ABSTRACT
During the Second World War, the invention of gruesomely efficient technological methods of mass extermination in concentration camps and on the battlefield, combined with the enormous number of civilian and combatant casualties, culminated in an emerging consciousness regarding the imperative of protecting human rights. Despite the growth of both the human rights and victims’ rights movements since the Second World War, it was not until the early 1990s that counter memories of wartime sexual violence attracted serious international attention. The 1997 ICTY Celebici case was the first international criminal trial since Nuremberg and Tokyo where more than one defendant was in the dock and the doctrine of command responsibility was used. The Foca trial was one of the biggest international rape trials in history. According to Kelly Askin, the decision reached in February 2001 represented ‘monumental jurisprudence’, a rare opportunity for survivors of sexual violence to hold three defendants accountable for rape, torture and enslavement.
