The Supreme Court of the Seychelles, which is prosecuting cases of Somali pirates apprehended by various countries in the Indian Ocean, cited and quoted from a memo prepared by the Case Western Reserve University War Crimes Research Office in its path-breaking judgment in the case of The Republic v. Mohamed Abdi Jama & Six Others, CS No. 53, July 25, 2012, at paragraphs 49-50.

Drawing from the memo’s research about 19th-century slavery cases, the Supreme Court concluded that the Seychelles could exercise universal jurisdiction over a vessel and its crew found in possession of piratical equipment on the high seas under an expanded conception of attempt to commit piracy.