In rejavor. In re Munyeshyaka.

French Cour de cassation, Criminal Chamber, March 26, 1996.

In Re Munyeshyaka. 1998 Bull, crim., No. 2, at 3.

French Cour de cassation, Criminal Chamber, January 6, 1998.

In the Javor case, certain Bosnian victims of the policy of “ethnic cleansing” that took place in Bosnia and Herzegovina, who were refugees in France, tried to rely on the universal jurisdiction of the French courts in order to file a criminal complaint (plainte avec constitution departie civile) with an investigating magistrate (juge d'instruction) against their Serb torturers.

Mugesera v. Minister of Citizenship and Immigration.

Immigration and Refugee Board (Appeal Division) of Canada, November 6, 1998.

In its landmark ruling of September 2, 1998, in the Akayesu case, the International Criminal Tribunal for Rwanda (ICTR) reviews the background of genocide in that country, noting in particular the role that hate propaganda played in preparing the tens of thousands of “willing executioners” who participated in the crimes of April to July, 1994. According to the Rwanda Tribunal, the “most notorious” propaganda agent was “a certain Leon Mugesera,” an extremist pamphleteer who gave a public speech in November 1992 calling for the extermination of the Tutsi. Mugesera fled Rwanda in the weeks following die incident. With the help of a network of aid workers, academics and diplomats that he had nurtured over many years, he was able to flee to Canada and obtain permanent resident status there.