Non-international character of the conflict in Rwanda

Notion(s) Filing Case
Appeal Judgement - 20.05.2005 SEMANZA Laurent
(ICTR-97-20-A)

192. […] Instead, the Chamber took notice only of general notorious facts not subject to reasonable dispute, including, inter alia: […] that there was an armed conflict not of an international character in Rwanda between 1 January 1994 and 17 July 1994; […]

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Notion(s) Filing Case
Decision on Reconsideration - 01.12.2006 KAREMERA et al.
(ICTR-98-44-AR73(C))

At para. 11, the Appeals Chamber recalled its previous finding and held that:

The existence of a non-international armed conflict is a notorious fact not subject to a reasonable dispute.[1]Whether a fact is one of common knowledge is a legal question, the answer to which does not turn on the evidence introduced in a particular case.

[1] The Prosecutor v. Semanza, Case No. ICTR-97-20-A,Judgment,20 May 2005, para.192

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