Tortured Law/Tortured "Justice"-Joint Criminal Enterprise In The Case Of Aloys Simba (original) (raw)

Beth S. Lyons was Trial Co-Counsel for Aloys Simba in 2004-2005, on the Defence team headed by Lead Counsel Me. Sadikou Ayo Alao. She is grateful to Me. Alao for discussions on the points in this paper. She is a member of the Bureau for the International Association of Democratic Lawyers (IADL) and an Alternate Representative for IADL to the U.N. in New York. Simba Decisions and Judgments may be found at the ICTR website, www.ictr.org. The author thanks Nathaniel G. Dutt for his assistance. I. JCE has been held to be part of "committing" under Articles 6(1) and 7 of the Statute of the International Tribunal for Rwanda; see generally Prosecutor v. Milutinovic et al., Case No. IT-99-37-AR72, Decision on Ojdanic Challenge to JCE Jurisdiction (Int'l Crim. Trib. for the Former Yugoslavia May 21, 2003), Separate Opinion by Judge David Hunt.