Abstract
In 2004, the International Criminal Tribunal for Rwanda (ICTR) has delivered six judgements, two on appeals, four on trial. 1 Only three of those judgements are presented in this paper, namely the Gacumbitsi Trial Judgement, Ndindabahizi Trial Judgement and Ntakirutimana Appeals Judgement. During the same period, there were eight on-going trials in which no judgement has been rendered yet: Among those trials, the Karemera et al. case has encountered some serious procedural incidents. Following a challenge to the impartiality of the Presiding Judge and of the Bench, Judge Andrésia Vaz (from Senegal) withdrew from the case. The Bureau therefore dismissed the Defence applications, considering them as moot. 2 The two remaining Judges decided to continue the trial with a third Judge appointed by the President of the Trial, in accordance with Rule 15 bis of the Rules of Procedure and Evidence. But, on an appeal lodged by the Defence...
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