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In 2011, the Trial Chamber of the International Criminal Tribunal for Rwanda (ICTR) found Justin Mugenzi and Prosper Mugiraneza guilty of conspiracy to commit genocide and direct and public incitement to commit genocide due to their roles in the removal and replacement of Jean-Baptiste Habyalimana as prefect of Butare in April 1994. In February 2013, the Appeals Chamber reversed these convictions and acquitted Mugenzi and Mugiraneza, determining that the appellants did not possess the requisite mens rea and genocidal intent. The ICTR’s goal is to bring justice and reconciliation to Rwanda, but these acquittals demonstrate its institutional weakness. The Appeals Chamber’s weak reasoning, simplistic view of the facts, and failure to take a strong stance against government leadership contributed to this weakness and may have a lasting impact on the ICTR’s legacy.


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8 Sep 2022
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  • Subject
    • Criminal Law

    • Criminal Procedure

    • Human Rights Law

    • International Law

    • Military, War, and Peace

  • Journal title
    • Boston College International and Comparative Law Review

  • Volume
    • 38

  • Issue
    • 3

  • Pagination
    • E. Supp. 1

  • Date submitted

    8 September 2022