A recent Brussels Court of Appeal judgment could be significant for the domestic enforcement of international prevention obligations.

The Court found, prima facie, that Belgium had failed to immediately take all measures reasonably within its power in response to known risks of genocide and serious IHL violations in Gaza.

Notably, it relied on Common Article 1 of the Geneva Conventions to support positive duties of prevention by third States. https://www.ejiltalk.org/domestic-courts-and-the-states-obligation-to-prevent-genocide-and-serious-violations-of-ihl-the-brussels-court-of-appeals-interlocutory-judgment-of-16-march-2026/