The ground of ‘crime against peace’ is not found to be of particular relevance in the cases of applicants from Nigeria.

In December 2020 the Office of the Prosecutor of the International Criminal Court concluded that there is reasonable basis to believe that war crimes and crimes against humanity had been committed by Boko Haram since July 2009 and by the Nigerian military since the beginning of the non-international armed conflict with Boko Haram since June 2011.The Prosecutor of the ICC has also examined alleged crimes falling outside of the context of this conflict.

Τhe violent clashes between herders and farmers and/or between communal militias have increased over the years, resulting in a growing number of deaths on both sides and serious human rights violations, including rape, abduction and attacks leading to the destruction of entire villages. Taking into account the evolution of the conflict, crimes committed in this context could also give rise to considerations under Article 12(2)(a) QD/Article 17(1)(a) QD as ‘crimes against humanity’.