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The principle of individual criminal responsibility set out in article 6 of the Statute of the ICTR18 does not include the notion of responsibility based on membership in a criminal organisation. The notion was considered in the context of the establishment of the International Criminal Tribunal for the former Yugoslavia (ICTY)19 as there had been reports of atrocities committed by paramilitary groups such as the "Tigers" (a Serb group commanded by Zaljko Raznjatovic (aka Arkan)), the "Cetniks" (a Serb group commanded by Vojislav Seselj), the "White Eagles" (a Serb group commanded by Mirko Jovic) and the "Fire Horses" (a Bosnian Croat paramilitary group).

Georgia became a Soviet Socialist Republic

During the Soviet period, Georgia was one of the wealthiest and most privileged republics, and its Black Sea coastline was a popular holiday destination for the Soviet elite. On April 9, 1991, shortly before the collapse of the Soviet Union, the Supreme Council of the Republic of Georgia declared independence from the U.S.S.R.

Secessionists took control of parts of South Ossetia and most of Abkhazia prior to cease-fire agreements brokered in 1992 and 1994, respectively. Georgia began to stabilize in 1995. However, the separatist conflicts in Georgia's regions of Abkhazia and South Ossetia remain unresolved.