The Hague: The Hind Rajab Foundation (HRF) has submitted a 120-page Article 15 complaint to the International Criminal Court (ICC) in The Hague, naming 24 Israeli soldiers and commanders accused of involvement in the killing of six-year-old Palestinian child Hind Rajab, her family members, and two Palestinian paramedics in Gaza.
The complaint on Tuesday, October 21, follows the broadcast of Al Jazeera Arabic’s investigative documentary “Tip of the Iceberg,” which, in cooperation with HRF, exposed the Israeli military units allegedly responsible for the January 2024 attack in Gaza City.
Israeli commanders named in ICC filing
According to the Foundation, the Vampire Empire Company of the 52nd Armoured Battalion — operating under Israel’s 401st Armoured Brigade — carried out the assault that resulted in the deaths of Hind, six members of her family, and paramedics Yusuf al-Zeino and Ahmed al-Madhoun.
Three senior officers were publicly identified:
- Colonel Beni Aharon, Commander of the 401st Armoured Brigade;
- Lieutenant Colonel Daniel Ella, Commander of the 52nd Armoured Battalion
- Major Sean Glass, Commander of the Vampire Empire Company.
HRF said an additional 22 tank crew members were also involved in the attack and have been named confidentially in the ICC submission.
Digital and forensic evidence presented
The Foundation’s legal team said it has submitted digital, satellite, and forensic evidence confirming that Merkava IV tanks repeatedly fired on the black Kia Picanto where Hind and her family were trapped, and later targeted the ambulance sent to rescue them.
“The attacks were carried out with full awareness of the victims’ civilian and protected status, following prior coordination between the Palestinian Red Crescent and Israeli authorities,” HRF said in its statement.
The organisation concluded that the acts constitute war crimes, crimes against humanity, and genocide under Articles 6, 7, and 8 of the Rome Statute.
Global legal action for accountability
In addition to the ICC complaint, HRF has launched legal proceedings under universal jurisdiction and dual nationality jurisdiction in several countries. The first case has been filed in Argentina against tank crew member Itay Cukierkopf, while further complaints are being prepared in Europe, Latin America, and North America.
“This is not merely a legal case — it is a challenge to global impunity,” said Dyab Abou Jahjah, General Director of the Hind Rajab Foundation. “They thought Hind’s murder would go unpunished. We are proving them wrong. Twenty-four names are now before the ICC, and more will follow in national courts.”
Natacha Bracq, HRF’s head of litigation, said the filing establishes “a direct chain of command, operational control, and deliberate intent,” adding that the evidence meets “the legal thresholds for prosecution under international criminal law.”
Foundation urges ICC to act
HRF has urged the ICC Prosecutor to include Hind Rajab’s killing in the Situation in the State of Palestine and to expand investigations to cover the Vampire Empire Company, the 52nd Armoured Battalion, and the 401st Armoured Brigade. The Foundation also called for arrest warrants for all identified suspects.
On January 29, 2024, the car carrying Hind and her family was struck by Israeli tank fire in Tel al-Hawa. Six relatives were killed instantly. Hind, wounded and terrified, survived for hours, whispering to dispatchers from the Palestine Red Crescent Society (PRCS): “I’m so scared… please come.”
An ambulance was dispatched to rescue her but was also shelled and destroyed. Both medics inside were killed instantly. Ten days later, rescue workers discovered Hind’s body beside her cousin, Layan.
