In the Ahmed case in 1996, the Administrative Law Division of the Council of State of the Netherlands ruled that a Somali national could not be granted the protection of the 1951 Refugee Convention since he was suspected of having been involved in committing crimes against humanity and, being a high-ranking soldier and acting on behalf of the Somali Government, was thus guilty of acts contrary to common Article 3 of the 1949 Geneva Conventions. 

The Report on the Practice of the Netherlands, with respect to the 1984 Convention against Torture and its ratification procedure in the Netherlands, and referring to decisions of the Dutch Administrative Law Division of the Council of State to refuse protection under the 1951 Refugee Convention to persons suspected of having been involved in committing crimes against humanity and crimes in violation of common Article 3 of the 1949 Geneva Conventions, states: “The Dutch government completely complied with the treaty requirements.”