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Human rights group Democracy for the Arab World Now (DAWN) said on Wednesday that it had submitted a list of 40 senior Israeli commanders to International Criminal Court (ICC) chief prosecutor Karim Khan over the Gaza war.

The commanders have participated in or have direct command responsibility over issues ranging from the "use of starvation as a weapon" to "operations that likely comprise indiscriminate and deliberate attacks on civilians", the pan-Arab rights group said.

The list, which also covers the siege of Gaza, concerns the period between 8 October and 13 November this year.

DAWN called on Khan to investigate "suspects for war crimes and crimes against humanity" including those on its list.

The group said it drew up its list solely from official and open-source channels, and that it includes almost all branches of the Israeli army and the Coordinator of Government Activities in the Territories – which it said manages the siege on Gaza.

"Israeli criminal law does not establish any type of 'command responsibility' for war crimes, which means Israeli courts never hold senior officers accountable — while it almost always absolves their subordinates of committing serious war crimes," Michael Schaeffer Omer-Man, director of Israel-Palestine research at DAWN, said in a press release.

"Because Israel doesn't even take the most basic step of investigating commanding officers, it cannot possibly argue the ICC is the wrong jurisdiction."

Schaeffer Omer-Man told °®Âþµº that the state parties to the Rome Statute, the treaty that created the ICC, must ensure the Gaza investigation "has at least the same resources of the Ukraine investigation, as 40 countries did earlier this year by donating millions of dollars" to the court.

"The most important thing states can do to ensure the ICC is able to hold Israeli war criminals accountable is to make public their own determinations of what crimes are taking place, and to ask the ICJ to examine the question of genocide," he added.

The Associated Press previously reported that an event held in the UK in March, and attended by more than 40 states saw £4 million ($5.1 million) in donations pledged to help with ICC work related to Ukraine and Russia.

DAWN is a US-based rights group founded by murdered Saudi journalist Jamal Khashoggi and now headed by the former executive director of Human Rights Watch's Middle East and North Africa section, Sarah Leah Whitson.