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==== As genocide ==== {{See also|Rwandan genocide}} In 1998, the [[International Criminal Tribunal for Rwanda]] established by the United Nations made landmark decisions that rape is a crime of [[genocide]] under [[international law]]. The trial of [[Jean-Paul Akayesu]], the mayor of Taba Commune in Rwanda, established precedents that rape is an element of the crime of genocide. The Akayesu judgement includes the first interpretation and application by an international court of the 1948 [[Convention on the Prevention and Punishment of the Crime of Genocide]]. The Trial Chamber held that rape, which it defined as "a physical invasion of a sexual nature committed on a person under circumstances which are coercive", and sexual assault constitute acts of genocide insofar as they were committed with the intent to destroy, in whole or in part, a targeted group. It found that sexual assault formed an integral part of the process of destroying the [[Tutsi]] ethnic group and that the rape was systematic and had been perpetrated against Tutsi women only, manifesting the specific intent required for those acts to constitute genocide.<ref>{{Cite web|date=2012-10-12|title=UNHCR {{!}} Refworld {{!}} The Prosecutor v. Jean-Paul Akayesu (Trial Judgement)|url=http://www.unhcr.org/refworld/publisher,ICTR,,,40278fbb4,0.html|access-date=2020-10-09|archive-url=https://web.archive.org/web/20121012031344/http://www.unhcr.org/refworld/publisher,ICTR,,,40278fbb4,0.html|archive-date=12 October 2012}}</ref> Judge [[Navanethem Pillay]] said in a statement after the verdict: "From time immemorial, rape has been regarded as one of the [[Wartime sexual violence|spoils of war]]. Now it will be considered a war crime. We want to send out a strong message that rape is no longer a trophy of war."<ref name=paulwalters>[[Navanethem Pillay]] is quoted by Professor Paul Walters in his presentation of her honorary [[doctorate of law]], [[Rhodes University]], April 2005 {{cite web |url=http://www.ru.ac.za/academic/graduation/addresses_and_citations/2005/Judge_Pillay_citation.doc |title=Judge Navanethem Pillay |access-date=2008-02-27 |url-status=dead |archive-url=https://web.archive.org/web/20081001193848/http://www.ru.ac.za/academic/graduation/addresses_and_citations/2005/Judge_Pillay_citation.doc |archive-date=1 October 2008}}</ref> An estimated 500,000 women were raped during the 1994 Rwandan Genocide.<ref>{{cite web|url=https://www.amnesty.org.nz/web/pages/home.nsf/0/e57ea3f05f6aa848cc256e460012f365?OpenDocument|archive-url=https://web.archive.org/web/20071212040642/http://www.amnesty.org.nz/web/pages/home.nsf/0/e57ea3f05f6aa848cc256e460012f365?OpenDocument|url-status = dead|title=Violence Against Women: Worldwide Statistics|archive-date=12 December 2007}}</ref>
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