ABSTRACT
In March 2010, the Appeals Chamber of the ICTR upheld the conviction of Simon Bikindi for “direct and public incitement to commit genocide based on public exhortations to kill Tutsis” which he made from a vehicle in an Interahamwe convoy outfitted with a public address system. Bikindi urged that the majority of the population, the Hutu, should rise up to exterminate the minority, the Tutsi. 1 The incitement took place at a time when mass killings of civilians was going on in the area.
