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Rwanda: ICTR Convicts Ex-Minister for Crimes Committed During 1994 Rwandan Genocide

(June 6, 2012) On May 31, 2012, Trial Chamber III of the Arusha, Tanzania, based International Criminal Court for Rwanda (ICTR) (ICTR website (last visited May 31, 2012)), convicted Callixte Nzabonimana on various charges for crimes he committed during the April through June 1994 Rwandan genocide, and it sentenced him to life in prison. (Callixte Nzabonimana Convicted and Sentenced to Life Imprisonment, ICTR website (May 31, 2012).)

The prosecutor brought charges against Nzabonimana on four counts: genocide; conspiracy to commit genocide; direct and public incitement to commit genocide; extermination as a crime against humanity; and murder as a crime against humanity. (The Prosecutor v. Callixte Nzabonimana, Case No. ICTR-98-44D-T, Summary of Judgment and Sentence (May 31, 2012), ICTR website.)

The prosecutor contended that during the 1994 genocide, Nzabonimana used his influence in Gitarama Prefecture, acquired due to various positions he held in the government, to encourage the killing and looting of the Tutsi people. (Id.) Although he had held other top positions before, Nzabonimana at the time served as the Minister of Youth and Associative Movements and as the Chairman of the National Republican Movement for Democracy and Development (MRND) Party in Gitarama Prefecture.(Id.)

The prosecutor introduced 19 witnesses and one rebuttal witness to show that during this period, Nzabonimana, among other acts, instigated the killing of Tutsis who were taking refuge at the Nyabikenke commune office, located in Gitarama Prefecture; entered into agreements with other members of the government to kill Tutsis in the Prefecture; and made statements inciting the killing of Tutsis at the Butare trading center (Rutobwe commune), at Cyayi center (near Nyabikenke communeoffice), and at a meeting in Murambi, all in Gitarama Prefecture. (Id.) The Chamber found Nzabonimana guilty of all but one of the crimes charged. It dismissed a charge of murder as a crime against humanity on grounds of redundancy. (Id.)

The ICTR was established by a United Nations Security Council resolution on November 8, 1994, to prosecute individuals suspected of perpetrating genocide and other serious violations of international humanitarian law in Rwanda and neighboring countries from January 1 to December 31, 1994, which claimed the lives of over 800,000 Tutsis and politically moderate Hutus. (General Information, ICTR website (last visited May 31, 2012);Rwandan Ex-Minister Jailed for Life over Genocide, REUTERS (May 31, 2012).) The ICTR consists of three organs: the Chambers and the Appeals Chamber, the Office of the Prosecutor (tasked with investigations and prosecutions), and the Registry (tasked with providing judicial and administrative support to the other organs). (General Information, supra.)