ a b "Statement of ICC Prosecutor, Karim A. A. Khan QC, on the Situation in Ukraine: "I have decided to proceed with opening an investigation."". International Criminal Court. 2022-02-28. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  60. ^ Siddiqui, Zoha; Liu, Nathaniel; Posthumus, Daniel; Zvobgo, Kelebogile (2022-03-04). "Could Putin Actually Face Accountability at the ICC?". Foreign Policy. Archived from the original on 2022-03-08. Retrieved 2022-03-10.
  61. ^ "War crimes court prosecutor opens Ukraine investigation". Reuters. 2022-03-02. Archived from the original on 2022-03-08. Retrieved 2022-03-10.
  62. ^ "How the Court works". International Criminal Court. Archived from the original on 2022-03-08. Retrieved 2022-03-08.
  63. ^ Sullivan, Becky (2022-02-28). "The ICC says it will open an investigation into alleged war crimes in Ukraine". NPR. Archived from the original on 2022-03-10. Retrieved 2022-03-10.
  64. ^ "ICC prosecutor: Team leaves to investigate war crimes in Ukraine". Reuters. 2022-03-04. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  65. ^ Falk, Thomas O. (2022-03-07). "Is Putin likely to face the ICC over Russia's actions in Ukraine?". al Jazeera. Archived from the original on 2022-03-09. Retrieved 2022-03-10.
  66. ^ Heller, Kevin Jon (2022-03-03). "Creating a Special Tribunal for Aggression Against Ukraine Is a Bad Idea". Opinio Juris. Archived from the original on 2022-03-08. Retrieved 2022-03-10.
Retrieved from "https://en.wikipedia.org/w/index.php?title=Legality_of_the_2022_Russian_invasion_of_Ukraine&oldid=1078593010"