The bodies lie scattered through Bucha.
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Many are handcuffed, shot through the head. Some are naked, charred after being thrown on bonfires. Others have been dumped in ditches, hastily dug as makeshift mass graves.
Ukrainians tell of Russian forces committing widespread rape, looting, and summarily murdering civilians during a month-long occupation. And Western powers are one-by-one calling for Vladimir Putin, the man who ordered them across the border, to be thrown in the dock.
The horrific images emanating from the outskirts of Kyiv alone seem an obvious basis for war crimes charges. But experts are warning a legal loophole will hamper attempts to hold Putin personally accountable.
The autocrat's fate is not simply a matter of getting him in handcuffs, and international leaders are looking back to the 1940s for a solution.
Crime of aggression
Moscow claims the West staged the Bucha massacre, despite New York Times analysis of satellite images showing bodies littering the streets three weeks ago - when the area was under Russian control.
Defence Minister Peter Dutton cited Bucha while joining the US in labelling Putin a "war criminal", and Australia is backing calls for a war crimes probe.
"The International Criminal Court and other bodies have the potential to investigate," Mr Dutton said on Friday.
"I'm sure that that evidence is being put together at the moment. So all we would urge is that if there is evidence of war crimes, then action is taken against Russia as quickly as possible."
But charging leaders over on-the-ground atrocities is a complex task. Unlike a foot soldier pulling the trigger, the culpability of politicians is murkier.
The crime of aggression - planning or carrying out "large-scale" aggression using a state military force - is the most direct route to prosecution for most autocrats.
"The evidentiary standards [for aggression] are not quite as forensic as they are with respect to standard war crimes," ANU international law expert Don Rothwell says.
"[You wouldn't need to] walk around the streets of these towns and villages in Ukraine, collecting forensic evidence."
While Putin could possibly be charged with a crime against humanity, there is already a mountain of public evidence implicating him in aggression, not least his declaration of a "special military operation" on live television.
But even in the unlikely event of his capture, a loophole prevents him from facing that charge: prosecution for aggression requires referral from the UN Security Council, over which Moscow holds a veto.
A Kremlin spokesman has already blasted the West's "unacceptable and unforgivable rhetoric" linking Putin to war crimes.
Nuremberg 2.0
More than 140 world leaders and legal experts are calling for a workaround: a new international tribunal mimicking those used to prosecute Nazi leaders after World War II.
The Nuremberg trials, initially held in the heartland of what was Nazi Germany in 1945, had offshoots sprawling across the US and Asia.
A number of the Nazi regime's most prominent members, including Adolf Hitler, committed suicide before facing trial. But the courts did secure convictions for more than 100 high-ranking German politicians, military leaders, and businessmen.
No one had been tried for the crime of aggression before the 1940s, or has been since.
Now a petition launched by former British prime minister Gordon Brown is calling for a Nuremberg-style tribunal over Ukraine, and has reached more than 1 million signatures worldwide.
"Now that crimes revealed at Bucha and Mariupol and elsewhere in Ukraine have shocked the world, we must set a clear path that brings Putin to justice," Mr Brown said.
"Doing so will show that the international community is prepared to do whatever it takes to hold him to account for his actions."
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The idea is also gaining traction in Australia, where former prime ministers Malcolm Turnbull and Kevin Rudd are adding their weight to the cause.
Mr Rudd told CNN that Russia's ability to circumvent charges means innovation is required.
"If you ... looked at new mechanisms, like they did and had to innovate in 1945, then there is a way in which these folks can be brought to justice," he said.
"If you let this just pass through as if it's just one of those things that happens, then we as an international community are degraded by that. We can't. This is rank barbarism of the first order."
Rothwell warns a "Nuremberg 2.0" court would require political will and funding, which is by no means guaranteed.
A key stumbling block could be the United States, the support of which is needed to make a court workable. But the US has historically been antagonistic towards the ICC.
Former US president Donald Trump sanctioned two ICC prosecutors who investigated alleged war crimes by American forces in Afghanistan, and by Israeli troops in Palestinian territories.
While that decision was reversed under Joe Biden, US Secretary of State Antony Blinken was at pains to stress he "disagrees strongly" with attempts to investigate the US and Israel.
"It places the US in a bit of a bind, in terms of how much it can be seen to be supporting the ICC," Rothwell says.
"That's why establishing a separate mechanism to deal with the crime of aggression might also be attractive to the US and to the Biden administration, because it circumvents those domestic political issues."
'Momentum building'
Washington is certainly showing signs of supporting a new court.
The US government formally codified Joe Biden's assertion Putin is a "war criminal", and this week dispatched Secretary Blinken to Brussels for key talks with allies over military support for Kyiv.
"All we can do is wait to see what comes out of those processes," he says.
"[But] that would suggest to me that there's some momentum building for this project."
Special courts were established in the 1990s to prosecute war criminals from the former Yugoslavia and Rwanda, waved through by the Soviet Union and China. And Rothwell is "very confident" any new court would be temporary and solely focused on atrocities in Ukraine.
"You might have a legal framework, but where is this tribunal going to operate from, and who's going to fund it?" he asks.
"If it's got a very narrow remit of trying Putin or others for the crime of aggression, then ... it doesn't need the same sort of infrastructure as an international criminal court does."