The word “genocide” is not used lightly when it is invoked in the context of proceedings before international courts and tribunals. Responsibility for genocide, be it individual criminal responsibility or state responsibility, is notoriously difficult to prove as the genocidal intent of perpetrators upon which both forms of responsibility are predicated, tends to often be somewhat elusive. When Ukraine initiated a lawsuit against the Russian Federation (Russia) before the International Court of Justice (ICJ) merely two days after Russia's invasion of Ukraine, it was initially assumed that Ukraine accused Russia of engaging in genocide against the Ukrainian people. However, in an unexpected twist, Ukraine sought for Russia to be held accountable for violating the terms of the Convention on the Prevention and Punishment of the Crime of Genocide (Genocide Convention) by using the purported “genocide in Donbas” as the pretext for launching a full-scale war against Ukraine disguised as a “special military operation.”1 In other words, Ukraine claimed that Russia breached its obligation to prevent and punish genocide by advancing a false claim of genocide in order to justify its aggression against Ukraine.