-
- International
Criminal Tribunal
- to
Investigate NATO Leaders
-
-
-
- TO:
- Madam Justice Louise Arbour, Prosecutor,
- International Criminal Tribunal for the Former
Yugoslavia,
- Churchillplein 1, 2501 EW, The Hague,
Netherlands.
-
- AND TO:
- William J. Clinton, Madeleine Albright and William S.
Cohen,
C/o William J. Clinton, President
The White House, 1600 Pennsylvania Ave NW
Washington, District of Columbia 20500, United States of
America
-
- Tony Blair, Robin Cook and George Robertson,
- C/o Rt. Hon. Tony Blair, Prime Minister
10 Downing St. SW1A 2AA London United Kingdom
-
- Javier Solana, Jamie Shea, Wesley K. Clark, Harold W.
German, Konrad Freytag.
D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani and
Daniel P. Leaf,
C/o Javier Solana, Secretary General
NATO Headquarters, 1110 Brussels, Belgium
-
- Jean Chrétien, Lloyd Axworthy and Arthur
Eggleton,
C/o Jean Chretien, M.P., Prime Minister
House of Commons, PO Box 1103, Ottawa, Ontario K1A 0A6,
Canada
-
- Jean-Luc Dehaene, E. Derycke and J.-P. Poncelet,
C/o M. Jean-Luc Dehaene, Premier Ministre
rue de la Loi 16, B-1000 Brussels, Belgium
-
- Vaclav Havel, J. Kavan and V. Vetchy,
C/o Vaclav Havel, President
Office of the President of the C.R., Hrad (Castle), 119
08 Praha 1, Czech Republic
-
- Poul Nyrup Rasmussen, N.H. Petersen and H.
Haekkerup,
C/o Poul Nyrup Rasmussen, Prime Minister
Prime Minister`s Office
Christiansborg, Prins Jorgens Gaard 11, DK-1218
Copenhagen, Denmark
-
- Jacques Chirac, Lionel Jospin, H. Védrine and
Alain Richard,
C/o M. Jacques Chirac, President de la Republique
Palais de l`Elysee, 55 et 57, rue du Faubourg
Saint-Honore, 75008 Paris, France
-
- Gerhard Schröder, J. Fischer and R.
Scharping
C/o Gerhard Schoeder, Chancellor
Adenauerallee 141, PA: Briefpost, PLZ 53106, 53113 Bonn,
Germany
-
- Kostas Simitis, G. Papandreou and A.
Tsohatzopoulos,
C/o Kostas Simitis, Prime Minister
Office of the Prime Minister, Greek Parliament Bldg,
Constitution Square, Athens, Greece
-
- Viktor Orban, J. Martonyi and J. Szabo,
C/oViktor Orban, Prime Minister
Kossuth Lajos ter 1-3, 1055 Budapest, Budapest fovaros,
Hungary
-
- David Oddsson, H. Asgrimsson and G. Palsson,
C/o David Oddsson, Prime Minister
Office of the Prime Minister, Stjornarradshusinu, 150
Reykjavik, Iceland
-
- Massimo D'Alema, L. Dini and C. Scognamiglio,
- C/o Massimo D'Alema, Presidenza del Consiglio dei
Ministri (Prime Minister)
- Piazza Colonna, 37, 00187 Rome, Italy
-
- Jean-Claude Juncker, J. Poos and Alex Bodry,
- C/o Jean-Claude Juncker, Prime Minister
- Ministere d`Etat, 4, rue de la Congregation, L-2910
Luxembourg
-
- Willem Kok, J. van Aartsen and F.H.G. de Grave,
- C/o Willem Kok, Prime Minister
- Binnenhof 20, 2513 AA, Postbus 20001, 2500 EA, The
Hague, Netherlands
-
- Kjell Magne Bondevik, K. Vollebæk and D.J.
Fjærvoll,
- C/o Kjell Magne Bondevik, Prime Minister
- Akersgt. 42, blokk H, P.O. Box 8001 Dep, N-0030 Oslo,
Norway
-
- Jerzy Buzek, B. Geremek and J. Onyszkiewicz,
- C/o Jerzy Buzek, Prime Minister
- Prime Minister's Office, al. Ujazdowskie 1/3, 00-583
Warsaw, Poland
-
- Antonio Manuel de Oliveira Guterres, J.J. Matos da
Gama and V. Simão,
- C/o Antonio Manuel de Oliveira Guterres, Prime
Minister
- Gabinete do Primeiro-Ministro, Lisboa, Portugal
-
- Jose Maria Aznar, A. Matutes and E. Serra
Rexach,
- C/o Excmo. Sr. Jose Maria Aznar
- Presidente del Gobierno, Complejo de la Moncloa, Edf.
Semillas
- 28071 Madrid, Spain
-
- Bulent Ecevit, I. Cem and H. S. Turk,
- C/o Bulent Ecevit, Prime Minister
- Office of the Prime Minister, Basbakanlik, 06573
Ankara, Turkey
-
- FROM:
-
- Professor Michael Mandel, Professor W. Neil Brooks,
Professor Judith A. Fudge,
- Professor H. J. Glasbeek, Professor Reuben A. Hasson
and Sil Salvaterra,
- Barrister and Solicitor, Community Legal Aid Services
Programme,
- Osgoode Hall Law School, York University,
- Toronto, Ontario,
- Canada M3J 1P3
-
- David Jacobs and Brian Shell, Barristers and
Solicitors,
- Shell, Jacobs Lawyers
- 672 Dupont Street,
- Suite 401
- Toronto, Ontario
- Canada M6G 1Z6
-
- Christopher Black, Barrister and Solicitor,
- 121 Nymark Avenue,
- Toronto, Ontario
- Canada M2J 2H3
-
- John Philpot, Barrister and Solicitor,
- Alariel Legault Beachemin Paquin Jobin Brisson &
Philpot
- 1259 rue Berri suite 1000
- Montréal, Québec
- Canada H2L 4C7
-
- Fred Stasiuk, Barrister and Solicitor,
- 296 Mill Road,
- Unit B6
- Etobicoke, Ontario,
- Canada M9G 4X8
-
- Professor Peter Rosenthal, Barrister and
Solicitor,
- Mathematics Department,
- The University of Toronto,
- Toronto, Ontario
- Canada
-
- Professor Roberto Bergalli,
- Departament de Dret Penal i Ciences Penals
- Universitat de Barcelona,
- Av. Diagonal 684 E-08034
- Barcelona, Spain
-
- The American Association of Jurists:
- Alejandro Teitelbaum,
- Permanent Representative to the United Nations in
Geneva.
- 80 Quai Gillet
- 69004 Lyon, France
-
- Alvaro Ramirez Gonzalez, President,
- Del Porton Oriental de la UCA 1 y media cuadra
arriba
- Apdo Postal 3348
- Managua, Nicaragua
-
- Vanessa Ramos,
- Secretary General
- 200 Mercer Street 4E
- New York, NY 10012
-
- Beinusz Szmukler,
- President, Consultative Council,
- Peru 971 8 piso, B
- 1068 Buenos Aires, Argentina
-
-
- IN THE INTERNATIONAL CRIMINAL TRIBUNAL FOR THE FORMER
YUGOSLAVIA
- RE: William J. Clinton, Madeleine Albright, William
S. Cohen, Tony Blair, Robin
- Cook, George Robertson, Javier Solana, Jamie Shea,
Wesley K. Clark, Harold W.
- German, Konrad Freytag. D.J.G. Wilby, Fabrizio
Maltinti, Giuseppe Marani,
- Daniel P. Leaf, Jean Chrétien, Lloyd Axworthy,
Arthur Eggleton, Jean-Luc
- Dehaene, E. Derycke, J.-P. Poncelet, Vaclav Havel, J.
Kavan, V. Vetchy, Poul
- Nyrup Rasmussen, N.H. Petersen, H. Haekkerup, Jacques
Chirac, Lionel Jospin, H.
- Védrine, Alain Richard, Gerhard Schröder,
J. Fischer, R. Scharping, Kostas
- Simitis, G. Papandreou, A. Tsohatzopoulos, Viktor
Orban, J. Martonyi, J. Szabo,
- David Oddsson, H. Asgrimsson, G. Palsson, Massimo
D'Alema, L. Dini, C.
- Scognamiglio, Jean-Claude Juncker, J. Poos, Alex
Bodry, Willem Kok, J. van
- Aartsen, F.H.G. de Grave, Kjell Magne Bondevik, K.
Vollebæk, D.J. Fjærvoll,
- Jerzy Buzek, B. Geremek, J. Onyszkiewicz, Antonio
Manuel de Oliveira Guterres,
- J.J. Matos da Gama, V. Simão, Jose Maria
Aznar, A. Matutes, E. Serra Rexach,
- Bulent Ecevit, I. Cem and H. S. Turk.
-
- NOTICE OF THE EXISTENCE OF INFORMATION CONCERNING
SERIOUS VIOLATIONS OF INTERNATIONAL HUMANITARIAN LAW
WITHIN THE JURISDICTION OF THE TRIBUNAL;
-
- REQUEST THAT THE PROSECUTOR INVESTIGATE NAMED
INDIVIDUALS FOR VIOLATIONS OF INTERNATIONAL HUMANITARIAN
LAW AND PREPARE INDICTMENTS AGAINST THEM PURSUANT TO
ARTICLES 18.1 AND 18.4 OF THE TRIBUNAL STATUTE.
-
-
-
- WHEREAS the International Tribunal for the
Prosecution of Persons Responsible
- for Serious Violations of International Humanitarian
Law Committed in the
- Territory of the Former Yugoslavia since 1991 was
established by the UN
- Security Council with "the power to prosecute persons
responsible for serious
- violations of international humanitarian law
committed in the territory of the
- former Yugoslavia since 1991 in accordance with the
provisions of" its Statute
- (Article 1);
-
- AND WHEREAS by Article 2 of the said Statute, the
Tribunal has the power "to
- prosecute persons committing or ordering to be
committed grave breaches of the
- Geneva Conventions of 12 August 1949, namely the
following acts against persons
- or property protected under the provisions of the
relevant Geneva Convention
- including the following:
-
- (a) wilful killing;
- (c) wilfully causing great suffering or serious
injury to body or health;
- (d) extensive destruction and appropriation of
property, not justified by military necessity
- and carried out unlawfully and wantonly.
- AND WHEREAS by Article 3 of the said Statute,
the International Tribunal shall
- have the power to prosecute persons violating the
laws or customs of war. Such
- violations shall include, but not be limited to:
-
- (a) employment of poisonous weapons or other weapons
to cause unnecessary
- suffering;
- (b) wanton destruction of cities, towns or villages,
or devastation not
- justified by military necessity;
- (c) attack, or bombardment, by whatever means, of
undefended towns, villages,
- dwellings, or buildings;
- (d) seizure of, destruction or wilful damage done to
institutions dedicated to
- religion, charity and education, the arts and
sciences, historic monuments and works of art
- and science.
-
- AND WHEREAS by Article 6 of the said Statute "the
International Tribunal shall
- have jurisdiction over natural persons pursuant to
the provisions of the
- present Statute;"
-
- AND WHEREAS Article 7 of the said Statute provides
for individual criminal
- responsibility thus:
- 1. A person who planned, instigated, ordered,
committed or otherwise aided and
- abetted in the planning, preparation or execution of
a crime referred to in
- articles 2 to 5 of the present Statute, shall be
individually responsible for
- the crime.
- 2. The official position of any accused person,
whether as Head of State
- or Government or as a responsible Government
official, shall not relieve such person of criminal
- responsibility or mitigate punishment.
- 3. The fact that any of the acts referred to in
articles 2 to 5 of the present
- Statute was committed by a subordinate does not
relieve his superior of
- criminal responsibility if he knew or had reason to
know that the subordinate
- was 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 thereof.
- 4. The fact that an accused person acted pursuant to
an order of a Government
- or of a superior shall not relieve him of criminal
responsibility, but may be
- considered in mitigation of punishment if the
International Tribunal determines
- that justice so requires.
-
- AND WHEREAS Article 8 of the said Statute provides
that the territorial and
- temporal jurisdiction of the Tribunal shall
extend to the territory of the
- former Socialist Federal Republic of Yugoslavia,
including its land surface,
- airspace and territorial waters. The temporal
jurisdiction of the International
- Tribunal shall extend to a period beginning on 1
January 1991;
-
- AND WHEREAS by Article 9 of the said Statute
the International Tribunal and
- national courts shall have concurrent jurisdiction to
prosecute persons for
- serious violations of international humanitarian law
committed in the territory
- of the former Yugoslavia since 1 January 1991
but the International Tribunal
- shall have primacy over national
courts;
-
- AND WHEREAS Article 18 of the said Statute provides
inter alia that:
-
- 1. The Prosecutor shall initiate investigations
ex-officio or on the basis of
- information obtained from any source, particularly
from Governments, United
- Nations organs, intergovernmental and
non-governmental organizations. The
- Prosecutor shall assess the information received or
obtained and decide whether
- there is sufficient basis to proceed.
- 2. The Prosecutor shall have the power to question
suspects, victims and
- witnesses, to collect evidence and to conduct on-site
investigations. In
- carrying out these tasks, the Prosecutor may, as
appropriate, seek the
- assistance of the State authorities concerned.
- 4. Upon a determination that a prima facie case
exists, the Prosecutor shall
- prepare an indictment containing a concise statement
of the facts and the crime
- or crimes with which the accused is charged under the
Statute. The indictment
- shall be transmitted to a judge of the Trial
Chamber.
-
- AND WHEREAS the President of the Tribunal, Judge
Gabrielle Kirk McDonald, in a
- press release of April 8, 1999, urged that:
- All States and organisations in possession of
information pertaining to the
- alleged commission of crimes within the jurisdiction
of the Tribunal should
- make such information available without delay to the
Prosecutor.
-
- AND WHEREAS on April 30 in Geneva the United Nations
High Commissioner for
- Human Rights Mary Robinson in a speech to the
Commission cited a letter from the
- Prosecutor in which the Prosecutor stated:
-
- The actions of individuals belonging to Serb forces,
the Kosovo Liberation Army
- (KLA), or NATO may come under scrutiny, if it appears
that serious violations
- of international humanitarian law have occurred.
-
- AND WHEREAS High Commissioner Robinson also stated in
her speech:
- In the NATO bombing of the Federal Republic of
Yugoslavia, large numbers of
- civilians have incontestably been killed, civilian
installations targeted on
- the grounds that they are or could be of military
application and NATO remains
- sole judge of what is or is not acceptable to bombıIn
this situation, the
- principle of proportionality must be adhered to by
those carrying out the
- bombing campaign. It surely must be right to ask
those carrying out the bombing
- campaign to weigh the consequences of their campaign
for civilians in the
- Federal Republic of Yugoslavia.
-
- AND WHEREAS NATO has carried out between 5,000 and
10,000 bombing missions over
- the territories of the former Yugoslavia since March
24, 1999;
-
- AND WHEREAS NATO leaders have openly admitted
targeting civilian infrastructure
- as well as military targets;
-
- AND WHEREAS the list of targets has included fuel
depots, oil refineries,
- government offices, power stations and communications
links, such as roads,
- tunnels, bridges and railway links, including those
not inside the region of,
- or in the vicinity of, Kosovo;
-
- AND WHEREAS in addition to these deliberate attacks
on civilian infrastructure
- and objects, there have been a great number of
attacks which have caused direct
- physical harm and death to civilians;
-
- AND WHEREAS it appears that these bombing missions
have directly caused the
- death of approximately 1,000 civilian men, women and
children and serious
- injury to 4,500 more;
-
- AND WHEREAS instances of this nature include the 12
April bombing of a train
- travelling from Belgrade to Ristovac as it crossed
the bridge spanning the
- Yuzhna Morava river at the Grdelica gorge, killing at
least 10 passengers and
- wounding 16; the 15 April bombing of a refugee convoy
in four separate
- locations along a 12 mile stretch of the road that
runs from Prizren to
- Djakovica, killing approximately 74 people; the 23
April bombing of Serbian
- Television editorial offices, killing approximately
15 people; the 27 April
- bombing of a residential district in Surdulica,
killing 16 people including 12
- children; and the May 1 bombing of a bus on the Luzan
bridge in Kosovo killing
- at least 34 people including 15 children;
-
- AND WHEREAS, though the above-named NATO leaders have
claimed that these
- incidents were accidents, they have also admitted
that they were an inevitable
- result of their bombing strategy, a strategy which
they appear to have
- continued unmodified and even to have intensified
throughout these incidents;
-
- AND WHEREAS there is ample evidence in the public
statements of NATO leaders
- that these attacks on civilian targets are part of a
deliberate attempt to
- terrorize the population to turn it against its
leadership;
-
- AND WHEREAS the NATO bombing has done an estimated
$100 billion dollars in
- property damage and completely destroyed or seriously
damaged dozens of
- bridges, railways and railway stations, major roads,
airports, including
- civilian airports, hospitals and health care centres,
television transmitters,
- medieval monasteries and religious shrines,
cultural-historical monuments and
- museums, hundreds of schools, faculties and
facilities for students and
- children, thousands of dwellings and civilian
industrial and agricultural
- facilities;
-
- AND WHEREAS refineries and warehouses storing liquid
raw materials and
- chemicals have been hit causing environmental
contamination and exposing the civilian
- population to the emission of poisonous gases;
-
- AND WHEREAS the NATO bombings have also made use of
weapons banned by
- international convention, including cruise missiles
utilizing depleted uranium
- highly toxic to human beings;
-
- AND WHEREAS credible detailed reports of the civilian
death and destruction
- inflicted by the NATO bombing are attached as an
Annex to this Notice;
-
- AND WHEREAS THEREFORE there is abundant evidence that
many instances of serious
- violations of international humanitarian law within
the jurisdiction of the
- Tribunal have been committed by NATO forces in the
attack on Yugoslavia
- commencing March 24 and continuing to this day;
-
- AND WHEREAS this evidence is readily available to the
Prosecutor in eyewitness,
- videotaped, televised and publicly broadcast reports,
in press reports and on
- the Internet, and in the evidence presented by the
Federal Republic of
- Yugoslavia in its current complaint against the NATO
countries before the
- International Court of Justice;
-
- AND WHEREAS all of the above-named persons, Heads of
State and Government
- of the 19 NATO countries, their Foreign Ministers and
Ministers of Defence, and
- officials and military leaders of NATO, have admitted
publicly to having agreed
- upon and ordered these actions, being fully aware of
their nature and effects;
-
- AND WHEREAS the above-named persons have acted in
open violation of the United
- Nations Charter, which provides in so far as is
relevant:
-
- Article 2
- 3. All Members shall settle their international
disputes by peaceful means in
- such a manner that international peace and security,
and justice, are not
- endangered.
- 4. All Members shall refrain in their international
relations from the threat
- or use of force against the territorial integrity or
political independence of
- any state, or in any other manner inconsistent with
the Purposes of the United
- Nations.
-
- Article 33
- 1. The parties to any dispute, the continuance of
which is likely to endanger
- the maintenance of international peace and security,
shall, first of all, seek
- a solution by negotiation, enquiry, mediation,
conciliation, arbitration,
- judicial settlement, resort to regional agencies or
arrangements, or other
- peaceful means of their own choice.
-
- Article 37
- 1. Should the parties to a dispute of the nature
referred to in Article 33 fail
- to settle it by the means indicated in that Article,
they shall refer it to the
- Security Council.
- 2. If the Security Council deems that the continuance
of the dispute is in fact
- likely to endanger the maintenance of international
peace and security, it
- shall decide whether to take action under Article 36
or to recommend such terms
- of settlement as it may consider appropriate.
-
- Article 39
- The Security Council shall determine the existence of
any threat to the peace,
- breach of the peace, or act of aggression and shall
make recommendations, or
- decide what measures shall be taken in accordance
with Articles 41 and 42, to
- maintain or restore international peace and
security.
-
- Article 41
- The Security Council may decide what measures not
involving the use of armed
- force are to be employed to give effect to its
decisions, and it may call upon
- the Members of the United Nations to apply such
measures. These may include
- complete or partial interruption of economic
relations and of rail, sea, air,
- postal, telegraphic, radio, and other means of
communication, and the severance
- of diplomatic relations.
-
- Article 42
- Should the Security Council consider that measures
provided for in Article 41
- would be inadequate or have proved to be inadequate,
it may take such action by
- air, sea, or land forces as may be necessary to
maintain or restore
- international peace and security. Such action may
include demonstrations,
- blockade, and other operations by air, sea, or land
forces of Members of the
- United Nations.
-
- Article 51
- Nothing in the present Charter shall impair the
inherent right of individual or
- collective self-defence if an armed attack occurs
against a Member of the
- United Nations, until the Security Council has taken
measures necessary to
- maintain international peace and security. Measures
taken by Members in the
- exercise of this right of self-defence shall be
immediately reported to the
- Security Council and shall not in any way affect the
authority and
- responsibility of the Security Council under the
present Charter to take at any
- time such action as it deems necessary in order to
maintain or restore
- international peace and security;
-
- AND WHEREAS the International Court of Justice has
stated in ruling against
- United States intervention in Nicaragua:
- In any event, while the United States might form its
own appraisal of the
- situation as to respect for human rights in
Nicaragua, the use of force could
- not be the appropriate method to monitor or ensure
such respect. With regard to
- the steps actually taken, the protection of human
rights, a strictly
- humanitarian objective, cannot be compatible with de
mining of ports, the
- destruction of oil installations, or again with de
training, arming and
- equipping of the contras.
-
- (CASE CONCERNING THE MILITARY AND PARAMILITARY
ACTIVITIES IN AND AGAINST NICARAGUA (NICARAGUA v. UNITED
STATES OF AMERICA) (MERITS) Judgment of 27 June, 1986,
I.C.J. Reports, 1986, p.134-135, paragraphs 267 and
268)
- AND WHEREAS the above-named persons, Heads of State
and Government of the 19
- NATO countries, their Foreign Ministers and Ministers
of Defence, and officials
- and military leaders of NATO have acted in open
violation of the NATO Treaty
- which provides in so far as is relevant:
-
- Article 1
- The Parties undertake, as set forth in the Charter of
the United Nations, to
- settle any international dispute in which they may be
involved by peaceful
- means in such a manner that international peace and
security and justice are
- not endangered, and to refrain in their international
relations from the threat
- or use of force in any manner inconsistent with the
purposes of the United
- Nations.
-
- Article 7
- This Treaty does not affect, and shall not be
interpreted as affecting in any
- way the rights and obligations under the Charter of
the Parties which are
- members of the United Nations, or the primary
responsibility of the Security
- Council for the maintenance of international peace
and security;
-
- AND WHEREAS the above-named persons have acted in
open violation of the
- Protocol Additional to the Geneva Conventions of 12
August 1949, and relating to the
- Protection of Victims of International Armed
Conflicts (Protocol I), 8 June
- 1977, which provides as follows:
-
- Art 51. Protection of the civilian population
- 1. The civilian population and individual civilians
shall enjoy general
- protection against dangers arising from military
operations. To give effect to
- this protection, the following rules, which are
additional to other applicable
- rules of international law, shall be observed in all
circumstances.
-
- 2. The civilian population as such, as well as
individual civilians, shall not
- be the object of attack. Acts or threats of violence
the primary purpose of
- which is to spread terror among the civilian
population are prohibited.
-
- 3. Civilians shall enjoy the protection afforded by
this section, unless and
- for such time as they take a direct part in
hostilities.
-
- 4. Indiscriminate attacks are prohibited.
Indiscriminate attacks are:
- (a) those which are not directed at a specific
military objective;
- (b) those which employ a method or means of combat
which cannot be directed at
- a specific military objective; or
- (c) those which employ a method or means of combat
the effects of which cannot
- be limited as required by this Protocol;
-
- and consequently, in each such case, are of a nature
to strike military
- objectives and civilians or civilian objects without
distinction.
-
- 5. Among others, the following types of attacks are
to be considered as
- indiscriminate:
-
- (a) an attack by bombardment by any methods or means
which treats as a single
- military objective a number of clearly separated and
distinct military
- objectives located in a city, town, village or other
area containing a similar
- concentration of civilians or civilian objects;
-
- and
-
- (b) an attack which may be expected to cause
incidental loss of civilian life,
- injury to civilians, damage to civilian objects, or a
combination thereof,
- which would be excessive in relation to the concrete
and direct military
- advantage anticipated.
-
- Art 79. Measures or protection for journalists
- 1. Journalists engaged in dangerous professional
missions in areas of armed
- conflict shall be considered as civilians within the
meaning of Article 50,
- paragraph 1.
-
- Article 85 - Repression of breaches of this
Protocol
- 3. In addition to the grave breaches defined in
Article 11, the following acts
- shall be regarded as grave breaches of this Protocol,
when committed wilfully,
- in violation of the relevant provisions of this
Protocol, and causing death or
- serious injury to body or health:
- (a) making the civilian population or individual
civilians the object of
- attack;
- (b) launching an indiscriminate attack affecting the
civilian population or
- civilian objects in the knowledge that such attack
will cause excessive loss of
- life, injury to civilians or damage to civilian
objects, as defined in Article
- 57, paragraph 2 (a)(iii);
-
- 5. Without prejudice to the application of the
Conventions and of this
- Protocol, grave breaches of these instruments shall
be regarded as war crimes.
- AND WHEREAS the above-named persons have acted in
open violation of the
- Principles of International Law Recognized in the
Charter of the Nüremberg
- Tribunal and in the Judgment of the Tribunal, as
adopted by the General
- Assembly of the united Nations (1950), which provide
in so far as is
- relevant:
-
- Principle III
- The fact that a person who committed an act which
constitutes a crime under
- international law acted as Head of State or
responsible Government official
- does not relieve him from responsibility under
international law.
-
- Principle IV
- The fact that a person acted pursuant to order of his
Government or of a
- superior does not relieve him from responsibility
under international law,
- provided a moral choice was in fact possible to
him.
-
- Principle VI
- The crimes hereinafter set out are punishable as
crimes under international
- law:
- (a) Crimes against peace:
- (i) Planning, preparation, initiation or waging of a
war of aggression or a war
- in violation of international treaties, agreements or
assurances;
- (ii) Participation in a common plan or conspiracy for
the accomplishment of any
- of the acts mentioned under (i).
- (b) War crimes:
- Violations of the laws or customs of war include, but
are not limited to,
- murder wanton destruction of cities, towns, or
villages, or devastation not
- justified by military necessity.
-
- Principle VII
- Complicity in the commission of a crime against
peace, a war crime, or a crime
- against humanity as set forth in Principle VI is a
crime under international
- law;
-
- THEREFORE we respectfully request that the
Prosecutor immediately investigate
- and indict for serious crimes against
international humanitarian law:
-
- THE FOLLOWING HEADS OF STATE AND GOVERNMENT,
MINISTERS OF FOREIGN AFFAIRS AN MINISTERS OF DEFENCE OF
THE NATO COUNTRIES:
- William J. Clinton, Madeleine Albright, William S.
Cohen (United States of America), Tony Blair, Robin Cook,
George Robertson (United Kingdom), Jean Chrétien,
Lloyd Axworthy, Arthur
- Eggleton (Canada), Jean-Luc Dehaene, E. Derycke,
J.-P. Poncelet (Belgium),
- Vaclav Havel, J. Kavan, V. Vetchy (Czech Republic),
Poul Nyrup Rasmussen, N.H.
- Petersen, H. Haekkerup (Denmark), Jacques Chirac,
Lionel Jospin, H. Védrine,
- Alain Richard (France), Gerhard Schröder, J.
Fischer, R. Scharping (Germany),
- Kostas Simitis, G. Papandreou, A. Tsohatzopoulos
(Greece), Viktor Orban, J.
- Martonyi, J. Szabo (Hungary), David Oddsson, H.
Asgrimsson, G. Palsson
- (Iceland), Massimo D'Alema, L. Dini, C. Scognamiglio
(Italy), Jean-Claude
- Juncker, J. Poos, Alex Bodry (Luxembourg), Willem
Kok, J. van Aartsen, F.H.G.
- de Grave (Netherlands), Kjell Magne Bondevik, K.
Vollebæk, D.J. Fjærvoll
- (Norway), Jerzy Buzek, B. Geremek, J. Onyszkiewicz
(Poland), Antonio Manuel de
- Oliveira Guterres, J.J. Matos da Gama, V.
Simão (Portugal), Jose Maria Aznar,
- A. Matutes, E. Serra Rexach (Spain), Bulent Ecevit,
I. Cem and H. S. Turk
- (Turkey);
-
- AND THE FOLLOWING OFFICIALS AND MILITARY LEADERS OF
NATO:
- Javier Solana, Jamie Shea, Wesley K. Clark, Harold W.
German, Konrad Freytag, D.J.G. Wilby, Fabrizio Maltinti,
Giuseppe Marani and Daniel P. Leaf;
-
- AND WHOEVER ELSE shall be determined by the
Prosecutor's investigations to have
- committed crimes in the NATO attack on Yugoslavia
commencing March 24, 1999.
-
- Respectfully submitted, this 6th day of May,
1999__________________________
-
- Michael Mandel
- (Professor)
- for
- W. Neil Brooks
- Judith A. Fudge
- H. J. Glasbeek
- Reuben A. Hasson
- (Professors)
- Sil Salvaterra
- David Jacobs
- Brian Shell
- Christopher Black
- John Philpot
- Fred Stasiuk
- (Barristers and Solicitors)
- Peter Rosenthal
- (Professor, Barrister and Solicitor)
- Roberto Bergalli (Professor)
- Alejandro Teitelbaum
- Alvaro Ramirez Gonzalez
- Vanessa Ramos
- Beinusz Szmukler
- (American Association of Jurists)
-
-
-
- ANNEX:
-
- CIVILIAN DEATH AND DESTRUCTION IN THE FORMER
YUGOSLAVIA
-
- The following are two reports from Ministry of
Foreign Affairs of the Federal
- Republic of Yugoslavia (a designated source of
information under Article 18.1
- of the Stature of the Tribunal):
-
- 1) NATO Crimes Against Civilians and Civilian
- Infrastructure in the Federal Republic of Yugoslavia
(MINISTRY OF FOREIGN
- AFFAIRS YUGOSLAV DAILY SURVEY -
- www.mfa.gov.yu/Bilteni/Engleski/si290499_1-e.html);
and
- 2) Civilian Victims and
- Devastation in NATO Aggression on Yugoslavia
(SERBIAINFO -
- www.serbia-info.com/news/1999-04/23/11210.html)
-
- NATO CRIMES AGAINST CIVILIANS AND CIVILIAN
INFRASTRUCTURE IN THE FEDERAL REPUBLIC OF YUGOSLAVIA
(April 29, 1999)
-
-
- The NATO criminal aggression represents the most
flagrant violation
- of the Charter of the United Nations since the
inception of the
- world Organization, a violation of the Helsinki Final
Act and the
- undermining of the very foundations of the
international legal
- order. At the same time, this aggression is a crime
against peace,
- stability and humanity.
-
- The Federal Republic of Yugoslavia has warned on time
the
- United Nations Security Council of a possible
aggression, and during the
- aggression itself it requested that it be immediately
halted and
- most strongly condemned. Had this legitimate request
of the Federal
- Republic of Yugoslavia been met, enormous human
sufferings and
- destruction would have been avoided. The most
illustrative examples
- are given below.
-
-
- KILLING AND PLIGHT OF THE CIVILIANS
-
- During the last thirty-six days of NATO aggression,
the Federal
- Republic of Yugoslavia has been exposed to extensive
civilian
- destruction, unprecedented in modern history of the
world. NATO
- aggressors have focused their attacks primarily on
civiliantargets,
- directly threatening the lives and fundamental human
rights of the
- entire population of the Federal Republic of
Yugoslavia. By bombing
- relentlessly the cities, towns and villages
throughout Yugoslavia,
- the NATO aggressor has killed so far, in nine hundred
attacks, more
- than a thousand civilians, including a great number
of children.
- Over five thousand people sustained injuries, many of
whom will
- remain crippled for life. At the same time, several
thousand private
- homes and flats have been ruined, mostly in Belgrade,
Nis, Cuprija,
- Aleksinac, Pristina, etc. We shall present the most
tragic instances
- of the killings and plight of the innocent civilian
population.
- Fifty-five passengers were killed and twenty-six
injured in an
- international passenger train on the
Belgrade-Thessaloniki line.
- More than four hundred civilians were killed by NATO
bombs in
- Kosmet: in the centre of Pristina, in Djakovica,
Prizren, Kosovo
- Polje, Urosevac, Kosovska Mitrovica, in refugee camps
in Orahovac
- and Srbica, Vitina, etc.
-
- Thirteen civilians were killed and twenty-five
wounded in an attack on Kursumlija.
- Twelve civilians were killed and forty wounded in the
bombing of Aleksinac.
- Sixteen RTS workers were killed and seventeen wounded
in the bombing of the
- headquarters of this biggest adio and Television
outlets in
- the FRY. Unfortunately, the final number of victims
has not been
- established yet since more victims have remained
buried in the rubble.
-
- In Pancevo, Cacak, Vranje and Nis the number of
casualties has been
- increasing each day.
-
- KILLING OF CHILDREN
-
- Children are the most vulnerable category of the
population,
- innocent and defenceless which suffer in particular
due to the
- barbaric bombing of NATO aircraft, which is
illustrated by the
- following examples:
-
- The killing of seven children in Srbica from cluster
bombs;
- The killing of five children from the Kodza family in
the village
- of Doganovici near Urosevac on 24 April 1999 as a
result of the
- delayed effect of bombs (Edon, aged 3, Fisnik, aged
9, Osman, aged 13,
- Burim, aged 14 and Vajdet, aged 15. Six other
children were also
- injured in the same incident, two of them were
seriously wounded.
-
- The killing of a three-year old Milica Rakic in the
Belgrade
- suburb of Batajnica;
- The killing of six children in the refugee centre in
Djakovica and
- 19 children in the refugee column on the
Prizren-Djakovica road;
-
- The death of a child in Kosovo Polje;
- The killing of five years old girl Arta Lugic while
her brothers
- Neron and Egzon and her sister Arijeta were seriously
wounded in
- Lipljane;
-
- The killing of nine children in Kursumlija;
- The killing of two children in Aleksinac, as well as
other numerous examples.
-
- Children are most often victims of the sprinkle
cluster bombs
- with delayed effect. The death toll on children would
have been even
- more tragic, had the missile struck the biggest
Maternity Hospital in
- Belgrade (It exploded some thirty metres away from
the Hospital).
-
-
- KILLING AND PLIGHT OF REFUGEES
-
- Particularly tragic is the fate of refugees, who
convinced that
- they should not believe the propaganda ploys on the
alleged "ethnic
- cleansing" decided to return to their homes.
Legitimate authorities
- of the FRY encourage them every day to do so and
guarantee their
- safety. On the occasion of a return of a large group
of refugees,
- on 14 April, on the Djakovica-Prizren road, NATO
aircraft killed 75
- citizens of the FRY and wounded 111. The attack of
NATO aircraft
- was systematically prepared and lasted for three
hours. In this way,
- NATO has in the most brutal way "demonstrated" that
the story of
- "humanitarian catastrophe" suits it only if it fits
in the
- legitimate aggression on the FRY, as well as that
innocent
- civilians are constantly taken advantage of for NATO
interests in the
- Balkans.
-
- In addition, NATO bombed several refugee camps in
which Serbs
- expelled from Croatia and Bosnia and Herzegovina were
accommodated
- (Djakovica, Pristina, Kursumlija, etc). Several
dozens of refugees
- were killed, mostly children and the frail,
ruthlessly ending their
- tragedy which came about in the wake of the break-up
of Yugoslavia.
-
-
- BOMBING OF SURDULICA
-
- The aggressors war planes bombed at noon, on 27 April
1999, the
- residential area of the town of Surdulica. On that
occasion 16
- citizens were killed (including 12 children), while
several dozen
- were wounded out of which twenty persons remained in
hospital for
- further medical treatment. Hundreds of houses were
raised to the
- ground or damaged. Special teams are still clearing
up the debris
- so that it is not possible at the moment to estimate
the real
- proportions of this notorious crime.
-
-
- ASSASSINATION ATTEMPT ON PRESIDENT OF THE
FEDERAL
- REPUBLIC OF YUGOSLAVIA SLOBODAN MILOSEVIC
-
- An assassination attempt on the President of the
Federal Republic of
- Yugoslavia on 22 April 1999 represents an organised
terrorist act
- without precedent in the history of modern Europe.
This is not only
- a crime against a Head of a sovereign State, but
primarily an
- attack on the democratically expressed will of a
people and thus against
- the foundations of the democratic values of the
civilisation.
- Although the residence of the President of the
Federal Republic of
- Yugoslavia was targeted, this attack has also a
symbolic meaning as
- if the targets had been the homes of all Yugoslav
citizens. This
- crime has caused abhorrence and condemnation by
international
- public. However, it is incomprehensible that the
United Nations
- Security Council has remained silent and failed to
condemn this
- terrorist act or the killings of civilians and
children.
-
-
- CRIME AGAINST THE FREEDOM OF SPEECH
-
- The destruction of more than ten private radio and
television
- stations, two dozen TV transmitters, as well as the
bombing of the
- Radio and Television of Serbia building on 23 April
1999 represents
- the biggest aggression against freedom of thought and
a disgrace to
- the civilization at the threshold of a third
millennium.
- Transmitters at Iriski venac, Krnjaca, Mt Cer,
Bukulja, Tornik,
- rnivrh, Jasetrebac, Ovcar, Grmija and others were
destroyed, so that
- the transmitter infrastructure at the entire
territory of Serbia
- was severely damaged. Two times in six days the
studios and transmitter
- located at the business centre "Usce" which housed TV
stations: BK
- TV, Pink, Kosava and SOS Channel, as well as several
other radio
- stations were bombed.
-
- Transmitter of the TV station Palma was bombed and
destroyed on 28
- April 1999.
-
- The satellite station "Yugoslavia" in the village of
Prilike near
- Ivanjica was severely damaged.
-
-
- BOMBING OF THE BUILDING OF THE RADIO AND
- TELEVISION OF SERBIA
-
- The building was demolished taking a heavy toll
during the bombing
- of the largest Radio and TV company in the Balkans
with 7000 employees
- and the state-of-the-art infrastructurewhich was made
available to hundreds
- of foreign correspondence.
- The aim of this crime, in which 16 RTS workers were
killed and 19
- wounded, was more than obvious: to suppress the right
to a
- different opinion and its being publicly expressed
with a view to pursuing
- further war-mongering manipulation with the world
public. Clearly,
- the intention of NATO aggressors is to prevent the
world public
- from learning the extensive scope of their crimes and
to impose on the
- world their totalitarian and single-minded
perception. Many
- newspapers in the world and renowned journalists have
already
- raised their voice against the propaganda
fabrications of the NATO
- aggressors.
-
- For all champions of the freedom of speech and for
all
- people committed to the right to freedom of
expression, this destructive
- act represents the last warning alarm before NATO
generals take
- control over the aggressors' media.
-
-
- DESTRUCTION OF VITAL YUGOSLAV ECONOMIC
FACILITIES
- According to the assessment of experts from Western
countries, the
- damage done to date by NATO air strikes is well in
excess of one
- hundred billion US dollars. By the destruction of
factories,
- business capacities and production facilities, more
than half a
- million people have lost their jobs and over two
million of them
- remained without any kind of income. Destroyed are
the industrial
- complexes in Belgrade, Novi Sad, Kragujevac, Nis,
Pancevo, Cacak,
- Kraljevo, Valjevo, Pristina, Vranje, Kursumlija,
Krusevac, Kula,
- Gnjilane, Sremska Mitrovica and in other towns and
cities.
- The petrochemical industry of the Federal Republic of
Yugoslavia
- has been totally destroyed, as well as the largest
Yugoslav factory of
- artificial fertilisers.
- Private entrepreneurs are a particular target of NATO
aggression
- and the most glaring example of it is the destruction
of the "Usce"
- business centre in Novi Beograd which was hit on 21
and 27 April
- 1999. That was one of the biggest business centres in
the Balkans,
- which housed more than a hundred newly established
private firms in
- full business expansion, foreign representative
offices, seven
- private Radio and TV stations and one of the most
modern
- poli-clinics in the FRY. The building of this
business centre is
- also one of the landmarks of modern Belgrade.
-
-
- DESTRUCTION OF BRIDGES
-
- On the false pretext of "neutralizing the military
power of the
- Federal Republic of Yugoslavia", the NATO aggressor
started
- systematic destruction of the major Yugoslav road and
rail traffic
- routes. About 20 bridges have been totally demolished
so far and a
- few dozen of them have been damaged. Also, several
dozen major and
- local roads, airports, railway tracks, railway
stations, etc. have
- been destroyed. All ruined facilities were part of
costly capital
- investments, into which the resources and the efforts
of several
- generations of Yugoslav citizens were pooled. All the
facilities
- are strategic part of the European traffic
infrastructure, and some of
- them are of historical and cultural importance ("The
Wailing Bridge"
- in Novi Sad, on which the Fascists killed several
thousand Jews
- in the Second World War).
-
- About 30 bridges have been destroyed including those
at
- the strategic European E-75 corridor. By the
destruction of the bridges
- on the Danube river the aggressors have blocked the
entire river
- navigation at this traffic artery of the greatest
importance for
- European economy and the shortest link between the
Northern and
- Mediterranean sea (The Rhein-Mein-Danube route).
Thus, the European
- shipping companies suffer each day the damage of over
20 million
- DM.
-
- Examples: Sloboda Bridge, Wailing Bridge, Zezelj
Bridge and the
- bridge in Beska (all in the city of Novi Sad),
several bridges on
- the Ibar primary road and on the major railway
lines.
-
-
-
- ENVIRONMENTAL DISASTER
-
- Concurrently with the humanitarian, NATO strikes have
caused an
- environmental catastrophe which is endangering not
only the Federal
- Republic of Yugoslavia, but also the neighbouring
countries and the
- entire European continent. Ecology does not recognize
boundaries.
- The NATO aggressor is thus teetering on the brink of
another
- Chernobyl in the heart of Europe. The destruction of
petrochemical
- installations, the warehouses storing semi-processed
and finished
- products of the chemical industry have already caused
significant
- adverse effects on the health of the population of
the Federal
- Republic of Yugoslavia and the neighbouring
countries. During some
- of the air strikes it was pure luck that an
environmental
- catastrophe was not provoked spreading all over
Europe.
- The aggressor's attacks did not spare even huge
forests, tourist
- centres and the national parks on the mountains of
Serbia
- (Kopaonik, Zlatibor, Divcibare, Tara, Prokletije,
Sara, Fruska Gora). The
- ozone layer was depleted by the exhaust gases. The
Black Sea, Aegean and
- the Adriatic basins, practically the entire
Mediterranean, are
- threatened by environmental pollution.
- Examples: Nitrogen factory in Pancevo, the oil
refineries in
- Pancevo and Novi Sad, the chemical company "Prva
iskra" in Baric and others.
-
-
-
- HOSPITALS AND HEALTH INSTITUTIONS
-
- The aggressors' bombings, calculated to provoke the
greatest
- possible confusion and panic among innocent people,
have damaged
- many clinical and hospital centres, inflicting not
only great
- material damage to property (destruction of buildings
and expensive
- medical equipment), but also causing new health
problems and
- intensifying psychological traumas among the sick
people. The
- destruction of all the three bridges in Novi Sad
totally cut off
- and left, without the supply of water, the largest
Yugoslav centre for
- the treatment of cardiovascular diseases, to which
several million
- people gravitate. The Maternity Hospital in Belgrade,
and the
- biggest hospital in the Balkans (Military Medical
Academy Hospital
- VMA), and the Orthopaedic hospital of Banjica, the
hospitals in
- Cuprija and Aleksinac, as well as the medical centres
in Pristina
- and in many other towns were damaged.
-
-
-
- DESTRUCTION OF PRE-SCHOOL INSTITUTIONS, SCHOOLS
- AND UNIVERSITIES
-
- Since the outset of the aggression, NATO has put a
stop to the
- education of close to one million pupils and students
in
- Yugoslavia. Over three hundred facilities built for
the education and
- upbringing of children and young people of all ages
were destroyed. This will
- inevitably be reflected on the development and social
integration
- of young people. Hard hit are university centre in
Nis (Machine
- Engineering, Civil Engineering, Electronical,
Technical, Law and
- Economics faculties), in Pristina (Agricultural and
Machine
- Engineering faculty) and Novi Sad (Faculty of
Philosophy).
-
- DESTRUCTION OF WORLD CULTURAL HERITAGE
- ON THE SOIL OF THE FR OF YUGOSLAVIA
-
- Kosovo and Metohija in particular, but also the
entire territory of
- the FR of Yugoslavia, is a treasury of European
culture and
- civilization since ancient times. By violating all
international
- conventions on the protection of civilization and its
heritage, and
- in the pursuit of the spirit of aggressive nihilism
and new
- barbarity, more than 50 monasteries and churches have
been severely
- damaged thus far, as well as a couple of dozen of
other cultural
- and historic monuments, some under UNESCO protection.
Severe damage was
- caused to the monastery of the Patriarchate of Pec
(12th century),
- Zica (13th century), Decani and Gracanica (14th
century, under
- UNSECO protection), medieval towns of Zvecan (13th
century) and
- Smederevo (15th century), Petrovaradin fortress (18th
century),
- seventeen monasteries on Fruska Gora (15-18th
century) and many
- other priceless historical monuments. The bombs have
even destroyed
- many cemeteries all across Yugoslavia.
-
-
-
- USE OF PROHIBITED WEAPONS
-
- In NATO attacks, the state-of-the-art weapons have
been used, but
- also those prohibited under international
conventions, such as
- cluster bombs and slow activating bombs. In a
month-long attacks on
- civilian and other facilities in Serbia, NATO
aircraft fired more
- than 3,500 missiles, including 60 containers with
14,400 cluster
- bombs. As many as 3,600 cluster bombs were used in
the attacks
- against towns in Kosmet - Pristina, Urosevac,
Djakovica, Prizren
- etc, and many other places and facilities in Serbia.
Before the
- attacks, radio locators were dropped from the
aircraft, found in
- the vicinity of many civilian and business facilities
in Serbia.
-
-
- CO-ORDINATION BETWEEN NATO AND TERRORISTS OF THE
SO-CALLED "KLA"
-
- While before the onset of the aggression Albanian
terrorists
- counted on NATO aircraft as air support to their
armed groups, now arming,
- equipping and transport of Albanians living in the
USA and other
- western countries is under way, for actions in the
FRY, with a view
- to making armed formations from them to serve as
ground troops of
- the "Alliance". Albanian terrorists are being trained
and armed in
- the camps in northern Albania - in Tropoje, Kukes and
Bajram Curri
- (they are trained by British, US and Turkish
commandos), and then
- illegally infiltrated into Kosovo and Metohija. Such
activity, in
- direct violation of the resolutions of Security
Council, has been
- particularly stepped up in April when concrete plans
for ground
- invasion against the FRY started to be hatched. So
far, several
- hundred terrorists have been transported from the USA
to Albania.
- Plans are made to equip, arm and train for
coordinated actions with
- NATO, around 6,000 Albanians. According to western
sources,
- Albanian terrorists represent the main source of
intelligence for NATO, of
- military character or those aimed at spreading
propaganda against
- our country.
-
- At the moment it is difficult to perceive and
evaluate all the
- humanitarian, economic, environmental, health and
other consequences
- of the NATO criminal aggression against the FR of
Yugoslavia. The
- greatest victim of the aggression is the entire
Yugoslav people and
- its material and cultural resources. At the same
time, the
- violation of the Charter of the United Nations, the
NATO has created a
- precedent which may a cast a shadow over the future
of all peoples
- and sovereign States. The cause for concern is all
the grater
- because, by combining pressure and promises, NATO is
drawing an
- increasing number of countries into its aggression
against the FR
- of Yugoslavia, which will have long-term negative
consequences on the
- future relations and co-operation between all
Southeast European
- countries. Attempts by NATO to justify its brutal
aggression by an
- alleged care for the refugees may bring about an
irreversible
- degradation of the United Nations and involve this
highest
- international forum in the crime against a country
which is one of
- its founding members.
-
-
-
-
- CIVILIAN VICTIMS AND DEVASTATION IN NATO
AGGRESSION
ON YUGOSLAVIA (April 23,1999)
-
- OVERVIEW OF DESTRUCTION OF CIVILIAN TARGETS ON THE
TERRITORY OF THE FEDERAL
- REPUBLIC OF YUGOSLAVIA AS A RESULT OF BARBARIC AND
CRIMINAL AGGRESSION BY NATO, FROM 24 MARCH TO 19 APRIL
1999
-
- CIVILIAN CASUALTIES
-
- From the onset of NATO aggression against our country
up to 19 April 1999, the
- North Atlantic Alliance made over 7,000 criminal
attacks against the territory
- of the Federal Republic of Yugoslavia. 700 warplanes,
of which 530 combat
- planes, were used; more than 2000 cruise missiles
were launched and over 6,000
- tons of explosives were dropped.
- About 500 civilians were killed and more than 4,000
sustained
- serious injuries e.g.: in Kursumlija: 13 dead and 25
wounded;
- in Pancevo: 2 dead and 4 wounded;
- in Cacak: one dead and 7 wounded;
- in Kragujevac: over 120 workers were wounded during
an attack on the car
- factory "Zastava";
- in Vranje: two dead and 23 wounded;
- in Aleksinac: 12 dead and more than 40 wounded;
- in Nagavac village, Orahovac municipality: 11 dead
and 5 wounded;
- in Pristina: 10 dead and 8 wounded;
- Grdelicka gorge: 55 killed and 16 wounded;
- attack on two refugee columns, with four cruise
missiles, on the
- Djakovica-Prizren road: 75 killed and 100 wounded, of
whom 26 critically;
- in the village of Srbica: 10 killed, among whom 7
children;
- Belgrade suburb of Batajnica: a three year old girl
was killed,and
- five civilians wounded.
-
-
- Three million children are endangered in our country
as a result of war and
- bombardment by NATO criminals.
- After these barbarian attacks hundreds of thousands
citizens have
- been exposed to poisonous gasses which can have a
lasting
- consequences on the health of the entire population
and the
- environment.
- After the demolition of the Petrovaradin bridge, Novi
Sad and
- Petrovaradin were cut of water supply (600 000
citizens) since the
- main and city pipeline was constructed into the
bridge. About one
- million citizens in our country are short of water
supply due to the
- bombardment of NATO aggressors.
-
-
- About 500 000 workers became jobless due to the total
destruction of industrial
- facilities all around the country. Two million
citizens have no means for
- living and cannot ensure the minimum for
existence.
-
- Overall material damage is enormous. Preliminary
estimates indicate that
- barbaric air strikes of the neo-fascist NATO
alliance, since the beginning of
- the unprovoked aggression on the SR of Yugoslavia,on
industrial, commercial and
- civil facilities and structures throughout our
peace-loving country, have
- incurred damages in excess of 10 billion dollars. In
the territory of the
- northern province of Vojvodine alone, damages have
been estimated in excess of
- 3,5 billion dollars.
-
-
- TRAFFIC
-
- The road and railway networks, especially road and
rail bridges,
- most of which were destroyed or damaged beyond
repair, suffered
- extensive destruction. The targets of attacks were
such
- communications as:
-
- 1. BRIDGES (11 DESTROYED AND 13 DAMAGED):
-
- 1.The Varadin Bridge over the Danube was destroyed
(on 1 April
- 1999);
- 2.The "Sloboda" (Freedom) Bridge over the Danube was
destroyed (on 4 April
- 1999);
- 3.The "Mladosti" (Youth) Bridge over the Danube,
connecting Backa
- Palanka with Ilok, was damaged (on 4 April
1999);
- 4.The new railway bridge over the Danube connecting
Bogojevo and
- Erdut was damaged (on 5 April 1999);
- 5.The road bridge over the Danube, connecting
Bogojevo with Erdut
- was damaged (on 5 April 1999);
- 6.The bridge over the Danube along the Beograd-Novi
Sad road, near
- Beska, Indjija municipality, was damaged (on 1 April
1999);
- 7.The road bridge along the Magura Belacevac road, 15
kilometres
- from Pristina, suffered extensive damage;
- 8.The "Zezeljov" Bridge in Novi Sad was damaged (on 5
April 1999);
- 9.The bridge over the Ibar river, Biljanovac
municipality, was
- damaged (on 5 - 13 April 1999);
- 10.The bridge over the Vrbacka river near Jezgrovic
was destroyed
- (on 5 April 1999);
- 11.The "Lozno" railway bridge near Usce was destroyed
(on 5 April
- 1999);
- 12.The road bridge on the road leading to Brvenik,
near Usce, was
- destroyed (on 5 April 1999);
- 13.The bridge along the Nis-Pristina primary road,
near Kursumlija,suffered
- extensive damage (on 5 April 1999);
- 14.The bridge near Zubin Potok was destroyed (on 5
April 1999);
- 15.The Grdelica gorge railway bridge was damaged (on
12 April 1999);
- 16.The road bridge over the Kosanica river near
Kursumlija was
- damaged (on 13 April 1999);
- 17.The old bridge on the river Rasina in the town of
Krusevac (12-13 April
- 1999);
- 18.The Krusevac-Pojate bridge on the river Zapadna
Morava, at the
- village of Jasika, was destroyed (on 13 April
1999);
- 19.The railway bridge on the river Lim, between
Priboj and
- Prijepolje, near hydroelectric power station Bistrica
was destroyed(on 15 April
- 1999);
- 20.The road bridge on the river Toplica, on the
Nis-Pristina road
- near the town of Kursumlija, was heavily damaged (14
and 19 April
- 1999);
- 21.The bridge on the river Ibar, at the village of
Biljanovac near
- Raska, sustained heavy damages (15.04.1999.);
- 22.The bridge between Smederevo and Kovin has been
destroyed (16
- April 1999);
- 23.The railway bridge on the river Kostajnica, near
Kursumlija, has sustained
- heavy damages and is out of service
(18.04.1999.);
- 24.The bridge on the river Kosanica, at the village
of Selo Visoko,has
- sustained heavy damages and is out of service
(18.04.1999.);
-
- 2. RAILWAYS RAILWAY STATIONS (12):
-
- 1.The Kraljevo - Kosovo Polje rail, near Ibarska
Slatina;
- 2.The Belgrade - Bar rail, due to the destruction of
the railway
- track near the village of Strbce and destruction of
the bridge on
- the river Lim, between Priboj and Prijepolje;
- 3.The Kursumlija - Prokuplje rail, near Pepeljevac
village;
- 4.The Kraljevo - Kosovo Polje rail, near Ibarska
Slatina;
- 5.The Nis - Pristina rail, near Kursumlija;
- 6."Sarpelj" tunnel, near Jerinje village, 15 km north
of Leposavic
- towards Raska, was destroyed;
- 7.Railway station in Kraljevo (Bogutovac);
- 8.Railway station in Kosovo Polje;
- 9.The Belgrade - Thessaloniki rail, due to the
destruction of the
- bridge in the Grdelica gorge;
- 10.Railway station in the town of Biljanovac;
- 11.Railway track and overpass (Josinacka Banja) near
the town of
- Biljanovac;
- 12.Railway track Kursumlija - Podujevo, due to
damages on the
- railway bridge at Kursumlija;
-
-
- 3. ROADS AND TRANSPORTERS (6 MAJOR ROADS):
-
- 1.Ibarska primary road, due to damages to the bridge
on the Ibar
- river, Biljanovac municipality, and destruction of
the road between Pozega and
- Cacak;
- 2.Belgrade-Zagreb highway, near Stari Banovci;
- 3.Traffic suspended on the Kosovska
Mitrovica-Ribarici section of
- the Adriatic highway due to the destruction of the
bridge over the
- Vrbacka river;
- 4."Jedinstvo" bus station in Vranje sustained
extensive damage;
- 5."Kosmet Prevoz" transporter in Gnjilane (a hangar
full of new
- buses);
- 6.Kraljevo-Raska primary road;
- 7.Bus station in Pristina;
- 8.Traffic has been suspended on the Krusevac-Pojate
road due to the destruction
- of the bridge on the Zapadna Morava, in the village
of Jasika;
- 9.Traffic has been suspended on the Nis-Pristina
road, due to the
- fact that the bridge on the river Toplica, near the
town of
- Kursumlija, has sustained heavy damage;
-
- 4. AIRPORTS (7):
-
- "Slatina" in Pristina; "Batajnica" and "Surcin" in
Belgrade; Nis
- airport; "Ponikve" in Uzice; "Golubovac" in
Podgorica, "Ladjevci"
- airport near Kraljevo; agricultural and sports
airfield in Sombor.
-
-
- ECONOMIC AND CIVILIAN TARGETS, PUBLIC
INSTITUTIONS
-
- The air strikes have so far destroyed or damaged all
over the
- Federal Republic of Yugoslavia several thousand
economic facilities and
- dwellings. In the Leskovac region alone, over 3,500
industrial facilities and
- dwellings were either destroyed or damaged.
-
- The devastation of NATO forces was particularly
manifest in
- Pristina, Novi Sad, Aleksinac, Djakovica, Prokuplje,
Gracanica,
- Cuprija, etc. Housing blocks on the outskirts of
Belgrade - Kijevo
- Knecevac, Batajnica, Jakovo, Borca, as well as the
area around
- Pancevo, were under attack.
-
- 1. INDUSTRY AND TRADE:
-
- The NATO aggressor's attacks targeted the factories
and industrial
- facilities which directly cater for the needs of the
population,
- among which are:
-
- 1."Lola Utva" agricultural aircraft factory in
Pancevo;
- 2."Galenika" drug factory in Belgrade;
- 3."Zdravlje" pharmaceutical plant in Leskovac;
- 4."Sloboda" white goods factory in Cacak;
- 5."Din" tobacco industry in Nis;
- 6."Elektronska industrija" factory in Nis;
- 7."Div" cigarette factory in Vranje;
- 8.Tubes factory in Urosevac;
- 9."Jastrebac" machine industry in Nis;
- 10."Milan Blagojevic" chemical plant in Lucani;
- 11.Plastics factory in Pristina;
- 12."Binacka Morava" hydro construction company in
Gnjilane;
- 13."Nova Jugoslavija" printers in Vranje;
- 14.Facilities of the "Beograd" rail company in
Nis;
- 15.Over 250 commercial and crafts shops in Djakovica
were destroyed;
- 16."Dijana" shoe factory in Sremska Mitrovica;
- 17."Zastava" car factory in Kragujevac;
- 18."14 Oktobar" machine factory in Krusevac;
- 19.Cotton yarn factory in PriStina;
- 20."Krusik" holding corporation in Valjevo;
- 21."Ciklonizacija" in Novi Sad;
- 22."Tehnogas" in Novi Sad;
- 23."Novograp" in Novi Sad;
- 24."Gumins" in Novi Sad;
- 25."Albus" in Novi Sad;
- 26."Petar Drapsin" in Novi Sad;
- 27."Motins" in Novi Sad;
- 28."Izolacija" in Novi Sad;
- 29."Novokabel" in Novi Sad;
- 30."Istra" fittings factory in Kula;
- 31.The port of Bogojevo;
- 32.Industrial complex "Dvadeset Prvi Maj" in
Rakovica;
- 33.Machine building plant "Industrija Motora
Rakovica" in Rakovica;
- 34.Factory "Jugostroj" in Pancevo;
- 35.Factory "Frigostroj" in Pancevo;
- 36.Surface coal mine "Belacevac";
-
- 2. REFINERIES AND WAREHOUSES
- Refineries and warehouses storing liquid raw
materials and chemicals intended
- for the oil and chemical industry, were hit in
Pancevo, Novi Sad, Sombor and
- elsewhere, causing large contamination of soil and
the air:
-
-
- 1.Fuel storage in Lipovica, which caused a great fire
in the Lipovica forest (on 26 March 1999);
- 2.Oil Refinery in Pancevo - totally demolished (4-16
April 1999);
- 3."Jugopetrol" installations in Smederevo (on 4-13
April 1999);
- 4."Jugopetrol" storage in Sombor (on 7 April
1999);
- 5."Beopetrol" storages in Belgrade and Bogutovac (on
4 April 1999);
- 6."Beopetrol" fuel storage in Pristina (on 7 April
1999);
- 7.Fuel storage of the boiler plant in Novi Beograd
(on 4 April 1999);
- 8.Thermo electric power station/boiler plant in Novi
Sad (on 5 April1999);
- 9.Oil Refinery in Novi Sad, storage of bitumen (5 and
6 April 1999);
- 10.Fuel storage "Naftagas promet" which is located 10
km from Sombor(5 April
- 1999);
- 11.Naftagas warehouse between Conoplje and Kljaicevo
(Sombor);
- 12.Jugopetrol warehouse in Pristina (on 12 April
1999);
- 13.Jugopetrol petrol station in Pristina ( on 13
April 1999);
- 14.Petrochemical industry "DP HIP PETROHEMIJA" in
Pancevo totally demolished
- (14-15 April 1999);
- 15.Fertilizer plant "DP HIP AZOTARA" in Pancevo -
totally destroyed (14-15
- April 1999);
- 16.Chemical plant "Prva Iskra" in Baric - destruction
of the
- production line (19 April 1999);
-
-
- 3. AGRICULTURE:
-
- 1.PIK "Kopaonik" in Kursumlija;
- 2.PIK "Mladost" in Gnjilane;
- 3.Agricultural Complex "Malizgan" in Dolac;
- 4.Agricultural Complex "Djuro Strugar" in Kula;
- 5.In forest fires caused by NATO cruise missiles and
bombs over 250 hectares of
- forests have been burned down;
- 6.Several thousand hectares of fertile land, many
rivers, lakes and underground
- waters have been polluted due to the spillage of
petrochemical substances, oil
- spills and slicks;
-
- 4. HOSPITALS AND HEALTH CARE CENTRES (16):
-
- NATO aviation also targeted many hospitals and
health-care
- institutions, which have been partially damaged or
totally
- destroyed, including:
-
- Hospital and Medical Centre in the territory in
Leskovac;
- Hospital and Poly-clinic in Nis;
- Gerontological Centre in Leskovac;
- General Hospital in Djakovica;
- City Hospital in Novi Sad;
- Gynaecological Hospital and Maternity Ward of the
Clinical Centre in Belgrade;
- Neuropsychiatric Ward "Dr. Laza Lazarevic" and
Central Pharmacy of
- the Emergency Centre in Belgrade;
- Army Medical Academy in Belgrade;
- Medical Centre and Ambulance Centre in
Aleksinac;
- "Sveti Sava" hospital in Belgrade;
- Medical Centre in Kraljevo;
- Dispensary on Mount Zlatibor;
- Health Care Centre in Rakovica;
-
- 5. SCHOOLS (MORE THAN 190 FACILITIES):
-
- Over 190 schools, faculties and facilities for
students and children were
- damaged or destroyed (over 20 faculties, 6 collages,
40 secondary and 80
- elementary schools, 6 student dormitories),
including:
-
- Elementary schools "16. oktobar" and "Vladimir
Rolovic" in Belgrade;
- Day-care centre in settlement Petlovo Brdo in
Belgrade;
- Two secondary schools in the territory of Nis;
- Elementary schools "Toza Markovic", "Djordje
Natosevic", "Veljko
- Vlahovic", "Sangaj" and "Djuro Danicic" and a
day-care centre "Duga" in Novi
- Sad and creches in Visarionova Street and in the
neighbourhood of Sangaj;
- Traffic School Centre, Faculty of Philosophy;
- Four elementary schools and a Medical high school in
the territory
- of Leskovac;
- Elementary school in Lucane, as well as a larger
number of educationfacilities
- in the territory of Kosovo and Metohija;
- Faculties of Law and Economics and elementary school
"Radoje
- Domanovic" in Nis;
- Elementary schools in Kraljevo and the villages of
Cvetka, Aketa and Ladjevci;
- In Sombor: elementary schools "Ivo Lola Ribar", "A.
Mrazovic", "N.
- Vukicevic" and "Nikola Tesla" in Kljajicevo;
- School centre in Kula;
- Elementary school and Engineering secondary school
centre in
- Rakovica;
-
- 6. PUBLIC AND HOUSING FACILITIES (TENS OF
THOUSANDS)
-
- Severe damage to the facilities of the Republican and
Federal
- Ministry of the Interior in Belgrade (3 April
1999),
- Damage to the building of the Institute for Security
of the Ministry of the
- Interior in Banjica (3 April 1999);
- Severe damage to the TV RTS studio in Pristina;
- Heavy damage to Hydro-Meteorological Station
(Bukulja, near
- Arandjelovac);
- Post Office in Pristina destroyed (7 April
1999);
- Refugee centre in Pristina destroyed (7 April
1999);
- "Tornik" ski resort on Mount Zlatibor (on 8 April
1999);
- "Divcibare" mountain resort (on 11 April 1999);
- "Baciste" Hotel on Mount Kopaonik (on 12 April
1999);
- City power plant in the town of Krusevac (12-13 April
1999);
- Meteorological Station on Mount Kopaonik damaged (on
13 April 1999);
- Four libraries in Rakovica sustained heavy damage:
"Radoje Dakic",
- "Isidora Sekulic", "Milos Crnjanski" and "Dusan
Matic";
- Refugee camp "7 juli" in Paracin has sustained heavy
damage;
- Office building of the Provincial Executive Council
of Vojvodina,
- Novi Sad;
- Several thousand housing facilities damaged or
destroyed, privatelyor State
- owned, across Yugoslavia - most striking examples
being housing blocks in
- downtown Aleksinac and those near Post Office in
Pristina.
-
- 7. INFRASTRUCTURE:
-
- Electrical Power Supply in Batajnica (26 March
1999);
- Damage to water supply system in Zemun (5 April
1999);
- Damage to a power station in Bogutovac (10 April
1999);
- Telephone lines cut off in Bogutovac (10 April
1999);
- Damage to a power station in Pristina (12 April
1999);
- Damage to Bistrica hydroelectric power station in
Polinje (13 April 1999);
-
- TELECOMMUNICATIONS
- TV TRANSMITTERS (17):
-
- 1.Jastrebac (Prokuplje)
- 2.Gucevo (Loznica)
- 3.Cot (Fruska Gora)
- 4.Grmija (Pristina)
- 5.Bogutovac (Pristina)
- 6.TV transmitter on Mt Goles (Pristina)
- 7.Mokra Gora (Pristina)
- 8.Kutlovac (Stari Trg)
- 9."Cigota" (Uzice)
- 10."Tornik" (Uzice)
- 11.Transmitter on Crni Vrh (Jagodina)
- 12.Satellite station (in Prilike near Ivanjica)
- 13.TV masts and transmitters (Novi Sad)
- 14.TV transmitter on Mt Ovcara (Cacak)
- 15.TV transmitter in Kijevo (Belgrade)
- 16.TV transmitter on Mt Cer
- 17.Communications relay on Mt Jagodnji (Krupanj)
-
- CULTURAL-HISTORICAL MONUMENTS AND RELIGIOUS
SHRINES
- MEDIEVAL MONASTERIES AND RELIGIOUS SHRINES (16):
-
- 1.Monastery Gracanica from 14th century (24 March - 6
April 1999);
- 2.Monastery Rakovica from 17th century (29 March
1999);
- 3.Patriarchate of Pec (1 April 1999);
- 4.Church in Jelasnica near Surdulica (4 April
1999);
- 5.Monastery of the Church of St. Juraj (built in
1714) in
- Petrovaradin (1 April 1999);
- 6.Monastery of Holy Mother (12th century) at the
estuary of the Kosanica in the
- Toplica - territory of municipality of Kursumlija (4
April 1999);
- 7.Monastery of St. Nicholas (12th century) in the
territory of the
- municipality of Kursumlija (4 April 1999);
- 8.Monastery of St. Archangel Gabriel in Zemun (5
April 1999);
- 9.Roman Catholic Church St. Antonio in Djakovica (29
March 1999);
- 10.Orthodox cemetery in Gnjilane (30 March
1999);
- 11.Monuments destroyed in Bogutovac (8 April
1999);
- 12."Kadinjaca" memorial complex (8 April 1999);
- 13.Vojlovica monastery near Pancevo (12 April
1999);
- 14.Hopovo monastery, iconostasis damaged (12 April
1999);
- 15.Orthodox Christian cemetery in Pristina (12 April
1999);
- 16.Monastery church St, Archangel Michael in Rakovica
(16 April
- 1999);
-
-
- CULTURAL-HISTORICAL MONUMENTS AND MUSEUMS (8):
-
- 1.Severe damage to the roof structure of the Fortress
of
- Petrovaradin (1 April 1999);
- 2.Heavy damage to "Tabacki bridge", four centuries
old, in Djakovica(5 April
- 1999);
- 3.Substantial damage to the building in Stara Carsija
(Old street)
- in Djakovica (5 April 1999);
- 4.Destroyed archives housed in one of the Government
buildings in
- Belgrade (3 April 1999);
- 5.Memorial complex in Gucevo (Loznica);
- 6.Memorial complex "Sumarice" in Kragujevac;
- 7.Vojvodina Museum in Novi Sad;
- 8.Old Military Barracks in Kragujevac - under the
protection of the state (16
- April 1999);
-
Source: Ministry of Foreign Affairs of FR
Yugoslavia
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