ABSTRACT
On 2 September 1988, Jean-Paul Akayesu, the former Bourgemestre of Taba Commune in Rwanda, was convicted of genocide by the Trial Chamber of the International Criminal Tribunal for Rwanda (ICTR)1 as a consequence of his actions during 1994, it having been proven beyond reasonable doubt that he had the requisite intention to ‘destroy’ the Tutsis (dolis specialis).2 This was the first time that an international criminal Tribunal had considered the meaning of the crime of genocide – the definition of which had been drawn from the 1948 Genocide Convention3 – and the first conviction at the international level for this crime. At the time, the Trial Chamber described the crime of genocide as the ‘crime of crimes’.4
