National Implementation of IHL
Hass & Priebke case, Military Appeals Court, 7 March 1998
Military Appeals Court
(last accessed on 30.08.2013)

In its judgement in the Hass and Priebke casein 1997 concerning the Ardeatine Caves massacre during the Second World War, Italy’s Military Tribunal of Rome, with respect to the conditions required for a reprisal, stated: “Also such a reaction must be proportionate to the damage suffered.” It found unacceptable the disproportion between the deaths of 33 German soldiers and the execution of 335 persons. In its relevant parts, the decision was confirmed by the Military Appeals Court.

File TypeSizeFile Name
application/pdf 360 KB Hass and Priebke - Decision of 07-03-98.pdf