Cumulative Charges, Convictions and Sentencing at the Ad Hoc International Tribunals for the Former Yugoslavia and Rwanda

[Although the issue of cumulative offences (concursus delictorum) is well developed in various national criminal justice systems, concursus delictorium is only at the formative stages of its development in international criminal law. Through an examination of the jurisprudence of the International Tribunal for the Former Yugoslavia and the International Tribunal for Rwanda, this article highlights various approaches that can be taken to the issue of consursus delictorium. Importantly, the adoption of a certain approach to this issue has direct implications with respect to the rights of those accused standing trial in The Hague or Arusha. In addition, the jurisprudence that emerges from the ICTY and ICTR will, no doubt, play an important role in the future development of this concept in both academic theory, and the future jurisprudence of the International Criminal Court.]