On June 26, 2026, the Democratic Republic of the Congo (DRC) filed a new case against Rwanda before the International Court of Justice (ICJ). Although not directly applicable to the DRC Application to the ICJ, that jurisprudence is nonetheless instructive here. Proxy Occupation and the IHL DebateAt the same time, the Application cannot be understood without the IHL debate on proxy occupation. “Occupation” Without Pleading OccupationHowever, the DRC Application takes this debate in a new direction. It shows that the factual architecture of proxy occupation may be used even where occupation itself is not formally pleaded.