While these countries referred themselves, they did under enormous pressure from the ICC. The Prosecutors chose to ‘follow closely’ African cases to the exclusion of others and then actively invited these countries to refer themselves, under threat of seeking prosecutions on their own if the country did not comply [1] . Self-referral under pressure does not show that the ICC is not biased against Africa rather it shows either that the ICC has been more interested in Africa than elsewhere, or that it has put more pressure on African states to self-refer.  [1] African Business