Nshogoza (ICTR-07-91)

This case summary is part of a collection of summaries describing the cases before the International Criminal Tribunal for Rwanda (ICTR). See the Online Resource Hub pages on the ICTR and International Criminal Law, and table of ICTR case summaries for additional information.

Source: Nshogoza (ICTR-07-91)

Trial Judgment: 7 July 2009; Appeal Judgment: 15 March 2010

Léonidas Nshogoza, a Rwandan national working as an investigator for the defense in the ICTR case against Yussuf Munyakazi, was indicted for obstructing or interfering with the administration of justice, a contempt of court charge unique in ICTR jurisprudence. The prosecution alleged that Nshogoza engaged in prohibited contact with ICTR-protected witnesses and bribed them to recant their statements.

In 2009, an ICTR Trial Chamber convicted Nshogoza of contempt of court for knowingly and willfully interfering with the ICTR’s administration of justice by bribing witnesses to change their testimony and improperly contacting protected witnesses. In 2010, the ICTR Appeals Chamber affirmed Nshogoza’s conviction but reduced his sentence from 12 months to six months’ imprisonment, finding that the Trial Chamber erred in its assessment of the gravity of the offence and applicable sentencing principles.