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The Prosecutor v. Laurent Semanza, Case No. ICTR-97-20, Judgement, Trial Chamber (15 May 2003). A Commentary

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Chapter Summary

One of the most significant aspects of the Trial Judgement is its handling of multiple criminal convictions under different statutory provisions, but based on the same conduct. Unlike the issue of cumulative charges, cumulative convictions for ideal concurrence have created much debate among commentators and among the judges of the ad hoc Tribunals. This chapter examines the issue of multiple convictions. Then, it draws a comparison between the Semanza case and other jurisprudences and shows that in fact the Chamber confirms a consistent jurisprudence of the ad hoc Tribunals on the issue of cumulative convictions. The Semanza Chamber, through its reasoning, recalls the criteria mainly taken into account by the other Chambers of the International Criminal Tribunal for the former Yugoslavia (ICTY) and International Criminal Tribunal for Rwanda (ICTR) including Judgements related to Judge Laïty Kama.

Keywords: criminal convictions; ICTY; International Criminal Tribunal for Rwanda (ICTR); Judge Laïty Kama; Prosecutor V. Laurent Semanza case; Semanza Chamber



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