By: John Boonstra on January 14, 2009 Susan Benesch at Opinio Juris calls attention to an interesting case at the International Criminal Tribunal for Rwanda: Simon Bikindi, the Rwandan pop star whose two-year trial at the ICTR was apparently the first attempt to criminalize music in international law, was just convicted of incitement to genocide but not, after all, for his songs, even though Rwandan genocidaires sang them like anthems while hacking people to death. The ICTR did find, notably, that the songs “amplified” the genocide, but it missed an important chance to develop jurisprudence on incitement to genocide. If the racist pronouncements broadcast far and wide over the infamous Radio Milles Collines throughout the genocide constituted incitement, then it seems logical that this acoustic jurisprudence would extend to inflammatory popular music. On the other hand, if a song just happened to be one that genocidaires liked to chant as they undertook their horrific acts, it would be difficult to prosecute the singer for incitement. But these songs were not the stuff you’d find Barney singing; and if the statement for which Bikindi was convicted is any indication, then Bikindi’s genocidal intentions should have been clear. In late June 1994, when most of the genocide was already over, Bikindi drove along a road in his native Gisenyi, calling over a loudspeaker, “The majority population, it’s you, the Hutu I am talking to. You know the minority population is the Tutsi. Exterminate quickly the remaining ones.” Unfortunately, in the murderous frenzy of the time in Rwanda, it’s no far stretch to imagine lyrics as ghastly as that statement.