entity. In general, the prosecuting state should not have any territorial, personal, national interest, or link to the crime in question when it was committed. (Langer. 2011). Advocates for universal jurisdiction argue that it is fundamental to achieving the following:  bringing justice to victims;  deterring state or quasi state officials from committing international crimes;  sending a powerful signal to potential human rights abusers that they cannot commit crimes with impunity and then spend their remaining years living comfortably in another country ensuring that other countries do not become safe havens for war criminals;  and, establishing a minimum rule of law by substantially closing the impunity gap for crimes against humanity (Human Rights Watch. 2014) On the other hand, critics of universal jurisdiction assert that it is an unnecessary interference with internal solutions to mass atrocities and a disruption of international relations (Coombes. 2011). It is often inordinately expensive as well. Some authoritarian leaders were tried for crimes against humanity in foreign countries. These criminal prosecutions were always carried out during the post-transition period and were meant to deal with gross human rights violations perpetrated during the pre-transition period so as to ensure deterrence of similar crimes in the future. The following are some cases that were prosecuted in other States.  In 2011, two Algerian refugees residing in Switzerland brought a case against former Algerian Defence Minister Khaled Nezzar for war crimes committed during the Algerian internal armed conflict (1992 – 1999)23. The former Defence Minister was accused of enforced disappearances, extrajudicial executions and acts of torture committed during the Algerian civil war. In a landmark ruling in 2012, the Swiss Federal Criminal Court ruled that the Minister Khaled Nezzar was not entitled to immunity before the Swiss courts after he had been arrested in Switzerland in 2011 (Giustiniani. 2013). Nezzar was arguing that he was entitled to jurisdictional immunity for crimes committed during the period he was in office (1992 – 1994) (Maroonian, 2015).  In July 2004, Jean Francois Ndengue, the head of the Congolese Police in 1999, was indicted in France for torture, forced disappearances and for crimes against humanity, perpetrated against Congolese nationals in the case known as the “Disappeared of the Beach” (Refugee Rights News. 2009). According to the Transitional Data Base Project, in 2004, a case was brought before the Denmark courts of a Ugandan refugee living in Denmark for crimes committed in Uganda in 1995. 23 The Algerian civil war began in 1992 when the Algerian military orchestrated a coup d'état to prevent political party, the Islamic Salvation Front (FIS) from winning the country's first democratic elections. The official estimate is that 200,000 Algerians were killed and approximately 15,000 forcibly disappeared. https:// http://faculty.virginia.edu/j.sw/uploads/research/Schulhofer-Wohl%202007%20Algeria.pdf 30