Case source

Ramchandra Adhikari v. Daoud & Partners, et

Ramchandra Adhikari v. Daoud & Partners, et, 845 F.3d 184 (5th Cir. 2017)

Source reviewed November 4, 2026

What the source establishes

The court held that § 1595 did not reach extraterritorial conduct before the 2008 amendment, and that § 1596 could not be applied to the alleged 2004 conduct because doing so would be impermissibly retroactive. For the ATS, the majority treated domestic conduct as relevant only when it related to the statute’s focus; it rejected the claimed domestic character of Al Asad and found the identified U.S. conduct insufficient on this record. It affirmed dismissal of all claims, including the refusal to toll the time-barred state tort claims. The opinion does not provide subsequent treatment of this decision.