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Copyright (c) 2001 The Regents of the University of California
U.C. Davis Journal of International Law & Policy

ARTICLE: Forced Marriage: Rwanda's Secret Revealed

Spring, 2001

7 U.C. Davis J. Int'l L. & Pol'y 197


Monika Satya Kalra*



An estimated half million people died in the 1994 Rwanda genocide. 1 A selected group of powerful Hutu leaders carefully orchestrated the genocide to eliminate Tutsis from Rwanda. 2 Although most of the victims were Tutsis, the Hutu killed a number of dissenting Hutus as well. By the end of the one hundred days of killing, the Hutu had eliminated approximately three-quarters of the Tutsi population. 3

The United Nations set up the International Criminal Tribunal for Rwanda (ICTR) in 1994 to prosecute key leaders of the genocide. 4 Initially, the Tribunal concentrated on crimes based on the killings. The ICTR's focus later expanded to include crimes of sexual violence, largely in response to great international pressure. 5 In 1998, four years after the establishment of the Tribunal, the ICTR found Jean-Paul Akayesu guilty of sexual violence crimes. 6 Despite taking steps to address these crimes, the ICTR's efforts are far from comprehensive. The ICTR has neglected various forms of sexual abuses suffered by Rwandan women during the 1994 genocide. Specifically, the Tribunal has not explored forced marriage.

This article addresses the need for the Office of the Prosecutor (OTP) of the ICTR to charge forced marriage as a crime of sexual violence. Part I explores the phenomenon of forced marriage in Rwanda. Part II addresses the importance of charging perpetrators with the crime of forced marriage. Part III discusses the legal framework for prosecuting forced marriage, and ...
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