Since the entry into force of the CCAIL until January 3, 200g--more recent data is not available (122) the Federal Prosecutor has filed eighty-six "incidents to be observed" (Beobachtungsvorgange), (123) the majority of which is based on complaints or communications filed by victims or NGOs representing victims; a few have been filed de oficio based on information from generally accessible sources.
131) This was the first High Court decision on the application of the complicated regulation of CPC section 153f and, implicitly, also on the principle of universal jurisdiction contained in CCAIL section 1.
135 In fact, with this argumentation the criterion of the territorial link has been reintroduced through the backdoor, ignoring the clear wording of CCAIL section 1 and paragraph two of CPC section 153f which shall guide prosecutorial discretion.
The scarce practice since the entry into force of the CCAIL has led to considerable criticism, in particular from NGOs.
4), since this requirement serves to fulfill the prevention of impunity as the overall aim of the substantive universal jurisdiction principle provided for by CCAIL section 1.