The Rule of Law

(It is incumbent to make clear the nature of the conflict in Ukraine. It is a war between freedom which is assured by the rule of law, and tyranny, which is characterized by the rule of force. The United Nations and the Post World War II order enshrined and protected the former while giving a juridical form to the community of nations. With its focus on the person, the post war order emphasized human rights, human development, peace, and the rule of law. All of these things proceed with the understanding that the dignity of the man is central to any right ordered, peaceful society. Increasingly, people are waking up to what is at stake as they slough off the Russian disinformation.)

Violations Of Law

There exists a natural society of nations, and in Christian ethics there is an essential unity and solidarity of the human race.1 Hugo Grotius, long considered the father of international law, held that “nature has established a degree of kindred amongst us” and injustice consists in anything that is “repugnant to the nature of society, established among rational creatures.”2 Emer de Vattel, the Eighteenth Century Swiss jurist and diplomat whose work was influential amongst the kings and queens of Europe as well as the American founders, wrote

“The universal society of the human race being an institution of nature herself, that is to say, a necessary consequence of the nature of man,–all men, in whatever stations they are placed, are bound to cultivate it, and to discharge its duties. They cannot liberate themselves from the obligation by any conventions, by any private association. When, therefore, they unite in civil society for the purpose of forming a separate state or nation, they may indeed enter into particular engagements towards those with whom they associate themselves; but they remain still bound to the performance of their duties toward the rest of mankind.”3

A society has a common good, and there is a common good for the natural society of nations. St. Thomas Aquinas wrote “A law, properly speaking, regards first and foremost the order to the common good.”4 The legal philosopher John Austin in explaining the positive law, or law created by the actions of men, noted the importance of intelligence in the creation of law when he wrote that law is the “rule laid down for the guidance of an intelligent being by an intelligent being.”5 The great legal scholar Malcolm Shaw writes that “international law has always considered its fundamental purpose to be the maintenance of international peace.”6 Shaw explains that “International law is more limited as far as the mechanisms for the creation of new rules are concerned. Custom relies upon a measure of state practice supported by opinio juris and is usually, although not invariably, an evolving and timely process. Treaties, on the other hand, are a more direct and formal method of international law creation.”7 The “fundamental principle of treaty law is undoubtedly the proposition that treaties are binding upon the parties to them and must be performed in good faith. This rule is termed pacta sunt servanda and is arguably the oldest principle of international law.”8 Treaties take many names to include charter, and the United Nations Charter is a treaty.9 Treaties, including charters, bring a moral responsibility such that they must be honored and hence pacta sunt servanda.10 Responsibility attaches to state actors who violate international law and that in itself helps to maintain order.11

Vladimir Putin, as evidenced by the statements of Aleksander Dugin, repudiates all of this. In a recent article Dugin wrote:

“Trump opposes globalism because he rejects any supranational institutions (the UN, WHO, EU, and so on) and, like classical realists, believes that the supreme authority is the sovereign nation-state, above which there is nothing and no one. This is precisely the meaning of his slogan `Make America Great Again’ (MAGA). According to this idea, the U.S. is primarily a great power that must act on the global stage as a full-fledged subject, concerned only with achieving its own goals and defending its values and interests. Trump’s ideology rejects any hint of internationalism or rhetoric about `universal human values,’ `world democracy,’ `human rights,’ and the like. The absolute imperative is America and its prosperity. Those who agree with this project are friends or allies; those who oppose it are enemies. The U.S. has no goals other than its own prosperity, and no authority has the right to dictate to Americans what to do, how to act, what to believe in, or what to worship.”12

Dugin, and Putin, are not presenting the Christian world view. They are offering a return to the law of the jungle, might makes right, devolution. They are rejecting the idea of the dignity of the person and solidarity.

The Russian invasion of Ukraine, and all that came from it, are violations of international law. These violations at their root are a rejection of the unity of mankind and the existence of a natural society of nations. We shall examine in short form just a few of the more egregious and patent violations. These are an illegal invasion of another country or the making of aggressive war, the violation of the sovereignty of another country, the violation of human rights, the violation of a number of treaties, and the repudiation by Russia of its duties as a member of the Security Council to keep the peace and uphold international law and order.

The war in Ukraine is about the international order. It is about a vision for humanity. It is a contest between the rule of force and the rule of law. Ukraine is fighting for the rule of law, which characterizes the free world. Russia represents the rule of force which represents tyranny. Does man have dignity, or is he chattel?

The Illegal War

Putin had the opportunity of having the International Court of Justice adjudicate his claims, especially as he was making historical arguments. The International Court of Justice was formed as part of the United Nations in Chapter XIV of the Charter. As set forth in Article 92, “The International Court of Justice shall be the principal judicial organ of the United Nations.” Under the statute establishing the Permanent Court of Justice and hence the International Court of Justice, the Member States may refer disputes to it for adjudication.13

One of the primary reasons for the United Nations is to avoid war. The Preamble of the United Nations Charter states clearly:

“We the peoples of the United Nations determined to save succeeding generations from the scourge of war…and for these ends to practice tolerance and live together in peace with one another as good neighbours, and to unite our strength to maintain international peace and security, and to ensure, by the acceptance of principles and the institution of the methods, that armed force shall not be used save in the common interest…have agreed to the present Charter of the United Nations and do hereby establish an international organization to be known as the United Nations.”

The Member States committed to the following purposes of the United Nations:

“1 To maintain international peace and security, and to that end: to take effective collective measures for the prevention and removal of threats to the peace, and for the suppression of acts of aggression or other breaches of the peace, and to bring about by peaceful means, and in conformity with the principles of justice and international law, adjustment or settlement of international disputes or situations which might lead to a breach of the peace…..”14

The Member States, and there are 193 now, are committed to the following actions in accordance with the principles and purposes of the United Nations:

“The Organization and its Members….shall act in accordance with the following Principles……3. All Members shall settle their international disputes by peaceful means in such a manner that international peace and security, and justice, are not endangered. 4. All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state….”15

A number of reasons for the Russian invasion of Ukraine have been proffered by a number of sources based on Putin’s own words and other matters. In a speech given three days before the invasion, Putin listed a number of grievances against the United States and the West, and in doing so set forth certain talking points as part of Russian disinformation.16 Any of a number of various commentators offered their own reasons for the invasion, but perhaps ultimately we have to look at what Russia told the United Nations, the community of nations, on the day of the invasion.

Professor Michael N. Schmitt is a Professor of Public International Law at the University of Reading and a Strauss Center Distinguished Scholar and Visiting professor of Law at the University of Texas amongst his other distinguished academic honors. He noted that on the day of the invasion (February 24, 2022), Russia’s ambassador to the United Nations stated that military action was “taken in accordance with Article 51 of the UN Charter in the exercise of the right of self-defence.” Professor Schmitt concluded that the “Russian justification for military action against Ukraine is without any basis in international law.”17

In reaching this conclusion, Professor Schmitt examined the statements of Putin18, the events in Ukraine since 2014, and the Minsk accords all in the light of international law. The Russian invasion was a continuation of the Russian attacks on Ukraine that began in 2014 and while the Minsk accords and other ceasefires temporarily suspended hostilities, Putin repudiated these by his actions. Ukraine’s right to self-defense remained intact despite Putin’s claims that NATO was hostile to and threatened Russia. Ukraine had the right to suppress the insurgency in Donbas. Russia’s right to self-defense had not matured and its attack was a violation of United Nations Charter Article 2(4)19 as well as customary international law thereby making it an “internationally wrongful act” and an act of aggression.20

The UN Security Council moved to condemn Russia’s invasion. It voted 11 to 1 to approve a resolution in that regard with the abstention of China, Indian and the United Arab Emirates Russia exercised its veto. As a result, the UN Security Council, the primary organ of the United Nations charged with keeping the peace, did not formally condemn Russia’s invasion.21

Professor Schmitt examined a number of legal arguments based on the facts and the contents of Putin’s speech. First, Putin claimed that Russia had a right to individual self-defense even though the alleged aggressors, NATO and the United States, had not launched military operations against Russia. This claim rests on what is known as the doctrine of “anticipatory self-defense.” Article 51 of the UN Charter states “Nothing in the present Charter shall impair the inherent right of individual or collective self-defence if an armed attack occurs against a Member of the United Nations…” This means an attack must be underway. Professor Yoram Dinstein explained in War, Aggression and Self-Defence that for an attack to be underway the first shots need not have been fired but that the attack must have been launched. The aggressor must be embarked on an “apparently irreversible course of action”. When it comes to Ukraine, there is no evidence either the United States, NATO or Ukraine launched a military operation against Russia much less even planned one.22

Imminent armed attack justifies forcible self-defense. The 2002 United States National Security Strategy argued that “imminency” is justified by a “visible mobilization of armies, navies and air forces preparing to attack.” There was no evidence that either the US, NATO or Ukraine was “at the gates” so to speak though the activities of Russian forces in Russia, Belarus and the Black Sea certainly presented evidence of an imminent attack on Ukraine.23

Preemption or preemptive self-defense also fails as a justification for Russia’s invasion. For this argument to succeed there must exist a “possible window of opportunity in the face of an attack that was going to occur.” The “possible window of opportunity” did not exist because the West was not marshalling its forces for an attack especially given the absence of any plans for such.24

Preventive self-defense is the last remaining possible justification, but it is not a justification at all. It is supposed to “deprive an adversary of its future ability to mount an armed attack” in a situation that does not allow for or justify anticipatory self-defense. Preventive self-defense occurs when either the adversary has neither a plan nor a decision nor the capability to attack, and so there is no need for immediate action lest delay result in forfeiting the right to defend oneself. Such an action is unlawful and an act of aggression. The victim is justified in seeking aid from other countries.25

Professor Schmitt notes that Putin’s comments suggested a rationale of collective defense but that also fails. Humanitarian assistance based on “freshly minted mutual military assistance treaties” for the defense of the Luhansk and the Donetsk People’s Republics was part of the basis of the claim. Intervention based on humanitarian assistance is a controversial topic still despite UN actions to make such a norm of action. The need for humanitarian assistance is not sufficiently evident given the factual situation which was that peacekeepers were on the ground and Russia had been fueling the fighting in the region.26

Professor Schmitt holds there is a fundamental problem with Putin’s claim of collective self-defense. Neither Luhansk nor Donetsk are separate states. Neither of these so-called republics is recognized by the international community which “overwhelmingly considers them part of Ukraine.” These two “republics” are “dependent upon its foreign sponsor” thereby negating claims that these are states justifying collective defense. Military intervention to assist with the independence of the two republics requires satisfaction of the criteria for self-determination of peoples. This in turn means that the peoples of Luhansk and Donetsk had to be distinct from the Ukrainians, but Putin has repeatedly claimed that Russians and Ukrainians are the same people. Factually, “but for Russia’s unlawful use of force” in Crimea and in support of the insurgents of the Donbas, the Luhansk and Donetsk People’s Republics would not exist. A state that is the product of unlawful use of force is not a state, and Russia has been unlawfully employing force in eastern Ukraine 2014.27

Finally, Russian actions in support of collective self-defense had to be both necessary and proportionate. Professor Schmitt concluded that neither of these criteria were met given active negotiations were underway, there was no indication the situation was worsening, and Russian peacekeepers had supposedly entered the area thereby lowering any threat from Ukraine. The Russian attack exceeded what was required especially as they struck – and continue to strike — into other parts of Ukraine. Vast stretches have been destroyed, millions displaced, and the civilian infrastructure badly damaged as will be further mentioned.28

War was outlawed by the United Nations Charter. Russia broke the law as it seeks to impose rule of force for rule of law.

–Sovereignty

The issue of Ukraine’s sovereignty arose before the invasion and after the invasion commenced. Putin repeatedly mentioned how Ukraine was part of Russia thereby revealing his intentions which were, and remain, to erase Ukraine. Ukraine’s sovereignty was threatened not only by the invasion but by Putin’s proposed peace deal, the terms of which are discussed later in this paper.

So, what is sovereignty? What are the characteristics of states?

States are the primary actors in the international community, and they are the primary subjects of international law.29 As previously stated, the purpose of international law is to insure peace between states.30 Peace allows for states to provide for the welfare of their people, and it is the result of right order. All in international relations should be oriented to achieve that goal, or to serve that principle. Therefore, the concept of legal personality31 arises by which states possess certain characteristics to effect objectives that are meant to bring peace within states and between states so as to allow for the common good of the international community.

Certain criteria must be met or characteristics found before states can be said to exist. Legal scholar James Crawford writes that these include a certain population, defined territory, a government, independence from other political entities or states, a degree of permanence, functions as a state and sovereignty which means primarily independence.32 To Crawford the concept of sovereignty is a broad one that refers to “the collection of rights held by a state, first in its capacity as the entity entitled to exercise control over its territory, and secondly, in its capacity to act on the international plane, representing that territory and its people.”33 Another preeminent legal scholar, Malcolm Shaw, holds that states have three fundamental rights given them by the international order: independence (or sovereignty), equality, and peaceful co-existence.34 The concept of independence or sovereignty includes a number of rights and duties: “for example, the right of a state to exercise jurisdiction over its territory and permanent population, or the right to engage upon an act of self-defence in certain situations.”35

Legal scholars before the modern day were explicitly in what states, as sovereigns, could do and had to do. Emmerich de Vattel, the Swiss jurist mentioned earlier whose book The Law of Nations was widely read and understood by the American colonists and the Founders, set forth the duties of a sovereign or the government of a country. These duties were to provide for the necessities of the nation,36 to procure the true happiness of a nation,37 and finally to fortify the nation against external attacks.38

The Catholic Church has long held a concept of international law, much of which formed the basis of the current international order. Part of that conception of international law recognizes the characteristics of a state which consist of duties and rights. Duties to other states rested on the concepts of charity and justice. John Eppstein, working with the International Union of Social Studies set out in the early 1950s a series of specific rights: the right to existence, the right to self-preservation and defense, the right to independence, the right of sovereignty (meaning internal control over people, territory and immigration as well as emigration), the right to equality, and the right to promote national interests.39

As each state has an obligation to the welfare of its own people, a state is to take steps to protect these people. Sovereignty gives the state the power and ability, if not also the right and the duty, to enter into treaties to advance the protection of its territory and people and to better insure their well-being. Included in the idea of entering into treaties is the idea of entering into alliances.

Putin’s assault on Ukraine seeks to deny its existence. In the course of his peace proposals, he seeks to strip from it the ability to defend itself, and take land from Ukraine. Land or territory taken by force is not recognized under international law.40 These are violations of its sovereignty.

Genocide

Genocide and cultural genocide41 are alleged against the Russians, and there is quite a bit of evidence to support these claims. Vladimir Putin and others are wanted by the International Criminal Court (ICC). Arrest warrants were first issued against Putin and Maria Lvova-Belova on March 17, 2023 alleging war crimes for the unlawful deportation and transfer of Ukrainian children during the Russo-Ukrainian War. This is the first such time a warrant has been issued against the leader of a permanent member of the United Nations Security Council.42

Other warrants issued from the ICC in June, 2024. Charged with crimes against humanity, the accused are Viktor Sokolov (Commander of the Black Sea Fleet), Sergey Kobylash (Commander of the Russian Air Force), Sergei Shoigu (Minister of Defense and Secretary of the Security Council), and Valery Gerasimov (Chief of the General Staff and Minister of Defense) all high ranking Russian officials. Under the Rome Statute which sets up the International Criminal Court, the 124 signatories are required to apprehend the accused should they appear in the jurisdiction of the signatory state. 43

There is also a case pending before the International Court of Justice begun on February 26, 2022 by Ukraine against Russia that deals with the Russian allegations of Ukrainian genocide justifying the Russian Invasion.44 Ukraine stated that: “the Russian Federation has falsely claimed that acts of genocide have occurred in the Luhansk and Donetsk oblasts of Ukraine, and on that basis recognized the so-called ‘Donetsk People’s Republic’ and ‘Luhansk People’s Republic’, and then declared and implemented a ‘special military operation’ against Ukraine”. Ukraine asked the ICJ to “[a]djudge and declare that there is no credible evidence that Ukraine is responsible for committing genocide in violation of the Genocide Convention in the Donetsk and Luhansk oblasts of Ukraine”, Russia objected, and on February 2, 2024 the ICJ found it had jurisdiction to hear the matter.45

On November 14, 2022, the Helsinki Commission, or the Commission on Security and Cooperation in Europe detailed some of the evidence of genocide against Russia. In summary, it is:

“Russia’s violently imperial war in Ukraine is not only a flagrant violation of international law and interstate norms, but it also carries all the hallmarks of an ongoing campaign of genocide in Ukraine. From Russian dictator Vladimir Putin’s 7,000-word screed that systematically and historically denies Ukrainian nationhood; to mass graves uncovered in almost every Ukrainian territory liberated from Russian occupation; to the Kremlin’s public campaign of mass deportation and of Ukrainian civilians and children through “filtration” concentration camps; to the deliberate targeting of maternity hospitals, medical facilities, schools, and basic civil infrastructure; to the widespread employment of rape and sexual violence as a weapon of terror—rarely has genocidal intent and pattern of action been so clearly telegraphed and demonstrated for the world to see. According to the five-point definition under the 1948 Convention on the Prevention and Punishment of the Crime of Genocide, Russia has demonstrated clear, notorious, and mounting evidence in all five criteria, even though only one must be fulfilled to qualify as genocide.”46

The UN High Commission for Refugees (UNHCR) (from which Trump withdrew) reports the situation is dire in Ukraine, as there is much human suffering:

“The full-scale invasion of Ukraine in February 2022 has resulted in loss of life, separation of family members, and loss of homes, belongings, savings and jobs. Civilian infrastructure has been damaged or destroyed, disrupting the supply and access to gas, electricity and fuel.  Attacks by missiles, rockets and drones continue to pose a risk to the safety and security of millions of Ukrainians. Approximately one-third of Ukrainians have been forced to flee their homes and around 3.7 million are currently displaced within the country, while some 6.8 million are displaced as refugees abroad. The humanitarian needs inside Ukraine continue to grow as the war persists, with an estimated 12.7 million people in need of multisectoral humanitarian assistance.”47

Conclusion

The free world is based on law. Only then can the dignity of man be realized, and that is the essence of the Christian Order. President Volodymyr Zelinskyy of Ukraine is fighting for the rule of law, for the world community, for the dignity of man, for the Christian Order.

1 John Eppstein, The Catholic Tradition of the Law of Nations (The Lawbook Exchange, Clark, New Jersey, 2012), 247-275.

2 Hugo Grotius, On the Law of War and Peace (Anodos Books, 2019), 12.

3 Emer de Vattel, The Law of Nations, (The Lawbook Exchange, Ltd., Clark, New Jersey, 2020), lx.

4 St. Thomas Aquinas, from Summa Theologica, the Basic Writings of Saint Thomas Aquinas, ed., Anton C. Pegis (New York: Random House, Inc., 1945), Vol. II as contained in Philosophy of Law ed. Joel Feinberg and Hyman Gross (Dickinson Publishing Company, Encino, California, 1975), 10.

5 John Austin, from The Province of Jurisprudence Determined, as contained in Philosophy of Law, 16.

6 Malcolm Shaw, International Law (9th Ed., Cambridge University Press, 2021), 879.

7 Ibid., 787.

8 Ibid., 788.

9 Ibid., 789; “UN Charter,” Academic Impact, United Nations, found at https://www.un.org/en/academic-impact/un-charter#:~:text=The%20Charter%20is%20an%20international,purposes%20of%20the%20United%20Nations as of December 27, 2024.

10 John Eppstein, Code of International Ethics (Sands & Company, Glasgow, Scotland, 1953), 16.

11 Nolkaemper, André (2009) “Constitutionalization and the Unity of the Law of International Responsibility,” Indiana Journal of Global Legal Studies: Vol. 16: Iss. 2, Article 7.

12 Aleksander Dugin, “Trump Has A Plan,” February 13, 2025, Katehon.

13 Article 36 of the Statute states: “1. The jurisdiction of the Court comprises all cases which the parties refer to it and all matters specially provided for in the Charter of the United Nations or in treaties and conventions in force. 2. The states parties to the present Statute may at any time declare that they recognize as compulsory ipso facto and without special agreement, in relation to any other state accepting the same obligation, the jurisdiction of the Court in all legal disputes concerning:  a.    the interpretation of a treaty;  b.    any question of international law;  c.    the existence of any fact which, if established, would constitute a breach of an international obligation;  d.    the nature or extent of the reparation to be made for the breach of an international obligation….”

14 United Nations Charter, Article 1.

15 United Nations Charter, Article 2.

16. “Full Text of Putin State of Nation Speech 21 Feb 2022,” February 22, 2023, Mirage as found at https://www.miragenews.com/full-text-of-putin-state-of-nation-speech-21-951701. Putin set forth a number of talking points for his disinformation campaign as part of his asymmetric warfare against the West, even though these comments contradicted other positions and undercut his claims for war as he set forth on February 24, 2022 and submitted to the United Nations: 1) Ukraine is not stable and has no tradition of statehood; 2) corruption in Ukraine and plundering by the West; 3) the USA and NATO see Russia as an enemy and are positioning for a preemptive strike; 4) the USA and NATO refuse to give security guarantees to Russia; 5) the rise of neo-Nazis and super-nationalism; 6) Ukraine acting unfairly towards Russia and the denial of everything that unites us' by distorting the consciousness and historical memory of millions of people’; 7) promotion of hatred against Russia and Russians in Ukraine; 8) Ukraine seeking NATO membership which is a threat to Russia; 9) promise from 1990 that NATO would not move east; 10) Clinton Putin conversation of 2000 about Russia joining NATO; 11) USA supports terrorists and withdrew from a nuclear treaty; 12) USA emplacing missiles in Poland and Rumania.

17 Michael N. Schmitt, “Russia’s `Special Military Operation’ and the (Claimed) Right of Self-Defense,” February 28, 2022, Lieber Institute West Point.

18, See, Al Jazeera Staff, “No other option: Excerpts of Putin’s speech declaring war,” February 24, 2022, Al Jazeera.

19 UN Charter, Article 2(4): “All Members 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.”

20 Schmitt, “Russia’s `Special Military Operation’ and the (Claimed) Right of Self-Defense.”

21 Ibid.

22 Ibid.; See, also, “Repertory of Practice United Nations Organs; Chapter VII, Article 51,” Found at https://legal.un.org/repertory/art51.shtml; Antonio Cassese, International Law (2nd Edition) (Oxford University Press, 2005), 358.

23 Ibid.; See, also, Part V, 2002 US NSS: “For centuries, international law recognized that nations need not suffer an attack before they can lawfully take action to defend themselves against forces that present an imminent danger of attack. Legal scholars and international jurists often conditioned the legitimacy of preemption on the existence of the imminent threat—most often a visible mobilization of armies, navies, and air forces preparing to attack.” Found at https://georgewbush-whitehouse.archives.gov/nsc/2002/nss5.html.

24 Ibid.

25 Ibid.; See, also, Kevin Jon Heller, “Why Preventive Self-Defense Violates the UN Charter,” March 7, 2012, Opinio Juris, Found at https://opiniojuris.org/2012/03/07/why-preventive-self-defense-violates-the-un-charter/; James Crawford, Brownlie’s Principles of Public International Law, (9th Ed.) (Oxford University Press, 2012), 723-725.

26 Ibid., See, also, James Crawford, Brownlie’s Principles of Public International Law, (9th Ed.) (Oxford University Press, 2012), 722-723.

27 Ibid.

28 Ibid

29 Antonio Cassese, International Law (2nd Edition, Oxford University Press, 2005), 71.

30 See, Malcolm Shaw, International Law (9th Ed., Cambridge University Press, 2021), 879; John Eppstein, The Catholic Tradition of the Law of Nations (The Lawbook Exchange Ltd., Clark, New Jersey 2012), 223, 259.

31 Crawford, 106.

32 Ibid., 117-126.

33 Ibid., 432.

34 Malcolm Shaw, International Law (9th Ed., Cambridge University Press, 2021), 192-197.

35 Ibid., 194.

36 Emmerich de Vattel, The Law of Nations (The Lawbook Exchange Ltd., Clark, NJ, 2020) see Book I, Chapter VI.

37 Ibid., Book I, Chapter X.

38 Ibid., Book I, Chapter XIV.

39 John Eppstein, Code of International Ethics (Sands and Company, Glasgow, UK, 1952), 56-87.

40 Briarly’s Law of Nations (7th Ed. Oxford University Press, 2012), 176.

41 Jade McGlynn, “Russia is committing cultural genocide in Ukraine; Historical Falsification, Youth Indoctrination, and the plunder of artifacts reveals the Kremlin’s true intentions,” April 23, 2024, Foreign Policy; Also, see, Rome Statute of the International Criminal Court, found at https://www.icc-cpi.int/sites/default/files/2024-05/Rome-Statute-eng.pdf as of December 27, 2024 and 18 USC 1091 et seq.

42 “Situation in Ukraine: ICC judges issue arrest warrants against Vladimir Vladimirovich Putin and Maria Alekseyevna Lvova-Belova,” Press Release March 17, 2023, International Criminal Court; Mike Corder, Raf Casert “International court issues war crimes warrant for Putin,” March 17, 2023, Associated Press.

43. “Situation in Ukraine: ICC judges issue arrest warrants against Sergein Kuzhugetovich Shoigu and Valery Valilyevich Gerasimov,” Press Release, 25 June 2024, International Criminal Court found at https://www.icc-cpi.int/news/situation-ukraine-icc-judges-issue-arrest-warrants-againt-sergei-kuzhugetovich-shoigu-and as of December 27, 2024; “Situation in Ukraine: ICC judges issue arrest warrants against Sergei Ivanovich Kobylash and Viktor Nikolayevich Sokolov,’ Press Release, 5 March 2024, International Criminal Court found at https://www.icc-cpi.int/news/situation-ukraine-icc-judges-isse-arrest-warrants-against-sergei-ivanovich-kobylash-and as of December 27, 2024.

44 See, International Court of Justice at https://www.icj-cij.org/case/182

45 Ibid.

46 “Russia’s Genocide in Ukraine,” November 14, 2022, CSCE, found at https://www.csce.gov/briefings/russias-genocide-in-ukraine-2/ as of December 24, 2024.

47 “Ukraine,” UNHCR The UN Refugee Agency, found at https://reporting.unhcr.org/operational/operations/ukraine#:~:text=Approximately%20one%2Dthird%20of%20Ukrainians,are%20displaced%20as%20refugees%20abroad as of December 24, 2024.

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