The idea of complementarity is that both international and domestic tribunals should compensate for any deficiency inherent in either of them. Most scholars are divided as to the exact time the principle of complementarity began in international criminal law. Some naturally linked it with the 1998 Rome Statute 1 while others traced it to the 1994 International Law Commission Draft Statute for an International Criminal Court (ICC). 2 Some others also claimed that the principle is traceable to the Working Group of 1992 3 or the discussion that took place within the precinct of the 1991 Commission. 4 The farthest in time is the claim that the principle of complementarity evolved, starting from ‘World War I until 1998.’ 5 However, it can be argued that the principle of complementarity began from the trial of Peter von Hagenbach in 1474 (Breisach Trial).