Abstract
Writing in 1964, Pieter Kooijmans challenged the principle of legal equality of states: it would have to prove its value or be discarded. He also predicted the relevance of the principle for a new subject of international law: the individual. Almost fifty years later, this article reviews how the principle has fared in international criminal law, a field of international law relevant both to states and to the individual. The review shows how the emergence of a more vertical international legal order has weakened the position of the principle of equality between states. The weakening of the principle in the relation between states has in turn affected the equality between individuals, which has contributed to further actual inequality between states. Contrary to one of Kooijmans’s scenarios, the emerging international legal order has not diminished the role of the ‘factual conditions of power politics’. Legal questions on permitted differentiations always involve inherently political assessments. For instance, Kooijmans’s concept of ‘juridically relevant’ differences requires a determination of which differences are ‘of intrinsic value for the existence of legal order’, and thus a decision on what that order should look like and how it is to be pursued. Moreover, factual conditions of power politics continue to encroach upon the principle of legal equality. Perhaps the principle of legal equality, like the fight against impunity, is more of an ideal than a reality. But the pursuit of the fight against impunity has thus far undermined the fight for more equality.
The author is University Lecturer, University of Cambridge, Fellow of the Lauterpacht Centre for International Law and Pembroke College, Cambridge.
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Notes
- 1.
Kooijmans 1964, at 4.
- 2.
Ibid., at 246.
- 3.
See, inter plurima alia, the 1976 International Covenant on Civil and Political Rights 999 UNTS 171, arts. 14(1) and 26; the 1966 International Convention on the Elimination of All Forms of Racial Discrimination 660 UNTS 195; the 1950 (European) Convention for the Protection of Human Rights and Fundamental Freedoms 213 UNTS 222, art. 14(1) read in conjunction with art. 6; the 1978 American Convention on Human Rights 1144 UNTS 123, art. 8, the 1982 African [Banjul] Charter on Human and Peoples’ Rights 21 ILM 58, arts. 3 and 19 and the Arab Charter on Human Rights, arts. 3, 11 and 12.
- 4.
- 5.
Kooijmans 1964, at 30.
- 6.
See Henrard 2008, para. 27.
- 7.
Kooijmans 1964, at 223. ‘It is regrettable … that the problem of equality is so often pushed aside with the maxim, “The equal equal, the unequal unequal”, without the realization that this maxim itself does not mean much, precisely because the question is what is equal for the law, and what is unequal.’
- 8.
Ibid., at 33.
- 9.
Ibid., at 238.
- 10.
Aristotle (translated by Ross) 1999, at 76. ‘All men agree that what is just in distribution must be according to merit in some sense, though they do not all specify the same sort of merit.’
- 11.
See, for instance, Kooijmans 1964, at 221.
- 12.
Gesina van der Molen was the first woman to obtain a PhD at Amsterdam’s Free University, a resistance fighter and an international legal scholar.
- 13.
Kooijmans 1964, at 94.
- 14.
See, for instance Oppenheim 1905, at 19-20, para. 14 and Aust 2010, at 100. See also Crawford 2012, at 449, observing, with a reference to Orwell’s Animal Farm, ‘[o]bviously, the allocation of power and the capacity to project it in reality are different things, which suggests that while all states are equal, some are more equal than others’ (footnote omitted).
- 15.
Kooijmans 1964, at 124-125.
- 16.
Ibid., at 102.
- 17.
See, for instance, Shaw 2008, at 215.
- 18.
Kooijmans 1964.
- 19.
International Law Commission, Principles of International Law Recognized in the Charter of the Nuremberg Tribunal and in the Judgment of the Tribunal, 1950, Report of the International Law Commission covering its Second Session, 5 June - 29 July 1950, UN Doc. A/1316, Principle III.
- 20.
- 21.
1945 Charter of the International Military Tribunal 82 UNTS. 280, arts. 1 and 6; and 1946 International Military Tribunal for the Far East Charter TIAS 1589, arts. 1 and 5.
- 22.
See, for instance, 1945 Charter of the United Nations, 1 UNTS XVI, arts. 53 and 107.
- 23.
See also Simpson, who uses the term ‘juridical sovereignty’ for the interaction between sovereign equality and two legal forms in which distinctions between states are mandated or authorised. Simpson 2004, at 6.
- 24.
See, more elaborately, Nouwen 2012, at 171.
- 25.
See 1998 Rome Statute of the International Criminal Court, 2187 UNTS. 90 (hereinafter RS), art. 12.
- 26.
Kooijmans 1964, at 102.
- 27.
See more elaborately on (in)equality before the Nuremberg and Tokyo tribunals and the ICTY and ICTR, Cryer 2005, at 206-221.
- 28.
RS, arts. 12 and 13.
- 29.
But according to Kooijmans the principle of equality is of little to help to new states objecting to being bound by pre-existing law: ‘[it] is an inadmissible exaggeration of the principle of equality … to hold that each new member of a legal community should first lend his approval to the law of which he will be subject in the future.’ Kooijman 1964, at 5.
- 30.
See ibid., at 112. ‘For only then can a special position be awarded to the Great Powers, if the inequality as to power is a relevant factor for the establishment of a legal order.’
- 31.
Ibid., at 243.
- 32.
Simpson 2004, at x.
- 33.
See, the International Covenant on Civil and Political Rights, arts. 14(1) and 26, the International Convention on the Elimination of All Forms of Racial Discrimination, the (European) Convention for the Protection of Human Rights and Fundamental Freedoms, art. 14(1) read in conjunction with art. 6, the American Convention on Human Rights, art. 8, the African [Banjul] Charter on Human and Peoples’ Rights, arts. 3 and 19 and the Arab Charter on Human Rights, arts. 3, 11 and 12.
- 34.
RS, arts. 27(1) (emphasis added).
- 35.
RS, art. 98(1).
- 36.
D. Tutu, ‘Why I Had No Choice but to Spurn Tony Blair’, Observer, 2 September 2012.
- 37.
S. Tisdall, ‘Technicians in the Workshop of Double Standards’, Guardian, 29 July 2008.
- 38.
‘Vow to pursue Sudan over “crimes”’, BBC News, 27 September 2008. See also, inter plurima alia, ‘Rwanda’s Kagame says ICC targeting poor, African countries’, AFP, 31 July 2008; R. Lough, ‘African Union accuses ICC Prosecutor of Bias’, Reuters, 29 January 2011.
- 39.
See ICC-OTP, Report on Preliminary Examination Activities (13 December 2011), http://www.icc-cpi.int/NR/rdonlyres/63682F4E−49C8-445D-8C13-F310A4F3AEC2/284116/OTPReportonPreliminaryExaminations13December2011.pdf. Accessed 16 January 2013.
- 40.
Buchet and Tallgren 2012, at 175.
- 41.
Ibid.
- 42.
See Kooijmans 1964, at 102.
- 43.
F. Haq, Yes, size does matter. Terraviva (1998), http://www.ips.org/icc/tv250602.htm. Accessed 9 November 2012.
- 44.
United Nations Diplomatic Conference of Plenipotentiaries on the Establishment of an International Criminal Court, Rome, 15 June - 17 July 1998, Official Records, Volume II, Summary records of the plenary meetings and of the meetings of the Committee of the Whole, UN Doc. A/CONF.183/13 (Vol.11), at 5-41.
- 45.
F. Haq, Yes, size does matter. Terraviva (1998), http://www.ips.org/icc/tv250602.htm. Accessed 9 November 2012.
- 46.
Ibid.
- 47.
Ibid.
- 48.
See Buchet and Tallgren 2012, at 185.
- 49.
See ibid., at 176. With respect to Japan: ‘Japon, qui malgré l’expérience directe qu’il peut faire valoir dans ce contexte, et en dépit de sa participation très active aux phases préalables, au cours desquelles il s’était distingué par la production de propositions écrites très complètes sur les principes généraux du droit pénal ou la coopération judiciaire, est mis en difficulté par l’empressement et le caractère informel des négociations.’
- 50.
Simpson 2004, at xiv.
- 51.
On international law’s promise to, and often deception of, countries in the Global South in other fields of law, see Pahuja 2011.
- 52.
See Agreement amending the Partnership Agreement between the Members of the African, Caribbean and Pacific Group of States and the European Community and its Members States, in particular art. 11(6)(a). ‘The Parties shall seek to take steps towards ratifying and implementing the Rome Statute.’
- 53.
See American Servicemembers’ Protection Act (ASPA) and the Nethercutt Amendment (part of the US Foreign Appropriations Bill).
- 54.
See http://www.iccnow.org/documents/CICCFS_BIAstatus_current.pdf. Accessed 14 January 2013.
- 55.
For a clear distinction between the loose and proper concepts of ‘human rights law’, see O’Keefe 2011, at 1003-1004.
- 56.
See also S.S. Wimbledon, Permanent Court of International Justice, Judgment of 17 August 1923, PCIJ ser. A vol. 1, at 25. ‘No doubt any convention creating an obligation of this kind places a restriction upon the exercise of the sovereign rights of the State, in the sense that it requires them to be exercised in a certain way. But the right of entering into international engagements is in attribute of State sovereignty.’
- 57.
Thanks to lawyer Barney Afako for a discussion on this topic.
- 58.
For instance, in Uganda, relevant ministers conceded never to have read the Rome Statute prior to ratification, indeed prior to the referral of the situation concerning the Lord’s Resistance Army to the ICC (interviews, Kampala, October 2008). It was only when the ICC was seen as an obstacle to the successful conclusion of the Juba peace process that they began to scrutinise the Rome Statute. See, more elaborately, Nouwen 2013, Chaps. 3 and 5.
- 59.
- 60.
Interview with the participant, Khartoum, December 2008.
- 61.
Milošević motion, 30 August 2011, cited in Prosecutor v. Slobodan Milošević, Trial Chamber, Decision on Preliminary Motions, Case No. IT-02-54, 8 November 2001, para. 8 (Milošević Preliminary Motions decision).
- 62.
Ibid., para. 9 (footnotes omitted).
- 63.
Ibid., para. 10 and 11.
- 64.
RS, art. 13.
- 65.
Moreno-Ocampo 2007–2008, at 219.
- 66.
- 67.
See also L. Moreno-Ocampo, Address to the Third Session of the Assembly of States Parties to the Rome Statute of the International Criminal Court (The Hague, 6 September 2004).
- 68.
RS, art. 12(3).
- 69.
ICC-OTP, Letter to Senders re Iraq (9 February 2006), http://www.icc-cpi.int/NR/rdonlyres/04D143C8-19FB-466C-AB77-4CDB2FDEBEF7/143682/OTP_letter_to_senders_re_Iraq_9_February_2006.pdf. Accessed 16 January 2013.
- 70.
See Nouwen and Werner 2010a.
- 71.
RS, arts 13(b) and 12 a contrario.
- 72.
UN Doc. S/RES/1593 (2005), para. 6 and UN Doc. S/RES/1970 (2011), para. 6.
- 73.
Letter from the Chief Prosecutor to the President of the Court Uganda, 17 June 2004, attached to Situation in Uganda, Decision assigning the situation in Uganda to Pre-Trial Chamber II, Presidency, Case No. ICC-02/04-1, 5 July 2004, at 4.
- 74.
See also Nouwen 2013, Chap. 4.
- 75.
See also Simpson 2007, at 46, on the paradox of cosmopolitanism which is that it represents an attempt to transcend sovereignty while remaining largely reliant on particular instantiations of it. See also A. Branch, What the ICC Review Conference can’t fix (2010), http://africanarguments.org/2010/03/what-the-icc-review-conference-can%E2%80%99t-fix/. Accessed 8 November 2012.
- 76.
Rastan 2008, at 439.
- 77.
RS, art. 53(3) provides for a review procedure in the event of a referral, but as long as the OTP does not decide not to open an investigation or prosecution, there is little to review. Moreover, without the OTP’s providing any information, the Chambers do not know whether the OTP should have sufficient material to open an investigation or pursue a prosecution.
- 78.
See also Cryer 2005, at 192.
- 79.
Contrast RS, art. 53(1) with art. 53(2).
- 80.
ICC-OTP, Annex to the ‘Paper on Some Policy Issues before the Office of the Prosecutor’: Referrals and Communications (2003), at 1. http://www.icc-cpi.int/NR/rdonlyres/278614ED-A8CA-4835-B91D-DB7FA7639E02/143706/policy_annex_final_210404.pdf. Accessed 16 January 2013.
- 81.
ICC-OTP, Criteria for Selection of Situations and Cases (June 2006), unpublished draft document, at 8. It could be argued that the Prosecutor has more discretion when deciding whether or not to open an investigation by using his or her proprio motu power than after a referral. According to art. 15(1) the Prosecutor ‘may’ initiate an investigation and according to art. 15(3) ‘shall’ submit a request for authorization if he or she concludes that there is a reasonable basis to proceed (taking into account, pursuant to rule 48, the criteria of art. 53). After a referral, art. 53 determines that the Prosecutor ‘shall’ initiate an investigation, unless certain criteria are fulfilled.
- 82.
ICC-OTP, Criteria for Selection of Situations and Cases (June 2006), unpublished draft document, at 8.
- 83.
ICC-OTP, Annex to the ‘Paper on Some Policy Issues before the Office of the Prosecutor’: Referrals and Communications (2003) at 1, http://www.icc-cpi.int/NR/rdonlyres/278614ED-A8CA-4835-B91D-DB7FA7639E02/143706/policy_annex_final_210404.pdf. Accessed 16 January 2013.
- 84.
ICC-OTP, Paper on Some Policy Issues before the Office of the Prosecutor (September 2003) at 2, http://www.icc-cpi.int/nr/rdonlyres/1fa7c4c6-de5f-42b7-8b25-60aa962ed8b6/143594/030905_policy_paper.pdf. Accessed 16 January 2013. But cf contra ICC-OTP, Criteria for Selection of Situations and Cases (June 2006), unpublished draft document, at 1 ‘The duty of independence goes beyond simply not seeking or acting on instructions. It also means that the selection process is not influenced by the presumed wishes of any external source, nor the importance of the cooperation of any particular party, nor the quality of cooperation provided. The selection process is independent of the cooperation-seeking process.’
- 85.
Cassese 1998, at 13.
- 86.
See Nouwen and Werner 2010a, at 952.
- 87.
G. Lerner, Ambassador: U.S. moving to support International Court. CNN (25 March 2010). See also, critically, S. Al-Bulushi and A. Branch, Africa: Africom and the ICC - Enforcing international justice in Africa? (2010), http://allafrica.com/stories/201005271324.html. Accessed 8 November 2012.
- 88.
Kokott 2011, para. 23, on sovereign equality.
- 89.
Kooijmans 1964, at 112.
- 90.
This is not unique to the ICC. The Rwandan government could influence the ICTR’s prosecutorial policy by refusing or threatening to refuse cooperation. See Cryer 2005, at 221. See also Ibid., at 230.
- 91.
Situation in Darfur, Sudan, Prosecutor v. Omar Hassan Ahmad Al Bashir, Decision Pursuant to Article 87(7) of the Rome Statute on the Failure by the Republic of Malawi to Comply with the Cooperation Requests Issued by the Court with Respect to the Arrest and Surrender of Omar Hassan Ahmad Al Bashir of 12 December 2011, Pre-Trial Chamber I, Case No. ICC-02/05-01/09-139, para. 18 (Malawi Cooperation Decision).
- 92.
Ibid., para. 43.
- 93.
Ibid., para. 36.
- 94.
In Milošević the ICTY dodged the issue of immunity ratione personae by interpreting his motion as an invocation of immunity ratione materiae. See Milošević Preliminary Motions decision, para. 28. See, more elaborately, Nouwen 2005, at 665.
- 95.
Arrest Warrant of 11 April 2000(Democratic Republic of the Congo v. Belgium), ICJ, Judgment of 14 February 2002, at para. 61 (emphasis added).
- 96.
Malawi Cooperation Decision, para. 33.
- 97.
Ibid., para. 34 (footnotes omitted; emphasis added).
- 98.
Ibid., para. 35. The original is The Prosecutor v. Charles Ghankay Taylor, Appeals Chamber, Special Court for Sierra Leone, Decision on Immunity from Jurisdiction, Case No. SCSL-2003-l-AR72(E), 31 May 2004, para. 51.
- 99.
L. Moreno-Ocampo, Working with Africa: The view from the ICC Prosecutor’s Office (Cape Winelands, 9 November 2009), at 9 http://www.iss.co.za/uploads/9Nov09Ocampo.pdf. Accessed 8 November 2012. See also Ibid., at 8.
- 100.
Ibid., at 2.
- 101.
ICC-OTP, Deputy Prosecutor’s Remarks: Introduction to the Rome Statute Establishing the ICC and Africa’s Involvement with the ICC (14 April 2009), http://www.icc-cpi.int/NR/rdonlyres/214816FF-DD8F-4908-97CF-B315C33F24FE/280279/20090414FatouRomeStatute.pdf. Accessed 8 November 2012.
- 102.
Moreno-Ocampo, see above n. 99, at 3. See also the film ‘The Reckoning’ (by Yates, de Onis and Kinoy 2009).
- 103.
Cited in ICC-OTP, Deputy Prosecutor’s Remarks: Introduction to the Rome Statute Establishing the ICC and Africa’s Involvement with the ICC (14 April 2009), at 3. http://www.icc-cpi.int/NR/rdonlyres/214816FF-DD8F-4908-97CF-B315C33F24FE/280279/20090414FatouRomeStatute.pdf. Accessed 8 November 2012.
- 104.
Ferguson 2006, at 10.
- 105.
A. Mbembe, On the Postcolony, cited in Ferguson 2006, at 10.
- 106.
Said 1995, at 1.
- 107.
Ferguson 2006, at 5.
- 108.
See, e.g. Oppenheim 1905, at 19-20, para. 14. ‘Since the Law of Nations is based on the common consent of States as sovereign communities, the member States of the Family of Nations are equal to each other as subjects of International Law. States are by their nature certainly not equal as regards power, extent, constitution, and the like. But as members of the community of nations they are equals, whatever differences between them may otherwise exist. This is a consequence of their sovereignty and of the fact that the Law of Nations is a law between, not above, the States.’
- 109.
Brownlie 2008, at 289. Indicative is the difference between the 7th edition of Brownlie’s Principles, written by Ian Brownlie, and the 8th edition, edited by James Crawford. Whereas the 7th edition still opened the chapter on ‘sovereignty and equality of states’ with the sentence ‘[t]he sovereignty and equality of states represent the basic constitutional doctrine of the law of nations’ (emphasis added), the opening line of the same chapter in the 8th edition is: ‘The sovereignty of states represents the basic constitutional doctrine of the law of nations’ (Crawford 2012, at 447). The subsequent text also illustrates that Crawford is more sceptical of the actual role played by the principle: whereas Brownlie still wrote ‘states are equal’, Crawford writes ‘then in this respect [sovereignty] at least [states] are equal’ (emphasis added).
- 110.
See A. Branch, What the ICC Review Conference can’t fix (2010), http://africanarguments.org/2010/03/what-the-icc-review-conference-can%E2%80%99t-fix/. Accessed 8 November 2012.
- 111.
Mamdani 2009, at 12.
- 112.
A. Branch, What the ICC Review Conference can’t fix (2010), http://africanarguments.org/2010/03/what-the-icc-review-conference-can%E2%80%99t-fix/. Accessed 8 November 2012.
- 113.
- 114.
Arrest Warrant of 11 April 2000 (Democratic Republic of the Congo v. Belgium), ICJ, Judgment of 14 February 2002, (Joint Separate Opinion Judges Higgins, Kooijmans and Buergenthal), para. 79.
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Nouwen, S.M. (2013). Legal Equality on Trial: Sovereigns and Individuals Before the International Criminal Court. In: Nijman, J., Werner, W. (eds) Netherlands Yearbook of International Law 2012. Netherlands Yearbook of International Law, vol 43. T.M.C. Asser Press, The Hague, The Netherlands. https://doi.org/10.1007/978-90-6704-915-3_7
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