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ECLI:NL:RBDHA:2017:16383

DISTRICT COURT OF THE HAGUE Criminal law Multiple judge panel of the Criminal Court responsible for cases concerning international crimes Public Prosecutor's office number: 09/748013-12 Date judgment: 15 December 2017 Defended action (Promis judgment) Based on the indictment and the examination in court the District Court of The Hague has delivered the following judgment in the case of the Prosecutor against the accused: [judgment according to the project for improved statement of grounds in criminal judgments] [Eshetu A.], born in [place of birth] on [day of birth] 1954, residing at [city], currently detained in the penitentiary institution "Krimpen aan den IJssel" in Krimpen aan den IJssel, the Netherlands. Name of the investigation: Merens Structure of the judgment The judgment is structured as follows:

  1. Introduction 1.1 Preamble 1.2 The Ethiopian calendar 1.3 The spelling of names 1.4 References 1.5 Use of the English language
  2. The charges
  3. The investigation 3.1 The criminal investigation 3.2 The investigation by the examining magistrate 3.3 The trial
  4. The admissibility of the Prosecution Service 4.1 Introduction 4.2 The position of the Prosecution Service 4.3 The opinion of the court
  5. The applicable law
  6. The history of Ethiopia
  7. The existence and the nature of the conflict 7.1 Introduction 7.2 The position of the Prosecution Service 7.3 The position of the Defence 7.4 The frame of reference 7.5 The nature of the conflict in Ethiopia 7.5.1 The EPRP and the State 7.5.2 Different warring factions and the State 7.5.3 The knowledge of the armed conflict
  8. The witness statements 8.1 Introduction 8.2 The position of the Prosecution Service 8.3 The position of the Defence 8.4 The reliability of the witness statements 8.4.1 The frame of reference 8.4.2 The reliability of the witness statements in this case 8.5 The witness statements 8.6 The requests to hear witnesses
  9. The documents in writing and the expert reports 9.1 Introduction 9.2 The position of the Prosecution Service 9.3 The position of the Defence 9.4 The case documents 9.4.1 The written documents 9.4.2 The expert reports and the examination of the experts
  10. Establishing the actual events 10.1 Introduction 10.2 Establishing the actual events
  11. Protected persons 11.1 Introduction 11.2 The position of the Prosecution Service 11.3 The position of the Defence 11.4 The opinion of the court
  12. Violations of the international humanitarian right 12.1 Introduction 12.2 The position of the Prosecution Service 12.3 The position of the Defence 12.4 The frame of reference 12.4.1 Regarding the charges under count 1 and 4 of the indictment 12.4.2 Regarding the charges under count 2 of the indictment 12.4.3 Regarding the charges under count 3 of the indictment 12.5 Violations of international humanitarian right in this case 12.5.1 Regarding the charges under count 1 and 4 of the indictment 12.5.2 Regarding the charges under count 2 of the indictment 12.5.3 Regarding the charges under count 3 of the indictment
  13. The determination of the role of the accused 13.1 Introduction 13.2 The position of the Prosecution Service 13.3 The position of the Defence 13.4 The actual determination of the role of the accused 13.5 The qualification of the role of the accused 13.5.1 The frame of reference for co-perpetration, complicity and incitement 13.5.2 The frame of reference for responsibility as a superior 13.5.3 Participation and liability in this case
  14. The nexus 14.1 Introduction 14.2 The position of the Prosecution Service 14.3 The position of the Defence 14.4 The frame of reference 14.5 The nexus in this case
  15. Violation of the 'WOS'
  16. The (partial) acquittals
  17. The judicial finding of facts
  18. The criminality of the facts stated as proven
  19. The criminal responsibility of the accused
  20. The passing of the sentence 20.1 The demand of the Prosecution Service 20.2 The position of the Defence 20.3 The judgment of the Court
  21. The claims of the injured parties 21.1 Introduction 21.2 The competence of the Court to judge the claims 21.3 The assessment of the claims
  22. The applicable articles of law
  23. The decision Attachment 1: The indictment Attachment 2: The requests to hear witnesses. Attachment 3: The finding of facts Attachment 4: The endnotes (literature & case law) 1Introduction 1.1 Preamble The accused stands trial for involvement in war crimes, committed in Ethiopia during the period from 1 February 1978 up and until 31 December
  24. War crimes are serious infringements of the humanitarian law of war, which sets out a minimum standard for the treatment of protected persons, to be observed by each of the factions involved in an armed conflict. In this context it does not matter which faction should be labelled as the aggressor in the conflict and it also irrelevant whether the opposite faction has respected the rules of the humanitarian law of war. Any person committing a serious violation of the humanitarian law of war can be criminally prosecuted for this, regardless of the side on which he fought. The fact that the accused was a member of the Derg, later renamed the Provisional Military Administrative Council (hereafter: PMAC), was not up for discussion during the trial. Neither was the existence disputed, of (armed) resistance against the Derg from numerous groups during that period. During the examination in court the accused has brought up a lot about the horrors, the backgrounds and the complexity of the conflict in Ethiopia during that period and the violence he says the Derg were faced with. However in this criminal case the Court will only pass a judgment on the question whether or not the accused can be found guilty of the serious violations of humanitarian law of war mentioned in the indictment and, if so, what would be the eventual punishment he deserves for this. However the Court will explicitly not express an opinion on the question which of the factions should go down in history as the one who had the right on their side. 1.2 The Ethiopian calendar Ethiopia uses a calendar based on the Coptic calendar, while the western world uses a Gregorian calendar. The Coptic calendar had twelve months of thirty days and a thirteenth month of five or six days, depending on the fact if the year in question is a leap year. Because of the use of these different calendars there is a difference of seven or eight years in which the Gregorian calendar is ahead of the Coptic one. Under the Coptic calendar the New Year starts on the first of September, while this happens on the 11th of September under the Gregorian calendar. The thirteen Ethiopian months have the following names: Meskerem (11 September up to 10 October) Tikimt (11 October up to 9 November) Hidar (10 November up to l 9 December) Tahsas (10 December up to 8 January) Tir (9 January up to 7 February) Yekatit (8 February up to 9 March) Megabit (10 March up to 8 April) Miyazia (9 April up to 8 May) Ghinbot (9 May up to 7 June) Sene (8 June up to 7 July) Hamle (8 July up to 6 August) Nehassie (7 August up to 5 September) Pagume (6 September up to 10 September, eventual leap year) From Meskerem 1 until Tahsas 22 (11 September up to 31 December) the difference is seven years. From Tahsas 23 up to Pagume 5 or 6 (1 January up to 10 September) the difference is eight years. During a leap year the date of 29 February appears in the Gregorian calendar. This coincides under the Gregorian calendar with Yekatit
  25. The date 1 March then becomes Yekatit
  26. All days under the Coptic calendar move one day until Pagume 6 is reached. Whenever the dates mentioned in the present judgment are under the Ethiopian calendar this is indicated behind the date (E). 1.3 The spelling of names There are a lot of names mentioned in the file. These are Ethiopian names which where originally written in the Amharic language. The Court wants to emphasize that in case of a translation of names from one spelling into the other (as in the present case from Amharic into Dutch) the spelling of the names will necessarily be phonetic. The Court has established that some of the names in the Dutch translation of the name lists, are spelled in different ways in the case-file (for example [person 322] and [person 322, different spelling]) and also that this spelling is sometimes not the same as the spelling used in the witness statements, although the witness does say that he or she recognises the names. For every discrepancy the Court has assessed if this discrepancy can be accounted for by the translation or if there is doubt whether the different spelling actually refers to the same person. For every indication in the judgment that a certain person was mentioned or recognised, the Court has made this assessment and found that the sound of the name was so similar that the discrepancy in spelling could be accounted for by the translation. 1.4 References In this judgment reference will be made to statements during the hearing in court, official reports and other documents in writing. This reference will be made in the following manner in footnotes, where evidence is concerned. If it concerns a police-report this is always an official report drawn up by one or more criminal investigation officers in compliance with all legal requirements. Therefore the reference will be 'police-report of....'; the dots will state what kind of police-report it concerns (for example a witness interrogation or an armed conflict) and on which page of the criminal case file the reference is made. Furthermore, in case of an official report of a witness examination the name of the witness will also be mentioned. If this concerns a witness statement during the hearing in court the reference will be 'statement of the witness, made during the hearing on court on....' the dots will state the date of the court hearing when the statement was made. If this concerns a document this is always an attachment to an official report of the hearing in court or an official report some other document drawn up by the police or the Prosecution Service. The reference will then be that is stated 'document, being an attachment to document....' the dots will state the number or the attachment/document, the official report or document it is attached to and (if included in the criminal case file) the page of the criminal case file this annex or document can be found. In case the document is literature there will be always a complete reference to the publication, as much as possible according to the guideline for legal authors. Where documents in the Amharic language are concerned, the Court will always refer to the lists that were translated into Dutch. However the Court will use this translation as evidence that should be evaluated in an interrelated context with the official report of findings of 41 pages in the Amharic language (page 950-955). When it concerns an official report drawn up by an examining magistrate and with one or more registrars this is always an official report drawn up in compliance with all legal requirements by an examining magistrate of the District Court of The Hague responsible for hearing criminal cases and one or more registrars. When it concerns an official report of an interrogation by an examining magistrate the reference will be 'official report of witness interrogation....by the examining magistrate': the dots will state the name of the witness or the export who was interrogated and the paragraph number of the official report of interrogation where the statement can be found. When it concerns the report of an expert the reference will be that ' report....' the dots will state the name of the expert and the page of the report. Besides, there are page numbers between parentheses in several places. These are not evidentiary materials but are intended as a guide for the reader who has a copy of the criminal case file. This judgment also contains references (mainly in the frames of reference) to literature and case law. These references are made by endnotes. References to literature and case law are made as much as possible according to the guidelines for legal authors. 1.5 Use of the English language Because of the international nature of the charges against the accused the Court frequently uses quotations and terminology in English in this judgment; 2The charge The accused stands trial for involvement in war crimes allegedly committed in Ethiopia during the period from 1 February 1978 up and until 31 December
  27. These facts are described in the amended indictment, which is attached to this sentence as annex
  28. The charges against the accused are, briefly stated, the following: Count 1: Deprivation of freedom and inhuman treatment during the period from 1 February 1978 up and until 31 July
  29. The accused allegedly subjected 321 persons in Debre Marcos and/or Metekel to cruel and inhuman treatment, pronounced sentences against them without prior prosecution and trial by an independent court and arbitrarily deprived them of their freedom. This fact was charged in the modes of co-perpetration, deliberately allowing as a superior and complicity. Count 2: Torture during the period from 1 February 1978 up and until 1 September
  30. The accused allegedly tortured nine persons who were held in detention. This offence is charged in the modes of co-perpetration, deliberately allowing as a superior and complicity. Count 3: The killing of 75 persons during the period from 14 August 1978 up and until 17 August
  31. The accused allegedly ordered the killing of 75 persons who were imprisoned in Debre Marcos and/or Metekel. This offence is charged in the modes of co-perpetration and incitement. Count 4: Deprivation of freedom and inhuman treatment during the period from 1 August 1978 up and until 31 December
  32. The accused allegedly subjected 240 persons to cruel and inhuman treatment in Debre Marcos en/or Metekel in a way described as under count
  33. This offence was charged in the modes of co-perpetration, deliberately allowing as a superior and complicity. The war crimes charged to the accused are defined in the articles 8 (old) and 9 (old) of the Dutch Criminal Law in Wartime Act [Wet Oorlogsstrafrecht] (hereafter: 'WOS'). 3The investigation 3.1 The criminal investigation On 13 June 1998 the Dutch magazine Vrij Nederland published an article called: “Oorlogsmisdaden, Ethiopische beul is ondergedoken in Nederland” ["War crimes, Ethiopian executioner hiding in the Netherlands"] The article said that during the Mengistu regime (Derg regime) in Ethiopia in 1978, a person named [Eshetu A.] had signed lists of names of persons that were executed or sentenced to prison with hard labour (see page 416-420). The former National Criminal Investigation Service [Dienst Nationale Recherche] of the Dutch National Police Force (hereafter: NR), which is now the Team International Crime of the Dutch National Criminal Investigation Service (hereafter: DLR), carried out an investigation on the basis of media publications to see if any other information could be found pointing to the alleged involvement of the accused during the period mentioned in the article. In a report of Human Rights Watch from 1994 called Ethiopia Reckoning under the Law reference is made to crimes committed by the Derg-regime: “During the Derg period, warfare continued and expanded throughout Ethiopia. The Derg regime continued and intensified the war in Eritrea and also fought a conventional war against Somalia, in 1977-78, when Somalia invaded and claimed the Ogaden region. The Derg also fought against ethnic-based insurgencies in nearly every part of the country– especially Tigrayans in the north, and Oromos and Somalis in the south and east. All of these wars were marked by widespread human rights and humanitarian law abuses against civilians.” (…)”These abuses included not only isolated massacres perpetrated by individual military units, but a systematic and general policy of terror and destruction aimed at the civilian population. The government’s counter-insurgency measures included mass killings of villagers by the army, the bombing of villages and market towns, killing of livestock, poisoning of wells, and forcible relocation of much of the rural population.” (see p. 465) When a police officer made a query on the Internet this resulted in two documents in which reference is made to a death sentence in absence of the accused because he was allegedly responsible for the death of a large number of persons during the former regime of Mengistu Haile Mariam. The accused was allegedly a senior official during this regime. The referred documents are: “IRIN Africa ETHIOPIA: Absent official sentenced to firing squad. A senior official from Mengistu Haile Mariam’s former regime was on May 8 (no year) sentenced to death ‘in absentia’ for the execution of 197 people. Lieutenant [Eshetu A.] was serving as a member of the Provisional Military Administrative Council for Gojjam. According to the court, the convict should be executed by firing squad.” (see page 484); and “Apanews, Ethiopia-Mengistu-Sentence, 11-1-2007: Former Ethiopian dictator Mengistu Haile Mariam and top officials of his regime were on Thursday sentenced to life imprisonment by an Ethiopian court (…) The court, however, ordered that the death penalty sentences it had previously passed, to remain against four accused, including (…) [Eshetu A.].” (see p. 486) On 8 October 2009 a public prosecutor of the Dutch National Prosecution Service issued a written request for judicial assistance to the Ethiopian authorities. After this the criminal investigation came to a standstill because the material that was promised during an execution mission, was not provided. On 3 July 2012 the investigation into possible involvement of the accused was reopened under the working title 'Merens' and the Public Prosecutor sent an official reminder of the request for judicial assistance issued in
  34. On 12 April 2013 a criminal investigation officer in Addis Abeba received a set of 41 pages in the Amharic language from the hands of mister [person x], [function person x] in Addis Abeba and [person y], [function person y] in Addis Abeba. [person x] and [person y] said that these were copies of documents used in the Ethiopian criminal proceedings against the accused. The criminal investigation officer numbered the pages from 1 to 41 according to the order of the pages upon receipt (see page 907-908 and 910-949). The texts in the Amharic language were translated into Dutch. In the written translation the page numbers are displayed above the translated text on the right-hand side. (see page 950-955 and 957-1003). On 24 October 2013, with the authorisation of Mr. [person z], [function person z] Dutch investigation officers were allowed to photograph other parts of the Ethiopian criminal case file against the accused. (see page 1195-1196 and 1198-1371). These pages of the case documents were translated into Dutch and classified with the aid of an interpreter. In the translation the interpreters have changed the dates in the text to the Gregorian calendar (see page 1372-1376 and 1377-1789). On 16 July 2012 the file of accused was received from the Dutch Immigration and Naturalisation Service (hereafter: IND) (see page 652-658, 660-664 and 666-885). On 8 May 2015 the Ethiopian authorities have expressed that they no longer wished to cooperate with the Dutch criminal investigation (see page 94 and 97). The NR and DLR heard sixteen witnesses in the United States of America, Canada and the Netherlands, who were in the prison in Debre Marcos during the Megistu regime or who are surviving relatives of people who were killed. Also the ex-wife and the son and daughter and some old acquaintances of the accused were heard. The NR also heard [person 328], who was mentioned in the article in the magazine Vrij Nederland. During the investigation against the accused special methods of investigation have been deployed. The telephone of the accused was tapped during several periods of time and in the context of the systematic gathering of information a series of conversations took place between the accused and a police officer who was not recognisable as such, and who worked for the undercover team of the department for shielded operations. On 29 September 2015, the accused was arrested by order of the public prosecutor of the National Public Prosecutor's Office. Directly after this the house of the accused was searched. During this search, inter alia, photo albums, photos, books, a military identity card, attestations, magazines and distinguishing signs were seized (see pages 210-211 and 224-226). On the same day the accused was taken into police-custody. On 2 October 2015 the examining magistrate placed the accused in pre-trial detention. After this and parallel to the investigation by the examining magistrate, the DLR continued the criminal investigation. This investigation included, among other things, the interrogation of the accused and an analysis of the seized items and documents that had, in some other way, become available in the course of the investigation. 3.2 The investigation by the examining magistrate On 9 December 2015 the examining-magistrate had pre-trial meeting with the public prosecutors and the defence lawyers, to discuss the wishes for further investigation on which the examining-magistrate had to decide. The records of these pre-trial meetings and the decisions of the examining-magistrate are in the case-file. The official reports of findings and the actions of the examining magistrate are also in the case-file. The examining-magistrate appointed Mr. W.C. de Jong, forensic expert in graphology, as expert and instructed him to carry out a forensic graphology examination. He submitted his report on 28 June 2016, and was examined as an expert-witness on 28 June
  35. After a joint nomination of the Prosecution Service and the Defence the examining magistrate appointed professor G.J. Abbink as expert to report on the different aspects of the conflict. Professor Abbink was also examined as a witness-expert by the examining magistrate after submitting his report. This examination took place on 8 November
  36. After the examination of the witness-expert Abbink the Defence requested on 9 November 2016 to appoint a new expert since Abbink, in the opinion of the Defence, had created an appearance of impropriety or bias, because he allegedly commented on the matter of guilt. The Prosecution Service submitted a written response to this request. In the decision of 14 November 2016, the examining magistrate declined this request because in her opinion it was not in the interest of the investigation to appoint a new expert. The first preliminary hearing of the trial against the accused took place on 7 January
  37. On that occasion the Court handed over the documents to the examining magistrate 'to do whatever the examining magistrates deems useful and desirable'. During the following preliminary hearings the (progress of the) investigation by the examining magistrate was discussed. During each of those hearings the Court has handed over the documents to the examining magistrate with the same 'open referral'. Up to mid November 2016 the examining magistrate had examined, besides the experts De Jong and Abbink, a total of eighteen witnesses. Fifteen of the witnesses were Ethiopian witnesses that were victims or surviving relatives of victims of the alleged conduct of the accused. All of these witnesses had also been heard either by the NR or the DLR. During a rogatory commission to the United States of America ten witnesses were heard. Four witnesses were heard in Canada. The [function person y] [person y], witness [person 329] and witness [person 321, different spelling] were heard in the Netherlands. In the Netherlands the examining magistrate also heard the verbalising officer working under number A-3751, who gathered systematic information in the investigation against the accused. Some Ethiopian witnesses were heard in their native language, Amharic, with the aid of an interpreter. Other Ethiopian witnesses were heard in English, also with the aid of an interpreter. All the official records of the examinations present a factual presentation of the interrogation. The person who was quoted in the article in the magazine Vrij Nederland indicated that he did not want to be further examined by the examining magistrate after a prolonged hearing by the NR. After hearing the arguments of both parties, and considering the state of the witness and the fact that he was not a direct eyewitness, the examining magistrate decided to cancel the examination. An official report was drawn up to record these actions and findings. On 15 November 2016 the examining magistrate decided that the investigative activities had been completed and closed the investigation. The examining magistrate submitted a folder containing all documents regarding the investigation carried out by the examining magistrate. On 16 February 2017 the Court declined a large number of requests for witnesses from the Defence. The case was referred again to the examining magistrate to handle the requests for witnesses that had been granted by the Court. On 18 April 2017 the examining magistrate examined witness [person 330]. On 25 August 2017 the examining magistrate examined witness [person 319, different spelling] in the United States with the aid of a psychologist. The other assigned witnesses could not be examined. This concerned Mengistu Haile Mariam, some witnesses who were hard to identify and the witness [person 331]. Later, on 30 October the Court rejected the examination of these witnesses, since it was considered unlikely that they would appear at the hearing in court within an acceptable time span. 3.3 3.3 The examination in court Court hearings - of a preliminary nature - where held on 7 January 2016, 31 March 2016, 28 June 2016, 22 September 2016, 21 November 2016, 9 January 2017, 12 May 2017 and 9 August
  38. The court hearings dealing with the substance of the case were originally scheduled to start on 21 November
  39. However, on 15 November 2016 the Court was informed that there had been a breach of confidence between the accused and his legal counsellors, and that the accused had now obtained the counsel of Mr. S. Arts and F.J.V.H. Stoffels, lawyers in Breda and Zevenbergen respectively. This led to a delay. The court hearings dealing with the substance of the case began on 6 February 2017, with the examination of the expert witness Abbink. This examination had the nature of a preliminary hearing to discuss the investigation wishes of the -new- Defence. The decision about these wishes for investigation was communicated at the hearing on 16 February
  40. The court hearings dealing with the substance of the case were then continued during the continuous hearings of 30 and 31 October, 2, 7, 8, 13, 14, 15, 16 and 17 November
  41. The investigation was closed at the hearing of 1 December
  42. Prior to 15 November 2016 the accused had been assisted by his legal counsellors J.J. Eizinga, lawyer in Amerongen, and S. Dogan, lawyer in Utrecht, and from this date onwards he was assisted by the afore mentioned legal counsellors Arts en Stoffels. With the exception of 15 November 2017, the accused has appeared and was heard at court hearings dealing with the substance of the case. The Court has taken cognizance of the demand of the public prosecutors N.H. Vogelenzang and A.J. van Dooren and of what was put forward by the legal counsellors of the accused and by the accused. The following aspects of the substance of the case should be mentioned or briefly discussed. Challenging of the Court After the preliminary hearing of 12 May 2017 the Court was challenged by the accused. The special judiciary panel for challenges of the court [wrakingskamer] ruled on 23 June 2017 that the request of the accused was not admissible. The accused lodged an appeal in cassation against this decision. Notwithstanding the ongoing appeal in cassation the Court continued the investigation on the basis that article 515, section five, of the Code of Criminal Procedure determines that there is no legal recourse against decisions on challenging and the Court was therefore not under challenge. In its ruling of 23 June 7 November 2017 the Supreme Court of the Netherlands dismissed the appeal in cassation of the accused as inadmissible for the reason mentioned before. Position of the Defence From the perspective that the criminal proceedings are void since the Court was supposed to be under challenge before the ruling of the Supreme Court and/or because there was no fair trial, the Defence decided to conduct a partial defence Injured parties As injured parties have joined [person 332] (sister of [person 4], mentioned as number 4 in the charges under count 1 and as number 1 in the charges under count 3), [person 321, different spelling] (mentioned as number 321 in the charges under count 1 and number 240 in the charges under count 4), [person 111, different spelling] (mentioned as number 111 in the charges under count 1 and number 30 in the charges under count 4), [person 174, different spelling] (mentioned as number 174 in the charges under count 1 and number 93 in the charges under count 4), [person 315] (mentioned as number 315 in the charges under count 1, under number 7 in the charges under count 2 and under number 234 in the charges under count 4) and [person 316] (mentioned as number 316 in the charges under count 1 and number 235 in the charges under count 4). They have each submitted a claim for compensation of immaterial damages for an amount of € 226,
  43. G. Sluiter and B. van Straaten, who are both lawyers in Amsterdam, assisted all these persons. Right to speak [person 332], [person 315], [person 174, different spelling], [person 333] (cousin/nephew of [person 4] afore mentioned and brother to [person 334] who is not mentioned in the indictment) and [person 317] (mentioned as number 317 in the indictment under count 1 and number 236 of the indictment under count 4) exercised their right to speak during the hearing of 2 November
  44. During the same hearing G. Sluiter, exercised the right to speak, as authorised legal counsel, on behalf of [person 111, different spelling] and the afore-mentioned [person 316]. The right to speak was introduced in 2005 in Dutch criminal procedure to allow victims and surviving relatives the possibility to tell the Court what the consequences of the committed criminal offences have been for them. Since then the circle of people and the scope of the right to speak have been extended, the last time on 1 April
  45. For the sake of completeness the Court recalls that article 21a of the Law on International Crimes [Wet internationale misdrijven] (hereafter: 'Wim'), entered into force on a April 2012, which determines -insofar as relevant to this case- that in case of criminal persecution for one of the crimes described in the 'WOS', committed before 1 April 1995, the provisions of the Code of Criminal Procedure regarding the victim shall apply. Therefore, the mentioned victims had the right to speak under the provisions of (the current) article 51a, first paragraph opening sentences and under a. and b. juncto, the articles 51c and 51e of the Code of Criminal Procedure. 4The admissibility of the Prosecution Service 4.1 Introduction The Defence argued that the Prosecution Service should be barred from criminal prosecution for several reasons. Regarding this defence the Court considers that in article 359a of the Code of Criminal Procedure the intended effect of a declaration of inadmissibility is reserved only for exceptional circumstances. This sanction is only appropriate in case of a gross violation of the principles of due process by which intentionally or with huge disregard for the interests of the defendant, his right to a fair trial was violated. (the Zwolsman criterion). This means that it should be established not only that there was a procedural error but also that the interests of the accused have been aversively affected by this error and that the right of the accused to a fair trial has been wronged intentionally or by gross negligence of these interests. In very exceptional cases the Prosecution Service can be barred although they cannot be blamed and the rights of the accused have not actually been violated. This circumstance occurs when the core of the legal order is touched by a gross violation of a fundamental principle such as the right to due process (the Karman criterion). The Court considers that if the Defence claims that there was a procedural error as referred to in article 359a of the Code of Criminal Procedure, then the Defence should clearly motivate why a presumed procedural error should lead to a (in this case, the ultimate) legal consequence. Only on such defence the Court is obliged to give a motivated ruling. In the opinion of the Court the Defence failed to provide this. It is hard to discern a structure in the counsel's speech; complaints possibly referring to the (non) admissibility are set out under the heading 'repeated witness requests' and it is hardly possible to identify a clearly substantiated position. The points of criticism rarely convey with sufficient clarity which actual provision is supposed to be infringed, how serious the supposed procedural error is, if this resulted in an actual disadvantage and if so, what this disadvantage is. Therefore the counsel's speech is not substantiated according to the applicable standards and for this reason a dismissal of this claim is to be expected. The claim of infringement of Karman-criterion is not (properly) substantiated and therefore might face the same fate. However, given the interest of the accused and the importance of this case the Court will respond. The Court interprets the defence regarding the procedural error in the following manner. After the release of the article on the accused the Prosecution Service has been sitting on its hands for too long. According to the Defence this irreparably impaired the rights of the accused. The accused has not, or not timely, been able to interrogate witnesses and has not been able to submit questions regarding the investigation to the Ethiopian authorities. Now the accused is faced with the fact that Ethiopia no longer wishes to cooperate. If the accused had been able to exercise his defence rights on time then the memory of the witnesses might have been less adversely affected or the witnesses might have influenced each other less. By providing selective information to the Canadian authorities the Prosecution Service seriously impaired the possibility to examine a witness in Canada [person 331], which had been allowed by the Court. Because of this the Canadian authorities refused to cooperate in the hearing of this witness by the examining magistrate. The position of the Defence was, briefly stated, that all these circumstances constitute a serious violation of the principle of due process by which the interests of the accused have been aversively affected and that the right of the accused to a fair trial has been wronged intentionally by or gross negligence of these interests Alternatively the Defence argues that there is such a gross violation of a fundamental principle of a due process, that this touches the hart of the legal system (Karman criterion). According to the Defence this violation should also lead to a declaration of non-admissibility. The Court understands that the Defence in this context refers to a criminal case file, which is considered unbalanced, one-sided and in which exculpatory investigations have not been included. 4.2 The position of the Prosecution Service The Prosecution Service argued that nothing indicates an intentional delay of the investigation from the side of the Prosecution Service. According to the Prosecution Service the Defence has rightly pointed out that a lot of time passed between the article in the magazine Vrij Nederland and the arrest of the accused. It cannot be established if Ethiopia, should the investigation against the accused have started earlier, would have cooperated in the examining of the witnesses there. It was a decision of the Canadian authorities not to cooperate with the interrogation of [person 331]. The claim that this would be a violation of the Karman criterion has not been substantiated at all. The Prosecution Service concluded that this defence should be rejected. 4.3 The opinion of the Court The Court observes, together with the Defence and the Prosecution Service that a large period of time has elapsed between the release of the article and the start of the criminal investigation. However, the statement that the police or the Prosecution Service intentionally or by gross negligence of the interests of the accused would have stalled in order to compromise his right to a fair trial, has not been substantiated or become apparent. The assumption that the Ethiopian authorities would have rendered full cooperation if the investigation had started earlier is based on speculation. Moreover at that time the criminal proceedings against the accused had already started in Ethiopia (the indictment against the accused is dated 23 December 1996). The reasons why the Ethiopian authorities in the end refused to cooperate therefore already existed. The allegation that the Prosecution Service would have sabotaged the possibility to hear this witness by informing the Canadian authorities about the mental condition of the witness [person 331], is based not only on an incorrect account of the comment on this subject of public prosecutor Vogelenzang at the hearing on 30 October 2017, but is also contradicted by the content of the e-mail which the examining magistrate received from the Canadian authorities. This e-mail shows that the Canadian authorities, based on their own investigation and findings, concluded that the witness suffers from PTSS, and for this reason the further execution of the request for judicial assistance was refused. In the opinion of the Court there is therefore no procedural error as referred to in article 359a of the Code of Criminal Procedure. The Court is of the opinion that sufficient effort was made by the Prosecution Service to make the investigation as wide-ranging as possible by also hearing possibly exculpatory witnesses like the ex-wife and the (former) friends of the accused. The refusal of the Ethiopian authorities at some point in time to allow further investigation in their country is not something that can be held against the Prosecution Service. Furthermore, the Court has not been able to determine a violation of such a fundamental principle of the right to due process as to touch the hart of the legal system, let alone a gross violation. Therefore the Court dismisses this defence. 5Applicable law Article 8 (old) and 9 (new) of the 'WOS' At the time of the facts mentioned in the indictment war crimes were criminalised, inter alia, in article 8 (old) of the 'WOS' and the superior responsibility in article 9 (old) of the 'WOS'. The text of Article 8 (old) and 9 (old) of the 'WOS' was: Article 8 Anyone who commits a breach in the laws and practices of war shall be liable to a term of imprisonment of not exceeding ten years. A term of imprisonment not exceeding ten years shall be imposed: 1°. If the act is likely to cause the death or serious bodily harm to another person; 2°. If the act involves inhuman treatment; 3°. If the act involves forcing another person to do, omit or tolerate something; 4°. If the act involves plundering.
  46. Death penalty, life imprisonment or a term of imprisonment not exceeding twenty years shall be imposed: 1°. If the act results in the death or serious bodily injury to another person or involves rape; 2°. If the act involves violence committed jointly and in conjunction with others against one or more persons or violence against a dead, sick or injured person; 3°. If the act involves destroying, damaging, rendering unusable or removing, goods, belonging entirely or partially to another person; 4°. If the act, referred to in the preceding paragraph under 3° or 4°, is committed in association with others; 5°. If the act is an expression of a policy of systematic terror or wrongful actions against the entire population or a specific group thereof; 6°. If the act involves breaking a promise, or constitutes a breach of an agreement entered upon with the opposing party as such; 7°. If the act involves making improper use of a flag or emblem or the military insignia or the uniform of the opposing party, protected by the laws and customs of war; Article 9 A superior shall be liable to the penalties prescribed for the offences referred to in the preceding article if he intentionally permits the commission of such an offence by a subordinate. The possibility of a pecuniary sanction was added to the first, second and third paragraph of article 8 (old) of the 'WOS', by the law of 10 March 1984 (Official gazette. 91, Law on classification of pecuniary sanctions and fines). The possibility of the death penalty was removed by the law of 14 June 1990 (Official gazette. 369) As from 1 October 2003 article 8 (old) of the 'WOS' was replaced by the articles 5, 6 and 7 of the 'Wim' and article 9 (old) of the 'WOS' by article 9 of the 'Wim'. This resulted in a change in legislation. According to article 1, second paragraph of the Criminal Code, if there is a change in the legislation after the offence has been committed the most favourable provisions for the accused shall apply. However the re-codification of the 'WOS' to 'Wim' is not due to a changed perception of the legislator of the punishable offences. Neither is a changed perception reflected in the eventual penalty, which in the 'Wim' is not really different from the 'WOS' and has been based on the grounds for an increase in penalty laid down in the 'WOS' . Furthermore, in judgments from this Court and the Court of Appeal of the Hague it has been established many times that article 1, second paragraph of the Criminal Code is not applicable in this context. Of course this is not the case for the afore-mentioned changes in the 'WOS', in which the possibility of a pecuniary sanction was added and the death penalty was removed. The term ‘the laws and the customs of war' The immediate cause for the criminalisation of crimes of war in the 'WOS' in the early fifties were the four Geneva Conventions of 1949 which determine the rules of humanitarian law in times of an armed conflict (hereafter: GC I, GC II, GC III, GC IV). In these conventions the central issues are the different categories of protected persons during an armed conflict. These categories are the wounded and sick in armed forces in the field (GC I), sick and shipwrecked members of armed forces at sea (GC II), on the treatment of prisoners of war (GC III), and civilian persons in time of war (GC IV) respectively . The Geneva conventions fully apply to the international armed conflicts and partially to non-international conflicts. These four conventions contain an article 3, which is the same in all conventions. This is the so-called common article 3 (hereafter: common article 3). The common article 3 contains minimum standards of behaviour which warring parties in a non-international conflict should comply with. The common article 3 is as follows: In the case of armed conflict of a non-international character in the territory of one of the High Contracting Parties, each Party to the conflict shall be bound to apply, as a minimum, the following provisions:
  47. Persons taking no active part in the hostilities, including members of armed forces who have laid down their arms and those placed ' hors de combat ' by sickness, wounds, detention, or any other cause, shall in all circumstances be treated humanely, without any adverse distinction founded on race, colour, religion or faith, sex, birth or wealth, or any other similar criteria. To this end, the following acts are and shall remain prohibited at any time and in any place whatsoever with respect to the above-mentioned persons: a. violence to life and person, in particular murder of all kinds, mutilation, cruel treatment and torture; b. taking of hostages; c. outrages upon personal dignity, in particular humiliating and degrading treatment; d. the passing of sentences and the carrying out of executions without previous judgment pronounced by a regularly constituted court, affording all the judicial guarantees which are recognized as indispensable by civilized peoples.
  48. The wounded and sick shall be collected and cared for. An impartial humanitarian body, such as the International Committee of the Red Cross, may offer its services to the Parties to the conflict. The Parties to the conflict should further endeavour to bring into force, by means of special agreements, all or part of the other provisions of the present Convention. The application of the preceding provisions shall not affect the legal status of the Parties to the conflict. The four Geneva Conventions were ratified by Ethiopia in
  49. The Geneva conventions contain the obligation for the member states to penalize and prosecute serious violations of the conventions. The legislator took this as 'an urgent reason to now come to a final legislation'. In article 8 (old) of the 'WOS' the choice was made to refer to 'the laws and customs of war'. The explanatory memorandum sets out that this means: "The offence described in article 8, is the act of violating the laws and customs of war. Therefore this provision refers directly to the law of war, not only to the written law of war, laid down in international treaties, but also to the international customary law as far as it refers to war"". The text of article 8, first paragraph, (old) of the 'WOS' offers the Court many sources that could be applied, without further specification. For the implementation of the elements of article 8 (old) of the 'WOS' the Court is expected to take account of international law and international justice. The term 'the laws and customs of war' refers, as mentioned, inter alia, to the four Geneva Conventions mentioned above but also to the Additional Protocols I and II (hereafter: AP I and II) of 8 June
  50. AP I and AP II fill some gaps in the Geneva Conventions. AP I does this for international armed conflicts, AP II for non-international armed conflicts. The aim of AP II is the (further) improvement of the protection of civilians and others who do not/not longer take part in the armed conflict. Ethiopia only joined AP I and AP II in 1994, which was after the period mentioned in the indictment. Finally, international customary law can be used as a reference for the interpretation of the term 'the laws and customs of war'. International customary law relies on two elements: 1) A general state practice and 2) a sense legal obligation (opinus juris). A custom can be accepted as a law if a sufficient number of states participate in a certain practice in a consistent manner (general practice of states) and if they are convinced that these practices are tolerated or required by international law (sense of legal obligation). The practice of states can consist of actions of all state organs, the conclusion of certain treaties, etc. Furthermore, states should not only implement the practice because it is politically appropriate, but because this practice is considered to be either required or allowed by international law. This legal obligation can be reflected in explicit statements, protest or reservation. It can be assumed that by concluding a treaty states are able to acknowledge that a certain practice is required or allowed by international law. Decisions of international organisations can also contain indications for the sense of legal obligation of states. This will depend, inter alia, on the content of the resolutions and the condition under which they are accepted. In case of a large number of dissenting votes the opinio juris is not likely to be adopted. The sense of legal obligation also derives from general practice. If there is no explicit proof of a dissenting sense of legal obligation, for example in the form of protest by states, it can be assumed that practice implies sense of legal obligation. In the following chapter the Court will address, as far as this is relevant, the question which interpretation should be given according to international humanitarian law to the laws and customs of war. The elements of war crimes Based on the common article 3 and its interpretation in (international) justice, a war crime in a non-international armed conflict, as the accused is charged of committing, requires the following elements:

(1)the existence of a non-international armed conflict on the territory of one of the contracting parties;
(2)the perpetrator has to have knowledge of this armed conflict.
(3)The victims should belong to one of the categories of protected persons referred to in the common article 3; meaning they should be persons who do not participate directly in the hostilities.
(4)There should be a close relationship between the offence and the armed conflict; known as nexus in the (international) literature and law. Criminalization of war crimes is intended to offer protection against offences (closely) related to warfare. Necessary steps for evaluating the indictment In order to evaluate the indictment the Court will give its position on the existence and the nature of the conflict in Ethiopia and the knowledge of the accused about this in chapter
  1. Followed by an overview of the witness statements, documents and expert reports in the case file and an assessment if they can be used as evidence in chapters
  2. and
  3. The Court will establish if the events mentioned in the indictment have actually taken place in chapter
  4. Then, in chapter 11, the Court will assess if the persons mentioned in the indictment are persons as referred to in article
  5. Thereafter the Court will determine in chapter
  6. if the established facts constitute actual violations of article 3 and the customary humanitarian law. In chapter 13 the Court will establish if the accused played a part in these facts and, if so, what was his part and thereafter how this eventual part should be qualified. The Court will then give its position on the existence of a nexus in chapter
  7. Finally the Court will decide if the established facts constitute a violation of the 'WOS' in chapter
  8. 6The history of Ethiopia The charges against the accused and the decisions of the Court on these matters can not be fully understood without prior knowledge of the political situation in Ethiopia and the history of the country during the period from 1930 to 1974; the reign of emperor Haile Selassie, and during the period from 1974; the period of the revolution. From the first half of the 1930's emperor Haile Selassie had absolute power in Ethiopia. His reign lasted up to 1974, but was interrupted by the Italian occupation in the years 1936 to
  9. The departure of the Italian occupier in 1941 was followed by the British rule over Ethiopia, which heavily encroached Ethiopian sovereignty. British nationals held key positions in Ethiopian administration. Eritrea, a former province of Ethiopia used by the Italians as an operational base against Ethiopia, became the stake of the territorial battle between Ethiopia and the United Kingdom. Eritrea finally became independent from the United Kingdom in 1953 and has since then been joined in an UN-mandated federation with Ethiopia. In this federation Eritrea had its own government and the legislative, executive en legislative powers had been formalised. This democratic experiment was, partly due to the imperial absolutism in Ethiopia, doomed to fail. After dismantling the frail democratic institutions, Etritrea became -again- an Ethiopian province in
  10. This process contains the roots of the Eritrean Liberation Movement (hereafter: ELM), which originated in Sudan and the Eritrean Liberation Front (hereafter: ELF) founded in
  11. From the ELF and some splinter groups later originated the Eritrean People’s Liberation Front (hereafter: EPLF). Around 1961 the armed conflict between the ELF and the Ethiopian army flared up, partly because Eritreans realised their civil and political rights were gradually weakened. In 1967 large scale attacks by Ethiopia led to the burning of dozens of Eritrean villages, the killing of ten of thousands of cattle and the flight of tens of thousands of Eritreans to Sudan. The suspicion of cooperating with ELF and EPLF was usually followed by execution. The ELF and the EPLF reacted by plundering villages, taking missionaries as hostages and executing 'collaborators'. The war with Eritrea was an important factor in the events leading to the revolution in
  12. A much earlier political signal was given by the coup in December 1960 by a group of military from the Imperial Bodyguard, who attempted to depose the emperor while he was abroad. The coup failed due to poor preparation and a lack of support and was suffocated after three days. Although emperor Haile Selassie apparently did not take the coup as a harbinger of more rebellions, the period from 1963 to 1970 saw increased resistance in different parts of the country. The position of the emperor no longer seemed untouchable. Besides the conflict with Eritrea there were civil disturbances among students in Addis Abeba and in several provinces, among which Gojjam, the impoverished peasant population rose up against the new tax laws. Because the Ethiopian society was fragmented by ethnic and physical boundaries and suffered from poverty, insecurity and fear of repression, it took quite some time before the revolution could make its entry. The years between the military coup and the revolution in 1974 showed a widening gap between the absolutist state on one side and the society on the other. The fact that the imperial regime was able to last until 1974 can possibly be accounted for by the lack of organisation of the different rebellious groups. Nevertheless the student movement did become stronger after the coup, possibly under the influence of the worldwide student movements and of the decolonisation process in African countries. In 1974 the unrest within the army became more apparent. The Derg was formed in June of the same year, it was intended as a representative of all military units, a sort of military parliament from which the higher ranks were excluded because of their ties with the imperial regime. With the failed coup of 1960 as a warning the Derg at first acted very careful and succeeded to obtain amnesty for political prisoners and exiles, to get a number of high ranking government officials locked up and to achieve broad public support. On 12 September 1974 the Derg made a proclamation in which emperor Haile Selassie was deposed and detained. In the same proclamation the Derg was transformed into the PMAC, the constitution was suspended, parliament dissolved and a ban was announced on strikes and demonstrations. The slogan People’s Government that was popular before was now changed into Provisional People’s Government. Besides there were two important leftist movements Ethiopian People’s Revolutionary Party (hereafter: EPRP) and All Ethiopian Socialist Movement (hereafter: Meison). A more aristocratic movement for independence was formed by de Ethiopian Democratic Union (hereafter: EDU), founded under the leadership of two members of the deposed emperor Haile Selassie. Rebellious military units and protests by workers were violently repressed. In November 1974 the PMAC announced that they had shot their president, Aman Andom and had executed around sixty persons in custody; some of them high ranking officials of the imperial regime but also members of their own party. It seems that the seeds of the so-called ‘Red Terror’, aimed at eliminating political enemies and scaring potential adversaries, were planted here for the first time. At the beginning of 1975 the Meison shifted more to the political direction of the PMAC, possibly because of its own rather weak position on the political stage. In 1975 and 1976 armed EDU-units were active, they controlled a large part of the Gondar region, especially along the border with Sudan. Furthermore, the Derg had to deal with the ELF and EPLF who fought a joined battle against the Ethiopian army. The EPRP and the PLF also had contact with the Tigray People’s Liberation Front (hereafter: TPLF), a leftist student movement, founded in 1975 that gained more control over the province of Tigray over the following years. February 1976 is generally considered as the actual beginning of the Red Terror. For the EPRP the Red Terror started at the end of August 1976 when the Derg launched the official destruction campaign against the EPRP, resulting in a mass detention of EPRP members and sympathisers and the execution of some of them. The EPRP fought the Derg with attacks and with her armed wing. After 3 February 1977, the day on which Derg-chairman Terrifi Banti was killed, vice-chairman Mengistu seized total control, became chairman and from that moment on the violence intensified. Three waves of Red Terror are described: from September 1976 to June 1977, from October 1977 to begin December 1977 and finally from December 77 to March
  13. The mass killings were partly based on the promise “for every revolutionary killed, a thousand counter-revolutionaries executed”. By the end of April 1977, anticipating 1 May demonstrations persons suspected of sympathising with the EPRP were killed in large numbers. It was estimated that some thousand children had been killed in Addis Abeba, after which their corpses were left lying in the streets. The families of the death were forbidden to mourn for them. There were also mass arrests of alleged EPRP-supporters. Families who, as was the custom, brought food to the prison should understand that the person was dead when they were sent away and told that they no longer had to bring anything. Although around March 1978 most of the mass killings had ended the detentions and executions continued, especially in the province. Alleged supporters of the PMAC were forced to admit their membership of the EPRP in public confessions. This happened under threat of death during so-called exposure meetings, mass meetings. When a person did not expose himself but was reported by someone else, he would be executed. Students and teachers were arrested during these kinds of meetings in schools. Parents and children were forced to report each other. The writer René Lefort described the period of the Red Terror as follows: “History offers few examples of revolutions that have devoured their own children with such viciousness and so much cruelty (…) The revolution swallowed the whole of the young generation of Ethiopian intellectuals, that is literates.“ The acts mentioned in the indictment allegedly took place during this period. 7The existence and the nature of the conflict 7.1 Introduction The Court has already set out that a war crime committed in a non-international armed conflict, as the accused is charged of, requires the existence of such a conflict on Ethiopian territory during the period mentioned in the indictment. Therefore the Court needs to examine if there was a non-international armed conflict during the period mentioned in the indictment. Unlike cases about -for example- Ruanda, former Yugoslavia or Afghanistan there is no (ad hoc) tribunal or court, which has considered this question before. If the court concludes that there was a non-international armed conflict, then it should be considered if the accused had cognizance of this conflict. The court will give an outline of the frame of reference used as a basis for the afore-mentioned considerations in chapter 7.
  14. 7.2 The position of the Prosecution Service The Prosecution Service has argued that during the period from February up to August 1978 there was a non-international armed conflict between the Ethiopian government controlled by the Derg and the EPLF/ ELF, EDU and EPRP. Although there were separate groups which each fulfilled the criteria for application of international humanitarian law, all of these groups fought the same government (the Derg) and (during that relevant period of time) and not each other. 7.3 The position of the Defence The Defence did not take a position regarding the (nature of the) conflict in Ethiopia. 7.4 The frame of reference In order to establish the existence of an armed conflict during a certain period of time an analyses of the actual situation is required, based on the nature and scope of the combat actions, their purpose and the basis on which the actions take place. If armed violence between states or long-term armed violence between a state and (an) organised armed group(s) or between such groups has reached a certain level of intensity, the hostilities can be qualified as an international armed conflict respectively a non-international armed conflict. The Court considers that the offences mentioned in the indictment can be related to the fights that took place between the Derg and the EARP and other (armed) opposition groups and not between the Derg and another state. Hence there is no international armed conflict. The Court will therefore review the actual situation, especially the nature and the scope of the combat-actions, their purpose and the basis on which the actions were carried out for conformity with the criteria developed in international law for a non-international armed conflict. Intensity and organisation The definition of a non-international armed conflict has not been laid down in a treaty. The basic criteria result from the common article 3 and article 1 of the AP II, which says “This Protocol, which develops and supplements Article 3 common to the Geneva Conventions of 12 August 1949 without modifying its existing conditions of application" This definition was developed -and generally accepted - in international jurisprudence, in order to be able to distinguish situations of (rare) violence in internal disorders and tensions of armed conflicts. The Tadić case has generally been recognised as authoritative for the definition of, inter alia, a non-international armed conflict. In this case
(1)the intensity of the conflict and
(2)the organisation of the parties of the conflict were emphasised as the basic criteria of an armed conflict. The criteria from the Tadić case have been widely used in international and national case law and have also been further developed by the ICTY, which in the Boskoski & Tarculovski case summed up the relevant factors for an objective review of the requirements of 'intensity' and 'organisation'. As a result of the development in the Tadić case law and doctrine the International Committee of the Red Cross (hereafter: ICRC) modified her understanding of an armed conflict and concluded in 2008 that non-international armed conflicts “are protracted armed confrontations occurring between governmental armed forces and the forces of one or more armed groups, or between such groups arising on the territory of a State [party to the Geneva Conventions]”, in which the armed confrontation “must reach a minimum level of intensity and the parties involved in the conflict must show a minimum of organization.” The ICRC defined organised armed groups as groups who “develop a sufficient degree of military organisation to conduct hostilities on behalf of a party to the conflict, albeit not always the same means, intensity and level of sophistication as State armed forces”. The International Criminal Court (hereafter: ICC) gave the following guidelines in the Lubanga case regarding the assessment of the level of organisation of an armed group: “When deciding if a body was an organised armed group (for the purpose of determining whether an armed conflict was not of an international character), the following non-exhaustive list of factors is potentially relevant: the force or group’s internal hierarchy; the command structure and rules; the extent to which military equipment, including firearms, are available; the force or group’s ability to plan military operations and put them into effect; and the extent, seriousness, and intensity of any military involvement.” To determine of a party to the conflict fulfils the necessary criterion of organisation five groups of factors are relevant, namely factors who: “
  1. indicate the presence of a command structure;
  2. indicate whether the group can carry out operations in an organised manner;
  3. indicate the level of logistics;
  4. determine whether an armed group possesses the level of discipline and the ability to implement the basic obligations of common article 3;
  5. indicate whether the armed group was able to speak with one voice.” Here again the factors themselves are not essential. What matters is that “’organized armed groups' must have a sufficient degree of organization, in order to enable them to carry out protracted armed violence”. To also determine the intensity of the violence, the following factors can be taken into account: “the number of civilians forced to flee from the combat zones; the type of weapons used, in particular the use of heavy weapons, and other military equipment, such as tanks and other heavy vehicles; the blocking or besieging of towns and the heavy shelling of these towns; the extent of destruction and the number of casualties caused by the shelling or fighting; the quantity of troops and units deployed; existence and change of frontlines between the parties; the occupation of territory, and towns and villages; the deployment of government forces to the crisis area; closure of roads”’ Separate acts of violence do not fulfil the minimum requirement for intensity and none of these factors would be in itself decisive. If one of these factors has a low level it can be compensated by another factor with a high level. Protracted violence Regarding the question if the violence was sufficiently protracted, the ICC considered the following in the Bemba Gombo case: “The Chamber notes that the concept of “protracted conflict” has not been explicitly defined in the jurisprudence of this Court, but has generally been addressed within the framework of assessing the intensity of the conflict. When assessing whether an armed conflict not of an international character was protracted, however, different chambers of this Court emphasised the duration of the violence as a relevant factor. This corresponds to the approach taken by chambers of the ICTY. The Chamber follows this jurisprudence. The Chamber notes the Defence’s submission that “if the conflict devolves to the level of riots, internal disturbances or tensions, or isolated or sporadic acts of violence, or if the conflict ceases to be between organized armed groups”, the threshold for the existence of a “protracted armed conflict” would cease to be met. The Chamber considers that the intensity and “protracted armed conflict” criteria do not require the violence to be continuous and uninterrupted. Rather, as set out in the first sentence common to Article 8
(2)(d) and 8
(2)(f), the essential criterion is that it go beyond “isolated or sporadic acts of violence”. Until where and when does international humanitarian law apply? If the threshold of a non-international armed conflict is reached, international humanitarian law applies and continues to apply for the whole territory which is under control of the parties until a “peaceful settlement” is reached. The armed conflict only ends when one of the parties ceases to exist, for example because it is so defeated that re-grouping or continuation of the hostilities is impossible, even in the longer term or if there is a permanent cessation of the armed confrontations without a genuine risk of resumption. The Appeals Chamber of the ICTY considered in the Kunarac case: “There is no necessary correlation between the area where the actual fighting is taking place and the geographical reach of the laws of war. The laws of war apply (….) in the case of internal armed conflicts, the whole territory under the control of a party to the conflict, whether or not actual combat takes place there, and continue to apply (…) in the case of internal armed conflicts, until a peaceful settlement is achieved. A violation of the laws or customs of war may therefore occur at a time when and in a place where no fighting is actually taking place.” 7.5 The nature of the conflict in Ethiopia 7.5.1 The EPRP and the State The EPRP A lot of the victims in this case belonged to or were sympathisers of the EPRP. The EPRP grew out of the student movement and was founded in 1972. From June 1974 the EPRP had a central leadership, a political program and it issued a publication named Democracia. Besides a central leadership the EPRP was organised according to geographical zones. These so-called inter zonal committees were given the authority to take independent decisions and a member of the central committee was added to every inter zonal committee. The EPRP had an armed wing, the Ethiopian People’s Revolutionary Army (hereafter: EPRA) commanded by the central committee and guided on an operational level by the Military Committee. Besides an army the EPRP had Urban Armed Wings, also called Urban Defence Wings, which fell under the Military Committee in the organisation structure. These Urban Armed Wings committed attacks and robberies to obtain weapons, and attacked members of Meison, among whom Mengistu's right hand, and committed a failed attack on Mengistu. Because of their increasing (armed) resistance the EPRP was declared enemy of the revolution by the Derg in September 1976. In 1977 EPRP-members committed attacks and murders. Several permanent secretaries of different ministries and around thirty kebele leaders were killed by the EPRP. David and Marina Ottaway describe the situation as follows: “The situation had reached the point by February that no Political Bureau Partisan was safe in the streets or even in his office”. The Uppsala University describes the EPRP as follows: “Communist EPRP was mainly active in the mid 1970s, when it engaged in both urban and rural armed opposition, but with a focus on the former. It initiated a campaign of urban guerrilla warfare in September 1976, involving bombings of public buildings and other symbols of state authority as well as assassinations of numerous public officials. The campaign was labelled the White Terror by the government, which in turn countered with what would be known as the Red Terror. During this campaign, government security forces systematically hunted down and killed suspected EPRP members and their supporters. Having been defeated in the towns by late 1977 EPRP’s urban component was forced to take refuge with the group’s rural component in Tigray and Gonder.” According to Kiflu Tadesse the EPRA increased in numbers, amounting to around 1500 troops in Tigray and Begedimir in 1977. Also Ghelawdewos Araia speaks of growth of the EPRA at the end of 1977 and the beginning of 1978. During the last months of 1977 the EPRA caught the 217th Nebelbal (“Flame”, a counter-resistance group of the Derg) regiment in an ambush in Begedimir in a place called Mayleham, in which officers were taken prisoner and weapons and ammunition were captured. In February 1978 the EPRA carried out actions in Wukro in Tigray in which officers of Nebelbal were killed. In July 1978 there was an operation of the EPRA against a military camp of the Derg in the Begedemir area, the camp was destroyed but a lot of EPRA troops were killed. Nonetheless, the number of EPRA members increased again with in influx from urban areas where people were flying from the Red Terror. As a result the EPRA was able to deploy contingents, each of them with their own command structure, in three regions. In December 1978 the R-3 Command was still able to launch an attack on Addis Zemen. The EPRP/EPRA was supported, trained and armed by the EPLF (and TPLF) and also received weapons from the ELF. The EPRA also carried out some military actions with the EPLF. At the hearing in court the accused stated that Gojjam and Gondar were conflict areas during the time he was in Gojjam as representative of the Derg. The EPRP had a large influence and the accused called the EPRP "a indescribably violent organisation in those times" His photo album is full of friends and comrades liquidated by the EPRP. The accused also declared that during his stay in Gojjam for the Derg, attacks took place in Gojjam, which were carried out by the EPRP. During his time the EPRP founded a military guerrilla camp in Metekel, in the western part of Gojjam. This was a place of special strategic interest, Not only was the area rich in natural resources, it was also located isolated from the rest of the country and was vulnerable to a seizure of power because of its lack of infrastructure. Furthermore, the area had a long unprotected border with Sudan, which made it easy for the EPRP and the EPLF and the TPLF to obtain supplies and weapons through Sudan. Because of its location the EPRA/EPRP basis was a threat for the entire nation. During this time there was also heavy fighting in the north, in Eritrea. The only main road from Addis Abeba to the north was through Debre Marcos. De EPRP had blocked this road, so the troops of the Derg could not move to the north. The military unit, which had cleared the road, went to Metekel at the request of the accused to dismantle the basis of the EPRP there. According to the accused this dismantling has been very important to decrease the power of the EPRP in Gojjam. “It was really not sure if Ethiopia would remain as an independent country. At the time Ethiopia was caught in an overwhelming swamp of warfare (...), internal warfare by separatists like ELF, EPLF, TPLF and EPRP in northern Ethiopia, TPLF, EPRP and EDU in the centre and the north (Tigray, Gonder, Wollo, Gojjam and north Shoa); EPRP and the saboteurs of TPLF and EPLF in the central areas and the cities” The interim conclusion of the Court In view of the afore-mentioned the Court holds the opinion that the EPRP (among which the military wing EPRA and the Urban Armed Wings) was a sufficiently organised armed group during the relevant period. The State The EPRP fought the Derg, the government at the time in Ethiopia. The Derg disposed of the government army, which in the reports over 1974-1977 of the Dutch embassy in Addis Abeba was estimated at 80.000 troops and according to the year-report of 1977-1978 had increased to 400.000 troops. The Derg reacted with violence towards (among others) the EPRP, the so-called Red Terror. As mentioned before the Derg declared the EPRP in 1976 the enemy of the revolution. During a speech in March 1977 Mengistu smashed a bottle of red liquid and said that the contra-revolutionaries would be crushed in the same way. During a meeting on 25 June 1977 he used similar terms: “the EPRP, EDU and the Eritrean secessionist reactionary organisations will be crushed”. Letters and post-telegrams of the Dutch ambassador from October, November and December 1977 speak of armed actions to chase members of the EPRP in Addis Abeba from their hideouts, purges through murders and executions of contra-revolutionaries belonging to the EPRP. The conclusion of the Court Considering the afore mentioned the Courts finds that during the period mentioned in the indictment there was an armed conflict in Ethiopia which no longer had the character of internal disturbances or tensions, like rebellions, isolated sporadic acts of violence or such actions. On the contrary, there was a protracted and intensive violence. The armed violence took place between the Derg (the government) on one side and the EPRP on the other side. Therefore the Court holds the opinion that in the period mentioned in the indictment there was a non-international armed conflict in the sense in which this expression is used in the humanitarian law of war and that the common article 3 applies to it. 7.5.2 Different warring factions and the State Even though the conclusion of the Court in itself suffices, the Court wants to point out, in view of the importance of this case, that the way set out by Prosecution Service also leads to the conclusion that there was a non-international armed conflict. The Court considers that to assess if a in a certain conflict the combat actions between the group(
  1. s)involved in the conflict had the required level of intensity to meet criteria for a non-international conflict, it can also be determined under certain conditions, if there are different groups fighting a common enemy. This can only be the case if each one of the parties involved meets the criterion of a sufficient organisational level. Such a situation may occur if the different groups cooperate on a more than incidental basis in the military field, like the coordination of military actions, but also armament, financing training and offering the possibility of safe passage. The pursuit of a common (temporary) objective might also be relevant. The Court will then address the question if the EPLF/ELF, the EDU and the TPLF in conjunction with the EPRP in 1978 in Ethiopia fulfilled this requirement. De EPRP/EPRA and the EPLF/ELF Since 1975 the ELF and the EPLF fought a common battle against the Ethiopian governmental army. Both organisations had chairmen, consultative bodies, political programs and command-units. Between 1975 and 1977 the ELF and the EPLF were in control of the largest part of the Eritrean territory. In this period the number of ELF and EPLF troops was larger than the number of troops of the Ethiopian army. In 1978 the Derg managed to recapture most of the cities from the rebels. Between 1978 and 1986 there were yearly government offensives against the Eritrean. This also transpires from the statement of the accused at the hearing in court that during his time in Gojjam an army unit was urgently sent to the north of Eritrea because of the fighting over there. From what is considered before and also from the witness statement at the hearing it is plainly apparent that there was a more than incidental cooperation between the EPLF/EFL on one side and the EPRP on the other side. This cooperation concerned all above mentioned areas of cooperation and the combat actions of the EPLF/ELF were in part directed at the objective of the EPRP (the overthrow of the Derg). The EPRP/EPRA and the EDU The EDU was - as described above - not a regional independence movement but a movement which grew out of the ancien régime ousted by the revolution. In 1975 armed units of EDU became active in Gojjam, Gondar and the west of Tigray. At the beginning of 1977 government troops were defeated. From mid 1977 the EDU suffered losses against the Derg in the Gondar region and against the TPLF in Tigray, which had forced back the majority of the EDU-troops over the border in Sudan. At a certain point in time there was some cooperation between the EDU and the EPRA, however in the opinion of the Court there are not enough leads to assess if this cooperation was more than occasional. The EPRP/EPRA and TPLF The TPLF was founded in 1975 and fought from the province of Tigray against the state for social justice and self-determination for all Ethiopians. The accused described a close cooperation between the TPLF and the EPRP, consisting, inter alia, of training and armaments. However the Court considers that - regardless of an eventual temporary cooperation in the sense of the simultaneous fight against the Derg in the province of Tigray- during the time-period which is relevant for the indictment there was no longer any cooperation between both opposing factions , on the contrary. In March 1978 the tensions between both factions and the competition between them, already present since 1975, were settled to the military advantage of the TPLF. The State The Court reiterates what has been considered before regarding the state and adds the following. According to an article of 2 March 1978 in the Ethiopia Herald Mengistu said in a speech in honour of Adowa Victory Day: "Imperialism and bureaucratic capitalism shall perish! The (…) EPRP and separatist forces shall perish! [. . .] Agence France Press points out that lieutenant colonel Megistu announced on 16 May 1978 that the long awaited offensive in Eritrea would begin. Different liberation movements were said to be in control of 90% of the territory in Eritrea. There was heavy fighting around the besieged city of Asmara, were 25.000 Ethiopian soldiers were supposedly stuck. From May onwards the Ethiopian air force used the airport in Makalle in the province of Tigray to bomb positions of the ELF and EPLF in Eritrea. Although a large number of the targets that were hit also had a military character, a lot of villages, cities and herds were attacked. The conclusion of the Court Based on the above, in and interrelated context and on an overall basis, the Court concludes that during the time period mentioned in the indictment there was in Ethiopia (also) a non-international armed conflict between the Derg on one side and the EPRP/ the EPLF and the ELF. The latter fought the same government and in that context they cooperated with sufficient intensity. Each of the groups mentioned had a sufficient level of organisation. The joint battle against the Derg was protracted and considering the mutual cooperation, had a sufficient level of intensity. The fact that the mentioned groups possibly had their own interests, besides their joint purpose -the fight against the Derg- like the separation of Eritrea, and sometimes also fought each other, is of no relevance. 7.5.3 The knowledge of the armed conflict Based on the above-mentioned statements of the accused and his documents the Court establishes that he was aware of the armed conflict. 8The witness statements 8.1 Introduction A large number of the documents in the file are witness statements. As in previous cases regarding international crimes this concerns hearsay statements and statements of eyewitnesses, which may or may not be victims of (parts of the) charged offences. The NR and the DLR have interrogated twenty-eight witnesses in the Netherlands, the United States of America and Canada. The examining magistrate heard eighteen witnesses (some of whom were the same) in these same countries. Since Ethiopia did not want to render judicial assistance it has not been possible to examine witnesses in Ethiopia. The Court however does have copies of a part of the case file used in the Ethiopian proceedings against the accused. This file also includes several witness statements. Neither the Dutch police nor examining-magistrate heard any of these witnesses. In a case like this the question of the reliability of the witness statements is always an important one. Not only because an eventual judicial finding of facts should be largely based on these statements but also because -more than in ordinary criminal cases- there are possible legal reservations against the statements. They are after all accounts of events that have taken place decades - in this case almost four- ago. Furthermore, witnesses might be traumatised by what they have seen and experienced and their culture and environment are different from ours. This entails that it possibly might be not responsible and/or preferable to use all the witness statements as the evidence. In order to assess this the Court will outline in the next paragraph the frame of reference to be used for the assessment of the reliability of the statements. Then the Court will indicate per witness if the statement (in principle) -or partly- can be used as evidence. Finally the Court will consider the requests for witnesses submitted by the Defence. 8.2 The position of the Prosecution Service The Prosecution Service has - referring to the jurisprudence in 'WOS' or 'Wim' cases of this Court, the Court of Appeal of The Hague and the Court of Appeal of Den Bosch - taken the position that neither the passing of time, nor the difference in culture, the seriousness of what the witnesses have experienced and their possible traumatisation, reduces the reliability of the statements. In their presentation of the overall evidence the Prosecution Service has used several statements of witnesses questioned by the Dutch police (and the examining-magistrate) all of them considered in an interrelated context. Some witness-statements have not been used, either because they did not contribute to the evidence, or because the statement contained inconsistencies. The Prosecution Service only referred to the witnesses from the Ethiopian criminal case-file in relation to other statements and/or evidence. 8.3 The position of the Defence The Defence took the view that the witness statements are not reliable enough, due to, inter alia, the passing of time, possible collusion and inconsistencies. Furthermore, the Defence requested to hear a large number of persons (again) as witness. The list of these requests has been attached to this judgment as annex 2. 8.4 The reliability of the witness statements 8.4.1 The frame of reference The Court of The Hague defined a framework to assess the reliability of witness statements. In this framework the following seven features are distinguished: I: the person of the witness; II: the realisation of the statement; III: the review in the light of objective information, obtained from another source; IV: the consistency of consecutive statements rendered by the witness; V: the quality of identifications and recognitions; IV: the consistency of the statements with statements from other witnesses; VII: the plausibility of the rendered statement(s). This framework was again used by the Court of The Hague in the case against Yvonne B., even though the quality of the identifications and recognitions was addressed in one of the other points of concern. In the above mentioned case the Court of Appeal of The Hague has defined the following objective criteria - referring to the considerations regarding the assessment of the reliability of witnesses in the criminal case against Guus K. -: a: the review in the light of objective information, obtained from other sources; b: the consistency of the consecutive statements, made by this witness; c: the consistency of the statements with statements of other witnesses; d: the plausibility of the content of the rendered statement(s). The Court of Appeal again applied this framework in the Tamil case. When applying these criteria in the present case the Court has considered the personality of the witness, how the statement came to be rendered and the quality of identifications and recognition. Although the assessment frameworks of the Court of Appeal and the District Court in the case against Joseph M. and the subsequent case law do not completely match in terms of structure, they do have the same features. Below the Court will, - subject to the referred case law, but also in terms of literature- give an outline of the criteria applied for the assessment of the reliability of the witness statements. It should be noted that to assess the reliability of the witness statements they should be considered in an interrelated context. It is also important to note that the mentioned criteria are just points of attention. Consequently this is not a list for which a certain number of checked boxes should lead to the conclusion that the witness is unreliable. The person of the witness It is possible to imagine circumstances, which might influence the reliability and/or the credibility of a witness. When assessing the reliability the following points should be taken into account: a.
  2. a)Involvement of the witness in the charged offences A witness that has been involved in the charged offences might have reasons to render a statement, which is contrary to the truth, for example in order to minimize his or her own role. In the case against Joseph M. the Court saw sufficient reason to examine the statement of an witness with caution, since the witness had a possible motive to render a statement which was incriminating for the accused and it could not be discarded that the witness had tried to minimise his won role /involvement and to shift the responsibility to the accused.
  3. b)Further interests or motives of witnesses to render a statement incriminating to the accused and contrary to the truth A witness might have interests or motives to render an incriminating statement, which is contrary to the truth (see ' the person of the witness' under a). However there should be specific indications for this, beyond the level of mere speculation or suggestion, especially if the incriminating statement is supported by other incriminating statements. For example the circumstance that the witness belonged to a group, which fell victim to the group to which the accused belonged, is insufficient. On the other hand the Court did consider the reliability of the witness to be at stake in the case of a witness who declared that an accused person was always in the company of this brother that committed offences and therefore the accused person also had to be guilty.
  4. c)Ability of the witnesses to distinguish between what they saw themselves and what they heard from others (de auditu) Science has recognised that is difficult for witnesses who have knowledge from their own observation, to distinguish what they have actually observed themselves from subsequent complements to this observation (post-hoc-information) from another source (for example what they have heard from other people) (source-amnesia). Therefore it is important that the statement reflects to what degree the witness is able to make this distinction. If witnesses talk to each other this might lead to collaborative storytelling which is a strong degree of social influencing between witnesses, causing their experiences and different interpretations to melt into one common account of what has happened.
  5. d)Disturbing effects due to cultural differences Due to cultural differences a witness might have difficulty in determining time, space and distance and/or might not be able to orientate himself or herself on the basis of maps, photos and images, and the way in which a witness reacts to (specifically difficult) questions might be influenced. For example in the case of Joseph M. the Court considered that the fact that part of the witnesses from Ruanda were not familiar with floor plans and maps and that some witnesses found it difficult to specifically set out dates, time-paths, distances and space. The Court ruled that this should not lead to negative conclusions regarding the reliability of the witness statements.In the case against Yvonne B. the Defence argued that lying is less problematic within Rwandese society and that the witnesses might render false statements because they wished to contribute to a conviction. The Court did not recognise this as a general defence against the evidence but did find that this calls for caution.
  6. e)The traumatisation of the witness A traumatised witness is not necessarily a less reliable witness. According to relevant literature memories of central details of a traumatic event are often more accurate and complete the memories of peripheral details of the same event. This is caused by the fact that in the case of such an event the attention focuses on threatening, central details (weapon focus effect) and because the boundaries of the traumatic image narrow (boundary restriction). This might result in less attention for other peripheral details, like the appearance of the perpetrator. However in the case against Joseph M. the Court did find that behavioural scientists do not agree on the effects of suppression and that the witness' or victim's account of the traumatic event should be considered with the necessary caution and only in a interrelated context with the other evidence. Nevertheless traumatisation might also lead the memory of the witness to suppression and dissociation, phenomena that influence the memory and on the perception in a general sense. By careful questioning - specifically questioning without external pressure-, possibly by repeating the questions - these statements can be made accessible. In such a case a witness might remembers new information in every subsequent interrogation.
  7. f)Other factors in the person of the witness Literature warns for the negative effects, which acquiescence (the tendency to answer affirmatively to questions), compliance (agreement with supplied information because the witness feels compelled to do so by the social context) and suggestibility (accepting information as correct under the assumption that the person who supplies the information will be right) might have on the quality of the statements. An appropriate way of questioning/interrogation might lower these risks. The fact that a witness was still a child at the time of the events does not necessarily have consequences for the reliability of the statement rendered at a later age. Investigation shows that the memory of children is accurate and that they can talk accurately about events, which have taken place some years ago. Nevertheless the chance of getting an unreliable statement from children and witnesses with a mental disability is higher compared to normally gifted adults. This might be due to the limitations in the memory, higher level of suggestibility, the language comprehension and the ability to think in abstract terms. The way in which the witness statements are recorded in writing might also make it more difficult to assess the reliability of the witness statements, for example if there is no verbatim transcription. Drafting a statement involves however, in principle, always a transformation process (normative transformation). The rendering of the statement The way the statement is rendered might influence the reliability of the statement. This could involve the following aspects. a.
  8. a)The way of asking questions, the content of the questions, the attitude and the behaviour of the interrogator The way the questions are asked and the content of the questions might influence the statement rendered by the witnesses. This might refer to asking closed questions, suggestive questions and confusing questions. If the interrogator pushes for an answer this might lead the witness to feel a social pressure to answer. This might also be culturally determined (see 'The person of the witness' under d).
  9. b)The length of the interrogation In view of the scope of the events it is not unusual for a witness hearing to take up considerable time. However this involves certain risks. In the case of Joseph M. the Court of Appeal considered that the chance of obtaining reliable information decreases if the interrogations go on for hours. This phenomenon is described in relevant literature as the output order-effect.
  10. c)Communication problems between interrogators and witnesses or between interpreter and witnesses Quite often the assistance of an interpreter is needed for the interrogation of a witness. This might lead to communication problems, but it might also happen that the interpreter gives a wrong translation. Nevertheless eventual misunderstandings between the interrogator and the witnesses, do not necessarily lead to an unreliable statement. If the misunderstandings have been cleared up or are insignificant this does not have to be a problem.
  11. d)Contact between the witness and other witnesses before rendering a statement Contact between different witnesses prior to the interrogations might lead to source amnesia (see ‘The person of the suspect' under c).
  12. e)Guarantees for the interrogation The Dutch legal system has guarantees for the rendering of witness statements to the police and the examining magistrate, also if this takes place abroad. If a witness has rendered several statements it is therefore preferable -as mentioned before- to use the statement rendered to the examining magistrate or the Dutch police. However in case of statements rendered to others it is difficult to check if there were adequate safeguards and which methodology was used to obtain them. This might lead to the conclusion that it is wiser not to use these statements as evidence or to use them with due caution. Review in the light of objective information obtained from other sources regarding the situation on-site Objective information might refer to information from forensic research or written sources like documents and reports about the conflict. In the case against Joseph M., inter alia, documents and reports about the genocide in Ruanda in 1994 were used and the actual findings by the ICTR about the armed conflict in Ruanda in 1994 and the ensuing actual events. Finding of facts in writings and reports based on, inter alia, statements of witnesses and experts and documents might in principle be accepted by the judge, although the Defence has not been able to influence the realisation of thereof. Consistency of subsequent statements rendered by the same witness When a witness has rendered several statements the consistency of those statements can be assessed, in the case against Joseph M. the Court considered: “In order to make an assessment of the accuracy or the memory of the witness and/or the victim the statements they rendered at different times to different (criminal investigation) authorities, should be compared. The level of consistency - regarding the level of similarity between the different statements- is then at stake and this again influences the power of evidence of the statement concerned, especially if this concerns aspects of a statement which are fundamental to the evidence. Although a high level of consistency does not guarantee the accurateness of the statement concerned this is likewise for the opposite” Among other factors the person of the witness (see 'The person of the witness' under a to
  13. f)and the way in which a statement was rendered (see 'the rendering of the statement' under a to
  14. q)can influence the consistency, but this is also applies to the time span between the events and the rendering of the statement. It is important to consider under what circumstances the identified inconsistencies occur. When this happens at the end of a long interrogation and/if there are symptoms of PTSS, one should be wary of commission errors, which means: incorrect elements in the memory. Furthermore, in case of possible unreliable statements consideration might be given to the extent in which (certain parts
  15. of)the statements are confirmed by other evidence. Statements containing inconsistencies, discrepancies or contradictions might be excluded from the evidence or the inconsistent part of the statement can be discarded as evidence. However this does not apply to all inconsistent statements, but is only possible in case
  16. i)the inconsistencies of the differences relate to an aspect of the statement which should be substantial for the evidence or which otherwise manifestly affect the reliability of the statement as a whole, and
  17. ii)if no satisfactory explanation for the discrepancies, inconsistencies or contradictions is to be found. The quality of the identifications and recognitions Witnesses can identify or recognise the accused person. However these identifications are not necessarily reliable. To assess this the following questions might be asked: a.
  18. a)Did the witness know the accused person? In principle the recognition by a witness of an acquaintance is significantly more reliable than the identification of an unknown person because the recognition of a person whom the witness has seen only once is far more difficult. This is supposed to be a matter of generally knowledge.
  19. b)What was the distance between the witness and the accused? The distance between the witness and the accused is an important factor in the observation, combined with the intensity of the light (see hereafter under d). In literature there is dissention about the question from what distance the quality of the observation starts to decline. An investigation from 1996 showed that at a distance of twenty meters, disregarding the intensity of the light, the recognition no longer complied with the lowest limit that was defined in criminal law for diagnostic value. Nevertheless later investigation learned that at a distance of fifteen meters, together with the intensity of the illumination, a less sharp decline was observed, but more of a monotonous change. It was found that for every meter of increased distance the number of correct recognitions declined with 0,60% and the number of incorrect recognitions increased by 0,48%.
  20. c)How long and/or how often did the witness see the accused? The time-span of the observation (exposure time) is important for the storage of it in the memory. When the observation lasts longer it will be better and the trace created in the memory will be more extensive.
  21. d)Was it light or dark? The intensity of the light influences the observation. A lower intensity of the light, combined with the distance, decreases the diagnostic value of the recognition (see above under b).
  22. e)Are there other factors, which make the observation more or less reliable? This might refer to the ability of the witness to see the actions of the accused, his weapon or clothes or to describe co-perpetrators.
  23. f)Did the witness see the accused en face? It also matters if the has seen the accused en face during the observation, because this benefits the recognition.
  24. g)Is the witness of the same race as the accused? According to several investigations people are better in recognising someone from their own race and ethnic group than a person from another race or ethnic group. Therefore recognition is in principle more accurate if the witness is from the same race and ethnicity as the accused. Plausibility of the content of the statements Finally the plausibility of the statement can be considered. However caution should be observed in this respect, since there is often an extreme context, which might touch on the boundaries of our comprehension. 8.4.2 The admissibility and the reliability of the witness statements in the present case The Court has applied the above mentioned frame of reference - only where relevant- on all the witness statements in the Dutch criminal case-file. The Court will give a brief outline of its findings per witness. It should be noted that the Court in principle does not question the witnesses' accounts of their personal experiences, namely the arrests, tortures and bad detention conditions they have suffered. There are no indications that any of the witnesses has stated contrary to the truth about this. The Court agrees with the Prosecution Service that in general such traumatic experiences are not easily forgotten. Nonetheless there are factors leading to the impossibility to establish, with the required degree of reliability, what the witnesses say they have seen and heard. Those circumstances might also lead the Court to conclude that part of their statement is not reliable enough to be admitted as evidence. There are also a few statements that, despite the fact that they can be considered as reliable, are not useful enough as evidence because they are for example statements about hearsay or because they relate to events which took place at another time or in another place than the events referred to in the indictment. In general the Court notes that the mere passing of time does not necessarily make the statements of the witnesses unreliable. The fact that some witnesses have had contact with each other, possibly have read books about the charged offences and have become aware of the criminal proceedings in Ethiopia against the accused can by itself not lead to the conclusion that these statements should be regarded as unreliable. Finally the Court points out that although some witnesses have submitted a claim as injured party, there is no indication that these witnesses have rendered statements which are contrary to the truth for their own personal gain. Such an assumption is contradicted by the very limited amount of the claims. [person 328] [person 328] came up as a possible witness because he is one of the persons quoted in the earlier mentioned article in Vrij Nederland. He was interrogated in October 2012 by the NR in the English language. He has primarily declared about the lists and the letters, which were shown to him during the interview for the article, the structure and the objective of the EPRP and the position and the role of the accused. The Court establishes that the witness cannot make a statement from his own observation about the charged offences. He has stated that when he visited a friend in Debre Marcos he saw that they were digging large holes on the prison site and that sixty or seventy people were taken from the prison that night and were killed six or seven kilometres from the prison. But the statement does not clarify when this would have happened, but besides it would seem that he only saw that holes were being dug and was aware of the death of the persons from hearsay. Therefore the Court does not consider his statement suitable as evidence. [person 333, different spelling] [person 333, different spelling] was mentioned by witness [person 328] as a potential witness. In 2013 a preparatory interview was held with him, after which he was interrogated in 2015 by the DLR and in 2016 by the examining magistrate. The interrogations took place with the aid of an interpreter in the English language. He is the brother of [person 334], who held a high position in the EPRP and about whom several witnesses stated that he was shot in the beginning of August 1978 just outside of Debre Marcos. The witness has declared mainly about the fate of his brother and the role of the accused. Since [person 333, different spelling] is not able to declare from his own observations about the charged offences, but only about what he has heard from others - whereby the source is often not mentioned - the Court finds that his statement can not contribute to the evidence. [person 319, different spelling] [person 319, different spelling] was mentioned by witness [person 333, different spelling] as a potential witness. In 2013 a preparatory interview was held with him, and in 2015 he was interrogated by the DLR. In 2017 he was examined -with the aid of a psychologist because he was said to be traumatised- by the examining magistrate. The interrogations took place with the aid of an interpreter in the English language. At the time mentioned in the indictment he was around fourteen years old and member of the EPRP. He has declared mainly about the exposure meetings and the role of the accused. The Court established that [person 319, different spelling] was the only witness to testify that no arrests have taken place during the exposure meetings nor that people were brought from there to a camp or a police station. However three years later he declared before the examining magistrate that two people were taken after the exposure meeting, although he did not see one of the persons being taken but concluded this. The Court notices however that he still mentions two persons in this last statement, while all other witnesses declare that a lot of people were taken after the exposure meeting. Therefore his statement is different from the statements of the other witnesses in one important point. Besides [person 319, different spelling] declared in all his interrogations about an incident, which took place during the exposure meeting, in which someone spit [Eshetu A.] and shouted how good the EPRP was. However the witness has made varying statements about who this person was. During his preparatory interview by the police the he said that this person was his male cousin by marriage, but to the police and then to the examining magistrate he did not mention his cousin but a high ranking EPRP leader whose name he did not know or a boy who had been exposed. The Court finds this difference between the statements all the more striking because one should not expect such an error to be made if it concerns a member of the family. Because of these contradictions, combined with the circumstance that there are indications of traumatising the Court is not, or not sufficiently, able to establish if [person 319, different spelling] actually saw what he describes or that he possible incorporated stories he heard from other people in his own memory. The Court finds it therefore not justified to use his statement as evidence. [person 314] [person 314] was mentioned as a potential witness by [person 333]. Two preparatory interviews were held with him and a third exploratory interview in 2014. In 2015 he was interrogated by the DLR and in 2016 by the examining magistrate. The interrogations took place with the aid of an interpreter in the English language. At the time of the offences mentioned in the indictment he was around twenty years old and he supported the EPRP. He has declared about the exposure meetings, his stay in a military camp, followed by a stay in a police-camp and in prison, detention conditions, tortures and executions. Furthermore, he has rendered an incriminating statement about the presence of the accused the exposure meetings and in one of the camps. The Court finds that the witness has not always declared consistently about what he himself has seen and heard and about what he heard from others. Besides he has declared that every night five or six youths were taken away. No other witness has declared this. He also seems confused about the presence of the accused in Gojjam at the same time as Kassay Aragaw. Furthermore, he has not declared consistently about whether he saw the accused in the police-camp or in the military camp. This gives the Court the impression that the witness unconsciously mixes things up or has not preserved them correctly. The Court finds it therefore not justified to use his statement as evidence. [person 316] [person 316] was mentioned as a potential witness by [person 314]. In 2015 he was interrogated by the DLR and in 2016 by the examining magistrate. The interrogations took place with the aid of an interpreter in the English language. At the time of the offences mentioned in the indictment he was around twenty years old and he was a member of the EPRP although he was not very active. He has declared about the exposure meetings, and the role of the accused in this respect, his stay in a police-camp and in prison, tortures and executions. Furthermore, he has declared about some incidents in which the accused was involved. The Court establishes that he has rendered consistent statements about what he has seen and experienced, but added some observations during his interrogation by the examining magistrate. He declared that he had not seen the accused every day in the camp, but he saw him twice in any case. The Court considers his statement to be reliable in principle and usable as evidence. However, the Court does observe that the witness does not always indicate clearly if he saw something himself or if he heard it from someone or concluded it. Therefore parts of his statement should be considered with due caution. [person 331] [person 331] was mentioned as a potential witness by [person 314]. In May 2015 she was interrogated by the DLR with the aid of an interpreter in the English language. In February 2017 the Court has ordered -upon a request from the Defence- that she should be interrogated as a witness by the examining magistrate. However the Canadian authorities did not give permission for an interrogation by the examining magistrate because [person 331] was allegedly traumatised. The Court will exclude the statement of [person 331] from the evidence, because the examining magistrate was not able to examine her, due to the refusal of the Canadian authorities and the Defence therefore has not been able to exercise the right to examine her. [person 315] [person 315] was mentioned as a potential witness by [person 314]. In 2013 two preparatory interviews were held with him, followed by an exploratory interview in 2014. In 2015 he was interrogated by the DLR and in 2016 by the examining magistrate. The interrogations took place with the aid of an interpreter in the English language. At the time of the facts mentioned in the indictment he was around eighteen years old and he was a member of the youth movement of the EPRP. He has declared specifically about the exposure meetings, his stay in a military camp, followed by a stay in a police-camp and in prison, the special interrogators, tortures, executions and the role of the accused. The Court establishes that [person 315] made a very elaborate and detailed statement. Those statements are also consistent and to not contain contradictions, except the date of his release, which he sets on May 1978 on one occasion and on June or July 1978 on another. It is the opinion of the Court however that this uncertainty is sufficiently resolved by the certificate of release, which was attached to one of the interrogations, which mentions 21 May 1978 as the date of his release. He resolved eventual uncertainties in his account about the source of the knowledge after being questioned about them. The Court sees no reason to doubt the reliability of the statement of [person 315]. The argument of the Defence that this witness did not put forward any other witnesses is - irrespective if this can be established- insufficient to arrive at a different conclusion. The statement of [person 315] can therefore be used as evidence without any restraint. [person 332] [person 332] was mentioned as a potential witness by [person 333]. Two preparatory interviews were held with her in 2013 and in 2015 she was interrogated twice by the DLR and in 2016 by the examining magistrate in the United States of America. These interrogations took place with the aid of an interpreter in the English language. At the time of the offences mentioned in the indictment she did not live in Debre Marcos or in Metekel but in Addis Abeba. Her elder brother [person 4, different spelling] and her younger sister were members of the EPRP. She has specifically declared about what had happened to her brother and male cousin and about executions of prisoners. Furthermore, she declared that she has regular contact with [person 136, different spelling], one of the victims mentioned in the indictment under count 1 and 2, and often talks to her. The Court establishes that the witness has not personally been present at an exposure meeting, or in a police-camp, military camp or prison, she stayed mainly in Addis Abeba and not in Debre Marcos. Regarding her statement about the events, which took place in Debre Marcos her knowledge, is based on what she heard from others. However the source of this knowledge does not always transpire. The Court cannot rule out the fact that [person 332] has obtained this knowledge from her contacts with one or more victims. Regarding what happened to her brother the Court also notices that she has declared that when she visited her brother in the police station she got the impression that her brother had been tortured because he did not stand up and that this was later confirmed by a friend of her brother's. However to the examining magistrate she rendered a different statement, namely that her brother told her that he had been tortured. In view of the above the Court concludes that the statement of this witness cannot be used as evidence. [person 111, different spelling] [person 111, different spelling] is mentioned by witness [person 314]. A preparatory interview was held with him and after this he was interrogated by the DLR in 2015. In 2016 was heard by the examining magistrate in the United States of America. The interrogations took place with the aid of an interpreter in the English language. At the time of the offences mentioned in the indictment he was twenty-nine years old, he worked as a teacher in Debre Marcos and was a member of the EPRP. He has declared about the exposure meetings, his stay in a military camp, followed by a stay in a police-camp and in prison, the special interrogators, the detention conditions, tortures the executions of fellow-prisoners and the decision by which he was sentenced to prison. Furthermore, he has rendered very incriminating statements about the role of [Eshetu A.]. The Court establishes that [person 111, different spelling] has made very consistent statements without contradictions and was able to make a very clear distinction between his own knowledge and what he heard from others. Because of his task in the so-called discipline committee the witness was in a position to see a lot. Regarding the role of the accused he clearly indicates states that there was another person with the name Eshetu, so there does not seem to be a mistaken identity. The Court therefore considers this witness to be very reliable. [person 336] [person 336] was mentioned as a potential witness by [person 332]. He was then interrogated in 2015 by the DLR in Canada. The interrogation by the DLR took place with the aid of an interpreter in the English language and the interrogation by the examining magistrate with the aid of an interpreter in Amharic. At the time of the offences mentioned in the indictment he was around twenty-two years old and he was a member of the EPRP. He has declared that he went into hiding in 1978 because the Derg were looking for him. In 1980 he was caught and ended up in a camp in Bahir Dar. The Court is convinced that [person 336] during the period mentioned in the indictment, or at least during the period that the accused was in Gojjam, was not in Debre Marcos or in Metekel. Therefore his statement about this period can only be based on what he has heard from others, while the witness often did not mention the source of his information. Furthermore, he has declared, after the police showed him lists with a number of names, that this were persons who were killed in May 1978, which is different from what other witnesses have stated. Based on these findings the Court considers his statement not usable as evidence. [person 318] [person 318] was mentioned as a potential witness by [person 336]. He was interrogated in 2015 by the DLR and in 2016 by the examining magistrate in Canada. The interrogation by the DLR took place with the a

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