JEAIL > Volume 10(1); 2017 > > East Asian Observer
Research Paper
Published online: May 30, 2017

Han Kim and North Korean Accountability for Torture and Unlawful Killing

Andrew Wolman
Hankuk University of Foreign Studies, 270 Imun-Dong, Dongdaemun-gu, Globeedorm, #A806, Seoul 02450 Korea.
Corresponding Author:

ⓒ Copyright YIJUN Institute of International Law
This is an Open Access article distributed under the terms of the Creative Commons Attribution Non-Commercial License ( which permits unrestricted non- commercial use, distribution, and reproduction in any medium, provided the original work is properly cited.


This note assesses the implications of the D.C. Circuit Court case of Han Kim v. Democratic People's Republic of Korea, in which the court found the North Korean state responsible for the torture and unlawful killing of Kim Dong Shik, a South Korean missionary who was abducted by the North Korean government while in China. In particular, this note shows how the judgment breaks new ground by holding a state responsible for torture and unlawful killing based solely on general evidence of that country's human rights practices, without additional information about the fate of the victim himself. This note also discusses this case's implications for the plaintiffs themselves, and for other victims of North Korean human rights abuses.

Keywords : Han Kim, North Korea, Accountability, Torture, Unlawful Killing

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