James E. Archibong
Abstract
International law traditionally governs relations between states. Individuals were regarded as objects. Contemporary international law has however evolved to accord certain rights and duties to individuals. Attempts were made after World War I to put certain individuals, including William Kaiser I, on trial. The gross violation of human rights and humanitarian law during World War II and the formation of the United Nations added impetus to the recognition of the rights and duties of individuals under international law. Sexual violence in conflict now constitutes an international crime. Several individuals have been tried and convicted. However, there are numerous setbacks to the prosecution of individuals involved in war-related sexual violence. This work examines these challenges and recommends certain measures, among them, the use of female investigators and interpreters, protection for witnesses, and cooperation between the UN and the ICC in bringing perpetrators to justice. It is also recommended that the prohibition of wartime sexual violence must be incorporated into domestic law and military codes of states.
Keywords: Armed conflict, individual responsibility, sexual violence, prosecution, justice
Introduction
War or armed conflict is regulated by international humanitarian law which is addressed to states and not individuals (Common Article 1 of Geneva Conventions 1949). In the past, when individuals violated rules of engagement in war, only their states could hold them accountable and only states bore responsibility for infractions perpetrated by their forces. This was because states were the only subject of international law (Agarwal, 2010:62). By the end of the First World War, attempts were made to try perpetrators of war crimes. Attempts to put the German Kaiser on trial were rebuffed by the Netherlands which refused to hand him over for trial. The trial by the German authorities of its nationals who committed crimes in that war was a sham.
The principle of holding individuals accountable for violations of the laws and customs of war was adumbrated after the Second World War when two tribunals, located at Nuremberg and Tokyo were established by the Allied Powers to try persons responsible for the heinous crimes committed in that war (Wright, 1947:38-72). Sex crimes were however not included in the charges though rape, sexual slavery, enforced prostitution, and other forms of sexual violence were widespread and systematic. These acts were not adjudged punishable as international crimes (Blank & Noone, 2013:646). There had not been any prosecution for sexual violence until the conflicts in the former Yugoslavia and Rwanda and the establishment of tribunals by the United Nations Security Council to prosecute individuals responsible for violations of the law of armed conflict. The sex crimes trials of former Yugoslavia and Rwanda were followed by those of Sierra Leone and the International Criminal Court.
Despite successes recorded in the prosecution of individuals for war-related sexual violence, the crime is still prevalent and is being perpetrated with impunity in Syria, Iraq, South Sudan, northeast Nigeria, and many other war-torn areas. This paper traces the origin of the concept of individual criminal responsibility for sexual violence in conflict and appraises the high-profile prosecutions so far conducted. While this is commendable, there are still thousands of victims in conflict zones around the world yearning for justice. There is a need to mobilize resources and sustain the tempo and energy of the prosecutions, for as the UN Security Council noted in numerous resolutions 1820, sexual violence in conflict constitutes a threat to international peace and security.
States as the only subjects of international law
Under classical international law, only states were recognized as subjects. It is not in doubt that international law governs the relationship between states, and states are its primary subjects. According to the realist theory, only states are subjects of international law (Agarwal, 2010:63). This is the traditional concept of international law which recognizes states alone as the subjects of international law. States alone bear rights and duties under international law. States are the subjects while the individuals who compose them are the objects of international law. Individuals do not have rights or duties under international law. If they have any rights at all, such rights can only be claimed through the state.
An entity may be deemed to possess international personality if it is capable of possessing international rights and duties and having the capacity to maintain its rights by bringing international claims (Brownlie, 2003:57). Individuals now possess limited international personality and are capable of certain rights and duties under current international law.
Status of individuals under international law
International law regulates the relations of states with one another. It refers to the body of customary and treaty rules that are considered legally binding by states in their intercourse with each other (Oppenheim, 1905:1-2). The definition has excluded individuals who were viewed as the object of international law. This means they were incapable of exercising legal rights and duties. If an individual incurred an injury that required remedy under international law, only a state could espouse the claim of such an individual (Statute of the International Court of Justice).
This view has been criticized by modern international law jurists. To say that only states are the subjects of international law is no longer tenable or defensible. At present, international law is not limited to states only. Its expansion into the economic, social, and other spheres has generated an increasing number of actors in the international legal order. International law now provides certain rights and duties to individuals. International organizations and, to some extent, individuals may be subjects of rights conferred and duties imposed by international law. Certain rules of law relating to individuals and non-state entities so far as the rights or duties of such individuals and non-state entities are the concern of the international community.
A shift from earlier views
The theory of recognizing an entity as a subject of international law based on the capacity of rights and duties under it appears to be sound. A few jurists who had earlier taken the stand that only States are the subjects of international law (Oppenheim, 1955:19) have shifted from their earlier view and have begun to state that States are primarily, but not exclusively the subjects of international law (Agarwal, 2010: 63).
Individual criminal responsibility after the First World War
In the aftermath of the First World War, a Peace Conference was convened and the Treaty of Versailles was adopted on 28 June 1919. The Treaty provided for the prosecution and punishment of individuals who violated the laws and customs of war. It mandated the Allied and Associated Powers to establish a special tribunal to try the William II of Hohenzollern, formerly German Emperor “for a Supreme offence against international morality and the sanctity of treaties” (Article 227 of the Treaty of Versailles 1919) about other individuals who perpetrated war crimes, Article 228 of the Treaty stated that “The German Government recognizes the right of the Allied and Associated Powers to bring before the military tribunals persons accused of having committed acts in violation of the laws and customs of war” (Article 227 of the Treaty of Versailles 1919) and that the German Government shall hand over all accused persons.
Atrocities of World War II as a catalyst for recognition of individual rights and duties
In the period after the Second World War, those individuals who committed heinous crimes were brought to justice with the establishment of the International Military Tribunals for Nuremberg and Tokyo. The Charter of the Nuremberg Tribunal provided the legal foundation for prosecuting persons accused of war crimes, crimes against peace, and crimes against humanity (Article 6 of the Charter of the IMT 1945).
The United Nations and the new perception of individuals
The attitude of international law concerning individuals significantly changed after the creation of the United Nations (Agarwal, 2010). A few jurists who had earlier taken the stand that only States are the subjects of international law (Oppenheim, 1955:19) have shifted from their earlier view and began to acknowledge that States are primarily, but not exclusively the subjects of international law. They further say that international organizations and individuals are also other entities as subjects of international law in addition to States.
In addition to States, individuals have been endowed with limited rights and duties under international law. The rights accorded individuals include human rights and the right to make petitions. International law imposes responsibility upon individuals for punishable offences committed by them (The offences for which individuals are responsible include piracy, espionage, genocide, apartheid, aircraft hijacking, and violation of rules of warfare). However, rape, sexual violence, sexual slavery, enforced prostitution, and other female-related offences committed in situations of armed conflict were not regarded as war crimes for which perpetrators could be prosecuted and punished (The 1949 Geneva Conventions provide penal sanctions for persons committing, or ordering to be committed, any of the grave breaches defined in the Conventions. The offences categorized as grave breaches do not include sexual offences).
Persistence of sexual violence after World War II
Since the end of the Second World War, sexual attack on women and girls in war zones has not abated. The mass rape of Bengali women by Pakistani soldiers in 1971 was a reminder that the sexual attack in conflict remained a major problem. During the Gulf War In 1990, there was a large-scale and premeditated sexual assault on Kuwaiti women by Iraqi forces. In those cases, the perpetrators were never held accountable because there was no legal basis to do so.
Individual criminal responsibility for sexual crimes: The turning point
The year 1993 was significant in the development of international humanitarian law. There were two major developments in the area of individual criminal responsibility for breach of common Article 3 to the Geneva Conventions and the Additional Protocol 11, hitherto not classified as grave breaches and therefore not punishable, and criminal responsibility for sex crimes, hitherto regarded as an inevitable consequence of armed conflict which was normal and also not punishable.
The disintegration of Yugoslavia in 1991 devolved into an armed conflict during which thousands of acts of sexual violence were committed, most notably the rape of detained Bosnian Serb and Bosnian Muslim women (Blank & Noone, 2013:646). The worldwide media, women’s rights groups, and other human rights movements loudly urged the United Nations to condemn the rapes. The UN Security Council, without hesitation, issued Resolution 820 condemning the massive, organized, and systematic detention and rape of women and reaffirmed that those who commit – or order – the commission of such acts will be held individually responsible.
Criminal Responsibility for sexual crimes: from law to action
The UN’s inclusion of rape as a crime against humanity within both statutes signaled the Security Council’s intent to ensure that the perpetrators of rape in Yugoslavia and Rwanda would be prosecuted under international law. The United Nations Security Council vested the ICTY and ICTR with jurisdiction to try perpetrators of sexual violence in those conflicts. The ICC Statute has also criminalized wartime sexual violence (Articles 7 and 8 of the Rome Statute 1998).
Individual Criminal Responsibility for sexual violence in former Yugoslavia
The trial of Dusko Tadic, ICTY 1996
This was the first time that an international tribunal heard direct evidence of rape. Tadic, a Bosnian Serb was charged with 31 counts of grave beaches, war crimes, and crimes against humanity in connection with the torture and murder of Muslims at three Serb prison camps (Prosecutor v Dusko Tadic, case no.IT-94-AR 72). His indictment initially did not acknowledge the importance of the evidence rape at Omarska. It was an amicus brief that made the Judges question the non-inclusion of sexual violence charges. The indictment was amended to include rape. The rape charges were however withdrawn because the witness would not testify due to lack of protection.
The significance of this case was that the Trial Chamber heard the first-ever testimony of rape as a war crime. Although the charges of rape were dropped before the commencement of trial, witness testimony was used as part of the evidence against Tadic in connection with other charges brought against him. The Trial Chamber found him guilty of sex crimes, even though not those in the original charge. It mentioned sexual violence against both men and women and the pain and suffering the victims went through. He was convicted of eleven counts among them “inhumane acts” including sexual mutilation as both a crime against humanity and a war crime.
Furundzija Case, 1998
The defendant was a Croatian military commander. He was charged in connection with the rape and assault of one Muslim victim (Prosecutor v Furundzija, case no. IT-9-917IA, Judgment (July 21, 2000) (Dec 10, 1998). In this case, soldiers had made a woman stand before them naked on a table while they stood around and laughed. While the woman was on the table, the accused pressed a knife against her thigh and threatened her with mutilation if she did not cooperate. Later she was raped by multiple assailants in multiple ways (vaginally, anally and orally).
The Tribunal found that the woman suffered severe physical and mental pain along with public humiliation. He was found guilty on both counts of war crimes. The Tribunal examined the definitions of rape from many countries to be able to arrive at its own, “conducting the first of several exercises in comparative law and the resulting expansive definitions welcome.” The tribunal gave the much-admired definitions of rape and of aiding and abetting.
Celebici Camp Case, 1998
This was a case between The Prosecutor and Zenjnil Delalic, Zadravko Mucic, Hazim Delic, and Esad Landzo. In the indictment against them, it was alleged that in 1992 forces consisting of Bosnian Muslims and Bosnian Croats took control of those villages populated mainly by Bosnian Serbs. Persons detained in the course of the incursion were held at Celebici prison camp in the village of Celebici where they were killed, tortured, sexually assaulted, and subjected to cruel and inhuman treatment by the four accused. Their trial set a milestone in international justice by recognizing rape as a form of torture and as such both a grave breach of the Geneva Conventions and a violation of the laws and customs of war. In its judgment, Zejnil Delalic was found not guilty of the 11 counts; Zdravko Mucic was guilty of 11 counts and sentenced to seven years imprisonment; Hazim Delic was found guilty of 13 counts and sentenced to 20 years imprisonment; and Esad Landzo was found guilty of 17 counts and sentenced to 15 years imprisonment.
Individual Criminal Responsibility for sexual violence in Rwanda
Jean-Paul Akayesu, 1998
The accused person was the mayor of Taba commune (Prosecutor v Akayesu (Akayesu Judgment), case no. ICTR 96-4-T, Judgment (Sep.2, 1998)). He was charged with rape related to the 1994 genocide. Displaced women who sought refuge at the bureau communal where he was in charge were regularly abused sexually by pro-government militias, the local police, and members of various armed groups. The women were subjected to gang rape and sexual slavery to the knowledge of Jean-Paul Akayesu and sometimes in his presence. Witnesses said he incited townspeople to join in the killing and turn former safe havens into places of torture, rape, and murder. In other instances, he promoted the acts of sexual violence due to his being at the scene and by declining to stop the assault on women. The International Criminal Tribunal for Rwanda convicted Akayesu of rape as a crime against humanity and genocide. The conviction is the first of its kind in international law. He was jailed for life.
Nyiramasuhuko and Ntahobali, 2001
Pauline Nyiramasuhuko was the Minister for Family Welfare and the Advancement of Women and one of the principal persons behind the Rwandan genocide. She instigated and supervised the large-scale rape of Tutsi women by Hutu forces in Rwanda between April and July 1994. During her trial, the Prosecutor told the Tribunal that the former Minister engaged the Interahamwe to rape and kill women. Pathetically and cruelly revealing was the fact that her son, Arsene, and other accomplices supervised the rape and killings (BBC News,). She was later arrested in Kenya and brought to face trial before the Rwandan Tribunal based in Arusha, Tanzania.
The indictment against the former Minister included rape which was described as a crime against humanity. Charged along with her were other co-accused persons, namely, her son Arsene Shalom Ntahobali (leader of a militia group), Joseph Kanyabashi (Mayor of Ngoma), Sylvain Nsabimana (Prefet of Butare) and Elie Ndayambaje (Mayor of Muganza). In a case that lasted 10 years, mother and son as well as other defendants were guilty of crimes against humanity including murder and systematic rapes. Nyiramasuhuko is the first woman to be convicted of rape as an international crime by an international tribunal. She and her son were sentenced to life in prison.
Individual Criminal Responsibility for sexual violence in Sierra Leone
Indictments were issued against the principal actors in the Sierra Leone conflict. They include former President of Liberia, Charles Taylor (Prosecutor v Charles Ghankay Taylor, no. SCSL-03-01), the former RUF leader, Foday Sankoh, ex-junta leader Johnny Paul Koroma, former rebel commanders: Issa Sesay, Morris Kallon, Alex Brima and Sam Bockarie. The charges against them included murder, rape, enslavement, looting, and recruitment of children to fight with the rebels (Associated Press,2009: Akpaekong, 2002).
Some of the rebel leaders have been tried, convicted, and sentenced for various crimes committed during the armed conflict. The Trial Chamber imposed upon Issa Sesay, Morris Kallon, and Augustine Gbao sentences of 52, 40, and 25 years of imprisonment respectively. The three were convicted of gender-based crimes against humanity namely rape, sexual slavery, and inhumane acts (forced marriage). They were also convicted of the war crime of outraging upon personal dignity. The Court outlined several gender-based acts, some committed by children such as rape, sexual mutilation and forced nudity, and civilian men being forced to rape civilian women on orders of the RUF.
The ICC and the prosecution of individuals for sexual offences
The ICC is also handling cases involving sexual violence against women in armed conflict. In the past, the Court was criticized for lack of emphasis on crimes of sexual violence perpetrated against women, particularly in DR Congo. In its first case, which was that of Thomas Lubanga, no charges of sexual violence were preferred despite evidence that young girls were raped and sexually assaulted by troops under his command.
The ICC has responded appropriately by including charges of sexual violence in its subsequent indictments. The second case to go to trial at the ICC was that of Germain Katanga, leader of the Forces for Patriotic. Resistance, (FRPI), in the DRC, contains charges of sexual violence. Sexual violence crimes are also included in the indictment against Jean-Pierre Bemba, a former vice-president of the DRC, who is charged with atrocities in the Central African Republic. Callixte Mbarushimana, a member of the Democratic Liberation Force of Rwanda, FDLR leadership is accused of war crimes and crimes against humanity, including rape in the east of DRC where more than 250 women were allegedly raped by FDLR troops under his command.
Prosecution of individuals: One step forward
The prosecution of individuals for war-related sexual violence is adjudged a step in the right direction. Already several individuals, including rebel leaders, military commanders senior government officials, and former heads of state have been tried and convicted for war-related sexual violence. The fact that the individual persons or commanders charged did not personally commit the act themselves is not an excuse or a defence if they and other persons in authority did nothing to prevent the crime or punish the perpetrator.
The prosecution and imprisonment of perpetrators of sexual violence in armed conflict is significant for several reasons. It will reduce impunity, if not put paid to it completely. The idea that women are spoils of war and could be sexually enslaved is quite unacceptable. Impunity concerning sexual violence in armed conflict is rife. Beyond sexual violence being perceived as a by-product of war, it has been used as a weapon of war to humiliate women and their families as well as punish their communities. Prosecuting perpetrators of sexual violence implies that women’s bodies will no longer be used as a battleground.
Criminal Responsibility Regardless of Rank or Position
The current advancement in the jurisprudence of international criminal law points to the fact that individuals are liable for breaches of humanitarian law notwithstanding their status. It applies to everybody in a position of authority whether military or civilian. Even heads of state and government are not exempted. The ad hoc tribunals for the former Yugoslavia, Rwanda, and Sierra Leone have firmly established the doctrine of individual criminal responsibility of persons in leadership positions during times of armed conflict (Rehman, 2010:756).
Several prominent political leaders have been tried and convicted for conflict-related sexual offences, among them, Charles Taylor (Prosecutor v Charles Ghankay Taylor, no. SCSL-03-01), former president of Liberia, Hissene Habre, former president of Chad and Jean-Pierre Bemba, former vice president of D.R. Congo. On trial also is the former president of Cote d’Ivoire, Laurent Gbagbo (The Prosecutor v Laurent Gbagbo ICC – 02 – /11 – 01/11). He was brought before the ICC in 2011 on charges of crimes against humanity, including rape.
Issues and setbacks relating to individual prosecutions
Very few individuals are prosecuted.
In most situations of armed conflict, the perpetrators of sexual violence are not brought to justice. They often go unpunished. Though the doctrine of individual criminal responsibility has come to stay, there is still a very long way to go before its benefits can be fully realized. Very few prosecutions of individuals have been carried out so far from the conflicts scattered around the world. Since the ad hoc tribunals for the former Yugoslavia, Rwanda Sierra Leone wound up their proceedings, there has not been any major prosecution for war–related sexual violence.
In most cases, individuals who commit rape and sexual violence are not prosecuted. The leaders of the armed groups are usually put on trial for the acts committed by their forces. They bear the greatest responsibility for crimes committed during the conflict. The responsibility is described as command responsibility when the leaders fail to prevent the commission of crimes or punish the perpetrators.
Impunity reigns in many war zones
International criminal law still has a long way to go in bringing perpetrators to justice. There are several reported cases of rape and sexual violence in Iraq, Syria and northeast Nigeria. Yazidi women in Iraq have been raped and sexually abused by ISIS fighters. In Syria, thousands of women have been sexually abused by all parties to the conflict. This is also the situation in northeast Nigeria (Barna, 2014) and South Sudan where widespread acts of rape and sexual violence are perpetrated by armed groups.
Factors that contribute to impunity
The following factors have been identified as contributing to impunity concerning war-related sexual violence:
- The general atmosphere of nonchalance towards violence against women.
- Implicit acceptance of rape and other kinds of sexual violence as an inescapable or inevitable part of armed conflict.
- Threats and retaliation against victims and those who divulge sexual assaults.
- Absence of appropriate legal mechanism for prosecution of perpetrators of those crimes.
- Laws giving pardon to perpetrators of sexual violence as part of the peacemaking and reconciliation process.
- Underreporting due to shame, fear of rejection by their husbands, families, and communities; the threat of divorce; and the impossibility of marrying.
Factors that hinder prosecution of sexual offenders
Several sociological, institutional, and legal factors impede the prosecution of wartime sexual offenders. These include lack of knowledge of state laws and remedies by victims; gender disparity which undermines the position of women in society; difficulty in identifying and arresting the perpetrator; and lack of sufficient evidence to secure conviction (Mansfield, 2009:377).
Lack of Effective Justice System
The lack of an effective justice system may constitute a barrier to the prosecution of perpetrators. In Burundi, system failures in the justice system have given rise to an atmosphere where victims of rape are not willing or able to strive for criminal proceedings. In most situations, the justice system suffers from the following set-backs (Human Rights Watch): a) deficiencies in the law; b) unwillingness of military and other officials to treat sexual violence as a serious offence; c) lack of protection for the victims and witnesses; d) insufficient attention to the needs of the victims; e) logistical and financial impediments; f) the dilapidated and fractured state of the judicial system; and g) the overwhelming task of delivering justice for the many crimes committed during the conflict.
Unwillingness to prosecute state personnel involved in sexual violence
The involvement of police and security forces in sexual violence is a major problem since they are meant to protect the victims. The state is always unwilling to prosecute its forces. In most cases, they are regarded as patriots, for making great sacrifices to end insurgency
Sexual violence by peacekeepers
In recent times, UN peacekeepers have been involved in sexual violence in their areas of deployment. There is yet no mechanism for prosecuting them. The law is silent on violations committed by peacekeepers. That is left to the contributing government.
Blaming of victims
Where such reports are lodged, it is not acted upon and in most cases the victim is blamed. Victims are usually unwilling to come forward for fear of stigma. As a result of shame, victims prefer to act as though nothing has happened (Mansfield, 2009:387). Victims are thus dissuaded from prosecuting offenders. An interviewee in DR Congo stated that “if you follow custom, you will hide the rape… custom says that you did it by will, not by force. It’s infidelity according to custom” ((Mansfield, 2009:387)).
Inability to apprehend perpetrators.
The majority of rapes in DR Congo are committed by various armed groups. Securing the arrest of the perpetrators is difficult. Most of them “come from the bush and retreat there following the rape and the theft of the victim’s property. For this type of rape, victims most often cannot identify the perpetrators, and generally can only describe what language they spoke or what armed group they came from. Consequently, many women do not know who to persecute.” In addition, it is difficult to bring a perpetrator who is a member of a rebel group before a tribunal, because he often lives in the bush in the territory which his group controls.
Conclusion
The international community must insist on respect for and protection of women’s rights as well as render appropriate support to the national government to ensure that perpetrators of sexual violence are brought to justice without further delay. It can assist through the provision of necessary infrastructure, funding, training, and an enabling environment to prosecute offenders.
The international community should demonstrate to the victims that their situation can truly be improved by coming forward to report cases of sexual violence. In this regard, recommended measures include the use of female investigators and interpreters and the guarantee of appropriate protection for women who testify in court. The international community should take responsibility for the safety of those willing to testify before international tribunals to ensure effective administration of justice. There should be an adequate protection programme for witnesses and potential witnesses and other forms of ancillary services. This should include physical and mental health, social, and other services to promote the interests of witnesses and to ensure the effective functioning of the ad hoc War Crimes Tribunals and the ICC. Adequate professional support and appropriate gender training should be provided for all departments of the ad hoc war Crimes Tribunals and the ICC, especially the witness protection unit of the Registry.
Gender balance should be a consideration in judicial appointments alongside the existing requirement of geographic distribution and professional and personal qualities. Gender balance in international judicial posts should indeed be an explicitly stated goal. The UN can cooperate and work with the ICC in bringing perpetrators to justice. Prohibition of rape and other forms of sexual violence must be incorporated into the domestic law and in the military codes and training handbook of all countries in the world.
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