This case summary is part of a collection of summaries describing the cases before the International Criminal Tribunal for Rwanda (ICTR). See the Online Resource Hub pages on the ICTR and International Criminal Law, and table of ICTR case summaries for additional information.


Zigiranyirazo (ICTR-01-73)

Trial Judgment: 8 December 2008; Appeal Judgment: 16 November 2009

Protais Zigiranyirazo, a former Member of Parliament, a former Prefect of Kibuye and Ruhengeri, and the brother-in-law of the late Rwandan President Juvenal Habyarimana, stood trial for his role in planning, preparing, and facilitating attacks on Tutsis during 1994 by establishing roadblocks in proximity of Zigiranyirazo’s three homes and by creating and supporting the Interahamwe militia. In addition, Zigiranyirazo stood trial for his involvement in the killings of Tutsis at Kesho and Rurunga Hills, and for the murders of three police officers and Stanislas Sinibagiwe. The prosecution charged Zigiranyirazo with direct responsibility for genocide, conspiracy to commit genocide, complicity in genocide, extermination as a crime against humanity, and murder as a crime against humanity.

In 2008, an ICTR Trial Chamber convicted Zigiranyirazo of genocide and extermination as a crime against humanity for his participation in a joint criminal enterprise to kill Tutsi civilians on Kesho Hill on April 8, 1994. In addition, the Trial Chamber convicted Zigiranyirazo of aiding and abetting genocide at the Kiyovu Roadblock in Kigali.

In 2009, the ICTR Appeals Chamber reversed Zigiranyirazo’s conviction for genocide and extermination as a crime against humanity on the grounds that the Trial Chamber misapplied the burden of proof with respect to alibi and that the Trial Chamber erred in its handling of the evidence. Accordingly, the Appeals Chamber reversed Zigiranyirazo’s 20-year sentence.