On 12 March 2008, the Appeals Chamber of the International Criminal Tribunal for Rwanda (ICTR) handed down its judgement in the case of Prosecutor v. Seromba, convicting the Roman-Catholic priest Athanase Seromba for his participation in the infamous bulldozing of Nyange church on 16 April 1994 and sentencing him to life imprisonment. Some 1,500 displaced Tutsi men, women and children died in the attack.
In this latest commentary published on the Hague Justice Portal, Senior Legal Officer Gregory Townsend analyses the Appeals Chamber’s Judgement and, in particular, its precedent-setting expansion of the legal definition of “committing” genocide as a mode of participation.