Introduction

The October 2025 conviction of Ali Muhammad Ali Abd-Al-Rahman (“Kushayb”) marks the first completed International Criminal Court (ICC) case arising from the atrocities committed in Darfur. The ICC had initially convicted Kushayb of 27 counts of war crimes and crimes against humanity committed in Darfur. Two months later in December 2025, the court sentenced him to a joint sentence of 20 years (ICC 2025a).

Ali Kushayb was a senior Janjaweed commander, who supported the Sudanese government’s repression of Darfur rebel groups during the Omar Al-Bashir presidency, and was responsible for the persecution and killing of hundreds of thousands of people in the Darfur region.

A total of 74 witnesses testified during the Kushayb trial: 2 were called by the Chamber, 54 by the Prosecution, 17 by the Defence, and 1 by the participating victims through their legal representatives (ICC 2025c). In addition, 1,861 evidentiary items were formally admitted into the record (Ibid). This marked the first Darfur-related case to reach completion, the first ICC trial stemming from a UNSC referral, the first conviction for gender-based persecution, and the first case in Sudan’s history that an individual has been convicted by an international tribunal for violations of international humanitarian and human rights law. Its significance, therefore, cannot be overstated.

However, as 1,592 victims, whose experiences speak not only to Darfur but to Sudan more broadly, finally received long-overdue recognition and a measure of justice following this sentencing, thousands more in Darfur have since lost their lives (UN News 2025). More than twenty years after the 2003 atrocities, communities across Sudan are once again witnessing similar patterns of violence that echoes that earlier period (Prosecutor v Abd-Al-Rahman 2025).

Amidst this suffering, what the case has represented is that Sudan has, at last, re-emerged on the international agenda, obtaining a measure of the recognition – and justice – it has long required, although amidst the backdrop of a continuation of mass atrocities currently taking place since the outbreak of war on April 15th, 2023.

This judgment arrives at a moment when international law is widely doubted, portrayed as weak, waning, politically compromised, and lacking enforceability. In this context, this piece argues against that prevailing narrative. The Kushayb verdict demonstrates that although international law can be manipulated, delayed, or politicized, it retains the capacity to deliver justice, even if belatedly. The constraints on and violations of international law do not signal its disappearance or irrelevance, but rather underscore its inherent limitations. Its existence and potential remain very much alive.

The Kushayb judgment not only challenges the narrative that international law is failing, but also establishes critical precedents for criminal accountability, signals renewed possibilities for additional arrest warrants in response to ongoing atrocities in Darfur, and clarifies the continued relevance and evolving role of international law in the Sudanese context and globally.

What Precedent does the Kushayb Verdict Set?

The ICC does not recognise stare decisis, the principle under which judges are required to follow earlier rulings in similar cases, in a strict formal sense, so the Kushayb judgment is not “precedent” in the way common law lawyers would use the term (Heikkila 2017). Yet in practice it is undeniably precedent-setting. As noted above, it is the first case arising from a UNSC referral to reach a completed trial and conviction. This matters in a context where the validity, good faith, and politics of UNSC referrals, and of the Council’s relationship with the ICC more broadly, have been heavily contested, particularly in relation to Sudan.

Sudan signed the Rome Statute of the International Criminal Court (1998) on 8 September 2000 but never ratified it, and has consistently taken the position that it is not bound. In 2008, Deng Alor Koul, then Minister for Foreign Affairs, formally notified the UN Secretary-General, as depositary of the Statute, that “Sudan does not intend to become a party to the Rome Statute (1998). Accordingly, Sudan has no legal obligation arising from its signature.” In parallel, Sudan fought vigorously within the African Union (AU) to secure political backing against the ICC, especially after the issuance of an arrest warrant for then-President Omar Al-Bashir (Imoedemhe 2015). Although Sudan’s relationship with the Court improved somewhat after the 2019 revolution and the formation of a technocratic transitional government, including a high-profile visit in 2020 by then-Prosecutor Fatou Bensouda, the Rome Statute of the International Criminal Court(1998) itself has still not been ratified (ICC 2020).

Against that background, the Kushayb judgment is significant because it confirms, in concrete terms, that Sudan can nonetheless be bound to the Court’s jurisdiction through UNSC action. Acting under UNSC Resolution 1593 (2005), the Council referred the situation in Darfur to the ICC in March 2005, and the Prosecutor opened an investigation in June 2005. Kushayb’s case demonstrates that such a referral can lead not only to arrest warrants, but to a fully completed trial, a detailed factual record, which is desperately needed in relation to atrocities in Sudan, and, indeed, a conviction. This goes directly to the credibility of UNSC referrals in other situations where scepticism about the Court’s effectiveness is high.

In relation to Darfur, seven individuals have been the subject of ICC proceedings. Kushayb is the first to be tried and convicted. Two cases were closed at an earlier stage: in February 2010, Pre-Trial Chamber I declined to confirm the charges against Bahr Idriss Abu Garda on the basis that the Prosecutor had not met the “substantial grounds to believe” standard (Prosecutor v Abu Garda 2010); whilst proceedings against Saleh Mohammed Jerbo Jamus were terminated following his death (ICC 2013).  Four arrest warrants remain outstanding for Omar Al-Bashir, Abdallah Banda Abakaer Nourain, Ahmad Muhammad Harun, and Abdel Raheem Muhammad Hussein (ICC n.d).

Despite these legal and political barriers, the Kushayb judgment shows that accountability is still possible even when national authorities actively resist it and cultivate a culture of impunity. This is not to suggest that the ICC or international law are beyond criticism; they are not. However, it does demonstrate that, when national systems fail, an international process can intervene and succeed. The reaction in Sudan to the verdict, and the sense of long-delayed recognition among victims, underscore that point. For the remaining suspects, the message is equally clear: conviction is now a proven, not a hypothetical, outcome. Time has not extinguished that risk, and that signal travels globally beyond Sudan.

Substantively, the case is also widely noted as the ICC’s first conviction for gender-based persecution. Under Counts 21 and 31, the Chamber found Kushayb guilty of persecution on political, ethnic and gender grounds, under Articles 7(1)(h) and 25(3)(a) of the Statute (Ibid). Both Count 21 and Count 31 included persecution as a crime against humanity and both referred to “gender grounds, concerning Fur males perceived as belonging to, or being associated with, or supporting rebel armed groups” (Ibid). The Chamber found that the Janjaweed and Government of Sudan forces targeted predominantly Fur men of fighting age because they were perceived as affiliated with rebel groups. In doing so, they also discriminated against them on the basis of political affiliation, ethnic identity and perceived gender role. This was novel. Kushayb is the first time the ICC has convicted an individual for persecution on the basis of gender as a crime against humanity, and consequently it expands the Court’s jurisprudence on how gendered harm can be framed and prosecuted as persecution, and not only as a set of discrete acts such as rape or sexual violence. 

In this sense, Kushayb operates as a test case on legality, jurisdiction and victim participation in a UNSC-referred situation involving a non-party State. The Chambers’ reasoning on how Rome Statute of the International Criminal Court(1998) crimes apply via Council referral (i.e., how the UNSC can give the ICC jurisdiction over crimes in a situation, even where the State concerned is not a Rome Statute party) will inevitably be invoked in future debates about referrals concerning States such as, Libya,  among possible others in the future

Finally, the participation of 1,592 recognised victims, and the forthcoming reparations phase, wherein victims of the crimes for which Kushayb was convicted are entitled to seek reparations (Rome Statute 1998), will serve as an important model for what victim-centred justice can, and cannot, look like in mass-atrocity contexts. Taken together, these elements form a kind of jurisprudence constante: future Chambers are not formally bound to follow Kushayb, but it will be difficult to ignore (ICC 2025a).

Will the ICC issue additional arrest warrants?

UNSC Resolution 1593, adopted in 2005, referred “the situation in Darfur since 1 July 2002” to the Prosecutor of the ICC, without specifying an end-date to the Court’s authority over events in the region. Adopted under Chapter VII of the UN Charter, this resolution marked the first use of Article 13(b) of the Rome Statute (1998) (UN Digital Library 2005), which enables the Court to exercise jurisdiction over crimes committed on the territory of a State that is not party to the Court. In principle, therefore, the Court may investigate and prosecute crimes in Darfur committed after 2002, so long as they fall within the “situation” referred by the UNSC.

A key controversy concerns whether the present atrocities in Darfur, particularly since the outbreak of hostilities in April 2023, are sufficiently linked to the situation that existed at the time of the 2005 referral. Some commentators argue that Sudan’s political trajectory, from the Bashir regime, through the 2019 revolution and transitional government, to the 2021 coup, along with the institutional evolution of the Janjaweed into the Rapid Support Forces, commonly referred to as the RSF, have created a fundamentally new context. Based on this view, the original referral can no longer serve as a jurisdictional basis (Lentner 2025).

I disagree with this reading. Both the Kushayb judgment and earlier Darfur filings consistently identify the “Government of Sudan Forces” (i.e. the Sudanese Armed Forces (SAF) and others) and the Janjaweed militias as principal perpetrators; the RSF are in substance, a reconfiguration of the Janjaweed, and key figures in the current leadership, including Hemedti, were already implicated in the original Darfur campaign. The continuity of core actors, patterns of violence, and targeted communities strongly supports the view that there remains a “sufficient link” between the crimes committed in 2003–2004 and those now being committed in Darfur, in line with the test developed in previous ICC jurisprudence.

This position is also reflected in the practice of the Office of the Prosecutor. Shortly after the outbreak of the 2023 conflict, ICC Prosecutor Karim A. A. Khan KC reaffirmed that the Court’s mandate under UNSC Resolution 1593, remained fully operative in relation to genocide, crimes against humanity and war crimes in Darfur, stressing that any individual responsible for such crimes would be investigated (ICC 2023). This remains the Office’s stated position. In its 3 November 2025 statement on El-Fasher, the Office expressly “recall[ed] that under UN Security Council Resolution 1593 (2005)he ICC has jurisdiction over crimes being committed in the ongoing conflict in Darfur” (ICC 2025d) and confirmed that it is investigating crimes allegedly committed in Darfur since the outbreak of hostilities in April 2023. This includes taking immediate steps to preserve and collect evidence related to the alleged crimes in El-Fasher for use in future prosecutions (ICC 2025d). Taken together, this institutional position presupposes that, at least as regards Darfur, the necessary connection to the original “situation” persists and that further arrest warrants remain legally possible on the basis of UNSC Resolution 1593 (2005) alone.

Scholars also argue, persuasively, in my view, that UNSC referrals under Article 13(b) must be interpreted strictly, given that they operate as an exceptional derogation from the principle of State consent (Ibid p20). This restrictive approach, however, does not negate the existence of a sufficient link within Darfur from the adoption of UNSC Resolution 1593 and until now.

UNSC Resolution (2005) was adopted by 11 votes in favour, none against and 4 abstentions. During the meeting at which the resolution was adopted, the Council did not engage in any explicit discussion of the temporal scope of the referral. On the contrary, several statements by Council members suggest a forward-looking intention. The United States expressed the hope that the people of Sudan would “enjoy a much, much better future”; the United Kingdom issued “a salutary warning to anyone intending to commit any further such atrocities”; and France described the resolution as sending “a forceful message…to all those who have committed or might be tempted to commit atrocities in Darfur” (ICC2025d, pp.4, 7-8).

Taken together, this silence on temporal limitation, combined with the deterrent and explicit prospective language in these statements (the “future” of Sudan was mentioned 5 times in the meeting records), supports the interpretation that the resolution was intended to apply to crimes committed after its adoption and thus continues to have legal relevance today.

However, the territorial scope of resolution 1593 is explicitly confined to the situation in Darfur. Although similar patterns of criminality have emerged across Sudanese territory since April 2023, the current referral cannot be stretched to encompass crimes committed wholly outside Darfur. For crimes committed beyond Darfur, a fresh UNSC referral (or an ad hoc declaration by Sudan under Article 12(3) of the Rome Statute (1998), which is highly unlikely at the moment) would be required to ground ICC jurisdiction. In sum, additional arrest warrants for crimes in Darfur are legally available under the existing referral, but extending accountability to atrocities occurring elsewhere in Sudan would require a new jurisdictional basis.

Implications on Sudan

The trajectory of the Kushayb case mirrors shifting political landscapes in Sudan. For years under the Omar Al-Bashir regime, Kushayb lived at liberty despite the ICC arrest warrant issued for him in April 2007 (ICC 2007). Following the 2019 revolution and the subsequent transition, the domestic calculus changed. Fearing arrest by Sudanese authorities during the transition, he moved to the Central African Republic (CAR) in early 2020 and, in June 2020, voluntarily surrendered himself to ICC custody, appearing before the Court later that month (Beaumont, 2020). During the proceedings, however, he sought to distance himself from his nom de guerre, telling the judges that he was not Ali Kushayb and maintaining that the Court had mistaken him for another person (Prosecutor v Abd-Al Rahman 2025). Notwithstanding, the fact remains that, despite these efforts and the upheavals in Sudan, including the outbreak of the current war in April 2023, he was tried and convicted. Changes in domestic regimes did not alter the ICC’s assessment of his responsibility. The lesson is clear: accountability is not something that can be managed through timing, identity strategies, or political shifts. For those committing crimes in Darfur today, the judgment signals that criminal responsibility is not a temporary risk, but a long-term, tangible one that can outlive regime change, coups and shifting alliances.

For nearly two decades, no Darfur-related case reached conviction, the ICC gradually receded from the Sudanese public imagination and, arguably, from international attention as well. This was in part due to the political and legal constraints under which the ICC operates, which this piece does not explore in detail, but whose effects in Sudan were unmistakable. Kushayb surrendered himself to the ICC in 2020, thirteen years after the first arrest warrant was issued for him in 2007, and was convicted only in 2025, eighteen years after that initial warrant. In this context, the fading of the ICC from Sudanese consciousness was hardly surprising.

The initial focus on the arrest warrant for Al-Bashir also meant that other defendants remained less visible, with their cases failing to attract comparable public attention. In the eyes of many Sudanese, the ICC appeared distant, slow, and unlikely ever to deliver concrete outcomes. The Kushayb verdict, nonetheless, alters that perception. It is not merely a symbolic moment, but a judicial finding that establishes a factual record of what happened in Darfur and formally recognises 1,592 participating victims. The echo of the 1,592 was loud. In a context where each new cycle of violence threatens to bury the last, this record will matter for memory and truth, and it will be more difficult for future authorities, whatever their political orientation, to erase, minimise or rewrite the history of Darfur. The judgment will become a crucial reference point for how Darfur is remembered and narrated within Sudan, both in legal fora and in broader public discourse.

At the same time, the judgment’s implications for Sudan are constrained. One conviction cannot undo decades of impunity, nor does it answer the many Sudanese who ask why other commanders in the RSF, the SAF or other Sudanese actors have yet to face trial. There is also a real risk that different factions will selectively instrumentalise the judgment to delegitimize their opponents, rather than to build a shared commitment to justice.

Moreover, the Kushayb judgment comes more than eighteen years after the first arrest warrant was issued in 2007, and Sudanese communities should not expect a swift process even if further warrants are issued in relation to current atrocities. Given that Sudan is de facto under the control of the SAF, with General Abdel Fattah Al-Burhan actively seeking international recognition as the country’s legitimate leader, meaningful cooperation with the ICC, let alone ratification of the Rome Statute (1998), which would extend the Court’s jurisdiction beyond Darfur, appears unlikely in the near term. While, in principle, the Rome Statute system gives priority to domestic prosecutions where a State is willing and able genuinely to investigate and prosecute, there are serious grounds to doubt that a SAF-led Sudan would undertake such proceedings in a credible manner.

For now, the ICC remains one of the few realistic avenues for justice in Darfur. Extending accountability to atrocities committed elsewhere in Sudan, however, would require a new UNSC referral under Article 13(b), which, as in UNSC Resolution 1593 (2005), would almost certainly be adopted without the endorsement of Sudan’s de facto authorities.

What does this say about international law?

The Kushayb verdict underscores that international law is neither a saviour nor a villain, but a framework whose force depends on how States choose to use it. The eighteen years between the first arrest warrant and the conviction show that politics can delay justice, sometimes brutally, but cannot erase legal responsibility. Apparent “failures” of international law do not reflect its absence. They reveal that it often functions slowly, selectively and under significant political constraint, for reasons that sit outside the four corners of the Rome Statute (1998) or any other treaty. International law cannot stop a war or repair Sudan’s politics, but it can classify conduct as criminal, attribute responsibility to individuals, and recognise victims as rights-holders rather than spectators to their own suffering.

At the same time, the judgment itself is the product of political decision-making. ICC jurisdiction in Darfur exists only because the UNSC adopted Resolution 1593, a political act that opened the door to this case. In this context, international law is best understood as a constrained tool that can be mobilised for accountability, rather than an autonomous force standing above politics.

Conclusion

The time for “amsah aksah,” the command to erase and wipe out, cited 39 times in the Kushayb judgment, is not over in Sudan’s reality. It is, however, definitely over for Kushayb himself. The fact that this phrase now appears in a conviction, rather than as an unchecked incitement to violence, offers a measure of hope that justice for the remaining suspects is not an empty promise. It shows that those words can be read not only as orders shouted, but as evidence analysed in a courtroom.

Yet Sudan needs far more than ICC arrest warrants and a single conviction. International proceedings cannot, on their own, deliver the social, cultural, legal and political transformation that genuine peace requires. That will demand a deeper paradigm shift, one rooted in Sudanese society itself: in how we understand responsibility, how we remember Darfur, and how we refuse to normalise “amsah aksah” as a way of doing politics. Lawyers, politicians and government officials have a role to play, but so do communities, civil society and survivors. In that wider struggle, the Kushayb verdict and the 20-year sentence are not an endpoint. It is a beginning.

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