A/65/219 38. These explicit expressions of commitment by the Security Council to take measures against perpetrators represent a credible threat of action that has been the basis for negotiation with many parties to conflict for commitments and action plans to address the grave violations for which they have been cited. The lack of action against some of the most persistent and egregious violators over the years is increasingly conspicuous, however, and reflects on the overall credibility of the United Nations agenda for children and armed conflict and on Member States and the Council itself. 39. Even as it is understood that sanctions are a measure of last resort, it is evident that the viability of the children and armed conflict agenda in which Member States have invested so much over the past years depends on the imposition of such measures against those who continue to flout international law and standards for the protection of children. 40. It should be noted that the focus of international criminal justice and mixed tribunals specifically on crimes against children has also raised the stakes in the fight against impunity. The Special Court for Sierra Leone paved the way for sanctioning individuals for child-specific violations by including such crimes in the indictments of all the individuals charged by the Court. This includes former President of Liberia Charles Taylor on counts of recruitment and use of children. In addition, despite the challenges in the trial of Thomas Lubanga Dyilo by the International Criminal Court for recruiting and using children, that case has symbolized the will of the international community to act for children and as such has sent a powerful message to perpetrators. As this is the first case before the International Criminal Court on the issue of children and armed conflict, and having filed an amicus curiae, the Special Representative gave testimony before the Court on the need to adopt a case-by-case method in deciding on what constitutes enlistment and conscription in terms of the statute. The Special Representative urged an interpretation that would not exclude girl children, who play multiple roles in many groups, not only as combatants but as wives and domestic aides. B. Dialogue with parties to conflict 41. It is the long-held position of the Special Representative of the SecretaryGeneral for Children in Armed Conflict and United Nations child protection partners that the international community must seek to engage all parties to conflict in dialogue for the purpose of eliciting concrete child protection commitments and to ensure that parties prepare and implement action plans to both prevent and address grave violations for which they have been cited. Such dialogue does not prejudge the legal status of non-state parties, nor does it confer legitimacy. The primacy and imperative to protect children must override political considerations. 42. It should be noted that this is consistent with General Assembly resolution 64/146 on the rights of the child, which urges State and non-state actors to end grave violations against children by taking time-bound and concrete protection measures. This presupposes a possibility of dialogue between parties to conflict and protection actors to establish the modalities and verification of such measures. 43. The element of dialogue with parties to conflict for the preparation of timebound action plans to address grave child rights violations represents one of the centrepieces of the United Nations agenda for children and armed conflict. In the 10-47421 11