In a regrettable decision on 16 June 2025, the majority of the ICC Pre-Trial Chamber found it lacked the power to make a finding on the Prosecution’s obligations under Article 15(3) of the Rome Statute in the case of Nigeria. This followed a complaint submitted by Amnesty International on 2 December 2024, on behalf of thousands of victims from the Jire Dole Networks in north-east Nigeria, where Boko Haram and the Nigerian army committed crimes under international law. The complaint argued that the Prosecutor had a duty to request the opening of an investigation after concluding in 2020 that there was a reasonable basis to proceed.