# Example — verifying an STL citation end-to-end

A worked example for the 2011 Interlocutory Decision (the most-cited and most-contested STL document). Illustrative, not a script.

## The request

The user is writing on the doctrine of terrorism in international criminal law and asks:

> "Can you give me the citation for the STL's holding that terrorism in peacetime is a crime under customary international law? With the precise wording and the paragraph?"

## Step 0 — Identify the document

The proposition rests on the **Interlocutory Decision on the Applicable Law** issued by the Appeals Chamber of the STL on **16 February 2011** in case STL-11-01. This is the foundational decision on this point and is universally cited as the source.

Critical context: the customary-international-law finding is **heavily contested** in subsequent scholarship and has not been adopted by other international tribunals. If the user is writing a brief, this matters; if the user is writing an article, the contested status should be flagged.

## Step 1 — Plan the citation

One quoted passage; one citation needed.

Form:
> *Prosecutor v. Ayyash et al.*, Case No. STL-11-01/I/AC/R176bis, Interlocutory Decision on the Applicable Law: Terrorism, Conspiracy, Homicide, Perpetration, Cumulative Charging (Appeals Chamber), 16 February 2011, para. [N].

## Step 2 — Verify

1. **stl-tsl.org.** Navigate to the principal case file (STL-11-01) and locate the Interlocutory Decision under "Decisions". The decision is one of the most prominent STL documents and is featured. **Existence verified.**
2. **legal-tools.org.** Cross-check. The decision is mirrored. **Stable PDF available.**
3. Open the decision and locate the customary international law finding. The Appeals Chamber's principal articulation of the definition appears in the section titled "The Definition of Terrorism under Customary International Law" (broadly paras 83-113 in the 2011 decision, though the exact paragraph for any specific quotation must be verified against the text).
4. Identify the specific quotation. **Paragraph verified.**

## Step 3 — Draft

> The STL Appeals Chamber held that "an emerging definition of transnational terrorism in customary international law" had crystallised, comprising three elements: (i) the perpetration of a criminal act (such as murder, kidnapping, hostage-taking, arson); (ii) the intent to spread fear or to coerce a national or international authority; (iii) a transnational element. *Prosecutor v. Ayyash et al.*, Case No. STL-11-01/I/AC/R176bis, Interlocutory Decision on the Applicable Law: Terrorism, Conspiracy, Homicide, Perpetration, Cumulative Charging (Appeals Chamber), 16 February 2011, para. [N — verify exact paragraph]. The customary international law finding has been heavily contested in scholarship (Saul, Milanović, Ambos, Kress) and has not been adopted by subsequent international tribunals.

If the exact paragraph and exact wording have not been pinned down in the session:

> The STL Appeals Chamber held in the Interlocutory Decision on the Applicable Law that an "emerging" definition of transnational terrorism had crystallised in customary international law, with three elements (criminal act, intent to spread fear or coerce authority, transnational element). *Prosecutor v. Ayyash et al.*, Case No. STL-11-01/I/AC/R176bis, Interlocutory Decision on the Applicable Law (Appeals Chamber), 16 February 2011 (the exact paragraph and the specific wording have not been confirmed in this session; the substance is from the section headed "The Definition of Terrorism under Customary International Law"). This finding is contested and has not been adopted by subsequent international tribunals.

## Step 4 — Self-audit

- STL Appeals Chamber, 16 February 2011 — correct.
- Case number STL-11-01/I/AC/R176bis — correct (R176bis is the sui generis procedure).
- Contested status flagged — correct (the user is writing a doctrinal article; the contested status matters).
- Verification level disclosed in the alternative form — correct.

## The lesson

Two STL-specific pitfalls were avoided:
1. The decision could have been confused with a Trial Chamber decision — it is an Appeals Chamber decision, on a sui generis procedure under Rule 176 bis.
2. The customary international law finding could have been presented as universally accepted — it is not, and an honest output flags the contested status.