International Criminal Court--Appeals Chamber--power of trial chamber to subpoena witnesses--duties of states parties to enforce subpoena and to compel attendance of witnesses--implied powers.

The article looks at the decision of the Appeals Chamber of the International Criminal Court (ICC) in the case Prosecutor v. Ruto on the power of trial chamber to subpoena witnesses. It mentions that the duties of states parties to enforce subpoena and to compel attendance of witnesses with the implied powers for testifying the witnesses of the charges of crimes against humanity under the principles of customary international criminal procedural law and rule of good faith.