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Rwanda
Claude Muhayimana
Type of liability
Personne physique
Alleged perpetrator(s)
Claude MUHAYIMANA
Nationality of alleged perpetrator(s)
French-Rwandan
Legal classification of crime(s)
Complicity in genocide
Complicity in crimes against humanity
Source of the complaint
NGO
Ongoing proceedings
oui
Regime
1 - TPIR / TPIY
4 - 113 CP
Summary of facts
Claude Muhayimana, a former driver at the Kibuye Guest House, allegedly transported Hutu militiamen to the sites of several attacks.
Between April and June 1994, he also allegedly participated in the attack on the school in Nyamishaba (Prefecture of Kibuye) and in the massacres of Tutsi civilians who had taken refuge in Karongi, Gitwa and Bisesero.
He is also accused of having taken part in the massacres perpetrated in the church of Kibuye, in western Rwanda, on April 17, 1994, and at the Gatwaro Stadium the following day, massacres that claimed thousands of lives.
Amnesty International France recalls that everyone is presumed innocent until proven guilty according to law.
Legal proceedings
<p><span class="TextRun Highlight MacChromeBold SCXW15608306 BCX0" lang="FR-FR" xml:lang="FR-FR" data-contrast="auto"><span class="NormalTextRun SCXW15608306 BCX0">April 28, 2010: Claude </span><span class="NormalTextRun SpellingErrorV2Themed SCXW15608306 BCX0">Muhayi</span><span class="NormalTextRun SpellingErrorV2Themed SCXW15608306 BCX0">man</span><span class="NormalTextRun SpellingErrorV2Themed SCXW15608306 BCX0">a</span><span class="NormalTextRun SCXW15608306 BCX0"> obtained French nationality; he lived in Rouen.</span></span><br />
December 13, 2011: The Rwandan judicial authorities issued an international arrest warrant against Claude Muhayimana for his alleged participation in the genocide against the Tutsi. The Rwandan authorities also submitted an extradition request to France.<br />
March 8, 2012: Claude Muhayimana was arrested at his workplace.<br />
March 9, 2012: Claude Muhayimana was placed in pre-trial detention.<br />
March 29, 2012: The Investigating Chamber of the Rouen Court of Appeal issued a favorable opinion on Rwanda’s extradition request, considering that the fundamental procedural guarantees and the protection of the rights of the defense would be ensured there. Claude Muhayimana filed an appeal to the Court of Cassation, alleging that he would not be guaranteed a fair trial in Rwanda.<br />
July 11, 2012: The Court of Cassation annulled the decision of the Rouen Court of Appeal.<br />
April 24, 2013: The extradition hearing took place at the Paris Court of Appeal.<br />
June 4, 2013: The CPCR filed a complaint with civil party application against Claude Muhayimana.<br />
June 5, 2013: The extradition hearing took place at the Paris High Court. Examination of the merits was postponed to September 25, 2013, then to November 13.<br />
November 13, 2013: A favorable opinion on extradition was issued; Claude Muhayimana filed an appeal with the Court of Cassation.<br />
February 24, 2014: The Court of Cassation ruled that Claude Muhayimana could not be extradited, as the Rwandan extradition request was based on laws that entered into force after the crimes were committed; he was released.<br />
April 9, 2014: Claude Muhayimana was arrested in Rouen following the complaint filed in June 2013 by the CPCR. He was indicted for his alleged involvement in the 1994 genocide against the Tutsi and placed in pre-trial detention.<br />
April 3, 2015: Claude Muhayimana was placed under judicial supervision.<br />
November 9, 2017: The investigating judge ordered his committal to the Paris Assize Court for “complicity in genocide” and “complicity in crimes against humanity” by aiding or abetting. Claude Muhayimana appealed the committal decision. The Public Prosecutor’s Office requested that the charges relating to the massacres committed in the Kiguye church and in the Gatwaro Stadium be dropped. Claude Muhayimana reportedly presented an alibi proving that he was not at the scene during the events.<br />
October 18, 2018: The appeal hearing against the committal decision was held before the Investigating Chamber of the Paris Court of Appeal.<br />
April 4, 2019: The Paris Court of Appeal dismissed the appeal and confirmed the committal to the Assize Court for “complicity in crimes against humanity” and “complicity in genocide”.<br />
November 22 to December 16, 2021: The trial took place before the Paris Assize Court. Claude Muhayimana was found guilty of “complicity in genocide” for having transported militiamen to various massacre sites during the genocide. He was sentenced to 14 years’ imprisonment. Philippe Meilhac, one of Claude Muhayimana’s lawyers, announced that he had appealed the conviction. The prosecution – which had sought 15 years’ imprisonment against Claude Muhayimana, describing him as an “actor in the genocide” and an “indispensable cog” – lodged a main appeal of its own.<br />
December 21, 2022: The Court of Appeal granted Claude Muhayimana’s release and placed him under judicial supervision pending his appeal trial.<br />
February 3 to 27, 2026: The appeal trial took place before the Paris Assize Court. On February 27, 2026, Claude Muhayimana was sentenced on appeal to fourteen years’ imprisonment for “complicity in genocide”.</p>
December 13, 2011: The Rwandan judicial authorities issued an international arrest warrant against Claude Muhayimana for his alleged participation in the genocide against the Tutsi. The Rwandan authorities also submitted an extradition request to France.<br />
March 8, 2012: Claude Muhayimana was arrested at his workplace.<br />
March 9, 2012: Claude Muhayimana was placed in pre-trial detention.<br />
March 29, 2012: The Investigating Chamber of the Rouen Court of Appeal issued a favorable opinion on Rwanda’s extradition request, considering that the fundamental procedural guarantees and the protection of the rights of the defense would be ensured there. Claude Muhayimana filed an appeal to the Court of Cassation, alleging that he would not be guaranteed a fair trial in Rwanda.<br />
July 11, 2012: The Court of Cassation annulled the decision of the Rouen Court of Appeal.<br />
April 24, 2013: The extradition hearing took place at the Paris Court of Appeal.<br />
June 4, 2013: The CPCR filed a complaint with civil party application against Claude Muhayimana.<br />
June 5, 2013: The extradition hearing took place at the Paris High Court. Examination of the merits was postponed to September 25, 2013, then to November 13.<br />
November 13, 2013: A favorable opinion on extradition was issued; Claude Muhayimana filed an appeal with the Court of Cassation.<br />
February 24, 2014: The Court of Cassation ruled that Claude Muhayimana could not be extradited, as the Rwandan extradition request was based on laws that entered into force after the crimes were committed; he was released.<br />
April 9, 2014: Claude Muhayimana was arrested in Rouen following the complaint filed in June 2013 by the CPCR. He was indicted for his alleged involvement in the 1994 genocide against the Tutsi and placed in pre-trial detention.<br />
April 3, 2015: Claude Muhayimana was placed under judicial supervision.<br />
November 9, 2017: The investigating judge ordered his committal to the Paris Assize Court for “complicity in genocide” and “complicity in crimes against humanity” by aiding or abetting. Claude Muhayimana appealed the committal decision. The Public Prosecutor’s Office requested that the charges relating to the massacres committed in the Kiguye church and in the Gatwaro Stadium be dropped. Claude Muhayimana reportedly presented an alibi proving that he was not at the scene during the events.<br />
October 18, 2018: The appeal hearing against the committal decision was held before the Investigating Chamber of the Paris Court of Appeal.<br />
April 4, 2019: The Paris Court of Appeal dismissed the appeal and confirmed the committal to the Assize Court for “complicity in crimes against humanity” and “complicity in genocide”.<br />
November 22 to December 16, 2021: The trial took place before the Paris Assize Court. Claude Muhayimana was found guilty of “complicity in genocide” for having transported militiamen to various massacre sites during the genocide. He was sentenced to 14 years’ imprisonment. Philippe Meilhac, one of Claude Muhayimana’s lawyers, announced that he had appealed the conviction. The prosecution – which had sought 15 years’ imprisonment against Claude Muhayimana, describing him as an “actor in the genocide” and an “indispensable cog” – lodged a main appeal of its own.<br />
December 21, 2022: The Court of Appeal granted Claude Muhayimana’s release and placed him under judicial supervision pending his appeal trial.<br />
February 3 to 27, 2026: The appeal trial took place before the Paris Assize Court. On February 27, 2026, Claude Muhayimana was sentenced on appeal to fourteen years’ imprisonment for “complicity in genocide”.</p>
Complaint
non
Names of NGOs / Victim(s)
CPCR
Legal basis for jurisdiction (article)
Law No. 96-432 of May 22, 1996
113-6 PC
113-6 PC
Court of Assizes judgment
Muhayimana was found guilty of complicity in genocide for having transported militiamen to various massacre sites during the genocide. He was sentenced to 14 years' imprisonment.
https://francegenocidetutsi.org/ArretCriminelEtFeuilleDeMotivationMuhayimana16122021.pdf
https://francegenocidetutsi.org/ArretCriminelEtFeuilleDeMotivationMuhayimana16122021.pdf
Court of Appeal ruling
Claude Muhayimana was sentenced on appeal to fourteen years' imprisonment for “complicity in genocide”.
https://www.collectifpartiescivilesrwanda.fr/proces-en-appel-de-claude-muhayimana-feuille-de-motivation-de-la-cour-dassises/
https://www.collectifpartiescivilesrwanda.fr/proces-en-appel-de-claude-muhayimana-feuille-de-motivation-de-la-cour-dassises/
Court of Cassation ruling
n/a
Sources
TRIAL International, « Universal Jurisdiction Annual Review 2023 », 2023