Gruesome nature of the crime

Notion(s) Filing Case
Appeal Judgement - 04.12.2001 KAYISHEMA & RUZINDANA

350.    […] The particularly gruesome manner in which the victim, Beatrice, was killed, is an aggravating circumstance. The fact that this act of killing also supported a conviction for the crime of genocide, because it was part of the policy of genocide within Kibuye préfecture, does not prevent a separate finding that the manner in which it was carried out gave rise to an aggravating circumstance. 

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ICTR Rule Rule 101(B) ICTY Rule Rule 101(B)