Monday, June 18, 2012

Closing Order of Case 002 against Senior KR Leaders Nuon Chea, Khieu Samphan, Ieng Sary, Ieng Thirith

In light of the HISTORIC (!) start of MOST COMPLEX (sic!) trial hearings beginning on   27 June 2011 and again ANOTHER HISTORIC (!) START of this same MOST COMPLEX (sic!) on 21 Nov. 2011 of Case 002 against the surviving Khmer Rouge senior leaders Nuon Chea, Khieu Samphan, Ieng Sary and Ieng Thirith, KI Media is posting installations of the public document of the Closing Order of Case 002 (or, Indictment). The Closing Order of the Co-Investigating Judges forms the basic document from which all the parties (co-prosecutors, lead co-lawyers for all civil parties, defense lawyers) make their arguments before the Trial Chamber judges (one Cambodian President, 2 Cambodian Judges, 2 UN judges). Up until now, the hearings involving these four surviving senior Khmer Rouge leaders have been in the Pre-Trial Chamber over issues of pre-trial detention and jurisdictional issues. Beginning in June November 2011, the Trial Chamber is hearing the substantive (sic!) arguments over the criminal charges   (genocide against Buddhists, genocide against Vietnamese, genocide against Cham Muslims, crimes against humanity at the 200 prisons, mass crimes in countless killing fields, Eastern Zone purges, penal code of 1956, etc.) of only the Phase I Movement in April 1975.
 
 Available in Khmer, English and French. Contact the ECCC for a free copy.  
 
CLOSING ORDER (or, INDICTMENT)
 
of Co-Investigating Judges You Bunleng and Marcel Lemonde
15 September 2010

  PART THREE: LEGAL FINDINGS 
 

XIII. CRIMES AGAINST HUMANITY 

 
A.  "CHAPEAU" ELEMENTS 
 
B. UNDERLYING OFFENCES CONSTITUTING CRIMES AGAINST HUMANITY

Other Inhumane Acts Through Forced Transfer
1439.       With respect to the actus reus, victims endured great suffering, or serious mental or physical suffering or injury or a serious attack on human dignity of similar gravity to other crimes against humanity. The victims were forced to leave the places where they lawfully resided without grounds permitted by international law.
1440.       The population movement occurred by force since the population was coerced to move by threats, physical violence, or by orders which they felt would lead to serious danger if disobeyed.
1441.       There is no evidence that the population lacked legal entitlement or authorization to reside in the places from which they were moved.
1442.       In their requests for investigative action, the lawyers for the Charged Persons submitted justifications for the movement of the population out of Phnom Penh related to the broader situation in Cambodia at the time (food and medical necessity, security, etc).5275 The Co- Investigating Judges find that neither the grounds brought forward by the Charged Persons nor other grounds under international law permitted the transfer of population.

Without Grounds Permitted by International Law
Security of the Population
1443.       With respect to phase 1, the movement of the entire population from Phnom Penh could not be justified as being for the security of the population in response to an alleged fear of a US bombing campaign. Whilst CPK soldiers cited such bombings as the reason for the inhabitant's evacuation, the CPK leadership immediately installed themselves in Phnom Penh following the evacuation, demonstrating that they did not anticipate any such bombing. Furthermore, the USA bombing campaign against Cambodia had ceased since 15 August 1973.
1444.       With respect to phases 2 and 3, no such justification exists on the evidence. Although certain witnesses state that phase 3 was the result of the conflict with Vietnam, it was nonetheless of a secondary role: the necessity of protecting the security of the population was not of itself the sole justification for this population movement.
Military Necessity
1445.       There is no evidence to demonstrate that the movement of the population from Phnom Penh (phase 1) was justified due to military necessary. Although CPK troops sending inhabitants out of the city sometimes referred to the need to fight remaining Lon Nol forces in the city, no large scale fighting or other military operations took place in Phnom Penh after 17 April 1975. The same reasoning applies to the alleged need to move the population to find and arrest CIA agents and for the alleged clearing efforts regarding mines and unexploded bombs.
1446.       With respect to phase 2, witnesses did not cite military necessity as a justification for the movement of sections of the population, and there is no such justification on the evidence.
1447.       With respect to phase 3, as explained above, several witnesses refer to removing people from the combat zone with Vietnam. However, the intensity of the conflict did not justify the extent of population movement.
Food Shortage

1448.       Even if this justification were found to be substantiated under international law, there is no evidence to support the argument that the movement of the population was necessary for addressing food shortages.
1449.       With respect to the movement of the population from Phnom Penh (phase 1), although food production, supply and distribution was hindered by the conflict, the city retained methods for receiving food supplies, be it by river, road or air. Despite these factors, the evidence shows that the supposed justification of a food shortage in Phnom Penh was not reflected in the steps taken by the CPK to implement the population movement: the inhabitants of Phnom Penh were generally not provided with food during the movement, there were limited or no food provisions at the place of destination, other than the requirement that the population produce their own food, despite the fact they were predominately city dwellers not accustomed to agricultural methods. As to the argument that the CPK regime had to refuse foreign aid to avoid interference into its internal affairs, a legal justification cannot be invoked when it is due to circumstances that were self-imposed.
1450.       With respect to phases 2 and 3, although witnesses cite food and the availability of more fertile land as the reason given for the population movement, a comparison of the situations at the place of departure and place of arrival does not demonstrate that the conditions necessitated population movement in those specific contexts.
Medical Care
1451.       Even if this justification were found to be substantiated under international law, there is no evidence to support the argument that the movement of the population was necessary for addressing a lack of medical care. With respect to phase 1, although medical supplies were reduced in Phnom Penh during the conflict, it was established over several years leading up to and continuing after 17 April 1975 that the city remained better medically equipped than other locations in the country.
1452.       With respect to phases 2 and 3, witness did not cite medical care as a justification for the movement of sections of the population, and there is no such justification on the evidence.
Creation of a Rural Society

1463. The policy to create a society based upon rural agricultural production as it was implemented by the CPK does not constitute a ground under international law permitting population transfer.
Element of "Return"
1464. As regards the requirement of the "return" of the victims, even if there had been a legal justification for the phases of movement in question, all the facts indicates that virtually all of the population was only able to return home after the fall of the regime.
1465. As regards the mens rea, the perpetrators of the three waves of forced movement were aware of the factual circumstances that established the gravity of the act, especially the harm inflicted through the violent and threatening measures by which the movement took place, the haste with which is was implemented, the lack of organization and coordination to ensure families were kept together and that the population was not generally provided with food, shelter and protection. Such harm was inflicted during movement and upon arrival.
1466. The three waves of movement of the population, by their nature or consequences, constituted or were part of the attack against the civilian population. The perpetrators knew that there was an attack on the civilian population and that their acts were part of it.
1467. The common purpose included the commission of the crime against humanity of other inhumane acts in the form of forced transfers. In effect, the implementation of the objective of operating work sites and cooperatives was facilitated by the subjugation of the population, by requiring that they move close to the places where they were being sent to work by the CPK. A review of the elements shows that the forced transfers assumed a systematic character and constituted an integral part of the common purpose. The generalized character of forced transfers throughout various regions of the country clearly indicates that this was decided and coordinated by the highest leadership of Democratic Kampuchea.
1468. The main recurrent pattern is that no accommodation was made for vulnerable persons in each wave of forced movement of the population: the people moved consisted of all ages and both sexes. The underlying justification of the population movement was that the persons moved were identified as actual or potential transgressors of the objectives of the CPK common purpose. In case of phase 1, the inhabitants of Phnom Penh were identified as "new" people, and for such people to remain in cities was deemed to be incompatible with the common purpose objectives of construction of socialism attaining the great leap forward through agrarian development. People from cities were also deemed suspicious through a potential association with the Lon Nol regime. With respect to phase 2, "new" people were targeted as well as people related to the Lon Nol regime, Chinese and Khmer Krom minorities and the Cham, particularly after the rebellions of late 1975. Phase 3 victims were inhabitants of purged areas which the administration selected as to their suspected allegiance to the purged officials or the Vietnamese, for being suspected as bad elements or traitors, Sihanouk or Lon Nol regime supporters, "new" people, monks, Cham, and people of Chinese or Vietnamese descent. The extent to which the population movement was done in accordance with achieving the common purpose is also evidenced by the fact that during the CPK era, the population was not returned to their residences from which they were moved.
1469. All three phases were implemented by CPK soldiers, militia, or cadres through the use of force. Orders to move were issued on short notice, not providing the population time for proper travel preparations. During phase 1, the population was expected to provide their own means of transportation which for most people amounted to travelling by foot. In phases 2 and 3, the CPK regime generally provided transport although significant hardship was inflicted on the population since they were not provided with sufficient supplies and support, entailing suffering and death among the population.

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