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Who is a Civilian? A Follow up on the Status of Hamas Police Officers

Published on January 9, 2009        Author: 
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At the end of 2008, I put up a post in which I suggested that a key issue in assessing the lawfulness of Israeli airstrikes in Gaza was determning the status of Hama police officers. Before attempting to make the proportionality calculation International Humanitarian Law (IHL) requires, one has to first answer the question who is a civilian and who is a legitimate target. As has been pointed out on this site, one needs to be clear about the relevant facts before engaging in the required legal analysis.

Darryl Li, a student of mine at Yale Law School, sent me an email, in response to my earlier post, in which he attempts to set out what he considers to be the relevant facts regarding the structure of the Gaza police and the status of the police officers. Darryl has worked in Gaza for Human Rights Watch, B’tselem (the Israeli Human Rights group), and the Palestinian Centre for Human Rights. With his permission, I set out some of his email to me.

Gaza police are distinct, operationally and otherwise, from the armed wing of Hamas, the ‘Izz al-Din al-Qassam Brigades.  There may be individuals who are members of both but Hamas-controlled police use the same facilities, wear the same uniforms, and have pretty much the same internal chain of command that existed under Fatah control, at least as far as I could tell during my last trip in January.  Hamas membership is not a prerequisite to being hired, though I’m sure it helps.  Indeed, the commander of the Gaza police, who was killed on the first day of the raids, Tawfiq Jabr, was actually a Fatah man, a career police official who had even supervised the arrest of Hamas activists during the Oslo period.

Ever since the establishment of the Palestinian Authority, the security services, and especially general police, have for the most part hampered armed attacks against Israel.  Not simply in the general sense of cracking down (or not — there is an old tired debate about this) on such groups, but more importantly because they have served as a public employment mechanism and have essentially ‘captured’ the labor of middle-aged cadres, Soviet and Chinese-trained, who developed considerable military experience while fighting in Lebanon. This dynamic deprived the armed groups of useful military experience and in the early years after 2000 left armed attacks essentially in the hands of children (case-in-point: Zakaria Zubaydi of the Aqsa brigades in Jenin).

In fact, the non-combatant status of Hamas policemen — which in this case is also tantamount to their plain-sight vulnerability to massive aerial attack — points to probably the only interesting political lesson I have drawn from this round of fighting, namely that Hamas has committed the same strategic error that they rightly criticized Fatah for: the doomed attempt to create a quasi-state authority without first achieving the rudiments of sovereignty.  Hamas, like Fatah before it, has the vulnerability of a state army without any of its benefits as far as ending the occupation is concerned. The Palestinians have at most a civil police force for internal control and an irregular wing to deter invasions of urban areas. . . .

Read the rest of this entry…

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A Follow-Up on Israel and Gaza

Published on January 3, 2009        Author: 
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I just wanted to add a few thoughts after Dapo’s excellent post on the Gaza conflict, of which there seems to be no end in sight.

First, a word of warning. As Dapo pointed out, talking about these matters without knowing all the facts is truly dangerous. Indeed, it only tends to expose the speaker’s political and ideological biases. Without knowing exactly how many of those killed in Gaza were actively participating in hostilities and/or were members of Hamas, it is far, far too early to speak of Israeli massacres or war crimes in Gaza. Take as an example the statement by Richard Falk, the recently appointed UN Special Rapporteur on human rights in the occupied territories, who condemned the Israeli air strikes as massive violations of international humanitarian law, war crimes and crimes against humanity on the very day that they began. How exactly does he know enough of the facts to actually be able to pass a reasoned judgment, when even today these facts are far from clear? Such statements only serve to reinforce the criticisms regarding Prof. Falk‘s bias against Israel that were made when he was appointed.

Far be it for me to minimize the humanitarian plight of the people of Gaza. But for a legal analysis of the issue to have any use at all, it must involve a measure of distance and objectivity.

In that regard the first legal issue I’d like to raise is that of proportionality, a word thrown around so much these days when talking about the Gaza conflict. It is truly astonishing to me how people who so casually label Israel’s action as disproportionate fail to distinguish between the various types of proportionality found in international law.

The first type of proportionality is the law on the use of force or jus ad bellum proportionality, as one of the conditions for the lawfulness of self-defense, together with the existence of an armed attack and the necessity to repel it. It is easy to instinctively qualify Israel’s action as an exercise of self-defense, lawful or unlawful — see, for example, this post by Ole Pedersen — which should then be assessed in the terms of the jus ad bellum.

But for the life of me, I just can’t see a jus ad bellum issue in regard of Israel’s actions in Gaza. This is simply not self-defense within the meaning of Article 51 of the UN Charter, as that concept of self-defense is an exception to the general prohibition on the use of force, that operates between states only and exclusively and is enshrined in Article 2(4) of the Charter. That prohibition was not triggered by Israel’s action, as Gaza is not a state, nor a part of any state, but is a part of the sui generis mandate territory of Palestine. In other words, no state claims sovereignty or title over Gaza, and the sovereignty of no state was infringed by Israel’s use of force. Article 2(4) does not apply, and consequently Article 51 and the self-defense notion of proportionality do not apply either, unless one is willing to argue that Palestine (Gaza included) already is a state in international law – a position that is in my view untenable.

(By way of authority, let me cite the ICJ’s Wall advisory opinion, at the much criticized para. 139. The Court has received much flak over the years for what appears to be its off-hand approach to armed attacks by non-state actors, to which Article 51 in the Court’s view supposedly does not apply. But the better reading of this decision is the one I have given above — Israel could not justify its building of the wall in the occupied Palestinian territories by resorting to Article 51, because Article 2(4) did not apply in the first place. A converse situation would be Israel’s response against Hezbollah, which required it to invade Lebanon, thereby triggering Article 2(4)).

That brings me to the second, IHL or jus in bello concept of proportionality, as enshrined in Art. 51(5)(b) of AP I. This concept of proportionality differs from the jus ad bellum one precisely in that is unconcerned with the overall goals, legitimacy or legality of the use of force. It is irrelevant, from the standpoint of IHL, that on balance ten or a hundred Palestinians are killed for every Israeli killed. It is likewise irrelevant whether the use of force is likely to achive its stated objective of putting an end to the rocket attacks by Hamas. That is not part of the IHL equation, since the point of IHL is precisely for it to apply in all conflicts, just or unjust, legitimate or illegitimate, equally to all sides.

What IHL tries to weigh – with great difficulty in some cases – is whether the expected civilian casualties are excessive in relation to the concrete and direct military advantage anticipated. The military advantage is just that, a military one. Does the attack hurt Hamas or not, and how much – not whether hurting Hamas in the first place is a good idea. It likewise must be emphasized that IHL proportionality is assessed in relation to every given attack, not in relation to the overall picture of the conflict. Without having a good idea about the facts on the ground, just knowing that on the whole many more Palestinians are killed than Israelis cannot suffice for making a judgment on proportionality.

The third type of proportionality is one under human rights law. Was it, for example, really necessary to kill a certain person, if he could have been captured instead? This type of proportionality was relied on, for instance, by the Israeli Supreme Court in the Targeted Killings case, to limit the use of targeted killings to measures of last resort. But it is also questionable if, and to what extent, this principle applies to the Gaza conflict, both because of the question whether Israel actually exercises effective overall control over Gaza, thus incurring extraterritorial human rights obligations, and because of the application of IHL as lex specialis.

Finally, I’d just like to add a few words to Dapo’s analysis of the question of how we are to legally characterize the Gaza conflict in the sense of IHL. Unlike Dapo, I don’t think that the characterization of the conflict depends on whether Gaza is still considered to be occupied by Israel or not. It is one thing to say that an international armed conflict is necessary for a belligerent occupation to arise in the first place. It is quite another to say that any conflict in an occupied territory, no matter how distant in time from the setup of the occupation, should qualify as international. It is precisely because no sovereign continues to claim Gaza that I would say that the conflict is probably non-international (FYI, for my criticism of the Israli Supreme Court’s qualification of the conflict in the Targeted Killings case, see this article in the International Review of the Red Cross).

But, as Dapo pointed out, the qualification of the conflict is not that important for the IHL proportionality assessment. What is important are the facts, and it is the facts that we are most sorely lacking.

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Top International Lawyers of 2008?

Published on December 31, 2008        Author: 
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At this time of the year, it is usual for the media to pubish lists of top this and top that of the year. I wonder whether it is possible to have list of the top international lawyers of 2008. If one were to try to construct such a list one would have come up with criteria for identiying these people. Presumably, one would be looking for those international lawyers who apppear to have been most influential. But how does one measure influence? Is influence not something which may only become apparent many years later? Perhaps one would need to distinguish between those lawyers operating in governments and IOs from international law academics.

The Times (of London) published a list ealier this year (see here) of the UK’s 100 most powerful lawyers. This is said to be “a list of the lawyers who have the most clout in shaping the rules we live by”. According to the Times, this list of 100 top UK lawyers:

is not a list of excellence, popularity or media mentions — although these can be factors. So it’s not just big names or brilliant stars (take comfort, those excluded). Instead, we tried to select the most powerful and influential within the law today — in the judiciary, private practice, in-house, public sector or politics.

How to measure power and influence — who really has clout?  . . .

We had in mind such factors as whether contenders can influence public or political opinion, or the strategy or policy of a big firm, company or government; whether they can shape or apply the law in a way that affects many people; whether they are respected, feared or emulated or contributed to the strength and quality of UK legal services.

Readers may be interested to see how many international lawyers are included in the list. There are some in the list who have made significant contributions to international law cases in the UK but who are perhaps better known for a more general contribution to UK Law. For example, some are judges [eg Lord Bingham, former Senior Law Lord and one of the judges in the Al-Skeini  case (extraterritorial application of the ECHR in Iraq); the Al-Jedda case (interaction between ECHR and UN Security Council resolutions with regard to detentions in Iraq by British forces); the A case (use in British proceedings of evidence obtained by torture). Others are human rights litigators who have also made important contributoions to that area of law (eg Phil Shiner).

There are three names on the list which are more likely to be recognised by non-UK international lawyers: Daniel Bethlehem, the Legal Adviser to the Foreign and Commonwealth Office (and former LSE & Cambridge academic)

Christopher Greenwood, currently Professor of International Law at the LSE, who has just been elected to the International Court of Justice

Dame Rosalyn Higgins, current President of the International Court of Justice (and also a former LSE Professor of International Law).

In my view, the fact that some of the lawyers on the list are international lawyers says something about the perception of international law in the UK (or at least about the perception of the place of international law by the persons who put the list together). One can only speculate whether any international lawyers would have made a similar list put together a couple of decades ago. Does anyone know of any similar lists in other countries? Do they include international lawyers? Perhaps readers would like to put together a list of the most influential public international lawyers of 2008.

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Israeli raids in Gaza: Proportionality and the Status of Hamas Policemen

Published on December 29, 2008        Author: 
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The latest Israeli raids in Gaza are said to have killed over 300 people (injuring over 1000 others) with most of the dead being Haman policemen and security officials. Israel has launched the raids in response to the repeated rocket fire into Israel from Gaza. Given the very high Palestinian casualties resulting from Israel’s raids and (as far as I can tell) the very low numbers killed or injured in Israel as a result of rocket fire there will be a debate about whether Israel’s actions are proportionate [I have found it difficult to find precise numbers of Israelis killed or injured by the rockets prior to the Israeli air raids]. Indeed, the UN Secretary General has been quoted as condemning Israel’s “excessive use of force leading to the killing and injuring of civilians” (see here). No doubt, human rights groups and others will accuse Israel of acting disproprotionately under international humanitarian law (IHL). The relevant rule of IHL that will be invoked is the rule that forbids attacks which may be expected to cause incidental loss of civilian life or civilian damage which is excessive when compared with the concrete and direct military advantage to be gained (Art. 51, Additional Protocol I 1977 to the Geneva Conventions of 1949). It is well known that the proportionality calculation is one which is not easy to make in practice nor is it easy to explain in theory. Afterall, one is not comparing two things that are necessarily commensurate, unless one makes a straight forward comparison between life lost and life expected to be saved by the military operation. Using that crude comparision, some will suggest that the taking of over 300 lives in order to save just a handful would be disproportionate (if the operation could be expected to cause such loss of life). I do not intend to disagree with that analysis.

However, I suggest that in this case, starting from the proportionality analysis is to start in the wrong place. The recent Israeli raids raises other more basic legal issues under IHL. The answers to those issues might suggest that one never gets to making a proportionality calculation. The proportionality rule requires a comparision between civilian loss (or life or of property) and the military advantage to be gained. Since we are told that most of the deaths caused by those raids are to Hamas policemen or security officials one has to ask whether these are civilians. Read the rest of this entry…

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Territorial Scope of Application of the Genocide Convention

Published on December 29, 2008        Author: 
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In the Bosnian Genocide case, Bosnia alleged that the Federal Republic of Yugoslavia (FRY, Serbia) was responsible for, inter alia, committing genocide and failing to prevent genocide on Bosnian territory. This argument, of course, immediately raised the question whether the FRY had any obligations under the Genocide Convention regarding its actions outside its own territory.

To answer this question, it is first necessary to recall that the Court interpreted the Convention so as to contain three distinct sets of obligations of state parties:

(1) The obligation to criminalize the crime of genocide and its ancillary crimes in their domestic law, and to prosecute the perpetrators of these crimes;

(2) The (positive) obligation to prevent genocide;

(3) The (negative) obligation not to commit genocide through their own organs or agents.

This expansive interpretation of the Convention is not uncontroversial. It is entirely possible to read the Convention as solely requiring (1) criminalization, that the (2) obligation to prevent genocide is merely hortatory, and that (3) is found nowhere in the treaty (see, for example, this article by P. Gaeta in the EJIL). For what it’s worth, I am entirely in agreement with the Court. But when do states actually have these various obligations, and is there is a single territorial scope of application of the Convention?

According to the Court, the territorial scope of the Convention varies with the particular set of obligations in question.

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Yet More on Immunity: Germany brings case against Italy before the ICJ

Published on December 26, 2008        Author: 
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For those of you who are not particularly interested in the law relating to immunity, I apologise for three consecutive posts on the topic. However, this is a week in which there just happen to have been many developments on this topic. This week Germany has insituted proceedings in the International Court of Justice against Italy (see here) alleging that through its judicial practice Italy has in recently years repeatedly disregarded the jurisdictional immunity due to Germany as a Sovereign State. The Press Release from the ICJ states that, according to the German Application:

“The critical stage of that development was reached by the judgment of the Corte di Cassazione of 11 March 2004 in the Ferrini case, where [that court] declared that Italy held jurisdiction with regard to a claim . . . brought by a person who during World War II had been deported to Germany to perform forced labour in the armaments industry. After this judgment had been rendered, numerous other proceedings were instituted against Germany before Italian courts by persons who had also suffered injury as a consequence of the armed conflict.” The Ferrini judgment having been recently confirmed “in a series of decisions delivered on 29 May 2008 and in a further judgment of 21 October 2008”, Germany “is concerned that hundreds of additional cases may be brought against it”.

The Applicant recalls that enforcement measures have already been taken against German assets in Italy: a “judicial mortgage” on Villa Vigoni, the German-Italian centre of cultural exchange, has been recorded in the land register. In addition to the claims brought against it by Italian nationals, Germany also cites “attempts by Greek nationals to enforce in Italy a judgment obtained in Greece on account of a . . . massacre committed by German military units during their withdrawal in 1944”.

The case clearly raises the question whether foreign States are immune in civil proceedings concerning violations of human rights and international humanitarian law. The case law on this question has, in recent years, been divided Read the rest of this entry…

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The Two Faces of the Genocide Convention

Published on December 24, 2008        Author: 
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In keeping with Christmas spirit, here’s my next post on the Genocide Convention.

Can a state be responsible for genocide? What does that even mean? Aren’t international crimes, in the sage words of the Nuremberg Tribunal, committed by men, not by abstract entities?Can a state even possess genocidal intent, a basic requirement for the crime of genocide?

A full answer to this question requires revisiting many old debates, particularly those during the drafting of the Genocide Convention and on then Draft Article 19 on state crimes of the International Law Commission’s project on state responsibility, that was removed from the final ILC Articles.

If there is one thing is made clear from an examination of the Convention’s travaux, as well as state practice, that is that states have excluded any form of state criminal responsibility for the crime of genocide or any other international crime. That does not mean, however, that no state responsibility exists. In my EJIL article on state responsibility for genocide, I’ve argued that the attribution model developed by the ILC, coupled with the fundamental distinction between primary and secondary rules of state responsibility, provides a simple answer to the conundrum of state responsibility for international crimes. If an individual commits an international crime such as genocide, and if the acts of this individual are attributable to a state, pursuant to the generally applicable secondary rules of attribution (if, for example, the individual is a state organ), than the state is responsible for the crime committed by that individual as an internationally wrongful act.

This responsibility is again not criminal, but the regular state responsibility recognized in international law, that carries with itobligations of cessation and reparation. It rests on a primary obligation of states not to have individuals whose acts are attributable to them to commit international crimes. Genocide is thus at the same time both an international crime, for which individuals are criminally responsible, and an internationally wrongful act, for which states to which the acts are attributable bear their own responsibility. That does not mean there is a ‘tort’ of genocide or ‘civil’ genocide in international law – genocide still, at all times, remains an international crime, and its elements must be proven to the exacting standards demanded by the relevant body of primary rules. Thus, for example, though a state – an abstract entity – cannot have genocidal intent, such intent of the individuals whose acts are being attributed to the state must be conclusively established.

The next question is whether this type of responsibility, that in my view undoubtedly exists in customary international law, also exists within the (jurisdictional) confines of the Genocide Convention. The ICJ gave an answer to this question in the Bosnian Genocide case.

Both at the preliminary objections and at the merits stage of the case the FRY/Serbia disputed the existence of a separate obligation of a state under the Convention not to commit genocide, asserting that the Convention was a classical international criminal law treaty, dealing with crimes committed by individuals, not states. All the Convention does is to require states parties to criminalize in their domestic law the crimes that it defines, and then prosecute the perpetrators of these crimes. Though Article IX of the Convention confers jurisdiction upon the Court to resolve disputes between contracting states ‘relating to the responsibility of a State for genocide or for any of the other acts enumerated in article III’, this was, in Serbia’s argument, merely a compromisory clause which did not create substantive rights and obligations.

The Court disagreed. It held that ‘Article I [of the Convention], in particular its undertaking to prevent, creates obligations distinct from those which appear in the subsequent Articles [of the Convention]’ so that the ‘the Contracting Parties have a direct obligation to prevent genocide.’ Moreover, according to the Court, even though

Article [I] does not expressis verbis require States to refrain from themselves committing genocide …[i]t would be paradoxical if States were thus under an obligation to prevent, so far as within their power, commission of genocide by persons over whom they have a certain influence, but were not forbidden to commit such acts through their own organs, or persons over whom they have such firm control that their conduct is attributable to the State concerned under international law. In short, the obligation to prevent genocide necessarily implies the prohibition of the commission of genocide.

(Genocide judgment, paras. 162, 165 & 166)

Though Serbia was on the facts not found responsible for the commission of genocide in Bosnia, the Court’s judgment affirmed the attribution model developed by the ILC and the distinction between primary and secondary rules. States can thus be brought before the ICJ under Article IX of the Convention not merely for failing to criminalize or prosecute genocide, but also for committing it through their organs or failing to prevent it.

In my next post I will deal with the territorial scope of state obligations under the Convention.

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Prosecution of Senior Rwandan Government Official in France: More on Immunity

Published on December 24, 2008        Author: 
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French authorities have announced this week (see here) that a senior Rwandan official, Rose Kabuye, who is curently detained in France, will be allowed to travel to Rwanda for the Christmas holidays. Rose Kabuye was at the time of her arrest the Chief of Protocol to current Rwandan President Paul Kagame. She is accused (see here), under French Anti-Terrorism laws, of complicity to murder in connection with the killing in 1994 of then Rwandan President Juvenal Habyarimana. It was, of course, that murder which led to the Rwanda Genocide.  She was arrested in November at Frankfurt Airport (Germany) under an arrest warrant issued by French officials. She was subsequently transferred to France. Her arrest has worsened the already bad relations between Rwanda and France. They have also led to a diplomatic row between Rwanda and Germany and Rwanda has expelled the German Ambassador in the country.

Rose Kabuye’s arrest, detention and prosecution raises questions regarding the immunity of foreign officials from criminal prosecution in foreign domestic courts. The particular question at issue in the Kabuye case is: which State officials are entitled to personal immunity? Was it lawful for France to issue an arrest warrant for a senior Rwandan official and was it lawful for German authorities to execute that warrant? Or was (is) Rose Kabuye within that category of officials who are entitled to personal immunity from the jurisdiction of foreign States for so long as they serve in their official position?  Read the rest of this entry…

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Immunity and International Criminal Tribunals

Published on December 20, 2008        Author: 
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Earlier this week, the Trial Chamber at International Criminal Tribunal for the Former Yugoslavia (ICTY) hearing the case against Radovan Karadzic issued a decision in which it stated that “According to customary international law, there are some acts for which immunity from prosecution cannot be invoked before international tribunals [para. 17 of the decision]”. The statement was made in the context of a ruling granting, in part, a request by Karadzic for the disclosure of certain documents by the Prosecutor.  Karadzic alleged that, at a meeting in Belgrade in July 1996, he reached an “immunity agreement” with US diplomat Richard Holbrooke in which he was promised that he would not face prosecution at the Tribunal if he withdrew from public life. He sought any documents in the possession of the Prosecutor concerning the alleged agreement and the meeting at which it was reached. He argued that the Holbrooke offer was attributable to the Tribunal because it was made in consultation with other members of the UN Security Council or believed to be so. The Trial Chamber ruled that the documents sought were not relevant to the preparation of Karadzic’s defence other than being of potential relevance to in the determination of any eventual sentence. It considered “it well establihed  that any immunity agreement in respect of an accused indicted for genocide, war crimes and/or crimes against humanity before an international tribunal would be invalid under international law [para. 25].”

Although Karadzic and the Trial Chamber discussed the alleged agreement in terms of immunity, the suggestion being that it related somehow to immunities conferred by international law, it may have been more accurate to refer to it as an amnesty agreement. Afterall, the suggestion in the alleged agreement was not that Karadzic was entitled to immunities which international law ordinarily accords but rather that the tribunal would refrain from prosecuting him.

The Trial Chamber’s view that international law immunities do not apply to prosecution for international crimes before international criminal tribunals is erroneous. Read the rest of this entry…

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60 Years of the Genocide Convention

Published on December 15, 2008        Author: 
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Many thanks to Dapo for inviting me to blog here at EJIL: Talk! – hopefully the blog will turn out to be as successful in the blawgosphere as the EJIL is in print. In the next couple of weeks I intend to write on various topics, first about certain issues regarding the the Genocide Convention, which has had its sixtieth anniversary last week, on December 9th.

On any account, the Convention is an extraordinary treaty, a historic pronouncement by states that the practice of exterminating human groups merely on account of their nation, race, religion or ethnicity, is something that can never condoned or resorted to. At the same time, the Convention is in many ways a deeply disappointing instrument.

One, rather obvious item of disappointment would be its record of compliance. How many genocides, exactly, has the Convention on the Prevention and Punishment of the Crime of Genocide actually prevented or punished? In the face of, say, Darfur, it is hard to escape the impression that the Convention has hardly been a success. Some authors have even conducted empirical studies suggesting that the Convention has contributed little or nothing to the actual compliance with the norms that it enshrines (see here, at 1981-1982).

For what it’s worth, I believe that this initial reflex of disappointment should be resisted. Before we ask ourselves whether the Convention does what it was supposed to do, we need to look at what it actually says. And it says very, very little. The definition of the crime of genocide requires the specific intent to (physically or biologically) destroy a national, ethnic, racial, or religious group, this enumeration of protected groups being exhaustive. The narrowness of this definition is such that it excludes the vast majority of acts that most lawyers, and by far the majority of the general public, think of as genocide.

Read the rest of this entry…

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