|
THE
SPECIAL COURT FOR
SIERRA LEONE
CASE
NO. SCSL –
03 –
I
THE
PROSECUTOR
Against
CHARLES
GHANKAY TAYLOR also
known as
CHARLES
GHANKAY MACARTHUR
DAPKPANA TAYLOR
INDICTMENT
The Prosecutor,
Special Court for
Sierra Leone, under
Article 15 of the
Statute of the
Special Court for
Sierra Leone (the
Statute) charges:
CHARLES
GHANKAY TAYLOR also
known as
(aka) CHARLES
GHANKAY MACARTHUR
DAPKPANA TAYLOR
with CRIMES
AGAINST HUMANITY,
VIOLATIONS OF
ARTICLE 3 COMMON TO
THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II and OTHER SERIOUS
VIOLATIONS OF
INTERNATIONAL
HUMANITARIAN LAW, in
violation of
Articles 2, 3 and 4
of the Statute
as set forth below:
THE ACCUSED
1. CHARLES
GHANKAY TAYLOR aka
CHARLES GHANKAY
MACARTHUR DAPKPANA
TAYLOR (the ACCUSED)
was born on or about
28 January 1948 at
Arthington in the
Republic of Liberia.
GENERAL
ALLEGATIONS
2. At all times
relevant to this
Indictment, a state
of armed conflict
existed within
Sierra Leone. For
the purposes of this
Indictment,
organized armed
factions involved in
this conflict
included the
Revolutionary United
Front (RUF), the
Civil Defence Forces
(CDF) and the Armed
Forces Revolutionary
Council (AFRC).
3. A nexus
existed between the
armed conflict and
all acts or
omissions charged
herein as Violations
of Article 3 common
to the Geneva
Conventions and of
Additional Protocol
II and as Other
Serious Violations
of International
Humanitarian Law.
4. The organized
armed group that
became known as the
RUF, led by FODAY
SAYBANA SANKOH aka
POPAY aka PAPA aka
PA, was founded
about 1988 or 1989
in Libya. The RUF,
under the leadership
of FODAY SAYBANA
SANKOH, began
organized armed
operations in Sierra
Leone in March 1991.
During the ensuing
armed conflict, the
RUF forces were also
referred to as
"RUF",
"rebels"
and "People's
Army".
5. The CDF was
comprised of Sierra
Leonean traditional
hunters, including
the Kamajors,
Gbethis, Kapras,
Tamaboros and Donsos.
The CDF fought
against the RUF and
AFRC.
6. On 30 November
1996, in Abidjan,
Ivory Coast, FODAY
SAYBANA SANKOH and
Ahmed Tejan Kabbah,
President of the
Republic of Sierra
Leone, signed a
peace agreement
which brought a
temporary cessation
to active
hostilities.
Thereafter, the
active hostilities
recommenced.
7. The AFRC was
founded by members
of the Armed Forces
of Sierra Leone who
seized power from
the elected
government of the
Republic of Sierra
Leone via a coup d'état
on 25 May 1997.
Soldiers of the
Sierra Leone Army (SLA)
comprised the
majority of the AFRC
membership. On that
date JOHNNY PAUL
KOROMA aka JPK
became the leader
and Chairman of the
AFRC. The AFRC
forces were also
referred to as
"Junta",
"soldiers",
"SLA", and
"ex-SLA".
8. Shortly after
the AFRC seized
power, at the
invitation of JOHNNY
PAUL KOROMA, and
upon the order of
FODAY SAYBANA SANKOH,
leader of the RUF,
the RUF joined with
the AFRC. The AFRC
and RUF acted
jointly thereafter.
The AFRC/RUF Junta
forces (Junta) were
also referred to as
"Junta",
"rebels",
"soldiers",
"SLA",
"ex-SLA"
and "People's
Army".
9. After the 25
May 1997 coup d'état,
a governing body,
the Supreme Council,
was created within
the Junta. The
governing body
included leaders of
both the AFRC and
RUF.
10. The Junta was
forced from power by
forces acting on
behalf of the ousted
government of
President Kabbah
about 14 February
1998. President
Kabbah's government
returned in March
1998. After the
Junta was removed
from power the AFRC/RUF
alliance continued.
11. On 7 July
1999, in Lomé,
Togo, FODAY SAYBANA
SANKOH and Ahmed
Tejan Kabbah,
President of the
Republic of Sierra
Leone, signed a
peace agreement.
However, active
hostilities
continued.
12. The ACCUSED
and all members of
the organized armed
factions engaged in
fighting within
Sierra Leone were
required to abide by
International
Humanitarian Law and
the laws and customs
governing the
conduct of armed
conflicts, including
the Geneva
Conventions of 12
August 1949, and
Additional Protocol
II to the Geneva
Conventions, to
which the Republic
of Sierra Leone
acceded on 21
October 1986.
13. All offences
alleged herein were
committed within the
territory of Sierra
Leone after 30
November 1996.
14. All acts and
omissions charged
herein as Crimes
Against Humanity
were committed as
part of a widespread
or systematic attack
directed against the
civilian population
of Sierra Leone.
15. The words
civilian or civilian
population used in
this Indictment
refer to persons who
took no active part
in the hostilities,
or who were no
longer taking an
active part in the
hostilities.
INDIVIDUAL
CRIMINAL
RESPONSIBILITY
16. Paragraphs 1
through 15 are
incorporated by
reference.
17. In the late
1980's CHARLES
GHANKAY TAYLOR
received military
training in Libya
from representatives
of the Government of
MU'AMMAR AL-QADHAFI.
While in Libya the ACCUSED
met and made common
cause with FODAY
SAYBANA SANKOH.
18. While in
Libya, the ACCUSED
formed or joined the
National Patriotic
Front of Liberia (NPFL).
At all times
relevant to this
Indictment the ACCUSED
was the leader of
the NPFL and/or the
President of the
Republic of Liberia.
19. In December
1989 the NPFL, led
by the ACCUSED,
began conducting
organized armed
attacks in Liberia.
The ACCUSED
and the NPFL were
assisted in these
attacks by FODAY
SAYBANA SANKOH and
his followers.
20. To obtain
access to the
mineral wealth of
the Republic of
Sierra Leone, in
particular the
diamond wealth of
Sierra Leone, and to
destabilize the
State, the ACCUSED
provided financial
support, military
training, personnel,
arms, ammunition and
other support and
encouragement to the
RUF, led by FODAY
SAYBANA SANKOH, in
preparation for RUF
armed action in the
Republic of Sierra
Leone, and during
the subsequent armed
conflict in Sierra
Leone.
21. Throughout
the course of the
armed conflict in
Sierra Leone, the
RUF and the AFRC/RUF
alliance, under the
authority, command
and control of FODAY
SAYBANA SANKOH,
JOHNNY PAUL KOROMA
and other leaders of
the RUF, AFRC and
AFRC/RUF alliance,
engaged in
notorious,
widespread or
systematic attacks
against the civilian
population of Sierra
Leone.
22. At all times
relevant to this
Indictment, CHARLES
GHANKAY TAYLOR
supported and
encouraged all
actions of the RUF
and AFRC/RUF
alliance, and acted
in concert with
FODAY SAYBANA SANKOH
and other leaders of
the RUF and AFRC/RUF
alliance. FODAY
SAYBANA SANKOH was
incarcerated in
Nigeria and Sierra
Leone and subjected
to restricted
movement in Sierra
Leone from about
March 1997 until
about April 1999.
During this time the
ACCUSED, in
concert with FODAY
SAYBANA SANKOH,
provided guidance
and direction to the
RUF, including SAM
BOCKARIE aka
MOSQUITO aka MASKITA.
23. The RUF and
the AFRC shared a
common plan, purpose
or design (joint
criminal enterprise)
which was to take
any actions
necessary to gain
and exercise
political power and
control over the
territory of Sierra
Leone, in particular
the diamond mining
areas. The natural
resources of Sierra
Leone, in particular
the diamonds, were
to be provided to
persons outside
Sierra Leone in
return for
assistance in
carrying out the
joint criminal
enterprise.
24. The joint
criminal enterprise
included gaining and
exercising control
over the population
of Sierra Leone in
order to prevent or
minimize resistance
to their geographic
control, and to use
members of the
population to
provide support to
the members of the
joint criminal
enterprise. The
crimes alleged in
this Indictment,
including unlawful
killings,
abductions, forced
labour, physical and
sexual violence, use
of child soldiers,
looting and burning
of civilian
structures, were
either actions
within the joint
criminal enterprise
or were a reasonably
foreseeable
consequence of the
joint criminal
enterprise.
25. The ACCUSED
participated in this
joint criminal
enterprise as part
of his continuing
efforts to gain
access to the
mineral wealth of
Sierra Leone and to
destabilize the
Government of Sierra
Leone.
26. CHARLES
GHANKAY TAYLOR,
by his acts or
omissions, is
individually
criminally
responsible pursuant
to Article 6.1. of
the Statute for the
crimes referred to
in Articles 2, 3 and
4 of the Statute as
alleged in this
Indictment, which
crimes the ACCUSED
planned, instigated,
ordered, committed
or in whose
planning,
preparation or
execution the ACCUSED
otherwise aided and
abetted, or which
crimes were within a
joint criminal
enterprise in which
the ACCUSED
participated or were
a reasonably
foreseeable
consequence of the
joint criminal
enterprise in which
the ACCUSED
participated.
27. In addition,
or alternatively,
pursuant to Article
6.3. of the Statute,
CHARLES GHANKAY
TAYLOR, while
holding positions of
superior
responsibility and
exercising command
and control over his
subordinates, is
individually
criminally
responsible for the
crimes referred to
in Articles 2, 3 and
4 of the Statute.
The ACCUSED
is responsible for
the criminal acts of
his subordinates in
that he knew or had
reason to know that
the subordinate was
about to commit such
acts or had done so
and the ACCUSED
failed to take the
necessary and
reasonable measures
to prevent such acts
or to punish the
perpetrators
thereof.
CHARGES
28. Paragraphs 16
through 27 are
incorporated by
reference.
29. At all times
relevant to this
Indictment, members
of the RUF, AFRC,
Junta and/or AFRC/RUF
forces (AFRC/RUF),
supported and
encouraged by,
acting in concert
with and/or
subordinate to CHARLES
GHANKAY TAYLOR,
conducted armed
attacks throughout
the territory of the
Republic of Sierra
Leone, including,
but not limited, to
Bo, Kono, Kenema,
Bombali and Kailahun
Districts and
Freetown. Targets of
the armed attacks
included civilians
and humanitarian
assistance personnel
and peacekeepers
assigned to the
United Nations
Mission in Sierra
Leone (UNAMSIL),
which had been
created by United
Nations Security
Council Resolution
1270 (1999).
30. These attacks
were carried out
primarily to
terrorize the
civilian population,
but also were used
to punish the
population for
failing to provide
sufficient support
to the AFRC/RUF, or
for allegedly
providing support to
the Kabbah
government or to
pro-government
forces. The attacks
included unlawful
killings, physical
and sexual violence
against civilian
men, women and
children, abductions
and looting and
destruction of
civilian property.
Many civilians saw
these crimes
committed; others
returned to their
homes or places of
refuge to find the
results of these
crimes - dead
bodies, mutilated
victims and looted
and burnt property.
31. As part of
the campaign of
terror and
punishment the AFRC/RUF
routinely captured
and abducted members
of the civilian
population. Captured
women and girls were
raped; many of them
were abducted and
used as sex slaves
and as forced labour.
Some of these women
and girls were held
captive for years.
Men and boys who
were abducted were
also used as forced
labour; some of them
were also held
captive for years.
Many abducted boys
and girls were given
combat training and
used in active
fighting. AFRC/RUF
also physically
mutilated men, women
and children,
including amputating
their hands or feet
and carving "AFRC"
and "RUF"
on their bodies.
COUNTS
1 - 2: TERRORIZING
THE CIVILIAN
POPULATION AND
COLLECTIVE
PUNISHMENTS
32. Members of
the AFRC/RUF
supported and
encouraged by,
acting in concert
with and/or
subordinate to
CHARLES GHANKAY
TAYLOR committed the
crimes set forth
below in paragraphs
33 through 58 and
charged in Counts 3
through 13, as part
of a campaign to
terrorize the
civilian population
of the Republic of
Sierra Leone, and
did terrorize that
population. The AFRC/RUF
also committed the
crimes to punish the
civilian population
for allegedly
supporting the
elected government
of President Ahmed
Tejan Kabbah and
factions aligned
with that
government, or for
failing to provide
sufficient support
to the AFRC/RUF.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 1:
Acts of Terrorism, a
VIOLATION OF
ARTICLE 3 COMMON TO
THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.d.
of the Statute;
And:
Count 2:
Collective
Punishments, a VIOLATION
OF ARTICLE 3 COMMON
TO THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.b.
of the Statute.
COUNTS
3 - 5: UNLAWFUL
KILLINGS
33. Victims were
routinely shot,
hacked to death and
burned to death.
Unlawful killings
included, but were
not limited to, the
following:
Bo District
34. Between 1
June 1997 and 30
June 1997, AFRC/RUF
attacked Tikonko,
Telu, Sembehun,
Gerihun and Mamboma,
unlawfully killing
an unknown number of
civilians;
Kenema
District
35. Between about
25 May 1997 and
about 19 February
1998, in locations
including Kenema
town, members of
AFRC/RUF unlawfully
killed an unknown
number of civilians;
Kono
District
36. About mid
February 1998, AFRC/RUF
fleeing from
Freetown arrived in
Kono District.
Between about 14
February 1998 and 30
June 1998, members
of AFRC/RUF
unlawfully killed
several hundred
civilians in various
locations in Kono
District, including
Koidu, Tombodu,
Foindu, Willifeh,
Mortema and Biaya;
Bombali
District
37. Between about
1 May 1998 and 31
July 1998, in
locations including
Karina, members of
AFRC/RUF unlawfully
killed an unknown
number of civilians;
Freetown
38. Between 6
January 1999 and 31
January 1999, AFRC/RUF
conducted armed
attacks throughout
the city of
Freetown. These
attacks included
large scale unlawful
killings of civilian
men, women and
children at
locations throughout
the city, including
the State House,
Parliament building,
Connaught Hospital,
and the Kissy,
Fourah Bay, Upgun,
Calaba Town and
Tower Hill areas of
the city.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 3:
Extermination, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.b. of the
Statute;
In addition, or
in the alternative:
Count 4:
Murder, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.a. of the
Statute;
In addition, or
in the alternative:
Count 5:
Violence to life,
health and physical
or mental well-being
of persons, in
particular murder, a
VIOLATION OF
ARTICLE 3 COMMON TO
THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.a.
of the Statute.
COUNTS
6 - 8: SEXUAL
VIOLENCE
39. Widespread
sexual violence
committed against
civilian women and
girls included
brutal rapes, often
by multiple rapists.
Acts of sexual
violence included,
but were not limited
to, the following:
Kono
District
40. Between about
14 February 1998 and
30 June 1998,
members of AFRC/RUF
raped hundreds of
women and girls at
various locations
throughout the
District, including
Koidu, Tombodu,
Kissi-town (or Kissi
Town), Foendor (or
Foendu), Tomendeh,
Fokoiya, Wondedu and
AFRC/RUF camps such
as "Superman
camp" and Kissi-town
(or Kissi Town)
camp. An unknown
number of women and
girls were abducted
from various
locations within the
District and used as
sex slaves;
Bombali
District
41. Between about
1 May 1998 and 31
July 1998, members
of AFRC/RUF raped an
unknown number of
women and girls in
locations such as
Mandaha. In
addition, an unknown
number of abducted
women and girls were
used as sex slaves;
Kailahun
District
42. At all times
relevant to this
Indictment, an
unknown number of
women and girls in
various locations in
the District were
subjected to sexual
violence. Many of
these victims were
captured in other
areas of the
Republic of Sierra
Leone, brought to
AFRC/RUF camps in
the District, and
used as sex slaves;
Freetown
43. Between 6
January 1999 and 31
January 1999,
members of AFRC/RUF
raped hundreds of
women and girls
throughout the
Freetown area, and
abducted hundreds of
women and girls and
used them as sex
slaves.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 6:
Rape, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.g. of the
Statute;
And:
Count 7:
Sexual slavery and
any other form of
sexual violence, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.g. of the
Statute;
In addition, or
in the alternative:
Count 8:
Outrages upon
personal dignity, a VIOLATION
OF ARTICLE 3 COMMON
TO THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.e.
of the Statute.
COUNTS
9 - 10: PHYSICAL
VIOLENCE
44. Widespread
physical violence,
including
mutilations, was
committed against
civilians. Victims
were often brought
to a central
location where
mutilations were
carried out. These
acts of physical
violence included,
but were not limited
to, the following:
Kono
District
45. Between about
14 February 1998 and
30 June 1998, AFRC/RUF
mutilated an unknown
number of civilians
in various locations
in the District,
including Tombodu,
Kaima (or Kayima)
and Wondedu. The
mutilations included
cutting off limbs
and carving "AFRC"
and "RUF"
on the bodies of the
civilians;
Freetown
46. Between 6
January 1999 and 31
January 1999, AFRC/RUF
mutilated an unknown
number of civilian
men, women and
children in various
areas of Freetown,
including the
northern and eastern
areas of the city,
and the Kissy area,
including the Kissy
mental hospital. The
mutilations included
cutting off limbs.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 9:
Violence to life,
health and physical
or mental well-being
of persons, in
particular cruel
treatment, a VIOLATION
OF ARTICLE 3 COMMON
TO THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.a.
of the Statute;
In addition, or
in the alternative:
Count 10:
Other inhumane acts,
a CRIME AGAINST
HUMANITY,
punishable under
Article 2.i. of the
Statute.
COUNT
11: USE OF CHILD
SOLDIERS
47. At all times
relevant to this
Indictment,
throughout the
Republic of Sierra
Leone, AFRC/RUF
routinely
conscripted,
enlisted and/or used
boys and girls under
the age of 15 to
participate in
active hostilities.
Many of these
children were first
abducted, then
trained in AFRC/RUF
camps in various
locations throughout
the country, and
thereafter used as
fighters.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 11:
Conscripting or
enlisting children
under the age of 15
years into armed
forces or groups, or
using them to
participate actively
in hostilities, an
OTHER SERIOUS
VIOLATION OF
INTERNATIONAL
HUMANITARIAN LAW,
punishable under
Article 4.c. of the
Statute.
COUNT
12: ABDUCTIONS AND
FORCED LABOUR
48. At all times
relevant to this
Indictment, AFRC/RUF
engaged in
widespread and large
scale abductions of
civilians and use of
civilians as forced
labour. Forced
labour included
domestic labour and
use as diamond
miners. The
abductions and
forced labour
included, but were
not limited to, the
following:
Kenema
District
49. Between about
1 August 1997 and
about 31 January
1998, AFRC/RUF
forced an unknown
number of civilians
living in the
District to mine for
diamonds at Cyborg
Pit in Tongo Field;
Kono
District
50. Between about
14 February 1998 and
30 June 1998, AFRC/RUF
forces abducted
hundreds of civilian
men, women and
children, and took
them to various
locations outside
the District, or to
locations within the
District such as
AFRC/RUF camps,
Tombodu, Koidu,
Wondedu, Tomendeh.
At these locations
the civilians were
used as forced
labour, including
domestic labour and
as diamond miners in
the Tombodu area;
Bombali
District
51. Between about
1 May 1998 and 31
July 1998, in
Bombali District,
AFRC/RUF abducted an
unknown number of
civilians and used
them as forced
labour;
Kailahun
District
52. At all times
relevant to this
Indictment, captured
civilian men, women
and children were
brought to various
locations within the
District and used as
forced labour;
Freetown
53. Between 6
January 1999 and 31
January 1999, in
particular as the
AFRC/RUF were being
driven out of
Freetown, the AFRC/RUF
abducted hundreds of
civilians, including
a large number of
children, from
various areas within
Freetown, including
Peacock Farm and
Calaba Town. These
abducted civilians
were used as forced
labour.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 12:
Enslavement, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.c. of the
Statute.
COUNT
13: LOOTING AND
BURNING
54. At all times
relevant to this
Indictment, AFRC/RUF
engaged in
widespread unlawful
taking and
destruction by
burning of civilian
property. This
looting and burning
included, but was
not limited to, the
following:
Bo District
55. Between 1
June 1997 and 30
June 1997, AFRC/RUF
forces looted and
burned an unknown
number of civilian
houses in Telu,
Sembehun, Mamboma
and Tikonko;
Kono
District
56. Between about
14 February 1998 and
30 June 1998, AFRC/RUF
engaged in
widespread looting
and burning in
various locations in
the District,
including Tombodu,
Foindu and Yardu
Sando, where
virtually every home
in the village was
looted and burned;
Bombali
District
57. Between 1
March 1998 and 30
June 1998, AFRC/RUF
forces burned an
unknown number of
civilian buildings
in locations such as
Karina;
Freetown
58. Between 6
January 1999 and 31
January 1999, AFRC/RUF
forces engaged in
widespread looting
and burning
throughout Freetown.
The majority of
houses that were
destroyed were in
the areas of Kissy
and eastern
Freetown; other
locations included
the Fourah Bay,
Upgun, State House
and Pademba Road
areas of the city.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 13:
Pillage, a VIOLATION
OF ARTICLE 3 COMMON
TO THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.f.
of the Statute.
COUNTS
14 - 17: ATTACKS ON
UNAMSIL PERSONNEL
59. Between about
15 April 2000 and
about 15 September
2000, AFRC/RUF
engaged in
widespread attacks
against UNAMSIL
peacekeepers and
humanitarian
assistance workers
within the Republic
of Sierra Leone,
including, but not
limited to locations
within Bombali,
Kailahun, Kambia,
Port Loko, and Kono
Districts. These
attacks included
unlawful killing of
UNAMSIL
peacekeepers, and
abducting hundreds
of peacekeepers and
humanitarian
assistance workers
who were then held
hostage.
By his acts or
omissions in
relation, but not
limited to these
events, CHARLES
GHANKAY TAYLOR,
pursuant to Article
6.1. and, or
alternatively,
Article 6.3. of the
Statute, is
individually
criminally
responsible for the
crimes alleged
below:
Count 14:
Intentionally
directing attacks
against personnel
involved in a
humanitarian
assistance or
peacekeeping
mission, an OTHER
SERIOUS VIOLATION OF
INTERNATIONAL
HUMANITARIAN LAW,
punishable under
Article 4.b. of the
Statute;
In addition, or
in the alternative:
Count 15:
For the unlawful
killings, Murder, a CRIME
AGAINST HUMANITY,
punishable under
Article 2.a. of the
Statute;
In addition, or
in the alternative:
Count 16:
Violence to life,
health and physical
or mental well-being
of persons, in
particular murder, a
VIOLATION OF
ARTICLE 3 COMMON TO
THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.a.
of the Statute;
In addition, or
in the alternative:
Count 17:
For the abductions
and holding as
hostage, Taking of
hostages, a VIOLATION
OF ARTICLE 3 COMMON
TO THE GENEVA
CONVENTIONS AND OF
ADDITIONAL PROTOCOL
II, punishable
under Article 3.c.
of the Statute.
Dated this 3rd
day of March 2003
Freetown, Sierra
Leone
______________________
David M. Crane
The Prosecutor
|
