ABSTRACT

In 1998, the International Criminal Tribunal for Rwanda (ICTR) convicted Jean-Paul Akayesu of genocide and crimes against humanity (Prosecutor v Akayesu (ICTR-96-4-T, Judgment 2 September 1998)). The decision was considered landmark for many reasons, including that it connected acts of rape to genocide, even without finding that Akayesu himself committed the rapes. Patricia Viseur-Sellers, former prosecutor and Legal Advisor for Gender at the International Criminal Tribunal for the Former Yugoslavia (ICTY) and a legal advisor to the ICTR trial team for Akayesu, calls Akayesu’s jurisprudence, particularly with regard to sex-based crimes, ‘stunning’ (2008: 42).