International Criminal Court: Israel’s appeal concerning the court’s jurisdiction under Article 19(2) of the Rome Statute

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Ioannis P. Tzivaras

Abstract

In April 2025, the Appeals Chamber of the International Criminal Court
(ICC) delivered a landmark judgment on Israel’s appeal concerning the Court’s
jurisdiction under Article 19(2) of the Rome Statute. This ruling revitalizes crit-
ical debates over the ICC’s ability to adjudicate cases involving sitting or for-
mer heads of state—an issue that has dominated international criminal law
since the ICC’s inception. The decision not only alters the procedural posture
of the Israel-Gaza situation, but also resonates across broader ICC caseloads
addressing complex jurisdictional and immunities questions.

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