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Ilias Bantekas

. Dutch courts utilised law that stood in the middle of the two categories previously enumerated. The Dutch metropolis applied the common Dutch penal law in addition to a number of decrees enacted by The Netherlands Government between 1943 and 1947. 187 On the other hand, the territories belonging to The Netherlands East Indies were regulated by several decrees enacted in 1946 by the Lieutenant Governor

in Principles of direct and superior responsibility in international humanitarian law