Luo Gan
In some instances, courts have refused to adjudicate Falun Gong cases against Chinese officials on the grounds of sovereign immunity. In November 2009, however, Jiang Zemin and Luo Gan were indicted by a Spanish court on charges of genocide and crimes against humanity for their involvement in the persecution of Falun Gong. One month later, an Argentine judge concluded that Jiang and Luo had adopted a "genocidal strategy" in pursuing the eradication of Falun Gong, and asked Interpol to seek their arrest.