Ibid, para Sample Clauses

Ibid, para. In a similar vein, the Council of Europe Guidelines 2010 warn against ‘second- ary victimisation’. Supra n. 12, para. 11. 36 ▇▇▇▇, Zarraga v ▇▇▇▇, Case C-491/10, Judgment of 22 December 2010, para. 64. 37 Ibid, para. 19.
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Ibid, para. 28. The EFTA Court furthermore highlighted that this was in line with the TRIPS agreement – that is, to leave the issue open for the States to regulate (para. 29).
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Ibid, para. For example, in a case including charges of ‘attempted murder,’ ‘the provision of medical assistance to the wounded by a person other than the one responsible for causing the injuries qualifies as circumstances outside the perpetrator’s control.’ Ibid, para. 99. 97 The Prosecutor ▇. ▇▇▇▇▇▇▇ ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇▇ Ngudjolo ▇▇▇▇, Decision on the Confirmation of Charges, para. 460. 98 ICRC Commentary to Art. 87, API, para. 3550. 99 Prosecutor v. ▇▇▇▇▇▇ ▇▇▇▇▇, Judgment, para. 76. 100 Prosecutor v ▇▇▇▇▇ ▇▇▇▇▇▇▇▇▇▇▇▇▇▇, et. al., Decision on Joint Challenge to Jurisdiction, IT-01-47-PT, 12 November 2002, paras. 167 – 179. perpetrators.101 The Rome Statute of the ICC alters the evidentiary thresholds for holding civilian and military commanders accountable under the theory of superior responsibility. In addition to the three elements found in the law of the ad-hoc tribunals, prosecutors at the ICC must establish that the crimes committed by subordinates occurred as a result of the superior’s ‘failure to exercise control properly over such forces.’102 In short, it is necessary to prove that the superior’s omission increased the risk of the commission of the crimes charged.103
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Related to Ibid, para

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