As commander of the combined assault unit “Storm” and deputy commander of the airborne training battalion, he exercised direct command of assault units and provided special combat training to personnel for conducting active offensive operations. There are reasonable grounds to believe that the person was involved in organizing and personally directing local assault operations characterized by high intensity and indiscriminate use of fire, which led to the destruction of residential buildings and civilian infrastructure that were not military targets, as well as to the death of civilians.

These actions are part of the Russian Federation's aggressive war against Ukraine and at the same time contain signs of violations of the laws and customs of war. At the same time, the person did not exercise the right to refuse to carry out a clearly criminal order, the obligation not to carry out which is provided for by international law, thus becoming an accomplice to the crime.

There are reasonable grounds to suspect that other violations of the laws and customs of war, as provided for by international treaties, the binding nature of which has been approved by the Verkhovna Rada of Ukraine, were committed by a group of persons acting in collusion, i.e., in the commission of a criminal offense under Part 2 of Article 28 and Part 1 of Article 438 of the Criminal Code of Ukraine.

Translated with DeepL.com (free version)