The ICTR's "Media" Judgment and the Reinvention of Direct and Public Incitement to Commit Genocide

Abstract

In December 2003 the Tanzania-based United Nations International Criminal Tribunal for Rwanda (ICTR) convicted three Rwandan radio and newspaper executives, Ferdinand Nahimana, Jean-Bosco Barayagwiza, and Hassan Ngeze, of direct and public incitement to commit genocide in 1994, sentencing them to life imprisonment. The ICTR's ''Media'' judgment marks a low point in international criminal justice, where the quality of decisions has fluctuated considerably.