Territoriality principle is regarded as the main principle for defining the scope of application of criminal codes in the context of territory and it is suplemented with active-passive personality, protective personality and univesality principles. The territoriality principle requires exercising criminal codes of a sovereign state on criminal offences that are committed within its borders and offender be subject to the criminal jurisdiction of the state on whose realm the crime is committed. The territoriality principle cannot be exercised without any exception. Commitments made by bilateral and multiletaral agreements among states constitute an exception of territoriality principle. The Status of Forces Agreement (SOFA) is one such example about the the immunity of persons from local criminal jurisdiction. Besides, ICC is endoved with a complemantary judicial power which exposes a case to be analysed in the context of judicial power upon persons covered by NATO SOFA and in the context of potential effects on territoriality principle