The Prosecutor v. Jean-Paul Akayesu: A Case Analysis
July 31, 2025
min read
The Prosecutor v. The case of Jean-Paul Akayesu remains one of the most critical events in the process of establishing international criminal law since it was the first time a worldwide tribunal pronounced a guilty judgment in the crime of genocide. It has deeper implications and is useful to the great interpretation and prosecution of international crimes than just this initial belief. This article expounds into the background fact of the case, its legal principles and what legacy it has left in the context of international justice.
The background to the case of Akayesu trial was the formation of the International Criminal Tribunal of Rwanda (ICTR). In 1994, the United Nations Security Council established the ICTR to prosecute persons who participated in the events in Rwanda that entail the commission of genocide and other grave violence of the international law of humanity during the period between January 1 and December 31, 1994. ICTR in its creation, together with the International Criminal Tribunal for the former Yugoslavia (ICTY), brought a new dimension in international relations and justice. The so-called post-Cold-War era led to the increased readiness on the part of the international community to intervene, to prosecute individuals due to their mass atrocities, shifting away to the mere idea of accountability that solely focused on state-centric accountability. The first conviction the Akayesu case, proved the viability in use of such ad hoc courts and the legal authorization of such bodies which proved vital in the eventual creation of a permanent criminal court as an international organization. It was a huge shift in the nature of individual criminal responsibility and significant undermining the concept of national sovereignty as a blanket protection of an offender of serious international offenses.
Other than being the first conviction based on genocide, what was novel about the Akayesu was the unreserved recognition and definition of sexual violence (chiefly rape) as a method to carry out genocide and other crimes against humanity. Such a feature in itself changed the field of international criminal justice. The fact that the judgment understood rape as a genocidal act is not just a legal description, it is an immense recognition on the systematic use of sexual violence as a weapon in war and another means of destruction on an identified group. This knowledge does not just include dropping the name of rape as a crime against humanity. It puts an emphasis on the particular motive of such acts being aimed towards the destruction of a group or a part of it, showing a better understanding of the psychological, social and reproductive damage created. The discovery placed on the table the intersections between gender (as well as race and sexuality), warfare, and genocide, and the international law had no choice except to acknowledge that violence towards women could constitute the heart of the occurrence of fundamental international crimes, not merely a secondary consequence.
Facts of the Case
Jean Paul Akayesu was a mayor of Tabagombe ( Bourgmestre ) at Gitarama prefect, Rwanda. This role was formalized according to which he was expected to ensure law and order in his commune. Taba however became a center of numerous atrocities when it came under attack in the Rwandan genocide in 1994. He was supposed to protect the people but instead he was a perpetrator of the violence, and did not stop it.
The Tribunal discovered that there was a strong de jure and de facto power that Akayesu had on the communal police, and the local population. His deeds were an ultimate act of disdain and misuse of power over people upon whom it was entrusted. It is an example of how genocide perpetrators tend to use the existing power distribution and social ranks when executing mass atrocities. It highlights the fact that these encounters are not just based on the individual evil, but on the institutional corruption of the power and the state or quasi-state exploitation of functions. This has wider implications in the appreciation of the critical role played by the local leaders in enhancing or deterring mass violence. The Tribunal held that by his orders, incitement, and permitting, Akayesu engaged in the killings, rapes, torture, and properties destruction of Tutsi civilians. He was the key element in the commission of such crimes by virtue of the fact that he was present in the communal office and acted as such.
Accounts submitted to the court during trial mentioned how Akayesu ordered or engaged in massacre of Tutsi citizens. Most importantly the ruling pointed out that he also authorized or commissioned or even allowed systematic rape and sexual assault of Tutsi women and girls seeking refuge or who found themselves in custody at the communal office. These were not just a random action, it was a planned destruction act. That all this happened mostly inside the communal office is also indicative that lots of atrocities were concentrated there- rapes, massacres. A place that was supposed to be a place of refuge or management center was turned into a place of organized violence. This fact shows that the genocide was not an indiscriminate and diffuse process, but was an action directly authorized and fulfilled at the seats of power at the local level. The fact that the communal office was turned into a tool of systematic sexual violence, killings and targeting proves that the civil order disintegrated completely and that the public spaces had been turned into a destructive object with the intention of maliciously perverting it. This clearly portrayed that the desire to kill a group can filter through all sections of a society and government in the case of genocide.
Legal Proceedings and Charges
Jean-Paul Akayesu was charged and later found guilty with charges on various counts, an illustration of the extent of his criminal activities in the genocide. The indictment was specific on Genocide, direct and public incitement to commit genocide, and a number of counts of Crimes against Humanity namely: murder, torture, rape, and other inhumane acts. Such a thorough indictment enabled the Tribunal to deal with the whole range of crimes that were perpetrated under the supervision of Akayesu.
The Akayesu indictment has employed the multi-count method and this was tactical. Whereas genocide attracts the most serious moral condemnation, determining the element of a genocidal intent (dolus specialis) can be an extremely difficult exercise in some instances. The accusation of the crime of humanity, murders, rapes, tortures, and other inhuman acts represented alternative channels through which conviction could be ensured as long as the perpetrators could be held responsible to their actions whereas the genocidal intent of each of their individual actions could not be conclusively determined. This method gave the best possibility of achieving conviction and all the types of damage suffered were covered thus showing what versatility and resilience is needed in criminal justice in the international areas where accountability must be captured.
Moreover, the conclusions of the Tribunal in regard to the criminal responsibility of Akayesu demonstrate the relationship between the direct and the indirect types of culpability. Some of the acts he personally committed or ordered were convicted as Akayesu was directly responsible, as stated in Article 6(1) of the ICTR Statute. More importantly, he was also found guilty of having committed the offense under Article 6(3) of the ICTR Statute (command or superior responsibility) of having failed to prevent or to punish the subordinates who committed atrocities. This two-fold use of responsibility is critical in the sense that it shows that even after international criminal law was born, it continues to hold individuals responsible not only on committing or inciting acts they directly commit, but also committing crimes by people they exercise effective control over, especially failing to exercise their control in the prevention and punishment. This extends the mantle of responsibility up the chain of command and it makes leaders who facilitate or facilitate atrocities culpable.
Principles Propounded by the ICTR in Akayesu
A. Definition and Elements of Genocide
ICTR, basing its interpretation on Article 2 of their Statute, gave a clear understanding of the genocide crime. This paper provides the acts that may constitute the crime of genocide, namely, killing members of the group, causing serious bodily or mental harm to members of the group, deliberately Inflicting on the group conditions of life that are calculated to bring about its physical destruction in whole or in part, Imposing measures intended to prevent births within the group, forcibly transferring children of the group to another group when committed with the intent to destroy, in whole or in part, a national, ethnical, racial or religious group.
The Tribunal decided without a doubt that the crime of genocide must have a particular intent (dolus specialis) to destroy a target group. Such intent should be established beyond reasonable doubt which differentiates genocide with other mass atrocities. The specific intent of Akayesu towards the Tutsi population was demonstrated in his actions that are characterized by the fact that he incited and did not intervene to protect the population. The fact that the strict maintenance of the dolus specialis prerequisite raised considerably by the Tribunal was a significant one as far as the prosecutors are concerned. The fact that it found this intent existed in the actions of Akayesu, even though there was not an overt statement to this extent, made the inference that intent may be read into a pattern of actions, statements to the populace, and the situation as a whole, especially with regard to the crimes that were being committed. This jurisprudential advance changed the reliance of instant confessions of purpose to relying on its extrapolation based on objective facts and circumstances. This has broader application regarding complex intent requirements in international criminal law, by how the prosecutors would interpret the complex intent requirements, it would be easier to convict the perpetuators of genocide without interfering with the high standard of evidence.
Article 2 has also been further defined by the ICTR concerning the definition of the concept of the protected groups where the ICTR indicated that the categories (national, ethnical, racial, or religious) were to be taken in the context of the ordinary meaning in respect to the words as are and the purpose of the Genocide Convention.
B. Sexual Violence as a Form of Genocide and Crime Against Humanity
The Akayesu ruling was landmark because it was first international jurisprudence to declare that rape, as well as other sexual offences, could amount to genocide. The Tribunal also concluded that rape, committed with the intent to destroy a group, falls under Article 2(2)(b)-(causing serious bodily or mental harm), and Article 2(2)-(c) of ICTR statute- (deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part). Rapes committed on Tutsis and women in Taba were also verified to have been done with an aim of destroying the Tutsi group.
The technical legal meaning of this specific genocide plus other acts of crimes against humanity definition of rape was not just a technical definition. It was a paradigm shift that did not only reflect the way in which international law viewed and responded to sexual violence in conflict. In the past, the aspects of sexual violence were overlooked as a subsidiary offense or a war loot. Akayesu had taken it as a central element of the most serious international crimes, (as it could be used as a tool to annihilate groups). This judicial signing caused waves of effects as more studies on sexual violence were conducted, more prosecutions and more support of the victims followed in future wars and courts. It was also able to facilitate inclusion of gender-related crimes in the Rome Statute, showing how one landmark judgment can transform legal and moral boundaries throughout the world.
In addition to genocide, ICTR revealed that rape and sexual assault were also tortures and other inhumane practices, falling into the heading of Crimes Against Humanity. This has put into place a multi-stratified legal system on prosecuting sexual violence. The Tribunal also stated that the testimony of the victim is the key to this process, as it is only through their stories that these crimes could be unveiled and their perpetrators found guilty, and recognized the enormous amount of courage that survivors had to spare in order to tell the world their stories.
C. Individual Criminal Responsibility
Article 6(3) of the ICTR Statute was used to convict Akayesu because of his failure to prevent or to punish his subordinates who committed atrocities. According to this principle, superiors are answerable to crimes committed by the inferior provided they knew or had the knowledge to know that the crimes continued in doing or were on the verge to be committed and failed to take any appropriate and proper measures to prevent them or give punishments to the perpetrator.
The judgment made it clear that command responsibility may be used against people who express de facto authoritative power, and not merely de jure (formal) power. As Bourgmestre, Akayesu had great de facto powers over the communal police and the local populace and therefore he was responsible to answer to their actions. Direct responsibility was also found against him in Article 6(1) on actions that he had taken or had ordered himself. Extending the concept of command responsibility to one of the leaders of the local civilians-Akayesu, de facto in his role, meant an epochal broadening of the concept of those capable of being criminally liable in connection with international crime. It has extended the chain of military command to those civilian superiors who do not stop or prosecute atrocities which are perpetrated by those who are under their de facto control. This puts forward a major tendency in the international criminal law, that all those in authority, no matter what their nominal position or military rank, should be singled out with the task of explaining their contribution to mass atrocities, thus preventing lapses in impunity and solidifying the idea that those charged with authority are also charged with responsibility.
D. Direct and Public Incitement to Commit Genocide
Akayesu had been found guilty of direct and public incitement to commit genocide. The ICTR explained the constituents of this crime as spelled out in Article 2(3) (c) of its Statute and insisted that the act of incitement ought to be direct (that is, make a definite request to action, rather than an indirect plea, such as implying) and published to the populace in general. Such speeches and directives of Akayesu were identified to fulfill these criteria. The important legal principles or definitions laid down/made by the Akayesu judgment are briefly explained, in the following table.
Impact and Legacy of the Akayesu Judgment
The Akayesu case had a great impact in the international criminal law because it was the first case where an international court convicted of genocide. It developed a precedent to the interpretation of the 1948 Genocide Convention which is applied in future prosecutions including at the ICTY and ICC. The Rome Statute has also been affected by this decision as an illustration of how one ruling can result in an overhaul in the legal systems around the world. It also relied on specificity and deep legal decisions so as to influence new laws.
This decision was of essence in the handling of sexual violence in international law because rape was defined as genocide or a crime against humanity. This has changed how sexual violence has long been ignored in history to become a major topic of inquiry and prosecution of such crimes. Akayesu case transformed the vision of gender-based violence as a personal offense into the serious attack on international law hence decreasing the degree of impunity of such violence.
Moreover, Akayesu also explained part of genocide, such as the existence of the covered groups and qualifying acts that cement legal analysis of further prosecutions. It finally confirmed the commitments of the international community to prosecute those who commit what is referred to as the crime of crimes.
Conclusion
The Akayesu case can be shot as an icon of the international criminal law, which confirms the ambition of the international community not to overlook those guilty of mass atrocities. Its history will be three-dimensional, with the first-ever international conviction on the charge of genocide and the landmark stating sexual violence as the internationally fundamental atrocity.
The careful exegesis of the acts of genocide by that judgment, its extension to cover individual criminal liability to cover de facto civilian superiors and its authority in direct incitement and its publicity have of jurisprudential value been invaluable. Above all, Akayesu becomes a great source of inspiration to the victims of Rwanda genocide and a positive light to the everlasting efforts of bringing to an end impunity on atrocity crime.
The background to the case of Akayesu trial was the formation of the International Criminal Tribunal of Rwanda (ICTR). In 1994, the United Nations Security Council established the ICTR to prosecute persons who participated in the events in Rwanda that entail the commission of genocide and other grave violence of the international law of humanity during the period between January 1 and December 31, 1994. ICTR in its creation, together with the International Criminal Tribunal for the former Yugoslavia (ICTY), brought a new dimension in international relations and justice. The so-called post-Cold-War era led to the increased readiness on the part of the international community to intervene, to prosecute individuals due to their mass atrocities, shifting away to the mere idea of accountability that solely focused on state-centric accountability. The first conviction the Akayesu case, proved the viability in use of such ad hoc courts and the legal authorization of such bodies which proved vital in the eventual creation of a permanent criminal court as an international organization. It was a huge shift in the nature of individual criminal responsibility and significant undermining the concept of national sovereignty as a blanket protection of an offender of serious international offenses.
Other than being the first conviction based on genocide, what was novel about the Akayesu was the unreserved recognition and definition of sexual violence (chiefly rape) as a method to carry out genocide and other crimes against humanity. Such a feature in itself changed the field of international criminal justice. The fact that the judgment understood rape as a genocidal act is not just a legal description, it is an immense recognition on the systematic use of sexual violence as a weapon in war and another means of destruction on an identified group. This knowledge does not just include dropping the name of rape as a crime against humanity. It puts an emphasis on the particular motive of such acts being aimed towards the destruction of a group or a part of it, showing a better understanding of the psychological, social and reproductive damage created. The discovery placed on the table the intersections between gender (as well as race and sexuality), warfare, and genocide, and the international law had no choice except to acknowledge that violence towards women could constitute the heart of the occurrence of fundamental international crimes, not merely a secondary consequence.
Facts of the Case
Jean Paul Akayesu was a mayor of Tabagombe ( Bourgmestre ) at Gitarama prefect, Rwanda. This role was formalized according to which he was expected to ensure law and order in his commune. Taba however became a center of numerous atrocities when it came under attack in the Rwandan genocide in 1994. He was supposed to protect the people but instead he was a perpetrator of the violence, and did not stop it.
The Tribunal discovered that there was a strong de jure and de facto power that Akayesu had on the communal police, and the local population. His deeds were an ultimate act of disdain and misuse of power over people upon whom it was entrusted. It is an example of how genocide perpetrators tend to use the existing power distribution and social ranks when executing mass atrocities. It highlights the fact that these encounters are not just based on the individual evil, but on the institutional corruption of the power and the state or quasi-state exploitation of functions. This has wider implications in the appreciation of the critical role played by the local leaders in enhancing or deterring mass violence. The Tribunal held that by his orders, incitement, and permitting, Akayesu engaged in the killings, rapes, torture, and properties destruction of Tutsi civilians. He was the key element in the commission of such crimes by virtue of the fact that he was present in the communal office and acted as such.
Accounts submitted to the court during trial mentioned how Akayesu ordered or engaged in massacre of Tutsi citizens. Most importantly the ruling pointed out that he also authorized or commissioned or even allowed systematic rape and sexual assault of Tutsi women and girls seeking refuge or who found themselves in custody at the communal office. These were not just a random action, it was a planned destruction act. That all this happened mostly inside the communal office is also indicative that lots of atrocities were concentrated there- rapes, massacres. A place that was supposed to be a place of refuge or management center was turned into a place of organized violence. This fact shows that the genocide was not an indiscriminate and diffuse process, but was an action directly authorized and fulfilled at the seats of power at the local level. The fact that the communal office was turned into a tool of systematic sexual violence, killings and targeting proves that the civil order disintegrated completely and that the public spaces had been turned into a destructive object with the intention of maliciously perverting it. This clearly portrayed that the desire to kill a group can filter through all sections of a society and government in the case of genocide.
Legal Proceedings and Charges
Jean-Paul Akayesu was charged and later found guilty with charges on various counts, an illustration of the extent of his criminal activities in the genocide. The indictment was specific on Genocide, direct and public incitement to commit genocide, and a number of counts of Crimes against Humanity namely: murder, torture, rape, and other inhumane acts. Such a thorough indictment enabled the Tribunal to deal with the whole range of crimes that were perpetrated under the supervision of Akayesu.
The Akayesu indictment has employed the multi-count method and this was tactical. Whereas genocide attracts the most serious moral condemnation, determining the element of a genocidal intent (dolus specialis) can be an extremely difficult exercise in some instances. The accusation of the crime of humanity, murders, rapes, tortures, and other inhuman acts represented alternative channels through which conviction could be ensured as long as the perpetrators could be held responsible to their actions whereas the genocidal intent of each of their individual actions could not be conclusively determined. This method gave the best possibility of achieving conviction and all the types of damage suffered were covered thus showing what versatility and resilience is needed in criminal justice in the international areas where accountability must be captured.
Moreover, the conclusions of the Tribunal in regard to the criminal responsibility of Akayesu demonstrate the relationship between the direct and the indirect types of culpability. Some of the acts he personally committed or ordered were convicted as Akayesu was directly responsible, as stated in Article 6(1) of the ICTR Statute. More importantly, he was also found guilty of having committed the offense under Article 6(3) of the ICTR Statute (command or superior responsibility) of having failed to prevent or to punish the subordinates who committed atrocities. This two-fold use of responsibility is critical in the sense that it shows that even after international criminal law was born, it continues to hold individuals responsible not only on committing or inciting acts they directly commit, but also committing crimes by people they exercise effective control over, especially failing to exercise their control in the prevention and punishment. This extends the mantle of responsibility up the chain of command and it makes leaders who facilitate or facilitate atrocities culpable.
Principles Propounded by the ICTR in Akayesu
A. Definition and Elements of Genocide
ICTR, basing its interpretation on Article 2 of their Statute, gave a clear understanding of the genocide crime. This paper provides the acts that may constitute the crime of genocide, namely, killing members of the group, causing serious bodily or mental harm to members of the group, deliberately Inflicting on the group conditions of life that are calculated to bring about its physical destruction in whole or in part, Imposing measures intended to prevent births within the group, forcibly transferring children of the group to another group when committed with the intent to destroy, in whole or in part, a national, ethnical, racial or religious group.
The Tribunal decided without a doubt that the crime of genocide must have a particular intent (dolus specialis) to destroy a target group. Such intent should be established beyond reasonable doubt which differentiates genocide with other mass atrocities. The specific intent of Akayesu towards the Tutsi population was demonstrated in his actions that are characterized by the fact that he incited and did not intervene to protect the population. The fact that the strict maintenance of the dolus specialis prerequisite raised considerably by the Tribunal was a significant one as far as the prosecutors are concerned. The fact that it found this intent existed in the actions of Akayesu, even though there was not an overt statement to this extent, made the inference that intent may be read into a pattern of actions, statements to the populace, and the situation as a whole, especially with regard to the crimes that were being committed. This jurisprudential advance changed the reliance of instant confessions of purpose to relying on its extrapolation based on objective facts and circumstances. This has broader application regarding complex intent requirements in international criminal law, by how the prosecutors would interpret the complex intent requirements, it would be easier to convict the perpetuators of genocide without interfering with the high standard of evidence.
Article 2 has also been further defined by the ICTR concerning the definition of the concept of the protected groups where the ICTR indicated that the categories (national, ethnical, racial, or religious) were to be taken in the context of the ordinary meaning in respect to the words as are and the purpose of the Genocide Convention.
B. Sexual Violence as a Form of Genocide and Crime Against Humanity
The Akayesu ruling was landmark because it was first international jurisprudence to declare that rape, as well as other sexual offences, could amount to genocide. The Tribunal also concluded that rape, committed with the intent to destroy a group, falls under Article 2(2)(b)-(causing serious bodily or mental harm), and Article 2(2)-(c) of ICTR statute- (deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part). Rapes committed on Tutsis and women in Taba were also verified to have been done with an aim of destroying the Tutsi group.
The technical legal meaning of this specific genocide plus other acts of crimes against humanity definition of rape was not just a technical definition. It was a paradigm shift that did not only reflect the way in which international law viewed and responded to sexual violence in conflict. In the past, the aspects of sexual violence were overlooked as a subsidiary offense or a war loot. Akayesu had taken it as a central element of the most serious international crimes, (as it could be used as a tool to annihilate groups). This judicial signing caused waves of effects as more studies on sexual violence were conducted, more prosecutions and more support of the victims followed in future wars and courts. It was also able to facilitate inclusion of gender-related crimes in the Rome Statute, showing how one landmark judgment can transform legal and moral boundaries throughout the world.
In addition to genocide, ICTR revealed that rape and sexual assault were also tortures and other inhumane practices, falling into the heading of Crimes Against Humanity. This has put into place a multi-stratified legal system on prosecuting sexual violence. The Tribunal also stated that the testimony of the victim is the key to this process, as it is only through their stories that these crimes could be unveiled and their perpetrators found guilty, and recognized the enormous amount of courage that survivors had to spare in order to tell the world their stories.
C. Individual Criminal Responsibility
Article 6(3) of the ICTR Statute was used to convict Akayesu because of his failure to prevent or to punish his subordinates who committed atrocities. According to this principle, superiors are answerable to crimes committed by the inferior provided they knew or had the knowledge to know that the crimes continued in doing or were on the verge to be committed and failed to take any appropriate and proper measures to prevent them or give punishments to the perpetrator.
The judgment made it clear that command responsibility may be used against people who express de facto authoritative power, and not merely de jure (formal) power. As Bourgmestre, Akayesu had great de facto powers over the communal police and the local populace and therefore he was responsible to answer to their actions. Direct responsibility was also found against him in Article 6(1) on actions that he had taken or had ordered himself. Extending the concept of command responsibility to one of the leaders of the local civilians-Akayesu, de facto in his role, meant an epochal broadening of the concept of those capable of being criminally liable in connection with international crime. It has extended the chain of military command to those civilian superiors who do not stop or prosecute atrocities which are perpetrated by those who are under their de facto control. This puts forward a major tendency in the international criminal law, that all those in authority, no matter what their nominal position or military rank, should be singled out with the task of explaining their contribution to mass atrocities, thus preventing lapses in impunity and solidifying the idea that those charged with authority are also charged with responsibility.
D. Direct and Public Incitement to Commit Genocide
Akayesu had been found guilty of direct and public incitement to commit genocide. The ICTR explained the constituents of this crime as spelled out in Article 2(3) (c) of its Statute and insisted that the act of incitement ought to be direct (that is, make a definite request to action, rather than an indirect plea, such as implying) and published to the populace in general. Such speeches and directives of Akayesu were identified to fulfill these criteria. The important legal principles or definitions laid down/made by the Akayesu judgment are briefly explained, in the following table.
Impact and Legacy of the Akayesu Judgment
The Akayesu case had a great impact in the international criminal law because it was the first case where an international court convicted of genocide. It developed a precedent to the interpretation of the 1948 Genocide Convention which is applied in future prosecutions including at the ICTY and ICC. The Rome Statute has also been affected by this decision as an illustration of how one ruling can result in an overhaul in the legal systems around the world. It also relied on specificity and deep legal decisions so as to influence new laws.
This decision was of essence in the handling of sexual violence in international law because rape was defined as genocide or a crime against humanity. This has changed how sexual violence has long been ignored in history to become a major topic of inquiry and prosecution of such crimes. Akayesu case transformed the vision of gender-based violence as a personal offense into the serious attack on international law hence decreasing the degree of impunity of such violence.
Moreover, Akayesu also explained part of genocide, such as the existence of the covered groups and qualifying acts that cement legal analysis of further prosecutions. It finally confirmed the commitments of the international community to prosecute those who commit what is referred to as the crime of crimes.
Conclusion
The Akayesu case can be shot as an icon of the international criminal law, which confirms the ambition of the international community not to overlook those guilty of mass atrocities. Its history will be three-dimensional, with the first-ever international conviction on the charge of genocide and the landmark stating sexual violence as the internationally fundamental atrocity.
The careful exegesis of the acts of genocide by that judgment, its extension to cover individual criminal liability to cover de facto civilian superiors and its authority in direct incitement and its publicity have of jurisprudential value been invaluable. Above all, Akayesu becomes a great source of inspiration to the victims of Rwanda genocide and a positive light to the everlasting efforts of bringing to an end impunity on atrocity crime.
About the Authors
Asal Raj Timsina
I am an undergraduate law student at Nepal Law Campus, where my academic focus includes a keen interest in international law and international politics. Furthermore, I possess a strong dedication to legal research and writing.
View all posts by Asal Raj Timsina