The Defence therefore submits that in accordance with the above principles, it is necessary for the Chamber to ascertain firstly, whether the offence set out under article 8(2)(e)(vii) was sufficiently accessible to Thomas Lubanga Dyilo. Secondly, in defining the contours of the offence set out under article 8(2)(e)(vii), the Chamber should construe it strictly and precisely, in a manner which is consistent with the requirement that it must have been foreseeable to Thomas Lubanga Dyilo that the underlying conduct of the offence could have entailed individual criminal responsibility