Prosecutor v. Rukundo

Citation: ICTR-01-70

Link to the full case: http://unictr.irmct.org/en/cases/ictr-01-70

Date of Trial Judgment: 27 February 2009

Date of Appeal Judgment: 20 October 2010


Emmanuel Rukundo was an ordained priest and former military chaplain for the Rwandan Army. He was tried for his role in ordering, instigating, and aiding and abetting soldiers, members of the Interahamwe militia, and armed civilians to commit widespread and systematic attacks against Tutsis in Gitarama prefecture. He was charged with direct responsibility for genocide, murder as a crime against humanity, and extermination as a crime against humanity.


In 2009, the ICTR Trial Chamber convicted Rukundo of genocide for killing one named individual and causing serious bodily harm to her two children, for abducting and killing Tutsi refugees from the St. Léon Minor Seminary, and for sexually assaulting a young Tutsi woman in the Seminary; of murder as a crime against humanity for the killing of one named individual; and of extermination as a crime against humanity for abductions and killings of Tutsi refugees at the Seminary.


In 2010, the ICTR Appeals Chamber upheld Rukundo’s convictions for genocide and crimes against humanity, but reversed the Trial Chamber on the narrow grounds of the form of responsibility used to convict Rukundo of genocide. It also reversed the Trial Chamber’s finding of guilt for sexual assault as a grounds for genocide on the grounds that the prosecution failed to show beyond a reasonable doubt, that Rukundo possessed genocidal intent with respect to his act of sexual assault. It reduced Rukundo’s sentence from 25 years’ to 23 years’ imprisonment.


Summary based on notes from the IJRC