From the International Criminal Tribunal for Rwanda to the International Criminal Court: Expanding the Definition of Genocide to Include Rape
![handle is hein.journals/dlr108 and id is 359 raw text is: I Comments I
From the International Criminal Tribunal for
Rwanda to the International Criminal Court:
Expanding the Definition of Genocide To
Include Rape
Alexandra A. Miller*
I. Introduction
On July 18, 1997, Kenyan and international authorities arrested
Pauline Nyiramasuhuko (Pauline), the former National Minister of
Family and Women's Affairs for Rwanda.1 The Office of the Prosecutor
for the International Criminal Tribunal for Rwanda (Tribunal), formed
to address the atrocities committed in Rwanda in 1994, charged Pauline
with eleven counts involving genocide and crimes against humanity.2
* J.D. Candidate, The Pennsylvania State University Dickinson School of Law,
2004.
1. Press Release, International Criminal Tribunal for Rwanda, Pauline
Nyiramasuhuko: Former Minister of Women Development Pleads Not Guilty (Sept. 3,
1997), available at www.ictr.org; see Peter Landesman, Woman's Work, N.Y. TIMES
MAG., Sept. 15, 2002, at 85. To date, Mr. Landesman's article on Pauline and the rapes
occurring during the genocide is the only extensive source on Pauline's background. Id.
2. Prosecutor v. Pauline Nyiramasuhuko & Shalom Ntahobali, Case No. ICTR-97-
21-I (Jan. 3, 2001), available.at http://www.ictr.org [hereinafter Nyiramasuhuko].](ViewImageLocal?handle=hein.journals/dlr108&div=25&collection=journals&method=preview&ext=.png&size=3)
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