In 2003, women and girls in the village of
Bogoro in the Democratic Republic of Congo
were sexually enslaved. Leader Germain
Katanga was brought before the
International Criminal Court (ICC0 on a
number of charges. Even though there was
sufficient evidence, forced marriage was
not charged due to lack of international
jurisprudence and lack of recognition of
forced marriage as a crime against
humanity. This article examines the
history of international prosecution of
sexually-based crimes and discusses the
precedents set by the International