Rwanda Case Law

UBUSHINJACYAHA v RUTUNGA

Court

Court of Appeal

Case number

RPAA/GEN 00003/2024/CA

Dr. Rutunga Venant knowingly provided essential assistance to gendarmes who, together with interahamwe, committed mass killings of Tutsi civilians at ISAR-Rubona. His actions constituted material and intentional complicity in genocide and extermination as a crime against humanity. The High Court's reduction of sentence was justified by his cooperation and lack of prior convictions, despite aggravating circumstances. Both appeals lacked merit; the conviction and 20-year sentence stand.

Source excerpt

• Complicity
• Genocide
• Crimes against humanity
• Sentencing
• Burden of proof
• Appeals

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IMIRONGO CoA - No 29 - November 2025

Court

Court of Appeal

Digest of Court of Appeal precedents on unsigned interview records, confessions, sentencing discretion, proof, testimony, retrials, and related procedure.

• Evidence
• Appeals
• Sentencing
• Criminal procedure
• Civil procedure
• Precedent

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UBUSHINJACYAHA v. BIZUMUREMYI N’ABANDI

Court

Court of Appeal

Case number

RPAA/GEN 00003/2023/CA

The Court of Appeal dismissed appeals by three appellants and upheld genocide convictions, holding that corroborated testimony was reliable despite minor inconsistencies and absent Gacaca mention.

• Genocide
• Evidence law
• Appeals
• Accessory liability
• Limitation of prosecution
• Evidence-law

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VOLIME IDASANZWE II Y'IMANZA ZA JENOSIDE

Court

Supreme Court

The appellate court found that minor inconsistencies in witness testimony regarding times, clothing, or precise locations did not undermine the core finding that Ntaganzwa Ladislas orchestrated, led, and participated in attacks against Tutsi civilians at Cyahinda and surrounding areas, and facilitated sexual violence, as corroborated by multiple witnesses and his own official correspondence. The court held that the trial court was entitled to rely on the testimony of a single credible witness for material facts and that the accused's alibi was not supported by credible evidence. The court fur…

Source excerpt

• Genocide
• Crimes against humanity
• War crimes
• Command responsibility
• Complicity
• Incitement to genocide

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UBUSHINJACYAHA v NTAGANIRA

Court

Supreme Court

Case number

RS/INJUST/RP 00006/2024/SC

The Supreme Court held that hearsay evidence from MUHAWENIMANA Sabine was inadmissible as it was not based on her direct knowledge but on information from the accused. The Court found that NTAGANIRA Samuel provided material assistance by locking the victim and principal offender together, thereby facilitating the commission of the crime. The revision application was dismissed, and the conviction and sentence imposed by the High Court were upheld.

Source excerpt

• Complicity
• Hearsay evidence
• Sexual offences against children
• Standard of proof
• Admissibility of evidence

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UBUSHINJACYAHA v. NTITENGUHA

Court

Court of Appeal

Case number

RPAA 00033/2021/CA

The Court held that Ntitenguha Théoneste's presence and participation in the group that assaulted the victim sufficed for criminal liability, but as he was not the leader or main instigator, his sentence should be mitigated to ten years' imprisonment.

Source excerpt

• Complicity
• Assault and battery
• Homicide
• Sentencing
• Group criminal liability

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PROSECUTION v KABILIMA

Court

Court of Appeal

Case number

RPAA/GEN00009/2019/CA

Court of Appeal held that Kabilima Jean Damascène failed to prove an alibi, upheld witness and documentary evidence, and convicted him of genocide and complicity.

• Genocide
• Accomplice liability
• Burden of proof
• Alibi defence
• Testimonial evidence
• Sentencing

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UBUSHINJACYAHA v KANAMUGIRE

Court

Court of Appeal

Case number

RPAA/GEN 00002/2019/CA

The Court of Appeal upheld Kanamugire Albert’s conviction as an accomplice to rape during the 1994 genocide, finding he knowingly led soldiers to the victims.

• Genocide
• Complicity
• Sexual violence
• Evidence
• Criminal liability
• Damages

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UBUSHINJACYAHA v NTAMABYALIRO

Court

Court of Appeal

Case number

RPAA/GEN 00006/2019/CA

The Court of Appeal upheld Ntamabyaliro Agnès’s convictions for complicity in genocide and the murder of the Butare Prefect, but reduced the sentence to ordinary life imprisonment.

• Genocide
• Complicity
• Criminal procedure
• Command responsibility
• Fair trial rights
• Evidence

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UBUSHINJACYAHA v KAYIBANDA N’ABANDI

Court

Court of Appeal

Case number

RPA 00002/2019/CA - RPA 00015/2019/CA

The Court of Appeal upheld convictions of three appellants, holding that detailed confessions to investigators and prosecutors could be relied on despite later retraction in court.

• Complicity
• Terrorism
• Spreading false information
• Evidentiary value of confessions
• Appeal procedure
• Criminal-law

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