One day after Al Jazeera Arabic aired a documentary revealing new details about the killing of six-year-old Hind Rajab in Gaza, the Hind Rajab Foundation (HRF) filed a 120-page legal submission to the International Criminal Court (ICC), naming 24 Israeli soldiers and commanders allegedly responsible for the deaths of Hind, her family, and rescuers.
The Article 15 communication, submitted on Tuesday, accuses members of Israel’s 401st Armoured Brigade, specifically the Vampire Empire Company of the 52nd Armoured Battalion, of deliberately targeting civilians in Gaza City on January 29, 2024.
The documentary, Ma Khafiya Aatham (Tip of the Iceberg), disclosed previously unknown details about the killing of the Rajab family and others in the final days of the conflict.
According to HRF, the attack killed Hind Rajab, six members of her family, and two Palestinian Red Crescent paramedics, Yusuf al-Zeino and Ahmed al-Madhoun, who were attempting to rescue her. The foundation said its submission includes digital, satellite, and forensic evidence showing that Israeli Merkava IV tanks repeatedly fired on the family’s black Kia Picanto and later struck the ambulance sent to assist them.
The filing identifies senior officers, including Col. Beni Aharon, commander of the 401st Armoured Brigade; Lt. Col. Daniel Ella, commander of the 52nd Armoured Battalion; and Maj. Sean Glass, commander of the Vampire Empire Company. The names of 22 other tank crew members have been submitted confidentially to the ICC and will be revealed progressively as national-level complaints are lodged in other jurisdictions.
“The attacks were carried out with full knowledge of the victims’ civilian and protected status,” the foundation said. “These acts amount to war crimes, crimes against humanity, and genocide under the Rome Statute.”
HRF said its legal team is pursuing parallel prosecutions under universal jurisdiction and dual nationality laws, targeting alleged perpetrators who hold foreign citizenships in addition to Israeli nationality. A first case has already been filed in Argentina against one of the named soldiers, Itay Cukierkopf, with additional cases being prepared in Europe, Latin America, and North America.
“This is not only a legal act — it’s a revolt against the global order of impunity,” said Dyab Abou Jahjah, HRF’s general director. “They believed Hind’s murder would be without accountability; we are proving them wrong, step by step.”
Natacha Bracq, HRF’s head of litigation, said the filing establishes “a direct chain of command, operational control, and deliberate intent,” adding that the evidence meets “the legal thresholds for prosecution under international criminal law.”
The foundation called on the ICC prosecutor’s office to incorporate the killings into its ongoing investigation into the Situation in the State of Palestine and to issue arrest warrants for the 24 individuals named.