Summers, M.A., &quot; The International Court of Justice &apos; s Decision in Congo v. Belgium: How Has It Affected the Development of a Principle of Universal Jurisdiction that Would Obligate All States to Prosecute War Criminals? &quot; , Boston University International Law Journal, vol. 21 (2003), pp. 63-100.
Summers, M.A., &quot; The International Court of Justice &apos; s Decision in Congo v. Belgium: How Has It Affected the Development of a Principle of Universal Jurisdiction that Would Obligate All States to Prosecute War Criminals? &quot; , Boston University International Law Journal, vol. 21 (2003), pp. 63-100.