Briefly Noted

On May 5, 2025, the International Court of Justice issued a provisional measures order in response to a request filed in March 2025 by Sudan against the United Arab Emirates (UAE) alleging violations of the Genocide Convention by a paramilitary organization known as the “Rapid Support Forces” in relation to the Masalit group in Sudan and specifically in West Darfur. The UAE opposed the Court’s jurisdiction. The Court initially expressed its “deep concern about the unfolding human tragedy in Sudan.” Sudan came before the Court on the basis of Article IX of the Genocide Convention, 1 given that both states are party to the Convention. However, the UAE made a reservation with regard to that Article, and no state (including Sudan) objected to its reservation. Sudan argued that the reservation is “vague and non-specific” and that no other such reservation has been made by any other party with regard to the Convention. It also argued that its failure to object to the reservation at the time was immaterial. The Court disagreed with Sudan and found that the absence of more specific language in the reservation “does not result in any uncertainty as to the effects of that reservation” because of the reference in the reservation to the “interpretation, application and fulfilment of the Genocide Convention.” Therefore, the Court held that Article IX is not a valid basis for the exercise of the Court’s jurisdiction and ordered the case removed from the general list.