Murder as a violation of the laws or customs of war
|Appeal Judgement - 08.04.2015||
616. The Appeals Chamber notes that there is no appellate jurisprudence which addresses the specific cumulative convictions for genocide and murder as a violation of the laws or customs of war. However, the ICTR Appeals Chamber has upheld cumulative convictions for war crimes, as a broad category, and genocide based on the materially distinct elements of genocide and war crimes. Relevantly, genocide requires proof of specific intent while war crimes require proof of the existence of a nexus between the alleged crimes and the armed conflict.
See also para. 617.
 See Semanza Appeal Judgement, para. 368; Rutaganda Appeal Judgement, para. 583.