A/HRC/8/14* page 11 jurisprudence, further clarified the interpretation of certain key notions of the Genocide Convention. This was the first case at the ICJ in which a State (Bosnia and Herzegovina) brought proceedings against another (Serbia and Montenegro) for the commission of genocide. 22. In its decision, the ICJ recalled, inter alia, that the commission of genocide requires a dolus specialis, or specific intent, that differentiates it from other crimes such as crimes against humanity.28 This argument is in line with a similar approach proposed by the ICTY argument in the Kupreskic et al. case.29 23. Further, following the ICTY’s reasoning in Stakic, the ICJ concluded that, in relationship to the genocide, the target group must be defined positively according to specific distinguishing well-established characteristics. 24. The Court also referred to the notion of ethnic cleansing, which it defined as “rendering an area ethnically homogeneous by using force or intimidation to remove persons of given groups from the area”.30 The Court indicated that ethnic cleansing can be a form of genocide only insofar as it falls within one of the categories of acts of genocide. Acts of ethnic cleansing would also need to fulfil the requirement of specific intent (dolus specialis) of genocide to be considered as such. The Court further indicated its view that “the term ‘ethnic cleansing’ has no legal significance of its own”.31 This conclusion clarifies the meaning of the term ethnic cleansing and its subordination to genocide, crimes against humanity and war crimes. 4. International Criminal Court 25. Certain developments at the International Criminal Court (ICC) have also contributed to the process of enforcement of international humanitarian law and human rights law, with the aim of combating impunity and ensuring accountability. In October 2005, the Office of the Prosecutor unsealed five arrest warrants in the context of its investigation of alleged crimes committed in Uganda against five of the most senior commanders of the Lord’s Resistance Army (LRA), charging them with crimes against humanity and war crimes (including enslavement and murder). 26. The Office of the Prosecutor also issued an arrest warrant on 10 February 2006 against Thomas Lubanga Dyilo, alleged leader of the Union des patriotes congolais, a non-State armed group operating in the Democratic Republic of the Congo. He is charged with the war crimes of 28 Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and Herzegovina v. Serbia and Montenegro), decision of 26 February 2007, paras. 187-188. 29 See IT-95-16-T. 30 Case Concerning the Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and Herzegovina v. Serbia and Montenegro), op. cit., para. 190. 31 Ibid.