Israeli military purchases, including attack dogs, are expected to weigh heavily when the Netherlands' court of appeal issues a ruling on Thursday over claims the Dutch state failed in its duty to prevent genocide in Gaza.
The state is accused of violating the 1948 Genocide Convention by continuing arms exports to Israel and failing to implement a 2024 advisory opinion of the International Court of Justice that dictates countries should stop trading with Israeli settlements in the occupied Palestinian territories.
There is plenty of evidence showing that dogs have also been used by the Israeli army to commit war crimes, said Lydia de Leeuw, strategic litigation head at Somo, the Amsterdam-based Centre for Research on Multinational Corporations, and one of the 10 NGOs that are part of the case.
"The Israeli army is using dogs to intimidate, attack and torture Palestinians in Gaza and the West Bank and in detention centres in Israel," Ms de Leeuw told The National. In July 2024, UN human rights chief Volker Turk cited "the release of dogs on detainees" in a damning report on ill-treatment and torture suffered by Palestinian detainees held arbitrarily by Israel.
That same month, a 24-year-old Palestinian man with Down syndrome, Muhammed Bahar, was mauled by an Israeli army dog in Gaza. Israeli soldiers prevented his family from helping him and left him to die after giving him minimal medical treatment.
Based on analysis of publicly available information, including statements by the Israeli military, "it is safe to say that the Netherlands is an important country supplying dogs to the Israeli army", Ms de Leeuw said.
An investigation published in April by Somo found that Dutch dog breeding company Four Winds K9 was offered legal support by Israeli authorities in 2016 after a Dutch human rights lawyer sued them over claims brought by a Palestinian boy, 16, from the West Bank.
Hamzeh Hashem had sustained severe injuries in 2014 from an Israeli army dog that was instructed by soldiers to bite him. Four Winds eventually agreed to pay him an undisclosed sum in 2018.
Leaked emails consulted by Somo showed that the Israeli Defence Ministry believed it was “very important to maintain the relationship” with Four Winds K9 because it had "been a major supplier of dogs to the Oketz unit for about 25 years".
Oketz is Israel’s specialist canine unit. It says that it only uses attack dogs in anti-terror operations despite claims by human rights organisations that they are also used to terrify civilians. There are also reports that the military deploys sniffer dogs trained to detect bombs in Gaza.
The export of dogs from the Netherlands to Israel has reportedly continued since the 2016 lawsuit. In January 2024, the Israeli Defence Ministry announced a major procurement operation with regular suppliers of trained dogs based in the Netherlands and Germany. The dogs are mostly Belgian shepherds of the Malinois breed – a common police dog.
Somo also found that 100 out of 110 veterinary certificates were issued to Four Winds K9 by the Netherlands Food and Consumer Product Safety Authority between October 2023 and February 2025 for dogs sold to the Israeli army.
Foreign policy above judicial scrutiny?
Another major question at the heart of the genocide case involving the state is whether foreign policy decisions are subject to judicial scrutiny. In December, the district court of The Hague that dismissed the case argued that it had to exercise restraint in its legal assessments of foreign policy decisions.
The court ruled that the state was fulfilling its obligations by reviewing its export licences on a case-by-case basis. It also deemed that a so-called discouragement policy on companies investing in the occupied territories was sufficient. The Netherlands has since said that it would work on legislation to implement the ICJ ban.
Plaintiffs hope that the court of appeal will clarify the implementation of the genocide convention in a national context. "What I expect is that the court of appeal will translate these big international legal obligations to what state practice should look like," Ms de Leeuw said.
Faced with similar questions, other states, such as the US, have stated that courts have no input at all on foreign policy decisions. If The Hague Court of Appeal comes to a similar conclusion, that would represent a "true crisis of the legal system", Ms de Leeuw said. "We have a serious problem if it is entirely left to an executive power to decide how to navigate something as vital as genocide prevention," she added.
Israel denies it has committed genocide in Gaza. Accusations of genocide have been issued by UN experts, international human rights experts, and increasingly, European politicians.
