In its decision on the confirmation of charges against germain katanga and mathieu ngudjolo chui,104 the international criminal court (icc) pre-trial chamber i addresses a substantial number of difficult legal issues, some of them for the first time. one of the most interesting passages of the decision deals with the question of perpetration through another person under article 25(3)(a) icc statute. . the accused germain katanga and mathieu ngudjolo chui were leaders of military groups