On November 13, 2019, the Supreme Court of the United Kingdom issued its judgment in R. v. T.R.A. interpreting section 134 of the Criminal Justice Act 1988 (CJA), which implements the United Nations Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment of 1984 (UNCAT). A press release issued by the Court explains that the appellant in the case was charged with conspiracy to commit torture and with several counts of torture in the context of the first Liberian civil war in 1990 and the takeover in parts of Liberia by an armed group, the National Patriotic Front of Liberia (NPFL) and its leader, Charles Taylor. The issue in the case was the meaning of "person acting in an official capacity" in section 134 of the CJA. In particular, the prosecution argued that because NPFL was the "de facto military government with effective control of the relevant area," those, such as the appellant, who acted with Charles Taylor, were acting in an official capacity and were therefore subject to liability under the CJA. The Court agreed with the Court of Appeal, and held that section 134(1) of the CJA "includes a person who acts or purports to act, otherwise than in a private and individual capacity, for or on behalf of an organisation or body which exercises, in the territory controlled by that organisation or body and in which the relevant conduct occurs, functions normally exercised by governments over their civilian populations. Furthermore, it covers any such person whether acting in peace time or in a situation of armed conflict." The case was remanded to consider new evidence of NPFL's control over the territory, in light of the Supreme Court's interpretation of the CJA.