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.
Trial Judgment: 27 February 2009; Appeal Judgment: 20 October 2010
Emmanuel Rukundo, an ordained priest and former military chaplain for the Rwandan Army, stood trial for his role in ordering, instigating, and aiding and abetting soldiers, members of the Interahamwe militia, and armed civilians to commit widespread and systematic attacks against Tutsis in Gitarama prefecture. The prosecution charged Rukundo with direct responsibility for genocide, murder as a crime against humanity, and extermination as a crime against humanity.
In 2009, and ICTR Trial Chamber convicted Rukundo of genocide for killing one named individual and causing serious bodily harm to her two children, for abducting and killing Tutsi refugees from the St. Léon Minor Seminary, and for sexually assaulting a young Tutsi woman in the Seminary; of murder as a crime against humanity for the killing of one named individual; and of extermination as a crime against humanity for abductions and killings of Tutsi refugees at the Seminary.
In 2010, the ICTR Appeals Chamber upheld Rukundo’s convictions for genocide and crimes against humanity, but reversed the Trial Chamber on the narrow grounds of the form of responsibility used to convict Rukundo of genocide. Additionally, the Appeals Chamber reversed the Trial Chamber’s finding of guilt for sexual assault as a grounds for genocide on the grounds that the prosecution failed to show beyond a reasonable doubt, that Rukundo possessed genocidal intent with respect to his act of sexual assault. The Appeals Chamber reduced Rukundo’s sentence from 25 years’ to 23 years’ imprisonment.