Rape as crime against humanity
|Appeal Judgement - 29.09.2014||
KAREMERA & NGIRUMPATSE
611. […] The Appeals Chamber considers that whilst the Trial Chamber’s findings on sexual assaults can reasonably underpin a conviction of genocide, they cannot form the basis of a conviction for rape as crime against humanity. The Appeals Chamber recalls that acts of sexual violence are a broader category than rape. […] Accordingly, the Appeals Chamber finds that the Trial Chamber erred in relying on its findings of sexual assaults committed throughout Rwanda to convict Karemera and Ngirumpatse of rape as a crime against humanity. […]
 See Rukundo, Trial Judgement, para. 380. See also Kunara~ et al. Appeal Judgement, para. 150.
 The Appeals Chamber finds that the Trial Chamber reasonably considered that rapes and sexual assaults amounted to genocide in the form of serious bodily and mental harm. See [Karemera and Ngirumpatse] Trial Judgement, para. 1667.