The author examines extreme forms of domestic violence against women and proposes international law as a supplement to domestic law in the area of domestic violence. She begins by discussing gaps and weaknesses in domestic law in the protection of victims and persecution of perpetrators of domestic violence. Here, she conceptualizes extreme forms of domestic violence as private torture, which she argues falls under the jurisdiction of international law as well as domestic violence law. In the second half of the article, the author discusses international law as a supplement to domestic law.