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Prosecutor v. Étienne Nzabonimana and Samuel Ndashyikirwa alias Samuel Manzi

This case summary is being revised and will be updated soon

Court Cour d'assises de l'arrondissement administratif de Bruxelles-Capitale, Belgium
Decision title Arrêt
Decision date 29 June 2005
  • Étienne Nzabonimana
  • Samuel Ndashyikirwa alias Samuel Manzi
  • Prosecutor
Other names
  • Manzi
Categories War crimes
Keywords genocide, jurisdiction (universal), Rwanda, war crimes
Other countries involved
  • Rwanda
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Legally relevant facts

Brought under Belgian laws of universal jurisdiction, two Rwandan businessmen were charged with war crimes committed during the genocide in 1994 in the second case of its kind in Belgium. The trial of Etienne Nzabonimana and Samuel Ndashyikirwa followed modifications in 2003 to a 1993 law allowing for the prosecution of persons suspected of war crimes, crimes against humanity and genocide, regardless of where the alleged acts were committed or the nationality of the accused or victims. Under the 2003 amendments to the law, which restricted the jurisdiction of Belgian courts to prosecute such cases, Nzabonimana and Ndashyikirwa could still be tried since they were arrested in Belgium.

The charges against the two related to massacres committed in the Kibungo area of Rwanda. Nzabonimana was accused of helping to organise the killings of civilians by the Interahamwe militias.

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Court's holding and analysis

On 29 June 2005, Nzabonimana and Ndashyikirwa were found guilty of war crimes and sentenced to 12 and ten years’ imprisonment respectively.

The decision of the Court has several interesting facts, including the decision that the men could be convicted for crimes committed against persons who had not been identified. Furthermore, the Court considered as extenuating circumstances the tense situation in Rwanda at the time of the killings, as well as the incitement of racial hatred by the RTLM radio station.