Year of Call: 2000 / Year of Silk: 2014
Practice Areas
Rodney Dixon QC has a diverse practice in the UK and globally in international law, public law, inquiries, compliance and regulation, and human rights. He appears on behalf of Governments, serving and former Heads of State, politicians, military commanders, individual complainants and defendants, international organisations, companies and businesses, NGOs, and victim groups. He specialises in public international law, international criminal law, and human rights and civil liberties before all international, regional and national courts. His expertise lies in cases concerning foreign relations, inter-State disputes, the armed forces, international prosecutions and defence, public inquiries, universal jurisdiction, claims with international components, mediation and arbitration, cross-border proceedings, asset recovery, extradition and mutual assistance. He is described in Chambers and Partners “as an exceptional barrister with clients on every continent” and “respected for his excellent advocacy skills and strong client care”.
Rodney’s work covers all international criminal courts; UN proceedings, claims, and special procedures; actions before the International Court of Justice (ICJ); cases at the European Court of Human Rights; applications before the African Commission and African Court on Human and Peoples’ Rights; Privy Council cases; bilateral investment treaty matters; territorial and border disputes; public inquiries and investigations; World Bank Sanctions Board proceedings; land claims and reparations; corporate compliance and regulation; detentions abroad; Interpol and international and European arrest warrants; and, private international law cases.
He is widely recognised as a leading counsel and expert for all international criminal courts and regularly appears before the ICC and other international criminal courts like the ICTY and ICTR for individual defendants, States, and victims, including on behalf of the UK Government; the Government of Kenya; the Comoros Government; the former Government of Egypt; the Government of Rwanda; the Prime Minister of Kosovo; Mr. Abdullah Al-Senussi; victims of the Gaza Flotilla raid; and, interveners in the Sudan ICC Situation in the case concerning President Al Bashir, and victims from Darfur. He is one of a handful of lawyers who has both prosecuted and defended in international courts. He has acted and advised before other hybrid courts including the Special Court for Sierra Leone, the Iraqi Special Tribunal, the Extraordinary Chambers in the Courts of Cambodia, the Special Tribunal for Lebanon, and the War Crimes Division of the High Court of Uganda.
Rodney is highly respected in the field of public inquiries and investigations. He was appointed as a Commissioner on the National Commission of Inquiry into post election violence in Zimbabwe following the elections there in August 2018. He has previously been instructed in several inquiries including, the Presidential Commission of Inquiry into Disappeared Persons in Sri Lanka; for victims in the Jamaican Commission of Inquiry into the Tivoli Gardens killings; and, as part of the counsel team for the UK Ministry of Defence in the Baha Mousa public inquiry. He was instructed by the Government of South Sudan as an international adviser in respect of legal and judicial reforms under the 2015 Peace Agreement following the civil war. He has advised the Government of Qatar regarding the land, air and sea blockade imposed on the country in 2017. His cases before the European Court of Human Rights have included for the Government of Georgia concerning the conflicts in South Ossetia and Abkhazia and for the Ukrainian Government regarding the occupation of Crimea and Eastern Ukraine. He has acted in cases and hearings before the African Court and African Commission on Human and Peoples’ Rights including in relation to mass death sentences imposed in Egypt. He has represented many persons arbitrarily detained abroad, including the former President of South Korea, prominent Moroccan journalist Taoufik Bouachrine, and women detained in Saudi Arabia. Rodney is currently acting for Durham University academic, Matthew Hedges, who was held in solitary confinement in the UAE.
Rodney is the co-author of the leading textbook Archbold International on the law, procedure and practice of all international criminal courts, now in its 5th Edition (Sweet & Maxwell). It has been described by Justice Richard Goldstone, the former Chief Prosecutor of the ICTY and ICTR, as the book that “will always be open on the desks in offices” at the courts in The Hague.
Rodney has advised and lectured in the fields of bribery and corruption, money laundering, and cybercrime, with particular emphasis on the cross-border aspects and inter-State co-operation. He regularly lectures at conferences and seminars on international law, human rights, and civil liberties topics. He is a Senior Research Fellow at the Department of War Studies, King’s College. He has lectured at the UK armed forces Joint Services Staff College on the law of armed conflict, and was an instructor on the Canadian Armed Forces Law of Armed Conflict Course – Land, Naval and Air Operations. He has trained Judges and lawyers on international law, rule of law and human rights topics in several jurisdictions including in Sri Lanka, Mexico, Rwanda, Uganda, Sierra Leone, Cambodia, Lebanon, Bosnia, Nigeria, Serbia, Kosovo, Romania, Croatia, Bulgaria, Denmark, Finland, Italy and Germany.
He is often interviewed as an expert commentator including by the BBC, SKY News, Al Jazeera, RT News, and TRT World on topics such as the prosecution of UK soldiers serving abroad, arrest warrants for foreign leaders and universal jurisdiction, business responsibilities and compliance, border disputes, detentions abroad, and the developments in human rights cases around the world.
“Extremely calm and personable, he gives off an air of confidence and certainty when giving advice. It is always very reassuring to have him involved in a case”.
Chambers and Partners 2019
Recommended as a leading silk in Public International Law: “An excellent QC, very experienced in the field of public international law”, as well as in International Crime and Extradition.
Legal 500 2019
“An exceptional barrister, highly esteemed for his wealth of knowledge” in representing international governments and political leaders and handling international criminal law matters before UK courts “who has long experience in international cases. A very good team player who provides invaluable support; an excellent practitioner who guides you through the process”.
Chambers and Partners 2018
Recommended as a leading silk in Public International Law: “Consistently professional, collegial and a pleasure to work with” and in International Crime and Extradition.
Legal 500 2017
“An exceptional international lawyer.” “He is extremely impressive, knowledgeable and responsive.” “He’s got clients on every continent,” and is “a force to be reckoned with.”
Chambers and Partners 2017
Recommended as a leading silk in Public International Law: “He has a great public international law practice and a top mind”.
Legal 500 2016
Recommended as a leading silk in international criminal law: “An exceptional practitioner”.
Legal 500 2016
Recommended in International Criminal Law for representing Governments and leaders and his expertise in the field: “Respected for his excellent advocacy skills and strong client care”, “He is extremely experienced and knows his way around international criminal law”, “He is a very personable practitioner who is very diligent and well liked by clients.”
Chambers and Partners 2016
Recommended as Leading Silk in Public International Law: “Very impressive and user-friendly.”
Legal 500 2015
Recommended in Public International Law and in International Criminal law: “An acclaimed new silk who regularly represents governments, political figures and military leaders.” “He has an outstanding intellect, works very, very hard and is rated very highly as an advocate. He’s seen as being a real force to be reckoned with.” “Amazing. He’s really on top of all the case law and procedure, and knows exactly what he’s doing.”
Chambers and Partners 2015
Recommended in Civil Liberties and Human Rights and in Public International Law: “A confident, and creative approach to the protection and promotion of international human rights.”
Legal 500 2014
Recommended in International Criminal Law: “He is praised for his knowledge of this complex area of law. He has great expertise, and has everything at his fingertips.”
Chambers and Partners 2014
Recommended in Public International Law: “the clear, eloquent and focused Rodney Dixon who is one of the best counsel who appears before the ICC”, and in Civil Liberties and Human Rights.
Legal 500: 2013, 2012 and 2011
Recommended in Public International Law: “recommended for his particularly strong expertise in international humanitarian and criminal law.”
Legal 500 2010
Attorney-General’s Panel of Civil Advocates (2006-2011) and appointed to ‘A’ Panel for Public International Law
Accredited Advocacy Trainer, Inner Temple – trained advocacy in the UK and abroad
Visiting Senior Research Fellow, Department of War Studies, King’s College London, 2012-2015
Honorary Lecturer, International Law, University of Utrecht, 2010/11, 2011/12, 2012/13
Legal adviser (International law) and Counsel in the Office of the Prosecutor of the UN International Criminal Tribunal for the former Yugoslavia (ICTY), 1995-1999
Transferred from ICTY and called to the Bar in 2000
Before working at the ICTY, qualified as a solicitor in South Africa
BA LLB, Rhodes University, South Africa
LLM (International Law and Human Rights, cum laude), Notre Dame University, USA
D.Phil candidate (International Law), Oxford University, Wolfson College
Association of Defence Counsel of the ICTY (ADC)
List of Counsel of the International Criminal Court (ICC)
List of Counsel for the Special Tribunal for Lebanon (STL)
List of Counsel for the Special Court for Sierra Leone (SCSL)
Disciplinary Committee of the ADC (2004-2005)
Member of South Eastern Circuit
Undertakes Public Access work
Representing Durham University academic who was held in solitary confinement for over 6 months in the UAE. Various legal actions being taken to obtain redress and compensation.
Serving as a Commissioner on the national Commission of Inquiry into post election violence in Zimbabwe following the August 2018 elections. Appointed by the President of Zimbabwe pursuant to the national Commissions of Inquiry Act.
Acting for companies in proceedings concerning allegations of corruption and bribery before the World Bank, Sanctions Board. Hearings to be held at the World Bank Headquarters in Washington DC.
Representing hundreds of persons displaced from their lands in Kericho County, Kenya, during the colonial period and thereafter. Hearings have been held before the National Land Commission in Kenya in order to seek reparations and compensation for those dispossessed.
Acting as international counsel for a leading journalist in Morocco, Mr Taoufik Bouachrine, who has been charged with human trafficking, rape and sexual assault. His trial has taken place before the criminal court in Casablanca.
Instructed to prepare legal opinion and report on the human rights situation in Saudi Arabia following the wave of arrests and detentions in September 2017. A copy of the report is here and interview about the report here.
The report is being submitted to the United Nations Human Rights Council in Geneva for consideration. Families of certain of those detained had asked for the report to be prepared and provided to UN bodies and Governments.
Representing persons on death row in Egypt in proceedings before the African Commission to have their death sentences set aside (Communication 670/17). The application concerns 16 persons sentenced to death by Egyptian courts. The African Commission has ordered provisional measures directing the Government of Egypt to suspend the death sentences pending the outcome of the proceedings.
Rodney Dixon QC is Counsel for the UK Government at the ICC in the Preliminary Examination for the Iraq Situation which concerns allegations of war crimes committed in Iraq.
Acting for three prominent Qatari nationals who were allegedly unlawfully detained and tortured in the UAE between 2013 and 2015 by UAE security officials before being released as a result of an agreement between the Governments of the UAE and Qatar. The Met Police have been requested to investigate the case under the universal jurisdiction provisions on torture of the Criminal Justice Act 1988.
Representing in international proceedings the former President of South Korea who has been impeached and is currently detained and on trial in Seoul on charges of corruption, bribery and abuse of power. Family, close associates and supporters have instructed Rodney Dixon QC to take all steps internationally to challenge President Park’s detention, particularly in light of her deteriorating health condition. Urgent proceedings have been launched before the UN Working Group on Arbitrary Detention in Geneva and other UN bodies to protect the former President’s rights and safeguard her well-being.
Appointed to act as international legal adviser to the Transitional Government of National Unity of South Sudan on legal and judicial reform relating to the 2015 Peace Agreement following the civil war in South Sudan.
Representing Georgia (being led by Ben Emmerson QC) in case against Russia before the European Court of Human Rights. The case concerns the conflict that broke out between Georgia and Russia in August 2008 in South Ossetia. Georgia is proceeding against Russia in an inter-State action for violations of the European Convention on Human Rights committed against Georgian civilians during the conflict including in respect of unlawful killings from bombardments and attacks on towns and villages, and torture and ill-treatment of captured prisoners of war and civilian detainees.
Acting as international counsel on behalf of a British national, Hasnat Karim, who was arrested following the terrorist attack on a cafe in Dhaka on 1 July. Mr Karim remains in custody in Dhaka without having been charged with any offence.
Acting for plaintiffs in civil claims for wrongful death under the Torture Victim Protection Act (TVPA) and the Alien Torts Statute (ATS).
Rodney Dixon QC advised on matters of international law to the Advisory Council of the Presidential Commission of Inquiry examining the final stages of the armed conflict in Sri Lanka. Final report of the Commission was tabled in Parliament in October 2015.
Representing US and other plaintiffs in civil suit for damages under the Foreign Sovereign Immunities Act arising from an attack on a US ship on the high seas.
Acted in extended proceedings before the African Commission on Human and Peoples Rights and United Nations brought on behalf of those sentenced to death in mass trials in Egypt in 2014. Made representations before the Commission at its seat in The Gambia. The death sentences were eventually set aside or are being reviewed.
Rodney Dixon QC is acting for the Government of the Union of the Comoros before the ICC in respect of the attack on the Gaza Flotilla on the High Seas in May 2010. Judicial review proceedings have been successfully brought against the decision of the ICC Prosecutor not to initiate an investigation into alleged war crimes.
Representing Dr Morsi, his Government and the Freedom and Justice Party of Egypt in several jurisdictions following the coup in Egypt in 2013 including before the UN, ICC, African Commission, and in judicial review proceedings in the UK concerning the immunity of state and military officials.
Karim Khan QC, Rodney Dixon QC and Dato’ Shyamala Alagendra represented TV station and journalist in trial at STL on allegations of witness interference. This is the first trial before an international court in which a corporate entity has faced charges. TV station and journalist has been acquitted of all counts.
Representing residents of Tivoli Gardens, who were victims of an attack and killings in Kingston, Jamaica in 2010, before the National Commission of Inquiry and in other international actions.
Submitted a ground-breaking communication to the African Commission on Human and Peoples’ Rights on behalf of Mishana Hosseinioun, which became one of the first cases which the African Commission submitted to the African Court on Human and Peoples’ Rights. Both the Court and the Commission imposed interim measures on Libya. The Court ultimately concluded that Libya had violated the rights of Dr Gaddafi.
Advising the Government of Sudan in respect of border and territorial disputes that were referred to the United Nations and the African Union.
Acting on behalf of former Intelligence Chief of Libya for the late Colonel Gaddafi in proceedings before the ICC and in other jurisdictions.
Counsel for the Kenyan Government in the Kenya cases before the ICC, inter alia against the President and Deputy President of Kenya, including in admissibility proceedings on grounds of complementarity.
Acting on behalf of former PM of Kosovo on charges of crimes against humanity and war crimes in protracted trial, appellate, and re-trial proceedings before the ICTY. Mr Haradinaj was acquitted of all charges at the first and second trials.
Defence Counsel for former investigator of Charles Taylor (ex-President of Liberia) on charges of bribery before the SCSL. Mr. Taylor was acquitted of all counts.
Acting for Home Office in case concerning the deprivation of UK citizenship and statelessness.
Representing the AG in judicial review of the AG’s refusal to grant permission to prosecute Tony Blair for alleged war crimes in Iraq.
Acting for the Ministry of Defence in judicial review proceedings concerning allegations of torture and inhuman treatment in detention facilities in Iraq.
Representing private security officer injured in Iraq in a civil claim in which jurisdiction to proceed in the UK before UK courts and the applicable law, were central issues.
Counsel for the Foreign Office in proceedings concerning a claim for damages arising from an alleged unlawful extradition of a British national from the US to Hong Kong.
Acting for OFSTED in Care Standards Tribunal inquiry into allegations of child abuse and child protection issues.
Counsel advising in respect of investment treaty matters arising from banking crisis in the UK and abroad.
Represented military commander of Bosnian Army before ICTY on allegations of command responsibility for the killings committed by foreign ‘mujahedin’ fighters in central Bosnia during the armed conflict in Bosnia. Mr. Kubura was acquitted of all murder counts.
Represented the Government of Mauritius in various cases before the Privy Council, including Tyack v The State of Mauritius concerning the application of UK sentencing guidelines in Mauritius.
10th January 2019
Leading text on law and procedure before all international criminal courts.
31st January 2015
Leading text on law and procedure before all international criminal courts.
30th January 2015
Authored chapters on ‘Crimes Against Humanity’ and ‘Protection of National Security Information’
30th November 2014
Expert participant in international and comparative study by King’s College Department of War Studies. Co-sponsored by the Economic and Social Research Council and the Defence Science and Technology Laboratory.
1st January 2011
Senior Expert Consultant for OSCE War Crimes Justice Project in the former Yugoslavia which produced publication and training manual on International Criminal Law and domestic prosecutions of war crimes.
20th May 2019
Rodney Dixon QC, counsel for jailed Moroccan journalist Toufik Bouachrine, assisted by Rhys Davies, have submitted an urgent request to Dr. Agnes Callamard, the UN Special Rapporteur investigating the killing of Jamal Khashoggi to obtain and examine Mr. Bouachrine’s mobile phone.
Read more3rd May 2019
Rodney Dixon QC appeared this week before the ICC Appeals Chamber on behalf of the Government of the Comoros. The ICC Prosecutor had appealed against the Pre-Trial Chamber’s ruling in judicial review proceedings in favour of the Comoros that the Prosecutor had erred in her decision not to open an investigation into the case referred to the ICC by the Comoros.
Read more19th March 2019
Leading international justice consultancy, MH Group, is launching an initiative for the ICC Prosecutor to open an investigation into those most responsible for war crimes and crimes against humanity committed against Palestinian civilians in Gaza, and in the West Bank and East Jerusalem. MH Group has instructed Rodney Dixon QC to prepare legal submissions to the ICC Prosecutor and to act on its behalf as legal counsel.
Read more14th March 2019
Rodney Dixon QC and Aidan Ellis have been representing the Kipsigis and Talai peoples of Kericho and Bomet County, Kenya in proceedings before the Kenyan National Land Commission. The Commission has now released its findings. It determined that the Kipsigis and Talai peoples had been the victims of historical land injustices during the colonial period in Kenya and thereafter. The Commission made far reaching recommendations to the British Government, Kenyan Government and the multi-national tea companies that operate in the counties.
Read more7th March 2019
Rodney Dixon QC is making an application to the ICC Prosecutor to open an investigation into crimes against humanity of unlawful deportation from Syria to Jordan. The case is being brought on behalf of 28 victims who have been forced to flee over the border into Jordan and are living in refugee camps.
Read more18th January 2019
Rodney Dixon QC is the keynote speaker at Kingsley Napley International Criminal Law Conference today. Please see click here for further information.
22nd November 2018
Matthew Hedges, a British PhD student who has been sentenced to life in prison in the UAE for espionage.
Read more19th November 2018
Rodney Dixon QC acted for the Government of the Comoros before the ICC in a judicial review application of the Prosecutor’s decision not to open an investigation into the Israeli Defence Forces (IDF) operation against the Mavi Marmara on the high seas in the Mediterranean in May 2010 when the Gaza Flotilla was intercepted.
Read more14th November 2018
The Zimbabwe Commission of Inquiry into the post-election violence of 1 August 2018 continues its hearings this week in Harare. The Chief of the Zimbabwe Defence Forces as well as the Chief of Police and the Head of the Electoral Commission are being heard before the Commission.
Read more12th October 2018
Rodney Dixon QC assisted by Aidan Ellis have appeared before the Kenya National Land Commission in hearings held this week in Kericho County. Submissions were made on behalf of over 100,000 residents of the county who have submitted land claims to the Commission for restitution and compensation arising from the colonial period and following independence in Kenya.
Read more9th October 2018
Rodney Dixon QC was a speaker at an event held at the Carnegie Endowment for International Peace in Washington DC on the human rights situation in Saudi Arabia.
Read more20th September 2018
Rodney Dixon QC was sworn in yesterday as a Commissioner to sit on the Commission of Inquiry established by the President of Zimbabwe under the Commissions of Inquiry Act to inquire into the post election violence that occurred on 1 August 2018 following the recent elections in Zimbabwe.
Read more25th July 2018
Emily Wilsdon chaired a seminar at the House of Commons with leading experts and lawyers to consider the effect on the religious rights and freedoms of Qataris, in the context of the blockade of Qatar and access to the Hajj.
Read more2nd July 2018
Rodney Dixon QC participated in a high level expert panel in Washington DC on war crimes that have been committed in the 3 year war in Yemen and the potential mechanisms to facilitate accountability and victim reparations.
Read more12th June 2018
Rodney Dixon QC, Myles Grandison and Aidan Ellis will speak at a panel discussion to be held in Parliament and hosted by Andy Slaughter MP on the detention and treatment of opponents and human rights defenders in Saudi Arabia. The event will focus on available legal remedies.
Read more24th May 2018
Ben Emmerson QC and Rodney Dixon QC appeared on behalf of the Government of Georgia at the hearing in Strasbourg in which the final submissions were presented on Georgia’s application. Georgia alleges widespread and systematic violations of the European Convention on Human Rights arising from the conflict in August 2008 covering two regions in Georgia, Abkhazia and South Ossetia.
Read more13th April 2018
Rodney Dixon QC acts for the parents of a 19 year old US national, Furkan Dogan, who was shot and killed on board the Mavi Marmara ship that was sailing to Gaza in May 2010 to deliver humanitarian aid. It was intercepted in international waters by the Israeli Defence Force, who killed 10 passengers including Furkan and injured over 50 persons.
Read more9th April 2018
Rodney Dixon QC has been appointed as international counsel for a leading journalist in Morocco, Mr Taoufik Bouachrine, who has been charged with human trafficking, rape and sexual assault.
Read more1st February 2018
Rodney Dixon QC, assisted by Aidan Ellis, with Lord Ken Macdonald QC have published their report and legal opinion on the mass arrests and detentions that occurred last September in Saudi Arabia. The full report can be found here.
Read more21st September 2017
Rodney Dixon QC has addressed an event at the UN General Assembly in New York hosted by the Qatari Ambassador to the UN and the Attorney General of Qatar on the current air, land and sea blockade of Qatar imposed by Saudi Arabia, the UAE, Bahrain and Egypt.
Read more14th September 2017
Rodney Dixon QC is representing three prominent Qatari nationals who were unlawfully detained and tortured in the UAE between 2013 and 2015 by UAE security officials.
Read more10th August 2017
Rodney Dixon QC has been instructed as international counsel for the impeached President Park Geun-hye of South Korea, currently on trial in Seoul on eighteen charges of corruption, bribery and abuse of power.
Read more6th July 2017
Andrew Cayley CMG QC and Rodney Dixon QC have been in Lagos, Nigeria meeting with Nigerian military prosecutors and investigators in connection with national investigations into terrorism and allegations of war crimes arising from the conflict with Boko Haram in Nigeria. The meetings were organised under the auspices of the Wayamo Foundation, and addressed key aspects of international humanitarian and criminal law and best practices for the investigation and prosecution of international crimes.
Read more4th July 2017
Chambers congratulates Karim Khan QC on his election as the President of the International Criminal Court Bar Association.
Read more18th April 2017
The event has been organised by Dr Victor Kattan, Senior Research Fellow at NUS.
More information can be found here.
22nd November 2016
Andrew, Rodney and Emily will participate in a week of discussions with the Mexican Armed Forces on International Humanitarian Law and International Criminal Law, an event which has been organised by Foro de Justicia International AC and its chief executive Professor Dr. Mónica Rocha-Herrera.
29th July 2016
Rodney Dixon QC representing Mr Hasnat Karim and his family has filed an urgent complaint with the UN Working Group on Arbitrary Detention seeking the immediate release of Mr. Karim from detention in Bangladesh.
Read more11th July 2016
Rodney Dixon QC will examine two intra-Asian arbitration disputes, considering their similarities and differences, the realities of enforcement, and what these cases portend for the Permanent Court of Arbitration’s role in the resolution of disputes relating to the Asian region; and ask whether Asian courts and centres for arbitration too should have a greater place in such dispute settlement.
Read more
20th June 2016
Rodney Dixon QC with Aidan Ellis have been acting for Dr Mishana Hosseinioun who petitioned the African Commission and Court on behalf of Mr. Gaddafi.
Read more8th June 2016
Rodney Dixon QC being led by Ben Emmerson QC is appearing on behalf of the Government of Georgia in hearings before the Grand Chamber of the ECtHR in Strasbourg in the case being brought against the Russian Federation.
Read more4th May 2016
Rodney Dixon QC has at the invitation of the Institute for Judicial and Legal Studies, conducted workshops on the application of international law in domestic jurisdictions for the Judges of the Supreme Court and practitioners in Mauritius.
Read more8th March 2016
Today the Appeals Panel of the Special Tribunal of Lebanon (Hague) dismissed 22 prosecution grounds of appeal in upholding the acquittal of Al Jadeed television station (Beirut) on charges of contempt.
Read more12th January 2016
Passengers on a US ship file civil suit against State of Israel in the US District Court for the District of Columbia for damages sustained during attack on the high seas.
5th November 2015
UK police are investigating allegations of torture and crimes against humanity committed by Egyptian officials who are visiting London.
22nd October 2015
Former Israeli PM sued for damages in US Federal Court in California for killing of US national on the high seas.
28th July 2015
Abdullah Al-Senussi has been sentenced to death by a Libyan court while his international lawyers continue to call for him to be tried before the ICC in The Hague
25th July 2015
ICC Prosecutor ordered by the Pre-Trial Chamber to reconsider her decision not to open an investigation following judicial review application by the Government of the Comoros.
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