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Dominique Ntawukulilyayo was the sub-prefect of the Gisaraga sub-prefecture within Butare prefecture, in Rwanda, from 21 September 1990 until he left Rwanda in July 1994.

On 3 August 2010, the Trial Chamber of the ICTR convicted Mr. Ntawukulilyayo of genocide for ordering, as well as aiding and abetting, the killings of Tutsi civilians at Kabuye hill in April 1994. He was sentenced to 25 years of imprisonment.

Ntawukulilyayo appealed his conviction. On 14 December 2011, the Appeals Chamber of the ICTR acquitted him of the charge of ordering the killings at Kabuye hill. Nevertheless, the Appeals Chamber agreed with the Trial Chamber that the Accused was guilty of aiding and abetting genocide by instructing the refugees who had gathered at Gisaraga market to move to Kabuye hill, and by transporting soldiers who participated in the attack at Kabuye hill on 23 April 1994. His sentence was reduced to a term of 20 years of imprisonment.  

During the Rwandan genocide Athanase Seromba was a Catholic priest at Nyange parish, Kibuye Prefecture. On 13 December 2006, Trial Chamber III of the ICTR convicted him of aiding and abetting genocide against Tutsi refugees who had sought refuge at Nyange parish in order to escape attacks committed against the Tutsis. The Trial Chamber also found that Seromba had assisted in the killing of Tutsi refugees as well as in the commission of acts causing serious bodily or mental harm. Thus, the Chamber convicted him of aiding and abetting the crimes of genocide and extermination as a crime against humanity and sentenced him to 15 years of imprisonment.

The Trial Chamber considered the Accused’s authority as a respected Catholic priest, the trust he had from several Tutsi refugees who had taken shelter in his parish to elude massacres and his failure to live up to the trust of the refugees who thought their lives would be safe there as aggravating factors. Seromba’s good reputation prior to the events of 1994, his relative youth at the time of the events and his voluntary surrender to the Tribunal were considered mitigating factors. 

The death of Rwandan President Habyariamana on 6 April 1994 reignited ethnic tensions in Rwanda between the Hutu and Tutsi populations that had previously resulted in a civil war in the early 1990s. An Interim Government was established, which developed a plan to eradicate the Tutsi “enemy” with the use of the armed forces and various civilian militia groups including the feared Interahamwe.

The six Accused in the present case all represented military, political or civilian authorities in Butare commune: Nyiramasuhuko was the Minister of Family and Women’s Development; Nsabimana served as the prefect of Butare from April until 17 June 1994; Nteziryayo was a member of the Ministry of the Interior; Kanyabashi was the mayor of Ngoma commune; Ndayambaje was the mayor of Muganza commune and Ntahobali was a leader of a unit of the Interahamwe. Following the replacement of the former prefect of Butare by Nsabimana on 20 April 1994, large scale massacres of Tutsi took place in Butare commune. Thousands were slaughtered with machetes and grenades at Mugombwe Church, Kabuye Hill, Kabakobwe Hill and Matyazo Clinic. In line with the Interim Government’s policy, roadblocks were set up at which Tutsi could be identified, separated, abducted, raped and killed by soldiers and Interhamwe alike. Megaphone announcements were heard throughout Butare town encouraging the Hutu to flush out and eradicate their Tutsi enemy.

The International Criminal Tribunal for Rwanda convicted each of the Accused variously for genocide, cnspiracy to commit genocide, direct and public incitement of genocide, the crimes against humanity of extermination, persecution and rape and the war crimes of violence to life and outrage supon personal dignity. Nyiramasuhuko, Ntahobali and Ndayambaje were sentenced to life imprisonment; Kanybashi, Nteziryayo and Nsabimana to 35, 30 and 25 years’ imprisonment respectively.

The case is currently on appeal before the Appeals Chamber of the ICTR. 

Following the death of Rwandan President Habyariamana in April 1994, an interim government was established in Rwanda within which Callixte Nzabonimana held the position of Minister of Youth and Associative Movements.

The Trial Chamber found that Nzabonimana was a figure of authority in Gitarama as a result of this position and his role in the political party, MNRD. Evidence presented led the Trial Chamber to conclude that the Accused had used this position of authority to direct the Hutu civilian population and commune policemen to attack the Tutsi’s. He did so by making a number of speeches, and further, by threatening local officials with death or replacement in the event that they opposed the killing of Tutsis.  His orders were carried out by Hutu civilians and by commune policemen who proceeded to attack and kill Tutsi civilians. Accordingly, the International Criminal Tribunal for Rwanda convicted the Accused of genocide, conspiracy to commit genocide, direct and public incitement to commit genocide and extermination as a crime against humanity. He was sentenced to life imprisonment.