Editing Genocide Convention (section)

=== Deliberately inflicting on the group conditions of life calculated to bring about its physical destruction ''Article II(c)'' ===
[[File:"Trail of the hide hunters." Buffalo lying dead in snow, 1872 - NARA - 520094.jpg|thumb|During the [[American Indian Wars|Indian wars]], the U.S. federal government promoted [[American bison|bison]] hunting for various reasons, including as a way of destroying the means of survival of [[Plains Indians]] to pressure them to remain on [[Indian reservation]]s. This has been cited by experts as an example of [[Native American genocide in the United States|genocide]] that involves removing the means of survival.<ref name=Hinton/>]]
The third prohibited act is distinguished from the genocidal act of killing because the deaths are not immediate (or may not even come to pass), but rather create circumstances that do not support prolonged life.<ref name=":0" /> Due to the longer period of time before the actual destruction would be achieved, the ICTR held that courts must consider the duration of time the conditions are imposed as an element of the act.<ref name=":4">''Kayishema and Ruzindana,'' (Trial Chamber), 21 May 1999, para. 548</ref> In the 19th century the United States federal government supported the [[bison hunting|extermination of bison]], which [[Native Americans in the United States|Native American]]s in the [[Great Plains]] relied on as a source of food. This was done for various reasons, primarily to pressure them onto reservations during times of conflict. Some genocide experts describe this as an example of genocide that involves removing the means of survival.<ref name=Hinton>{{Cite book |publisher=[[Duke University Press]] |isbn=9780822376149 |title=Colonial Genocide in Indigenous North America |year=2014 |last1=Hinton |first1=Alexander |last2=Woolford |first2=Andrew |last3=Benvenuto |first3=Jeff |page=292 |quote=}}</ref>

The ICTR provided guidance into what constitutes a violation of the third act. In Akayesu, it identified "subjecting a group of people to a subsistence diet, systematic expulsion from homes and the reduction of essential medical services below minimum requirement"<ref>Prosecutor v. Akayesu, Case No. ICTR-96-4-T, Judgment, 2 September 1998, para. 506.</ref> as rising to genocide. In Kayishema and Ruzindana, it extended the list to include "lack of proper housing, clothing, hygiene and medical care or excessive work or physical exertion" among the conditions.<ref name=":4" /> It further noted that, in addition to deprivation of necessary resources, rape could also fit within this prohibited act.<ref name=":4" /> In August 2023, founding chief prosecutor of the [[International Criminal Court]] (ICC) [[Luis Moreno Ocampo]] published a report presenting evidence that [[Azerbaijan]] was committing genocide against the ethnic Armenians of [[Republic of Artsakh|Artsakh]] [[Nagorno-Karabakh]] under Article II(c) of the Genocide Convention by placing their historic land under a comprehensive [[blockade]], cutting all access to food, medical supplies, electricity, gas, internet, and stopping all movement of people to and from Armenia.<ref>{{cite web |url=https://luismorenoocampo.com/lmo_en/report-armenia/ |title=REPORT ARMENIA – Luis Moreno Ocampo}}</ref>