Intentionally using starvation of civilians as a method of warfare The crime of intentionally using starvation of civilians as a method of warfare by depriving them of objects indispensable to their survival could potentially be relevant to environmental harm. It is designed to protect the civilian population during armed conflict by ensuring that 411 Situation in Darfur, The Sudan, Case No.ICC-02/05, Summary of Prosecution’s Application under Article 58, 14 July 2008, pp.5-7. 412 Rome Statute, article 8(2)(b)(ii). 413 In the Court’s first trial, Xxxxxxx, the Pre-Trial Judge classified the conflict as international, only for the Trial Chamber, to classify it as non-international, as was upheld on appeal. 414 See, e.g., Bemba article 74 Decision, para.152.
