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The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine

Michelle Coleman Orcid Logo

Journal of Law, Religion and State, Volume: 13, Issue: 2/3, Pages: 222 - 252

Swansea University Author: Michelle Coleman Orcid Logo

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DOI (Published version): 10.5117/jlrs2025.2.3.004.cole

Abstract

International crimes have been alleged throughout the ongoing war in Ukraine with potential liability focused on political and military leaders and low-level combatants. One group that has thus far been overlooked for potential involvement in international crimes are religious leaders. There is evid...

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Published in: Journal of Law, Religion and State
ISSN: 2212-4810 2212-6465
Published: Amsterdam University Press 2025
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URI: https://cronfa.swan.ac.uk/Record/cronfa70246
first_indexed 2025-09-02T07:24:26Z
last_indexed 2026-04-22T07:24:40Z
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spelling 2026-04-21T11:16:58.5486726 v2 70246 2025-09-01 The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine 54f57826dde45d78478523c9c265a1ce 0000-0002-2615-1021 Michelle Coleman Michelle Coleman true false 2025-09-01 HRCL International crimes have been alleged throughout the ongoing war in Ukraine with potential liability focused on political and military leaders and low-level combatants. One group that has thus far been overlooked for potential involvement in international crimes are religious leaders. There is evidence that leaders of the Russian Orthodox Church (ROC), in particular, Patriarch Kirill, influence the Russian political and military leaders, the public, and believers. This influence could involve participation in international crimes. Not investigating or questioning this influence could allow impunity to be perpetuated. This article explores whether leaders of the ROC could be prosecuted for international crimes arising during the Russia-Ukraine war. Specifically focusing on ROC Patriarch Kirill, it discusses whether a prosecution is likely. The article is not meant to set forward a complete case against Kirill, rather, it is an important starting point to open the discussion, based on publicly available evidence. After highlighting Kirill’s participation in the war, the article discusses the potential courts which could consider such a case. Then, the possible crimes including aggression, genocide, war crimes, and crimes against humanity, followed by the potential modes are liability are assessed. Finally, the Media Case from the International Criminal Tribunal from Rwanda is used as an analogous case to examine whether Kirill could be prosecuted as a propagandist. The article concludes that there is not currently enough evidence to raise a prosecution, however if more evidence was discovered or Kirill’s actions and statements became more extreme, a prosecution could be possible. Journal Article Journal of Law, Religion and State 13 2/3 222 252 Amsterdam University Press 2212-4810 2212-6465 Russian Orthodox Church, ROC, Kirill, crimes against humanity, war crimes, aggression, genocide, international criminal law, International Criminal Court 1 12 2025 2025-12-01 10.5117/jlrs2025.2.3.004.cole COLLEGE NANME Hillary Rodham Clinton Law School COLLEGE CODE HRCL Swansea University Not Required 2026-04-21T11:16:58.5486726 2025-09-01T09:46:51.6716692 Faculty of Humanities and Social Sciences Hilary Rodham Clinton School of Law Michelle Coleman 0000-0002-2615-1021 1 70246__36540__c1a0f3281ec14a87b81db47dbec5bfb6.pdf 70246.VOR.pdf 2026-04-21T11:14:55.6240566 Output 371669 application/pdf Version of Record true © Michelle Coleman. This is an open access article distributed under the terms of the CC BY-NC 4.0 license. true eng http://creativecommons.org/licenses/by-nc/4.0
title The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
spellingShingle The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
Michelle Coleman
title_short The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
title_full The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
title_fullStr The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
title_full_unstemmed The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
title_sort The Russian Orthodox Church and International Crimes: Exploring the Potential for Religious Leadership Liability for Crimes Committed in the War in Ukraine
author_id_str_mv 54f57826dde45d78478523c9c265a1ce
author_id_fullname_str_mv 54f57826dde45d78478523c9c265a1ce_***_Michelle Coleman
author Michelle Coleman
author2 Michelle Coleman
format Journal article
container_title Journal of Law, Religion and State
container_volume 13
container_issue 2/3
container_start_page 222
publishDate 2025
institution Swansea University
issn 2212-4810
2212-6465
doi_str_mv 10.5117/jlrs2025.2.3.004.cole
publisher Amsterdam University Press
college_str Faculty of Humanities and Social Sciences
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hierarchy_top_id facultyofhumanitiesandsocialsciences
hierarchy_top_title Faculty of Humanities and Social Sciences
hierarchy_parent_id facultyofhumanitiesandsocialsciences
hierarchy_parent_title Faculty of Humanities and Social Sciences
department_str Hilary Rodham Clinton School of Law{{{_:::_}}}Faculty of Humanities and Social Sciences{{{_:::_}}}Hilary Rodham Clinton School of Law
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description International crimes have been alleged throughout the ongoing war in Ukraine with potential liability focused on political and military leaders and low-level combatants. One group that has thus far been overlooked for potential involvement in international crimes are religious leaders. There is evidence that leaders of the Russian Orthodox Church (ROC), in particular, Patriarch Kirill, influence the Russian political and military leaders, the public, and believers. This influence could involve participation in international crimes. Not investigating or questioning this influence could allow impunity to be perpetuated. This article explores whether leaders of the ROC could be prosecuted for international crimes arising during the Russia-Ukraine war. Specifically focusing on ROC Patriarch Kirill, it discusses whether a prosecution is likely. The article is not meant to set forward a complete case against Kirill, rather, it is an important starting point to open the discussion, based on publicly available evidence. After highlighting Kirill’s participation in the war, the article discusses the potential courts which could consider such a case. Then, the possible crimes including aggression, genocide, war crimes, and crimes against humanity, followed by the potential modes are liability are assessed. Finally, the Media Case from the International Criminal Tribunal from Rwanda is used as an analogous case to examine whether Kirill could be prosecuted as a propagandist. The article concludes that there is not currently enough evidence to raise a prosecution, however if more evidence was discovered or Kirill’s actions and statements became more extreme, a prosecution could be possible.
published_date 2025-12-01T08:24:40Z
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