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PART III - TRIALS AND TRIBUNALS

Truth and justice, June 2006, Daan Bronkhorst


THE SIGNIFICANCE OF TRIALS

In most states that had truth commissions or lustration efforts (some fifty in total) some people have been convicted, but generally only a handful. With all the enthusiasm caused by trials, there is a caveat. The significance of trials for reconciliation may be quite limited. In a book on reconciliation in the former Yugoslavia and Rwanda, Eric Stover and Harvey Weinstein wrote:
Our studies suggest that there is no link between criminal trials (whether international or national or local and traditional) and reconciliation […] In fact, we found criminal trials – and especially those of local perpetrators – often divided small multi-ethnic communities by causing further suspicion and fear. Survivors rarely, if ever, connected retributive justice with reconciliation. Reconciliation, in their eyes, was mostly a personal matter to be settled between individuals… [Neither is there] a direct link between exposure to trauma and a desire for trials of suspected war criminals.
Survivors generally press for trials. But the authors’ research findings suggest that if they get what they want, it may not have the expected effect at all:
For survivors the idea of 'justice' encompasses more than criminal trials. It means returning stolen property; locating and identifying the bodies of missing; capturing and trying all war criminals, from the garden-variety killers in their communities all the way up to the national ideologues who had poisoned their neighbours with ethnic hatred; securing reparations and apologies; leading lives devoid of fear; securing meaningful jobs; providing their children with good schools and teachers; and helping those traumatized by atrocities to recover.

DOMESTIC ADJUDICATION

Some truth commission operations did not preclude domestic trials in later years, as in Argentina, Bolivia, Chile, Guatemala, Germany, South Africa and Sri Lanka. However, domestic trials have remained conspicuously absent in most countries that have an appalling human rights record. In very few cases were truth commissions directly connected with judicial bodies that could rule on ‘prosecution or amnesty’, such as the South African Amnesty Committee.

In some countries a special prosecutor, special court or mixed system effectively took on both the fact-finding tasks of a truth commission and the judicial prosecution of those responsible.

  • The Special Prosecutor's Office in Ethiopia was established in 1992 to create a historical record of the abuses committed during the Mengistu Government (the Derg period). The federal High Court considered the cases of 2,658 defendants accused of genocide, war crimes, and aggravated homicide. Trials began in 1994. In April 2002, of the 6,426 defendants who were awaiting trial 2,952 had been tried in absentia. A total of 1,569 cases had decisions handed down; of these 1,017 persons were convicted. As of early 2006, about a thousand persons remained in detention charged with Derg-era offences. 
  • In Iraq, the long-awaited trial of Saddam Hussain started in Iraq in October 2005. Although the opportunity to obtain justice for some of the crimes committed under his regime was welcome, Amnesty International had ‘serious concerns about the lack of fair trial guarantees in the statute of the tribunal, denial of proper access to counsel and the provision of the death penalty’. 
  •  In May 2006, eleven Bosnian Serbs appeared before the Sarajevo-based Bosnia-Herzegovina War Crimes Chamber to face charges of war crimes. They were charged with genocide against Bosnian Muslims in the former eastern Bosnian Muslim enclave of Srebrenica in July 1995. This so-called 'Kravica' case has been the first case relating to the Srebrenica massacre before Bosnia's War Crimes Chamber which was officially opened in March 2005. During the trial, the court said, some testimony already given before the Hague-based International Criminal Tribunal for the former Yugoslavia (ICTY) by some high-ranking Bosnian Serb military officers indicted for war crimes, is to be used before the court in Sarajevo.

INTERNATIONAL ADJUDICATION

So far, only few perpetrators of gross human rights violations have been brought to justice under a form of international adjudication. However, there has been significant progress given that between the end of the Tokyo Tribunal in 1948 and the start of the Yugoslavia Tribunal 35 years later, no one was tried internationally.
In its Annual Report 2006, Amnesty International 'saw some significant developments towards bringing to justice those responsible for crimes under international law, including genocide, crimes against humanity, war crimes, torture, extrajudicial executions and enforced disappearances. However, there was also continuing widespread impunity in national courts in the states where crimes were committed, as well as only limited use of universal jurisdiction by courts in other states.' The report noted, among many items:

  • In October 2005, the International Criminal Court (ICC) announced its first ever arrest warrants for five leaders of the Lord's Resistance Army for crimes against humanity and war crimes committed in northern Uganda. 
  • The ICC continued to investigate crimes committed in the Democratic Republic of Congo [it issued the first arrest warrants in March 2006] 
  • While the UN Security Council's referral to the ICC of crimes committed in Darfur, Sudan, was a positive step in addressing impunity, it was disappointing that the Security Council, as part of a compromise to ensure US support, included in its resolution a provision to exempt nationals of states not party to the Rome Statute of the ICC (other than Sudan) from the jurisdiction of the Court. 
  • The Special Court for Sierra Leone advanced in three trials involving nine suspects charged with war crimes and crimes against humanity. However, the Sierra Leone government took no steps to end an amnesty which prevents prosecution of all others in Sierra Leone responsible for crimes under international law. 
  • Some progress was made in establishing Extraordinary Chambers for Cambodia. These were expected to try no more than half a dozen people for crimes committed while the Khmer Rouge were in power, while tens of thousands of others continued to benefit from a national amnesty.

INTERNATIONAL (OR MIXED) AD HOC TRIBUNALS AND SPECIAL COURTS

Ad hoc international tribunals were established under UN auspices in the 1990s: on the former Yugoslavia in 1993 and on Rwanda in 1994. 

  • The International Tribunal for the Prosecution of Persons Responsible for Serious Violations of International Humanitarian Law Committed in the Territory of the Former Yugoslavia since 1991 (ICTY), is a body of the United Nations established to prosecute war crimes in the former Yugoslavia. It was established by Resolution 827 of the UN Security Council, which was passed on May 25, 1993. It has jurisdiction over certain types of crime committed on the territory of the former Yugoslavia since 1991: grave breaches of the 1949 Geneva Conventions, violations of the laws or customs of war, genocide, and crime against humanity. It can try only individuals, not organizations or governments. The maximum sentence it can impose is life imprisonment. Various countries have signed agreements with the UN to carry out custodial sentences. The last indictment was issued March 15, 2004. The tribunal aims to complete all trials by the end of 2008 and all appeals by 2010. The Tribunal employs some 1,200 staff. Its main organisational components are Chambers, Registry and the Office of the Prosecutor. The two-year budget for the Tribunal for 2004 and 2005 was US$ 270,000. As of March 2006, the ICTY had indicted 161 persons. Only six of these remained at large. The cases against 85 of the indicted had been concluded: 43 were found guilty, 8 acquitted, 25 had their indictments withdrawn and six had died. 
  •  The International Criminal Tribunal for Rwanda (ICTR) was created on November 8, 1994 by the United Nations Security Council in order to judge those people responsible for the acts of genocide and other serious violations of the international law performed in the territory of Rwanda, or by Rwandan citizens in nearby states, between 1 January and 31 December 1994. The tribunal has jurisdiction over genocide, crimes against humanity and war crimes. The first trial started in 1997. The Tribunal consists of 16 Judges in four ‘chambers’ - three to hear trials, and one to hear appeals. In addition, there are 9 ad litem judges, making 25 in all. The ICTR will have spent upwards of 1 billion U. S. dollars by 2007 since its inauguration in 1995. The staff consists of some 1,000 people from 85 countries. Up to early 2006, the Tribunal had finished 21 trials and convicted 27 accused persons; 11 trials were in progress; 15 individuals were awaiting trial in detention; 18 others were still at large. All trials are to be completed by the end of 2008. 
  •  The Serious Crimes Unit (SCU) in East Timor was responsible for investigations and indictments concerning genocide, war crimes, crimes against humanity, murder, sexual offences and torture that occurred in 1999. Pursuant to UN Security Council resolutions, the SCU ceased its investigations in November 2004 and ceased virtually all other operations in August 2005. At the time of its closure the SCU had filed 95 indictments against 391 persons. Of these 290 remained at large in Indonesia with little chance of being returned to stand trial. In 2000 the UN-sponsored transitional administration had also established the Special Panels on Serious Crimes within the Dili District Court to try those charged with the mass killings and other gross human rights violations committed in 1999. The two Special Panels each consist of two foreign judges and a local judge. The Special Panels were adjourned in May 2005. The Special Panels had then issued 84 convictions, three acquittals (one of which was later overturned by the Court of Appeals) and 13 indictment dismissals. 
  • In January 2002, the UN and the government of Sierra Leone adopted an Agreement on the Establishment of a Special Court for Sierra Leone ‘to prosecute persons who bear the greatest responsibility for serious violations of international humanitarian law and Sierra Leonean law committed in the territory of Sierra Leone since 30 November 1996’. The Special Court has primacy over the national courts of Sierra Leone. It is therefore an international criminal court, although some of its judges and other officials are nationals of Sierra Leone, giving it a hybrid character. As of early 2006, eleven persons associated with all three of the country's former warring factions stood indicted. In March 2006, former president Charles Taylor, who had found exile in Nigeria, was arrested and handed over to the court. 
  •  In 2005, Cambodia was finally set to proceed with a United Nations-prescribed tribunal against former Khmer Rouge leaders for their alleged role in genocide and crimes against humanity, including culpability for the deaths of an estimated 1.7 million people. The court is half-foreign, half-Cambodian. International prosecutors are expected to unearth compelling new evidence against former senior Khmer Rouge cadres, some of whom now serve in Prime Minister Hun Sen's government. The Supreme Council of the Magistracy approved 30 judicial officials for the trial, 13 of whom are UN-appointed foreign nationals. The five-member trial chambers and seven-member Supreme Court chamber will sit more Cambodian judges than foreign ones, while the Cambodian government and the UN will each provide one prosecutor and one investigating judge. The courts will act on a ‘super-majority’ basis, where judgments must be agreed by at least one foreign judge. However, the same is not true for the co-prosecutors, and the Cambodian prosecutor may veto contested indictments.

THE INTERNATIONAL CRIMINAL COURT

The International Criminal Court (ICC) was established in 2002 as a permanent tribunal to prosecute individuals for genocide, crimes against humanity, and war crimes, as defined by several international agreements, most prominently the Rome Statute of the International Criminal Court. The foundational Rome Statute (1998) became a binding treaty at the moment 60 states had ratified it, on 11 April 2002. The ICC is designed to complement existing national judicial systems; however, the Court can exercise its jurisdiction if national courts are unwilling or unable to investigate or prosecute such crimes, thus being a ‘court of last resort,’ leaving the primary responsibility to exercise jurisdiction over alleged criminals to individual states. The Chief Prosecutor of the court initially decided to open an investigation into three matters: Uganda and the Lord's Resistance Army; the situation in Ituri, Democratic Republic of Congo; and the situation in Darfur, Sudan. As of early 2006, more than 100 states were parties to the Statute.

The official seat of the ICC is in The Hague (Netherlands), but the Rome Statute permits the court to engage in proceedings anywhere. The ICC has a prosecutor and 18 judges. The ICC is composed of the Court itself, divided into a number of chambers (Pre-Trial, Trial and Appellate); the Registry; the Office of the Prosecutor; and the Assembly of State Parties. The United States has not ratified the treaty creating the court, objecting the interference with their national sovereignty and a fear of politically motivated prosecutions. The US has also made Bilateral Immunity Agreements, so-called ‘Article 98’ agreements, with a number of countries, prohibiting the surrender to the ICC of a broad scope of persons including current or former government officials, military personnel, and U.S. employees (including non-national contractors) and nationals.

On 17 March 2006 Thomas Lubanga Dyilo, a Congolese national and alleged founder and leader of the Union des Patriotes Congolais (UPC) was arrested in Kinshasa and transferred to the ICC. The court found that there were reasonable grounds to believe that Mr Lubanga had committed the crime of conscripting and enlisting children under the age of fifteen years, and using them to participate actively in hostilities. Lubanga was the first person to be arrested and transferred to the ICC since the entry into force of the Statute in July 2002.

UNIVERSAL JURISDICTION

Under international law, states can enact national criminal laws which allow national courts to investigate and prosecute people suspected of crimes committed outside of the state's territory, including crimes committed by a national of the state, crimes committed against a national of the state and crimes committed against a state's essential security interests. There is also an all-inclusive form of jurisdiction called universal jurisdiction which provides that national courts can investigate and prosecute a person suspected of committing a crime anywhere in the world regardless of the nationality of the accused or the victim or the absence of any links to the state where the court is located. Since the Second World War, more than a dozen states have conducted investigations, commenced prosecutions and completed trials based on universal jurisdiction for the crimes or arrested people with a view to extraditing the persons to a state that will prosecute. These states include Australia, Austria, Belgium, Canada, Denmark, France, Germany, Israel, Mexico, Netherlands, Senegal, Spain, Switzerland, the United Kingdom, the United States.

So far there have been few cases of arrests under the principle of universal jurisdiction. Serb war criminals have been prosecuted in German, Danish and other courts. Canada opened its first case under its universal jurisdiction legislation of 2000, charging Désiré Munyaneza with genocide, crimes against humanity and war crimes committed in 1994 in Rwanda. The most noticeable case have been the detention of Chilean General Augusto Pinochet in London, 1998-2000, and the attempt in 2000-2001 to convict the former ruler of Chad, Hissein Habré before a court in Senegal.

  • The Pinochet case is the most well known case where states have exercised universal jurisdiction. On 16 October 1998, Augusto Pinochet, the former President of Chile was arrested in London in response to an arrest warrant issued by a Spanish court charging Augusto Pinochet with human rights violations including murder, torture and ''disappearance'' committed during his administration in Chile between 1973 to 1990. Most of the crimes that Augusto Pinochet was charged with were committed in Chile against Chilean nationals. Spain applied for Augusto Pinochet's extradition to be prosecuted in Spain. Belgium, France and Switzerland also issued extradition requests. In March 1999 the House of Lords, the UK's highest court, ruled that Augusto Pinochet's immunity as a former head of state extends only to acts done in his official capacity as a head of state. The Law Lords ruled that acts of torture as crimes under international law could not be acts within the official capacity of a head of state and that extradition proceedings to Spain should continue. In March 2000, Augusto Pinochet was returned to Chile on grounds that he was not medically fit to stand trial. Later he was against put under house arrest, pending cases before Chilean courts.
  • In February 2000, a Senegalese court relying on the principle of universal jurisdiction, indicted Chad's exiled former President, Hissein Habré, on charges of torture committed during his rule between 1982 and 1990. A 1992 Truth Commission Report concluded that 40,000 political murders and 200,000 cases of torture occurred in Chad when Habré was President. Senegal had ratified the Convention against Torture, which requires states parties to exercise universal jurisdiction over persons found in their territory. Habré's lawyers challenged the indictment and the Court of Cassation ruled that Senegalese courts have no jurisdiction over acts committed by foreign national outside their territory. Habré was still held in Senegal as a result of an appeal by the UN Committee against Torture to Senegal. Complaints have since been filed against Habré in Belgium. 
  • In Belgium in 1993, parliament voted a law of universal jurisdiction, allowing it to judge people accused of war crimes, crimes against humanity or genocide. In 2001, four Rwandan people were convicted of sentences from 12 to 20 years of prison for their involvement in 1994 Rwandan genocide. But there was quickly an explosion of suits deposed. Prime Minister Ariel Sharon was accused of involvement in the 1982 Sabra-Shatila massacre in Lebanon, conducted by a Christian militia ostensibily under his control, while some Israelis deposed a suit against Yasser Arafat for his presumed responsibility for terrorist actions. In 2003, Iraqi victims of a 1991 Bagdad bombing deposed a suit against George H.W. Bush, Colin Powell and Dick Cheney. Confronted with this sharp increase in deposed suits, Belgium established the condition that the accused person must be Belgian or present in Belgium. However, in September 2005, Chad's dictator Hissène Habré was indicted for crimes against humanity, torture, war crimes and other human rights violations by a Belgium court. 
  • In October 2005, the Audiencia Nacional, the National Court of Spain, declared that the ‘principle of universal jurisdiction prevails over the existence of national interests’, following a suit deposed in 1999 against atrocities committed in Guatemala between 1978 and 1986. In July 2003, the Argentine judiciary started procedures to extradite (or bring to trial) 46 former members of the junta apparatus, on a request of the Spanish judge Baltasar Garzón.

CIVIL SUITS

Another way to claim compensation is through civil suits. The civil law of many countries allows for public officials to be sued for damages resulting from human rights violations. Often civil suits are the only remedy left when criminal prosecution has been blocked. For example in Uruguay in 1990, several relatives of people killed or ‘disappeared’ obtained compensation from the state following civil court rulings. Also Czech lustration laws were prompted by civil suits.

There also have been civil suits, notably in the USA, against perpetrators of extrajudicial executions and torture in foreign countries. In July 2003, Human Rights Watch described the Alien Tort Claims Act (ATCA) as ‘one of the only tools Americans have to make human rights abusers pay for their actions’. The Act allows foreign victims of serious human rights abuse abroad to sue the perpetrators in US courts. The ATCA was written in 1789, the original intent being to persuade European countries that the new United States would not become a haven for pirates. In 1979 the father and sister of Joel Filartiga, a seventeen-year-old who had been tortured to death in Paraguay, used the act against Joel’s torturer, who was living in Brooklyn at the time. They were awarded US$ 10 million in damages (but were not able to collect the money from the defendant). Later cases included that of Bosnian victims of a rape camp who sued Bosnian Serb leader Radovan Karadzic. Over twenty individuals from Guatemala, Philippines, Ethiopia, Argentina, the former Yugoslavia and other countries have been convicted to pay damages, or are awaiting a judicial ruling. Over 25 cases against corporations have been brought under the ATCA.

Claimants have been assisted by NGOs such as the Center for Justice & Accountability and the Center for Constitutional Rights in the US, and Redress in the UK.

AMNESTY

Some truth commission reports were followed by an overall amnesty (El Salvador, 1993, Uruguay 1986) or could not easily cancel previously ruled amnesties (Chile, Haiti). Other commissions were instrumental in convictions which were however overturned by amnesty or pardon later (Argentina, 1980s).

Justice is essential, but international law does not unconditionally demand punishment in all cases; it also offers the option of amnesty. The Fourth Geneva Convention states in Article 146 that ‘the parties...shall bring persons alleged to have committed serious breaches before its own courts, or hand them over to another High Contracting Party’. These serious breaches refer to ‘wilful killing, torture or inhuman treatment’. The Second Protocol of the Geneva Conventions states in Article 6.5 that ‘at the end of the hostilities, the authorities shall endeavour to grant the broadest possible amnesty’.

Conditions for proclaiming amnesty have included:

  • Official, public acknowledgment regarding individual perpetrators. 
  • Amnesty or pardon petitioned by individual perpetrators. 
  • Full disclosure by perpetrators. 
  • Victims are allowed to seek reparation from the state. 
  • Amnesty decided on by a regular judicial body (not a temporary commission, a government or parliament, or a treaty).

Amnesty International's position on pardons and amnesties is that `impunity negates the values of truth and justice and leads to the occurrence of further violations'. In a letter to President Nelson Mandela in June 1994, Amnesty International pointed out that victims and their families have a right, recognized under UN human rights treaties, to full investigation and redress. The organization was concerned that any pardons should be granted only after perpetrators of serious human rights violations are brought to justice. Pardons notwithstanding, those who are convicted must be prohibited from holding future positions involving authority over prisoners, or from having responsibility for decisions on the use of force.

ONGOING DEMANDS FOR TRIALS

Truth commission may by now be well established in the international scene, yet they have not at all become irrefutable. There are many groups and individuals, particularly in such countries as Argentina, Chile and Guatemala where a truth commission was supposed to finalize a repressive past once and for all, which see such commissions as a political move to pass over the real culprits. Groups of relatives of ‘disappeared’ and killed persons continue to demand prosecution. They are justified in doing so, for three reasons: 

  1.  It is the law: International law, according to most experts, places a responsibility on governments to prosecute, in particular regarding the most serious crimes such as genocide, extrajudicial executions, ‘disappearances’ and torture. The Inter-American Court on Human Rights, among others, has repeatedly stated that amnesties are not acceptable if they sweep crimes under the carpet.
  2. It is possible: Recent developments in particular have shown that it is possible to bring to book even the most high-level state functionaries. This is the tendency in the ad hoc tribunals on the former Yugoslavia and Rwanda, in the Statute of the International Criminal Court, and in the examples of successful application of universal jurisdiction. 
  3. It is a real need: Committees of relatives and other groups by their very demands indicate that the ‘reconciliation’ which the truth commissions were presumed to bring about, remains unacceptable for many who were particularly afflicted by the human rights abuses of the recent past.

COMMUNITY-BASED JUSTICE

Community-based and traditional systems of justice are used to adjudicate and mediate where the state justice system does not reach down to the local level, or where ethnic, religious or national groups have successfully defended their traditions against the central authority. Community justice may help solve conflicts and foster re-integration. However, since they do not adhere to international standards of human rights, they run serious risks of arbitrariness and can generally not be appealed. They should at best be used as a supplementary means of justice.

Common features of such systems include:

  • They are often unrelated to national or international law. 
  • They focus on community-oriented problem solving. 
  • The arbiters are generally influential people from the community. 
  • Usually the defendants have no professional legal representation. 
  • Decisions are often a compromise, a settlement. 
  • The penalties emphasize restoration above retribution. 
  • The enforcement is through social pressure rather than coercion. 

The judiciary in Rwanda continues efforts to resolve the enormous genocide caseload of more than 53 thousand detainees (as of early 2006). Traditionally this system dealt with civil conflicts on land, marriage and property. Gacaca processes are being held at local level, overseen by legal advisers and a department of the Supreme Court. Gacaca public courts served as the government's primary judicial process for adjudicating thousands of genocide cases. The gacaca law provides for reduced sentences, including community service, for cooperation and credit for time served. Lawyers were not permitted to participate officially in gacaca but could testify as private citizens. There was a right of appeal in gacaca proceedings at sector-level courts in the 118 pilot project gacaca sectors. Legislation establishing the Gacaca tribunals was enacted in early 2001. In late 2001, 260,000 adults of ‘integrity, honesty and good conduct’ were selected by local communities to serve as magistrates on the more than 10,000 gacaca tribunals. These magistrates received limited training. Gacaca tribunals are legally established judicial bodies and their judges can impose sentences as high as life imprisonment. The gacaca system officially began in 2005. The department of gacaca jurisdiction then declared that more than 760,000 people could be prosecuted (one in four of the adult population) and that the process should be completed by 2007. Amnesty International noted in its 2006 Report that ‘there was widespread distrust of the gacaca system. Some Rwandans feared being exposed for their involvement in the genocide by the gacaca tribunals. Others feared that the tribunals could be used by individuals to resolve personal conflicts or to make economic gain.’ As of early 2006, there was a total of 40 thousand cases, including genocide cases, pending in the courts.

Other examples of community-based mechanisms are:

  • Bangladesh: The salesh informal court on village level. 
  • Australia: The traditional justice system of indigenous people. 
  • Bhutan: The jambi system of traditional mediators. 
  • Pakistan: The sardar feudal and tribal justice system. 
  • Afghanistan: The saranwali system of community mediators. 
  • Northern Ireland: The ‘community restorative justice projects’ 
  • Mozambique: The khufemba traditional healing system, with II curandeiros as traditional healers.

In a report on Afghanistan, in August 2003, Amnesty International recommended to ‘undertake a comprehensive review of the informal justice systems (…):This review must assess whether these systems apply procedures and laws that are in conformity with human rights protections, including the right to a fair trial, the prohibitions against torture, and ill-treatment and non-discrimination (…). The relationship between informal systems and the formal judicial system must be set out by law. (…) [The government] must ensure that jirgas and shuras, if they are allowed to continue to function, fully conform to international human rights law. If this cannot be ensured then these informal justice mechanisms must be abolished (..) All cases in which there are indications that a jirga or shura has perpetrated human rights abuses must be thoroughly investigated and all those participating in them must be brought to justice.’

LITERATURE AND WEBSITES

Amnesty International, ‘International Justice’, at http://web.amnesty.org/pages/uj-index-eng
Bass, Gary Jonathan (2001). Stay the Hand of Vengeance: The Politics of War Crimes Tribunals. Princeton University Press.
Coalition for the International Criminal Court, at www.iccnow.org.
Lattimer, Mark & Philippe Sands, eds. 2004). Justice for Crimes Against Humanity. New York: Hart.
Neier, Aryeh (1998). War Crimes: Brutality, Genocide, Terror, and the Struggle for Justice. New York: Crown.
Project on International Courts and Tribunals, at www.pict-pcti.org
Robertson, Geoffrey (1999). Crimes Against Humanity: The Struggle for Global Justice. New York: New Press.
Roht-Arriaza, Naomi, ed. (1995). Impunity and Human Rights in International Law and Practice. New York: Oxford University Press.
Shelton, Dinah, ed. (2004). Encyclopedia of Genocide and Crimes against Humanity. New York: Macmillan.
Shelton, Dinah (2005). Remedies in International Human Rights Law. Oxford: Oxford University Press.
Wikipedia, at www.wikipedia.org
See also under ‘Literature’ in Part I - Truth Commissions

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