Under International criminal law, prosecutions can also be situated at the international level through the use of ad hoc tribunals, hybrid courts, and the International Criminal Court (the ICC). The ICC, because of the principle of complementarity, is a court of last resort for countries that are unable or unwilling to fulfill their obligation to investigate and address legacies of massive human rights violations within their jurisdiction. The Court has jurisdiction over individuals responsible for genocide, war crimes and crimes against humanity committed since July 1, 200224, and is one of the most powerful human rights courts created to deter perpetrators of human rights violations, particularly those who benefit from the laxity of or manipulate legal systems in their own countries, to avoid prosecution. Since inception the ICC has indicted individuals from Uganda, DRC, Central African Republic, Sudan and Kenya and is also investigating cases from Libya, Cote d‟Ivoire and Mali (Reeler & Mue. 2004). Zimbabwe has signed but not ratified this statute.25 There are three ways in which a situation can be referred to the ICC:  A state party to the Rome Statute may refer its own situation to the ICC, as Uganda, the Democratic Republic of the Congo (DRC), and the Central African Republic (CAR) and Mali have done.  The UN Security Council may refer a case to the ICC, as it did in the case of Darfur, Sudan and Libya. With Sudan for instance, the legality of the referral has been challenged, as Sudan is not party to the ICC‟s Rome Statute.  The Office of the Prosecutor may open a case, as it did in Kenya, although the prosecutor is required to obtain authorization from the court‟s Pre-Trial Chamber before commencing investigations and must be able to show that he or she has sufficient grounds to pursue such investigations. Currently all of the cases that the ICC is investigating and prosecuting concern crimes allegedly committed in African countries. This has raised questions as to whether this is an example of the selectivity of international criminal law (Report of the AU Panel of the Wise. 2013). There are currently three cases relating to Côte d‟Ivoire before the ICC, with two people in detention awaiting trial: former President Laurent Gbagbo and former Youth Minister Charles Blé-Goudé. They were both transferred to the Court by Côte d‟Ivoire. On November 30, 2011, the former president, Gbagbo, was transferred to the ICC where he was charged with four crimes against humanity (murder, rape, other inhumane acts – attempted murder, and persecution) in connection with post-election violence in Côte d‟Ivoire in 2010 and 2011. In 2012, another case was brought to the ICC against Simone Gbagbo wife of former President Laurent Gbagbo for alleged crimes against humanity committed in the context of post-electoral violence between 16 December 2010 and 12 April 2011. 24 25 The ICC was established in 2002 by the Rome Statute Here it should be noted that the 2013 Constitution in Zimbabwe requires the domestication of all international treaties and covenants 31