The International Criminal Court prosecutor argued on Tuesday he had enough evidence for a further arrest warrant against Sudan's President Omar al-Beshir for genocide.
In a document submitted to the ICC appeals chamber, Luis Moreno-Ocampo urged the court to "determine that there are reasonable grounds to believe that President Al-Beshir is criminally responsible for the three counts of genocide".
Beshir already faces an ICC arrest warrant for war crimes and crimes against humanity, but the African Union on Friday said it would not cooperate with the warrant and again appealed to the United Nations to delay the case.
"The prosecution submitted detailed evidence on the mobilisation and use of the entire Sudanese state apparatus for the purpose of destroying a substantial part of the Fur, Masalit and Zaghawa ethnic groups in the entire region of Darfur during more than six years," Moreno-Ocampo said in the document.
He urged the appeals chamber to "correct the error" of omitting the genocide counts against Beshir and to remand the case back to the ICC's pre-trial chamber in The Hague.
Initial arrest warrant
The initial arrest warrant against Beshir for war crimes and crimes against humanity in the western Darfur region between 2003 and 2005 was issued on 4 March.
On that occasion the prosecutor implicated the Sudanese leader in the deaths of 35 000 people.
On Tuesday, the prosecutor detailed more evidence to "prove the genocidal intentions of President Omar al-Beshir."
Beshir has defied the existing arrest warrant by travelling to nations that are not signatories to the world's first permanent war crimes tribunal, before attending last week's AU summit in Libya.
Thirty African states have signed the Rome statutes creating the court, and have treaty obligations to arrest Beshir if he travels on their territory.
'New world terrorism'
But the AU last week backed Libyan leader and current AU chief Moamer Kadhafi, who said the ICC represented a "new world terrorism". He was supported by many countries who felt the court was unfairly targeting Africans.
The United Nations says up to 300 000 people have died and 2.7 million have fled their homes since ethnic minority rebels in Darfur rose up against the Arab-dominated regime in Khartoum in February 2003.
Sudan's government says 10 000 have been killed.
The AU has called for the UN Security Council to implement a one-year delay to the indictment. It has argued that a warrant against Beshir would disrupt international efforts to bring peace to Darfur.
The UN Security Council can ask the court, via a resolution, to suspend investigations or prosecutions for 12 months, under the Rome Statute.
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