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AMICUS the International Criminal Court
I. Introduction
1. On 14 June 2018, Pre-Trial Chamber I (the “Chamber”) of the International Criminal
Court (the “Court”), granted the Bangladeshi Non-Governmental Representatives
(“BNGR”) leave to submit amicus curiae observations on the “Prosecution’s Request
for a Ruling on Jurisdiction under Article 19(3) of the Statute” (the “Request”).1
2. BNGR are an informal group of leading Bangladeshi civil society organisations,
humanitarian agencies, eminent jurists, human rights advocates and respected
scholars who have worked extensively with the Rohingya people allegedly
deported from Myanmar into Bangladesh and on issues related to their deportation.
A full list of all BNGR members is attached at Annex A. BNGR are assisted in this
submission by international lawyers, including barristers from Red Lion Chambers,
London, and a team of Bangladeshi researchers, including from among BNGR
members, a list of whom is attached at Annex B.
3. BNGR files this amicus curiae brief on three areas of its expertise as per its request
for leave: i) the circumstances surrounding the presence of members of the
Rohingya people from Myanmar on the territory of Bangladesh; ii) the crimes, in
addition to deportation, that commenced in Myanmar but were completed in
Bangladesh that the Chamber may exercise territorial jurisdiction over; and iii) an
overview of Bangladeshi law on territorial jurisdiction over cross-border crimes.
