WAR CRIMES AND CRIMES AGAINST HUMANITY COMPLAINT AGAINST UKRAINE

Dear Ladies and Gentlemen!

We, the citizens living in Donbass region, Ukraine, hereby are bringing a complaint requesting a war crimes indictment against high-ranking Ukrainian officials, and other military and government personnel for the use of military forces and heavy armament which are used for extrajudicial and illegal purposes, causing the deaths of hundreds of innocent civilians and wantonly destroying cities, towns, villages in Donbass not warranted by military necessity.

As the representative of the people of Donbass region - the carrier of the Supreme power of Ukraine - we are compelled to send this petition to you to attract the attention of international organizations to the crying crimes by the Ukrainian government. People of Donbass humbly ask you to take any action or campaign possible against these war crimes for an immediate cessation of hostilities by Ukrainian government. We need your humanitarian and legal assistance urgently, as Kiev continues its full scale punitive operation with heavy and indiscriminate shelling of residential areas using both artillery and aviation.

We appeal to all Ukrainian government officials, military and civilian, and to all public officials, to do as required by the International Geneva Conventions, and by Conscience, to refuse to participate in crimes against Donbass people, to denounce them, and to resist them nonviolently.

We demand an open international investigation of all military crimes committed by Ukraine!

Please find below the criminal complaint against Ukraine.

We look forward to hearing from you soon.

Yours faithfully,

 Nikitin Igor

WAR CRIMES AND CRIMES AGAINST HUMANITY COMPLAINT

AGAINST UKRAINE

People of Donbass look into the responsibility of high-ranking Ukrainian officials for authorizing war crimes and crimes against humanity in Donbass in the context of the so-called `anti – terrorist operation’ launched by Ukrainian interim government on 15 April, 2014.

Complaint’s Allegations:

WE, THE PEOPLE OF DONBASS, CHARGE THE UKRAINIAN INTERIM PRESIDENT, TURCHINOV, DIRECTOR OF THE SECURITY SERVICE OF UKRAINE, NALIVAICHENKO, MINISTER OF INTERIORS OF UKRAINE, AVAKOV, AND ALL THOSE PLANNING THE “ANTI-TERRORIST OPERATION”, THOSE USING MILITARY HEAVY ARMAMENT, AND THE FULL MILITARY CHAIN OF COMMAND WITH CRIMES AGAINST PEACE & CRIMES AGAINST HUMANITY, WITH VIOLATIONS OF INTERNATIONAL GENEVA CONVENTIONS, EXTRAJUDICIAL KILLINGS, AND KILLING OF INNOCENT CIVILIANS.

From Turchinov, Nalivaichenko on down, the political and military leaders in Ukrainian interim government in charge of ordering, allowing and implementing abusive and illegal use of military forces and military heavy armament in the context of the “anti – terrorist operation” since April 15, 2014, must be investigated and held accountable. Ukrainian military and government high-ranking officials have committed war crimes against civilians in Donetsk and Lugansk oblasts, so-called Donbass region.

The defendants ordered war crimes, aided or abetted war crimes, or failed, as civilian superiors or military commanders, to prevent their commission by subordinates, or to punish their subordinates, actions that are explicitly prohibited by International Humanitarian Law.

Military heavy armament are being used by Ukrainian military not only in combat situations for the purpose of “anti-terrorist operations” but also for killings of civilians far removed from military action.

Extra judicial killings, such as those the Ukraine carries out by military hardware and machines are an intentional, premeditated, and deliberate use of lethal force to commit murder in violation of International Law.

The Military attacks supported, ordered, and executed by the Ukrainian government are a deliberate illegal use of force against civilians, and as such are a felonious violation of International Geneva Convention.

It is a matter of public record that the Ukrainian military forces are applying heavy armaments widely, including armored vehicles, artillery and aviation in several cities of Donbass which has nearly always resulted in the deaths of many civilians and destruction of towns, villiges and infrastructure of Donbass region.

The Ukrainian military and other pro-government armed groups committed the following list of crimes that legally constitute war crime and/or crimes against humanity, in blatant violation of the provisions of the 1949 Geneva Conventions, the 1984 Convention Against Torture and the 1977 International Covenant on Civil and Political Rights, The Rome Statute of the International Criminal Court – to all of which the Ukraine is a party. Under international humanitarian treaty and customary law, and as re-stated in Ukrainian law, these acts constitute war crimes and crimes against humanity.

LIST OF CRIMES

 Armed conflict - Anti-Terrorist Operation in Donbas, Ukraine, April - July 2014

 Perpetrator – Ukrainian interim government

 (1) Heavy and indiscriminate shelling of Slavyansk, Konstantinovka and Kramatorsk
 War crimes, crimes against humanity (mass murder of civilians and destruction of property)
 - Ukrainian Army engaged in mass atrocities against the civilian population of Donbass and looting and destruction of gaz stations, churches, hospitals, secondary school, civilian property, in order to flush out the Self-Defence forces of Donbass, starting from April 15 until now. In addition, Ukraine started the hostilities without explicit warning, and without giving a humanitarian corridors for civilians to leave the area. Hundreds of civilian, including at least 19 children, were killed or badly injured as a result.

(2) Complete destruction of village Semenovka, suburb of Slavyansk
 War crimes, crimes against humanity (mass murder of civilians and destruction of property)
 - Ukrainian Army by use of heavy armaments, including armored vehicles, artillery and aviation, in April and May, 2014 completely obliterated village Semenovka, the suburb of Slavyansk,.

(3) Massive airstrikes and destruction of Donetsk Airport 
 War crimes, crimes against humanity (killings of civilians and destruction of Donetsk infrastructure)
 - On 27 May, 2014 Ukrainian Army applied heavy armaments, including artillery and aviation directly at the location of Donetsk International Airport which is the densely populated residential place. At the same time Ukrainian military snipers fired at residential buildings near the airport. Those acts resulted in the deaths of more than 20 civilians and destruction of city and airport infrastructure.

(4) Incidents
 War crimes (murder of wounded self-defence fighters in ambulance lorry)
 - On 27 May 2014, a Ukrainian military forces attacked the ambulance lorry nearby of Donetsk airport and killed at least 20 wounded persons from the Donetsk airport. 
 - The same day was attacked ambulance that carried a wounded persons from Donetsk airport building.

(5) Missile strike on the center of Lugansk
 War crimes, crimes against humanity (mass murder of civilians)

(6) Use of white phosphorus munition 
Starting from 12 June Ukrainian military has been using white phosphorus munition during shelling of Semenovka and Slovyansk.

(7)Use of chemical weapons 
On 28-30 June 2014, a Ukrainian military forces launched gas artillery shells against self-defences forces 

.. and many others