bosnia report
New Series No: 26 November - December 2001
 
ICTY - Indictment against Slobodan Milosevic
by The Prosecutor of the Tribunal

THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER YUGOSLAVIA

Case No. IT-01-51-I

THE PROSECUTOR OF THE TRIBUNAL

AGAINST

SLOBODAN MILOSEVIC

INDICTMENT

The Prosecutor of the International Criminal Tribunal for the former Yugoslavia, pursuant to her authority under Article 18 of the Statute of the International Criminal Tribunal for the former Yugoslavia ("the Statute of the Tribunal"), charges:

SLOBODAN MILOSEVIC

with GENOCIDE, CRIMES AGAINST HUMANITY, GRAVE BREACHES OF THE GENEVA CONVENTIONS and VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR as set forth below:

THE ACCUSED

1. Slobodan MILOSEVIC, son of Svetozar Milosevic, was born on 20 August 1941 in Pozarevac, in the present-day Republic of Serbia, one of the constituent republics of the Federal Republic of Yugoslavia ("FRY"). In 1964, he graduated from the Law Faculty of the University of Belgrade and began a career in management and banking. Until 1978, he held the posts of deputy director and later general director at Tehnogas, a major oil company in the then Socialist Federal Republic of Yugoslavia ("SFRY"). Thereafter, he became president of Beogradska banka (Beobanka), one of the largest banks in the SFRY, a post he held until 1983.

2. Slobodan MILOSEVIC, joined the League of Communists of Yugoslavia in 1959. In 1984, he became Chairman of the City Committee of the League of Communists of Belgrade. In 1986, he was elected Chairman of the Presidium of the Central Committee of the League of Communists of Serbia and was re-elected in 1988. On 16 July 1990, the League of Communists of Serbia and the Socialist Alliance of Working People of Serbia united, forming a new party named the Socialist Party of Serbia ("SPS"). On 17 July 1990, Slobodan MILOSEVIC was elected President of the SPS and remained in that post except during the period from 24 May 1991 to 24 October 1992.

3. Slobodan MILOSEVIC was elected President of the Presidency of the then Socialist Republic of Serbia on 8 May 1989 and re-elected on 5 December 1989. After the adoption of a new Constitution, on 28 September 1990, the Socialist Republic of Serbia became the Republic of Serbia, and Slobodan MILOSEVIC was elected to the newly established office of President of the Republic of Serbia in multi-party elections, held in December 1990. He was re-elected to this office in elections held on 20 December 1992.

4. After serving two terms as President of the Republic of Serbia, Slobodan MILOSEVIC was elected President of the Federal Republic of Yugoslavia on 15 July 1997, beginning his official duties on 23 July 1997. Following his defeat in the Federal Republic of Yugoslavia’s presidential election of September 2000, Slobodan MILOSEVIC relinquished his position on 6 October 2000.

INDIVIDUAL CRIMINAL RESPONSIBILITY

Article 7(1) of the Statute of the Tribunal

5. Slobodan MILOSEVIC is individually criminally responsible for the crimes referred to in Articles 2, 3, 4 and 5 of the Statute of the Tribunal as described in this indictment, which he planned, instigated, ordered, committed, or in whose planning, preparation, or execution he otherwise aided and abetted. By using the word "committed" in this indictment, the Prosecutor does not intend to suggest that the accused physically committed any of the crimes charged personally. "Committed" in this indictment refers to participation in a joint criminal enterprise as a co-perpetrator.

6. Slobodan MILOSEVIC participated in the joint criminal enterprise as set out below. The purpose of this joint criminal enterprise was the forcible and permanent removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats, from large areas of the Republic of Bosnia and Herzegovina (hereinafter referred to as "Bosnia and Herzegovina"), through the commission of crimes which are in violation of Articles 2, 3, 4 and 5 of the Statute of the Tribunal.

7. The joint criminal enterprise was in existence by 1 August 1991 and continued until at least 31 December 1995. The individuals participating in this joint criminal enterprise included Slobodan MILOSEVIC, Radovan KARADZIC, Momcilo KRAJISNIK, Biljana PLAVSIC, General Ratko MLADIC, Borisav JOVIC, Branko KOSTIC, Veljko KADIJEVIC, Blagoje ADZIC, Milan MARTIC, Jovica STANISIC, Franko SIMATOVIC, also known as "Frenki," Radovan STOJICIC, also known as "Badza," Vojislav SESELJ, Zeljko RAZNATOVIC, also known as "Arkan," and other known and unknown participants.

8. The crimes enumerated in Counts 1 to 29 of this indictment were within the object of the joint criminal enterprise. Alternatively, the crimes enumerated in Counts 1 to 15 and 19 to 29 were natural and foreseeable consequences of the execution of the object of the joint criminal enterprise and the accused was aware that such crimes were the possible outcome of the execution of the joint criminal enterprise.

9. In order for the joint criminal enterprise to succeed in its objective, Slobodan MILOSEVIC worked in concert with or through other individuals in the joint criminal enterprise. Each participant or co-perpetrator within the joint criminal enterprise, sharing the intent to contribute to the enterprise, played his or her own role or roles that significantly contributed to achieving the objective of the enterprise. The roles of the participants or co-perpetrators include, but are not limited to, the following:

10. Radovan KARADZIC was President of the Serbian Democratic Party of Bosnia and Herzegovina (Srpska demokratska stranka Bosne i Hercegovine or "SDS") throughout the period of the indictment. On 27 March 1992, KARADZIC became the President of the Bosnian Serb "National Security Council." On 12 May 1992, he was elected President of the three-member Presidency of the self-proclaimed Serbian Republic of Bosnia and Herzegovina (hereinafter referred to as "Republika Srpska") and remained in this position after the Presidency was expanded to five members on 2 June 1992. On 17 December 1992, KARADZIC was elected President of Republika Srpska and remained in that position throughout the period of this indictment. In his capacity as a member of the Bosnian Serb National Security Council, member of the Presidency, as President of Republika Srpska, and in his position of leadership within the SDS party and organs of the Republika Srpska government, Radovan KARADZIC, together with others, commanded, directed, or otherwise exercised effective control over the Territorial Defence ("TO"), the Bosnian Serb army ("VRS") and the police forces of Republika Srpska who participated in the crimes specified in this indictment.

11. Momcilo KRAJISNIK, a close associate of Radovan KARADZIC, was a member of the SDS Main Board from 12 July 1991. On 24 October 1991, the day of the founding of the "Assembly of the Serbian People of Bosnia and Herzegovina," (hereinafter referred to as the "Bosnian Serb Assembly") KRAJISNIK was elected its President. From 27 March 1992, KRAJISNIK was a member of the Bosnian Serb National Security Council. He became a member of the five-member Presidency on 2 June 1992. When the Bosnian Serb Assembly elected Radovan KARADZIC President of Republika Srpska on 17 December 1992, KRAJISNIK ceased to be a member of the Presidency, but continued to be one of the most important political leaders in Republika Srpska and remained the President of its National Assembly until 19 October 1996. In his capacity as a member of the Bosnian Serb National Security Council as a member of the Presidency of Republika Srpska, and in his position of leadership within the SDS party and organs of the Republika Srpska government, Momcilo KRAJISNIK, together with others, commanded, directed, or otherwise exercised effective control over the TO, the VRS and the police forces of Republika Srpska who participated in the crimes specified in this indictment.

12. Biljana PLAVSIC, a high-ranking SDS politician, on 28 February 1992, became one of two Acting Presidents of the Serbian Republic of Bosnia and Herzegovina, together with Nikola KOLJEVIC. As an Acting President, Biljana PLAVSIC became an ex officio member of the Bosnian Serb National Security Council. On 12 May 1992, she was elected as a member of the three-member Presidency and remained in this position after it was expanded to five members. When the Bosnian Serb Assembly elected Radovan KARADZIC President of Republika Srpska on 17 December 1992, it also elected Biljana PLAVSIC one of two Vice-Presidents, a position she held until 19 July 1996. In her capacity as Vice-President, member of the Bosnian Serb National Security Council as a member of the Presidency of Republika Srpska, and in her position of leadership within the SDS party and organs of the Republika Srpska government, Biljana PLAVSIC, together with others, commanded, directed, or otherwise exercised effective control over the TO, the VRS and the police forces of Republika Srpska who participated in the crimes specified in this indictment.

13. General Ratko MLADIC, a military career officer previously stationed in Macedonia and Kosovo, became the commander of the 9th Corps (Knin Corps) of the Yugoslav People’s Army ("JNA") in June 1991 and participated in the fighting in Croatia. On 4 October 1991, the SFRY Presidency promoted him to Major General. Subsequently, in May 1992, he assumed command of the forces of the Second Military District of the JNA in Sarajevo. From 12 May 1992 until November 1996, he was the Commander of the Main Staff of the VRS and in this capacity, together with others, commanded, directed, or otherwise exercised effective control over the VRS and other units acting in co-ordination with the VRS who participated in the crimes specified in this indictment.

14. Borisav JOVIC was successively the Vice-President, President and then a member of the SFRY Presidency from 15 May 1989 until April 1992, as well as the President of the SPS from May 1991 until October 1992, and a high ranking official of the SPS until November 1995. Borisav JOVIC and Branko KOSTIC, the Vice-President and then Acting President of the Presidency of the SFRY, together with others during the relevant period, commanded, directed, or otherwise exercised effective control over the JNA and members of the TO and paramilitary units acting in co-ordination with, and under supervision of, the JNA.

15. General Veljko KADIJEVIC, as Federal Secretary for National Defence from 15 May 1988 until 6 January 1992, commanded, directed, or otherwise exercised effective control over the JNA and other units acting in co-ordination with the JNA.

16. General Blagoje ADZIC, in his capacity as JNA Chief of Staff from 1990 to 28 February 1992 and Acting Federal Secretary for National Defence from mid-1991 to 28 February 1992, Federal Secretary for National Defence from 28 February 1992 to 27 April 1992 and JNA Chief of Staff from 27 April 1992 to 8 May 1992, together with others, commanded, directed, or otherwise exercised effective control over the JNA and other units acting in co-ordination with the JNA.

17. Jovica STANISIC, in his capacity as chief of the State Security (Drzavna bezbednost or "DB") of the Republic of Serbia from March 1991 to October 1998, commanded, directed, or otherwise exercised effective control over members of the DB, who participated in the perpetration of the crimes specified in this indictment. In addition, he provided arms, funds, training, or other substantial assistance or support to Serb paramilitary units and police units that were subsequently involved in the crimes specified in this indictment.

18. Franko SIMATOVIC, also known as "Frenki," as head of the special operations component of the DB of the Republic of Serbia, commanded, directed, or otherwise exercised effective control over agents of the DB who perpetrated crimes specified in this indictment. In addition, he provided arms, funds, training, or other substantial assistance or support to Serb paramilitary units and police units that were subsequently involved in the crimes charged in this indictment.

19. Radovan STOJICIC also known as "Badza" as Deputy Minister of Interior of Serbia and head of Public Security Service, commanded, directed or otherwise exercised effective control over special forces of the Serbian MUP and volunteer units who participated in the crimes specified in this indictment. In addition, he provided arms, funds, training, or other substantial assistance or support to Serb paramilitary units and police units that were subsequently involved in the crimes specified in this indictment.

20. Milan MARTIC, as "Secretary of the Secretariat of Internal Affairs" of the so-called Serbian Autonomous Region ("SAO") Krajina from 4 January 1991 until 29 May 1991; as "Minister of Defence" of the SAO Krajina from 29 May 1991 to 27 June 1991; and as "Minister of Internal Affairs" for the SAO Krajina (later "Republic of Serbian Krajina") from 27 June 1991 to January 1994, established, commanded, directed, and otherwise exercised effective control over members of his police force (referred to as "Martic’s Police," "Martic’s Militia," "Marticevci," "SAO Krajina Police" or "SAO Krajina Militia") who were subsequently involved in the crimes specified in this indictment.

21. Zeljko RAZNATOVIC, also known as "Arkan," in 1990 established and commanded the Serbian Volunteer Guard, a paramilitary unit commonly known as "Arkanovci" or "Arkan’s Tigers," who during the time relevant to this indictment operated in Bosnia and Herzegovina and were involved in the crimes charged in this indictment. In addition, he maintained a significant military base in Erdut, Croatia, where he functioned as commander. Other paramilitary groups and TO units were trained at this base and were subsequently involved in the crimes charged in this indictment.

22. Vojislav SESELJ, as President of the Serbian Radical Party (SRS) from at least February 1991 throughout the time relevant to this indictment recruited or otherwise provided substantial assistance or support to Serb paramilitary units, commonly known as "Seseljevci" or "Seselj’s men," who perpetrated crimes as specified in this indictment. In addition, he openly espoused and encouraged the creation of a "Greater Serbia" by violence and other unlawful means, and actively participated in war propaganda and spreading inter-ethnic hatred.

23. From 1987 until late 2000, Slobodan MILOSEVIC was the dominant political figure in Serbia and the SFRY/FRY. He acquired control of all facets of the Serbian government, including the police and the state security services. In addition, he gained control over the political leaderships of Kosovo, Vojvodina, and Montenegro.

24. In his capacity as the President of Serbia and through his leading position in the SPS party, Slobodan MILOSEVIC exercised effective control or substantial influence over the above listed participants in the joint criminal enterprise and either alone or acting in concert with them and additional known and unknown persons effectively controlled or substantially influenced the actions of the Federal Presidency of the SFRY and later the FRY, the Serbian Ministry of Internal Affairs ("MUP"), the JNA, the Yugoslav Army ("VJ") and the VRS, as well as Serb paramilitary groups.

25. Slobodan MILOSEVIC, acting alone and in concert with other members of the joint criminal enterprise participated in the joint criminal enterprise in the following ways:

a) He exerted effective control over elements of the JNA and VJ which participated in the planning, preparation, facilitation and execution of the forcible removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats, from large areas of Bosnia and Herzegovina.

b) He provided financial, logistical and political support to the VRS. These forces subsequently participated in the execution of the joint criminal enterprise through the commission of crimes which are in violation of Articles 2, 3, 4 and 5 of the Statute of the Tribunal.

c) He exercised substantial influence over, and assisted, the political leadership of Republika Srpska in the planning, preparation, facilitation and execution of the take-over of municipalities in Bosnia and Herzegovina and the subsequent forcible removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats, from those municipalities.

d) He participated in the planning and preparation of the take-over of municipalities in Bosnia and Herzegovina and the subsequent forcible removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats, from those municipalities. He provided the financial, material and logistical support necessary for such take-over.

e) He participated in the formation, financing, supply, support and direction of special forces of the Republic of Serbia Ministry of Internal Affairs. These special forces participated in the execution of the joint criminal enterprise through the commission of crimes which are in violation of Articles 2, 3, 4 and 5 of the Statute of the Tribunal.

f) He participated in providing financial, logistical and political support and direction to Serbian irregular forces or paramilitaries. These forces participated in the execution of the joint criminal enterprise through the commission of crimes which are in violation of Articles 2, 3, 4 and 5 of the Statute of the Tribunal.

g) He controlled, manipulated or otherwise utilised Serbian state-run media to spread exaggerated and false messages of ethnically based attacks by Bosnian Muslims and Croats against Serb people intended to create an atmosphere of fear and hatred among Serbs living in Serbia, Croatia and Bosnia and Herzegovina which contributed to the forcible removal of the majority of non-Serbs, principally Bosnian Muslims and Bosnian Croats, from large areas of Bosnia and Herzegovina.

26. Slobodan MILOSEVIC knowingly and wilfully participated in the joint criminal enterprise, while being aware of the foreseeable consequences of this enterprise. On this basis, he bears individual criminal responsibility for these crimes under Article 7(1) of the Statute of the Tribunal, in addition to his responsibility under the same Article for having planned, instigated, ordered or otherwise aided and abetted in the planning, preparation and execution of these crimes.

Article 7(3) of the Statute of the Tribunal

27. Slobodan MILOSEVIC, while holding positions of superior authority, is also individually criminally responsible for the acts or omissions of his subordinates, pursuant to Article 7(3) of the Statute of the Tribunal. A superior is responsible for the criminal acts of his subordinates if he knew or had reason to know that his subordinates were about to commit such acts or had done so, and the superior failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators.

28. From at least March 1991 until 15 June 1992, Slobodan MILOSEVIC exercised effective control over the four members of the "Serbian Bloc" within the Presidency of the SFRY. These four individuals were Borisav JOVIC, the representative of the Republic of Serbia; Branko KOSTIC, the representative of the Republic of Montenegro; Jugoslav KOSTIC, the representative of the Autonomous Province of Vojvodina; and Sejdo BAJRAMOVIC, the representative of the Autonomous Province of Kosovo and Metohija. Slobodan MILOSEVIC used Borisav JOVIC and Branko KOSTIC as his primary agents in the Presidency and through them he directed the actions of the "Serbian Bloc." From 1 October 1991, in the absence of the representatives of the Presidency from Croatia, Slovenia, Macedonia and Bosnia and Herzegovina, the four members of the "Serbian Bloc" exercised the powers of the Presidency, including that of collective "Commander-in-Chief" of the JNA. This "Rump Presidency" acted without dissension to execute Slobodan MILOSEVIC’s policies. The Federal Presidency had effective control over the JNA as its "Commander-in-Chief" and other units under the supervision of the JNA. Generals Veljko KADIJEVIC and Blagoje ADZIC, who directed and supervised the JNA forces in Bosnia and Herzegovina, were in constant communication and consultation with the accused.

29. On 27 April 1992, the Supreme Defence Council was formed. Throughout the time relevant to this indictment, Slobodan MILOSEVIC was a member of the Supreme Defence Council and exercised substantial influence and control over other members of the Council. The Supreme Defence Council and the President of the FRY had de jure control over the JNA and later the VJ. In addition to his de jure powers, at all times relevant to this indictment, Slobodan MILOSEVIC exercised de facto control over the JNA and the VJ through his control over the high ranking officers of these armies.

30. Slobodan MILOSEVIC is therefore individually criminally responsible, under Article 7(3) of the Statute of the Tribunal, for the participation of the members of the JNA and the VJ and other units under the supervision of the JNA and the VJ in the crimes described in this indictment.

31. From the time Slobodan MILOSEVIC came to power in Serbia, he exercised control over key officials in the Serbian MUP, among them Radmilo BOGDANOVIC and Zoran SOKOLOVIC, who were both, at different times, the Minister of Internal Affairs of Serbia. He also exercised control over Jovica STANISIC and Franko SIMATOVIC, both high-ranking officials in the DB. Through these officials, Slobodan MILOSEVIC exercised effective control over agents of the MUP, including the DB, who directed and supported the actions of the special forces and Serb paramilitary groups operating in Bosnia and Herzegovina. The accused Slobodan MILOSEVIC is therefore individually criminally responsible, under Article 7(3) of the Statute of the Tribunal, for the participation of the members of the Serbian MUP, including the DB, in the crimes described in this indictment.

THE CHARGES

COUNTS 1 and 2
GENOCIDE OR COMPLICITY IN GENOCIDE

32. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with other members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation and execution of the destruction, in whole or in part, of the Bosnian Muslim and Bosnian Croat national, ethnical, racial or religious groups, as such, in territories within Bosnia and Herzegovina, including: Bijeljina; Bosanski Novi; Bosanski Samac; Bratunac; Brcko; Doboj; Foca; Sarajevo (Ilijas); Kljuc; Kotor Varos; Sarajevo (Novi Grad); Prijedor; Rogatica; Sanski Most; Srebrenica; Visegrad; Vlasenica and Zvornik. The destruction of these groups was effected by:

a) The widespread killing of thousands of Bosnian Muslims and Bosnian Croats, during and after the take-over of territories within Bosnia and Herzegovina, including those listed above, as specified in Schedule A to this indictment. In many of the territories, educated and leading members of these groups were specifically targeted for execution, often in accordance with pre-prepared lists. After the fall of Srebrenica in July 1995, almost all captured Bosnian Muslim men and boys, altogether several thousands, were executed at the places where they had been captured or at sites to which they had been transported for execution.

b) The killing of thousands of Bosnian Muslims and Bosnian Croats in detention facilities within Bosnia and Herzegovina, including those situated within the territories listed above, as specified in Schedule B to this indictment.

c) The causing of serious bodily and mental harm to thousands of Bosnian Muslims and Bosnian Croats during their confinement in detention facilities within Bosnia and Herzegovina, including those situated within the territories listed above, as specified in Schedule C to this indictment. Members of these groups, during their confinement in detention facilities and during their interrogation at these locations, police stations and military barracks, were continuously subjected to, or forced to witness, inhumane acts, including murder, sexual violence, torture and beatings.

d) The detention of thousands of Bosnian Muslims and Bosnian Croats in detention facilities within Bosnia and Herzegovina, including those situated within the territories listed above, under conditions of life calculated to bring about the partial physical destruction of those groups, namely through starvation, contaminated water, forced labour, inadequate medical care and constant physical and psychological assault.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 1: GENOCIDE, punishable under Articles 4(3)(a) and 7(1) and 7(3) of the Statute of the Tribunal; or

Count 2: COMPLICITY IN GENOCIDE, punishable under Articles 4(3)(e) and 7(1) and 7(3) of the Statute of the Tribunal.

COUNT 3
PERSECUTIONS

33. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation or execution of persecutions of non-Serbs, principally Bosnian Muslims and Bosnian Croats, within the territories of Banja Luka; Bihac; Bijeljina; Bileca; Bosanska Dubica; Bosanska Gradiska; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac; Bratunac; Brcko; Cajnice; Celinac; Doboj; Donji Vakuf; Foca; Gacko; Gorazde, Sarajevo (Hadzici); Sarajevo (Ilidza); Sarajevo (Ilijas); Kljuc; Kalinovik; Kotor Varos; Nevesinje; Sarajevo (Novi Grad); Sarajevo (Novo Sarajevo); Sarajevo (Pale); Prijedor; Prnjavor; Rogatica; Rudo; Sanski Most; Sekovici; Sipovo; Sokolac; Srebrenica; Teslic; Trebinje; Sarajevo (Trnovo); Visegrad; Vlasenica; Sarajevo (Vogosca) and Zvornik.

34. Throughout this period, Serb forces, comprised of JNA, VJ, VRS units, local TO units, local and Serbian MUP police units and paramilitary units from Serbia and Montenegro, attacked and took control of towns and villages in these territories. After the take-over, the Serb forces in co-operation with the local Serb authorities established a regime of persecutions designed to drive the non-Serb civilian population from these territories.

35. These persecutions were committed on the discriminatory grounds of political affiliation, race or religion and included:

a) The extermination or murder of thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians, including women and the elderly, in those territories listed above, the details of which are set out in Schedules A and B to this indictment.

b) The prolonged and routine imprisonment and confinement of thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians in detention facilities within and outside of Bosnia and Herzegovina, the details of which are set out in Schedule C to this indictment.

c) The establishment and perpetuation of inhumane living conditions against Bosnian Muslim, Bosnian Croat and other non-Serb civilians, within the above mentioned detention facilities. These living conditions were brutal and characterised by inhumane treatment, overcrowding, starvation, forced labour and systematic physical and psychological abuse, including torture, beatings and sexual assault.

d) The prolonged and frequent forced labour of Bosnian Muslim, Bosnian Croat and other non-Serb civilians, from these detention facilities. The forced labour included digging graves and trenches and other forms of manual labour at the frontlines.

e) The cruel and inhumane treatment of Bosnian Muslim, Bosnian Croat and other non-Serb civilians during and after the take-over of the municipalities specified above. Such inhumane treatment included, but was not limited to, sexual violence, torture, physical and psychological abuse and forced existence under inhumane living conditions.

f) The imposition of restrictive and discriminatory measures against Bosnian Muslims, Bosnian Croats and other non-Serbs, such as, the restriction of freedom of movement; removal from positions of authority in local government institutions and the police; dismissal from jobs; arbitrary searches of their homes; denial of the right to judicial process and the denial of the right of equal access to public services, including proper medical care.

g) The beating and robbing of Bosnian Muslim, Bosnian Croat and other non-Serb civilians.

h) The forcible transfer and deportation of thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians, from the territories listed above, to locations outside of Serb held territories as described in paragraphs 40 and 41 and Schedule D to this indictment.

i) The appropriation and plunder of property belonging to Bosnian Muslim, Bosnian Croat and other non-Serb civilians.

j) The intentional and wanton destruction of homes, other public and private property belonging to Bosnian Muslims and Bosnian Croats, their cultural and religious institutions, historical monuments and other sacred sites, as described in paragraph 42.

k) The obstruction of humanitarian aid, in particular medical and food supplies into the besieged enclaves Bihac, Gorazde, Srebrenica and Zepa, and the deprivation of water from the civilians trapped in the enclaves designed to create unbearable living conditions.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 3: Persecutions on political, racial or religious grounds, a CRIME AGAINST HUMANITY, punishable under Articles 5(h) and 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 4 to 7
EXTERMINATION, MURDER AND WILFUL KILLING

36. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with other members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation or execution of the extermination, murder and wilful killings of non-Serbs, principally Bosnian Muslims and Bosnian Croats living in the territories of Banja Luka; Bihac; Bijeljina; Bileca;; Bosanska Gradiska; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac; Bratunac; Brcko; Cajnice; Celinac; Doboj; Foca; Gacko; Sarajevo (Ilijas); Kljuc; Kalinovik; Kotor Varos; Nevesinje; Sarajevo (Novi Grad); Prijedor; Prnjavor; Rogatica; Rudo; Sanski Most; Sokolac; Srebrenica; Teslic; Visegrad; Vlasenica and Zvornik. The extermination, murder and wilful killings of these groups were effected by:

a) The killing of Bosnian Muslims, Bosnian Croats and other non-Serbs in their towns and villages, during and after the take-over of the territories listed above including those specified in Schedule A to this indictment.

b) The killing of Bosnian Muslims, Bosnian Croats and other non-Serbs in detention facilities and during their deportation or forcible transfers, including those specified in Schedule B to this indictment.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 4: Extermination, a CRIME AGAINST HUMANITY, punishable under Articles 5(b) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 5: Murder, a CRIME AGAINST HUMANITY, punishable under Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 6: Wilful killing, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 7: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 8 to 15
UNLAWFUL CONFINEMENT, IMPRISONMENT, TORTURE, WILFULLY CAUSING GREAT SUFFERING, OTHER INHUMANE ACTS

37. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation or execution of the unlawful confinement or imprisonment under inhumane conditions of Bosnian Muslims, Bosnian Croats and other non-Serbs within the territories of Banja Luka; Bihac; Bijeljina; Bileca; Bosanska Dubica; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac; Bratunac; Brcko; Cajnice; Celinac; Doboj; Donji Vakuf; Foca; Gacko; Kljuc; Kalinovik; Kotor Varos; Nevesinje; Prijedor; Prnjavor; Rogatica; Rudo; Sanski Most; Sokolac; Teslic; Visegrad; Vlasenica and Zvornik.

38. Serb military forces, comprised of JNA, VJ, VRS, TO and paramilitary units acting in co-operation with local police staff and local Serb authorities, arrested and detained thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians from the territories listed above. These civilians were held in short and long-term detention, of which the major facilities are specified in Schedule C to this indictment.

39. The living conditions in these detention facilities were brutal and characterised by inhumane treatment, overcrowding, starvation, forced labour, inadequate medical care and systematic physical and psychological assault, including torture, beatings and sexual assault.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 8: Imprisonment, a CRIME AGAINST HUMANITY, punishable under Articles 5(e) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 9: Torture, a CRIME AGAINST HUMANITY, punishable under Articles 5(f) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 10: Inhumane acts, a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 11: Unlawful Confinement, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(g) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 12: Torture, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(b) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 13: Wilfully causing great suffering, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(c) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 14: Torture, a VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 15: Cruel Treatment, a VIOLATIONS OF THE LAWS OR CUSTOMS OF WAR as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 16 to 18
DEPORTATION AND INHUMANE ACTS (FORCIBLE TRANSFERS)

40. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation or execution of the unlawful forcible transfer, also qualifying as deportation where indicated hereinafter, of tens of thousands of Bosnian Muslim, Bosnian Croat and other non-Serb civilians from their legal domiciles in the territories of Banja Luka (deportation); Bihac; Bijeljina; Bileca (deportation); Bosanska Dubica; Bosanska Gradiska; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac (deportation); Bratunac; Brcko; Cajnice; Celinac; Doboj; Donji Vakuf; Foca; Gacko (deportation); Sarajevo (Hadzici); Sarajevo (Ilidza); Sarajevo (Ilijas); Kljuc; Kalinovik; Kotor Varos; Nevesinje; Sarajevo (Novi Grad); Sarajevo (Novo Sarajevo); Sarajevo (Pale); Prijedor; Prnjavor; Rogatica; Rudo (deportation); Sanski Most; Sekovici; Sipovo; Sokolac; Srebrenica; Teslic; Trebinje; Sarajevo (Trnovo); Visegrad; Vlasenica; Sarajevo (Vogosca) and Zvornik (deportation), to other areas both inside and outside Bosnia and Herzegovina. The details of such acts and omissions are described in Schedule D.

41. In order to achieve this objective, Serb forces comprised of JNA, VJ, VRS and TO, paramilitary units acting in co-operation with local police staff, local Serb authorities and special forces of the Serbian Ministry of Internal Affairs under the effective control of Slobodan MILOSEVIC or other members of the joint criminal enterprise, subjugated villages and towns in Bosnia and Herzegovina and participated with members of the SDS in the disarming of the non-Serb population. The towns and villages, including areas in which the inhabitants complied and offered no resistance, were then attacked. These attacks were intended to compel the non-Serb population to flee. After taking control of the towns and villages, the Serb forces often rounded-up the remaining non-Serb civilian population and forcibly removed them from the area. On other occasions, the Serb forces in co-operation with the local Serb authorities imposed restrictive and discriminatory measures on the non-Serb population and engaged in a campaign of terror designed to drive them out of the territory. The majority of non-Serbs that remained were eventually deported or forcibly transferred from their homes.

By these acts and omissions Slobodan MILOSEVIC committed:

Count 16: Deportation, a CRIME AGAINST HUMANITY, punishable under Articles 5(d) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 17: Inhumane Acts (Forcible Transfers), a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 18: Unlawful Deportation or Transfer, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(g) and 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 19 to 22
WANTON DESTRUCTION, PLUNDER OF PUBLIC OR PRIVATE PROPERTY

42. From on or about 1 March 1992 until 31 December 1995, Slobodan MILOSEVIC, acting alone or in concert with members of the joint criminal enterprise, planned, instigated, ordered, committed or otherwise aided and abetted the planning, preparation or execution of the wanton destruction and plunder of the public and private property of the Bosnian Muslim, Bosnian Croat and other non-Serb populations within the territories of Banja Luka; Bihac; Bijeljina; Bileca; Bosanska Dubica; Bosanska Gradiska; Bosanska Krupa; Bosanski Novi; Bosanski Petrovac; Bosanski Samac; Bratunac; Brcko; Cajnice; Celinac; Doboj; Donji Vakuf; Foca; Gacko; Sarajevo (Hadzici); Sarajevo (Ilidza); Sarajevo (Ilijas); Kljuc; Kalinovik; Kotor Varos; Nevesinje; Sarajevo (Novi Grad); Sarajevo (Novo Sarajevo); Sarajevo (Pale); Prijedor; Prnjavor; Rogatica; Rudo; Sanski Most; Sekovici; Sipovo; Sokolac; Srebrenica; Teslic; Sarajevo (Trnovo); Trebinje; Visegrad; Vlasenica; Sarajevo (Vogosca), and Zvornik. This intentional and wanton destruction and plunder was not justified by military necessity and included:

a) The appropriation and plunder of property belonging to Bosnian Muslim, Bosnian Croat and other non-Serb civilians, including the coerced signing of documents relinquishing property rights.

b) The intentional and wanton destruction of homes and other property owned by Bosnian Muslim, Bosnian Croat and other non-Serb civilians. Such destruction was employed as a means to compel non-Serbs to flee their legal domiciles and to prevent their subsequent return.

c) The intentional and wanton destruction of religious and cultural buildings of the Bosnian Muslim and Bosnian Croat communities including, but not limited to, mosques, churches, libraries, educational buildings and cultural centres.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 19: Extensive destruction and appropriation of property, not justified by military necessity and carried out unlawfully and wantonly, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(d) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 20: Wanton destruction of villages, or devastation not justified by military necessity, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, punishable under Articles 3(b) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 21: Wilful destruction or wilful damage done to historic monuments and institutions dedicated to education or religion, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, punishable under Articles 3(d) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 22: Plunder of public or private property, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, punishable under Articles 3(e) and 7(1) and 7(3) of the Statute of the Tribunal.

COUNTS 23 to 29
MURDER, WILFUL KILLING, WILFULLY CAUSING GREAT SUFFERING, CRUEL TREATMENT, ATTACKS ON CIVILIANS

43. Between April 1992 and November 1995, Slobodan MILOSEVIC, acting alone or in concert with members of the joint criminal enterprise, planned, instigated, ordered, committed, or otherwise aided and abetted the planning, preparation, or execution of a military campaign of artillery and mortar shelling and sniping onto civilian areas of Sarajevo and upon its civilian population, killing and wounding thousands of civilians of all ages and both sexes.

44. In this time period, the Sarajevo Romanija Corps of the VRS, under the effective control of Radovan KARADZIC and General Ratko MLADIC, launched an extensive, forty-four month shelling and sniping attack on Sarajevo, mostly from positions in the hills surrounding the city with an unobstructed view of Sarajevo.

45. The Sarajevo Romanija Corps conducted a protracted campaign of shelling and sniping upon Sarajevo during which civilians were either specifically targeted or the subject of reckless fire into areas where civilians were known to have been. Among the victims of this campaign were civilians who were, amongst other things, tending vegetable plots, queuing for bread or water, attending funerals, shopping in markets, riding on trams, gathering wood. Specific instances of sniping are described in Schedule E attached to this indictment. Specific instances of shelling are set forth in Schedule F.

By these acts and omissions, Slobodan MILOSEVIC committed:

Count 23: Murder, a CRIME AGAINST HUMANITY, punishable under Articles 5(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 24: Inhumane acts, a CRIME AGAINST HUMANITY, punishable under Articles 5(i) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 25: Wilful killing, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(a) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 26: Wilfully causing great suffering, a GRAVE BREACH OF THE GENEVA CONVENTIONS OF 1949, punishable under Articles 2(c) and 7(1) and 7(3) of the Statute of the Tribunal.

Count 27: Murder, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 28: Cruel treatment, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Common Article 3(1)(a) of the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

Count 29: Attacks on civilians, a VIOLATION OF THE LAWS OR CUSTOMS OF WAR, as recognised by Article 51 (2) of Additional Protocol I and Article 13 (2) of Additional Protocol II to the Geneva Conventions of 1949, punishable under Articles 3 and 7(1) and 7(3) of the Statute of the Tribunal.

GENERAL LEGAL ALLEGATIONS

46. All acts and omissions alleged in this indictment occurred on the territory of the former Yugoslavia.

47. At all times relevant to this indictment, a state of international armed conflict and partial occupation existed in Bosnia and Herzegovina.

48. All acts and omissions charged as Grave Breaches of the Geneva Conventions of 1949 occurred during the international armed conflict and partial occupation of Bosnia and Herzegovina. All such acts and omissions were committed against persons protected under the Geneva Conventions.

49. All acts and omissions charged relative to the destruction of property as Grave Breaches of the Geneva Conventions of 1949 involved "protected property" under the relevant provisions of the Geneva Conventions.

50. At all times relevant to this indictment Slobodan MILOSEVIC was required to abide by the laws and customs governing the conduct of armed conflicts, including the Geneva Conventions of 1949 and the Additional Protocols thereto.

51. All conduct charged as Crimes against Humanity was part of a widespread or systematic attack directed against the Bosnian Muslim, Bosnian Croat and other non-Serb civilian populations within large areas of Bosnia and Herzegovina.

ADDITIONAL FACTS

52. In November 1990, multi-party elections were held in Bosnia and Herzegovina. At the Republic level, the SDA ("Stranka Demokratske Akcije - Party of Democratic Action) the party of the Bosnian Muslims won 86 seats; the SDS, the party of the Bosnian Serbs, won 72 seats and the HDZ (Hrvatska demokratska zajednica - Croatian Democratic Community) won 44 seats in the Assembly.

53. The central idea within the SDS political platform, as articulated by its leaders, including Radovan KARADZIC, Momcilo KRAJISNIK and Biljana PLAVSIC, was the unification of all Serbs within one state. The SDS regarded the separation of Bosnia and Herzegovina from the SFRY as a threat to the interests of the Serbs.

54. On 5 February 1991 the Assembly of the Republic of Serbia passed a "Law on Ministries" submitted by Slobodan MILOSEVIC. This law established twenty "Ministries" of the Serbian government, including the Ministry for Links with Serbs outside Serbia. This Ministry assisted the SDS to establish the Serb Republic of Bosnia and Herzegovina.

55. The results of the November 1990 elections meant that, as time went on, the SDS would be unable through peaceful means to keep the Republic of Bosnia and Herzegovina in what was becoming a Serb-dominated Yugoslavia. As a result, Serb people within certain areas of Bosnia and Herzegovina, with Serb majorities, began to organise themselves into formal regional structures that they referred to as "Associations of Municipalities." In April 1991 the Association of Municipalities of Bosnian Krajina, centred in Banja Luka, was formed.

56. In March 1991, the collective Presidency of the SFRY reached a deadlock on several issues including the issue of instituting a state of emergency in Yugoslavia. The representatives on the Presidency from the Republic of Serbia, the Republic of Montenegro, the Autonomous Province of Vojvodina, and the Autonomous Province of Kosovo and Metohija all resigned from their posts. In a televised address on 16 March 1991, Slobodan MILOSEVIC, in his capacity as President of the Republic of Serbia, declared that Yugoslavia was finished and that Serbia would no longer be bound by decisions of the Federal Presidency.

57. On 25 March 1991, Slobodan MILOSEVIC and Franjo TUDMAN met in Karadjordjevo and discussed the partition of Bosnia and Herzegovina between Serbia and Croatia.

58. On 25 June 1991, Slovenia and Croatia declared their independence. On 26 June, the JNA intervened in Slovenia. In the summer of 1991, fighting broke out in Croatia.

59. In August 1991 Radovan KARADZIC instituted a system of secret communication between the local boards of the SDS and the Main Staff and with the Republic of Serbia. This secret communication protocol was declared mandatory for the transmission of reports and orders.

60. From autumn 1991, the JNA began to withdraw its forces out of Croatia. Forces under the control of the JNA began to re-deploy in Bosnia and Herzegovina. Many of these troops were deployed to areas in which there was no garrison or other JNA facility.

61. As the war continued in Croatia it appeared increasingly likely that Bosnia and Herzegovina would also declare its independence from the SFRY. The SDS, realising it could not prevent the secession of Bosnia and Herzegovina from the SFRY, began the creation of a separate Serbian entity within Bosnia and Herzegovina. During the period from September to November 1991, several Serbian Autonomous Regions (SAO) were formed, some of them on the basis of the Associations of Municipalities referred to above.

62. On 12 September 1991, the Serbian Autonomous Region of Herzegovina was proclaimed. On 16 September 1991, the Autonomous Region of Krajina was proclaimed by the Assembly of the Association of Municipalities of Bosnian Krajina. By 21 November 1991, the Serbian Autonomous Regions and Autonomous Regions consisted of the Autonomous Region of Krajina, the SAO Herzegovina, the SAO Romanija-Birac, the SAO Semberija, and SAO Northern Bosnia.

63. On 3 October 1991, the four members of the SFRY Presidency from Serbia and Montenegro (Borisav JOVIC, Jugoslav KOSTIC, Sejdo BAJRAMOVIC and Branko KOSTIC) assumed the function of the SFRY Presidency, circumventing the roles and responsibilities of the Presidency members from Slovenia, Croatia, Bosnia and Herzegovina and Macedonia.

64. On 15 October 1991, at the meeting of the SDS Party Council the decision was reached to form a separate assembly, entitled the "Assembly of the Serbian People of Bosnia and Herzegovina" to secure Serb interests.

65. On or around 22 October 1991, Slobodan MILOSEVIC, together with other members of the joint criminal enterprise, continued to advocate for a unitary Serb state governed from Belgrade, Serbia. On the same date the "Rump Presidency" called for the mobilisation of reservists in Serbia and "other regions that want to stay in Yugoslavia."

66. On or about 26 October 1991, Radovan KARADZIC declared a full mobilisation of the TO and the formation of field units in the Serb Republic of Bosnia and Herzegovina.

67. On 24 October 1991, the Assembly of the Serbian People in Bosnia and Herzegovina, dominated by the SDS, decided to conduct a "Plebiscite of the Serbian People in Bosnia and Herzegovina" in order to decide whether to stay in the common state of Yugoslavia with Serbia, Montenegro, the Serbian Autonomous Region of Krajina, SAO Western Slavonia and SAO Eastern Slavonia, Baranja and Western Srem.

68. On 9 and 10 November 1991, the Bosnian Serbs held the plebiscite on the issue of whether Bosnia and Herzegovina should stay in Yugoslavia or become an independent state. The results overwhelmingly showed that the Bosnian Serbs wanted to stay in Yugoslavia.

69. On 21 November 1991, the Assembly of the Serbian People of Bosnia and Herzegovina, proclaimed as part of the territory of the federal Yugoslav state all those municipalities, local communities and populated places, in which over 50% of the people of Serbian nationality had voted, during the plebiscite, to remain in that state as well as those places where citizens of other nationalities had expressed themselves in favour of remaining in Yugoslavia.

70. On 11 December 1991, the Assembly of the Serbian People delivered a detailed request to the JNA to protect with all available means as "integral parts of the State of Yugoslavia" the territories of Bosnia and Herzegovina in which the plebiscite of the Serbian people and other citizens on remaining in a joint Yugoslav state had been conducted.

71. On 19 December 1991, the SDS issued instructions for the "Organisation and Activity of the Organs of the Serbian People in Bosnia and Herzegovina in Extraordinary Circumstances" which provided a plan for the SDS take-over of municipalities in Bosnia and Herzegovina.

72. On 9 January 1992, the Assembly of the Serbian People of Bosnia and Herzegovina adopted a declaration on the Proclamation of the Serbian Republic of Bosnia and Herzegovina. The territory of that republic was declared to include "the territories of the Serbian Autonomous Regions and Districts and of other Serbian ethnic entities in Bosnia and Herzegovina, including the regions in which the Serbian people remained in the minority due to the genocide conducted against it in World War Two", and it was declared to be a part of the federal Yugoslav state. On 12 August 1992, the name of the Bosnian Serb Republic was changed to Republika Srpska.

73. From 29 February to 2 March 1992, Bosnia and Herzegovina held a referendum on independence. At the urging of the SDS, the majority of Bosnian Serbs boycotted the vote. The referendum resulted in a pro-independence majority.

74. On 18 March 1992, during the 11th session of the Assembly of the Serbian People, a conclusion was reached to "prepare for the next session proposals for the take-over of power in the Republic of Serbian People of Bosnia and Herzegovina."

75. From March 1992 onwards, Serb regular and irregular forces seized control of territories within Bosnia and Herzegovina, including those specified in this indictment.

76. On 6 April 1992, the United States and the European Community formally recognized the independence of Bosnia and Herzegovina.

77. On 27 April 1992, Serbia and Montenegro proclaimed a new Federal Republic of Yugoslavia and declared it the successor state of the Socialist Federal Republic of Yugoslavia.

78. On 12 May 1992, at the 16th Assembly of the Serbian People in Bosnia and Herzegovina, Radovan KARADZIC announced the six strategic objectives of the Serbian People in Bosnia and Herzegovina. These objectives included the eradication of the Drina River as a border between the Serbian states. During the same session, General Ratko MLADIC told the Assembly that it would not be possible to separate Serbs from non-Serbs and have the non-Serbs simply leave the territory. He warned that attempting this process would amount to genocide.

79. On 15 May 1992, the United Nations Security Council in its resolution number 752 demanded that all interference from outside Bosnia and Herzegovina by units of the JNA cease immediately and that those units either be withdrawn, be subjected to the authority of the Government of the Republic, or be disbanded and disarmed.

____________________________
Carla Del Ponte
Prosecutor

Dated this 22nd day of November 2001
At The Hague
The Netherlands

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