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.


Bizimungu et al. (ICTR-99-50) “Government II”

Trial Judgment: 30 September 2011; Appeal Judgment: 4 February 2013

Jérôme Bicamumpaka, the former Rwandan Minister of Foreign Affairs; Casimir Bizimungu, the former Rwandan Minister of Health; Justin Mugenzi, the former Rwandan Minister of Commerce; and Prosper Mugiraneza, the former Rwandan Minister of Civil Service, were indicted for their alleged roles, as members of the Rwandan Interim Government in 1994, in massacres of Tutsis across Rwanda in 1994. The prosecution charged the defendants with direct and superior responsibility for conspiracy to commit genocide, genocide, complicity in genocide, direct and public incitement to commit genocide, murder, extermination and rape as crimes against humanity, as well as violence to life and outrages upon personal dignity as war crimes.

In 2011, an ICTR Trial Chamber convicted both Mugenzi and Mugiraneza of conspiracy to commit genocide for their participation in the decision to remove Butare’s Tutsi Prefect, Jean-Baptiste Habyalimana and incitement to commit genocide based on their participation in a joint criminal enterprise at the Butare Prefect installation ceremony, where President Théodore Sindikubwabo gave an inflammatory speech leading to the killing of Tutsis. The Trial Chamber acquitted both Bicamumpaka and Bizimungu on all counts. In 2013, the ICTR Appeals Chamber reversed the convictions against both Mugenzi and Mugiraneza due to errors in the Trial Chamber’s assessment of evidence, and accordingly the Appeals Chamber acquitted both defendants.