Background
A former Belgian colony, the Democratic Republic of the Congo gained its independence on 30 June 1960. Following its independence, the country was first named the Republic of the Congo-Léopoldville, differentiating it from the neighbouring territory of the Republic of the Congo-Brazzaville. With the passing of the Luluabourg Constitution on 1 August 1964, the country was renamed the Democratic Republic of the Congo. Joseph Kasavubu, leader of the Alliance of Bakongo (Alliance des Bakongo, or ABAKO), served as the country’s first president, with Patrice Lumumba, leader of the Congolese National Movement (Mouvement National Congolais, or MNC), as the prime minister. Immediately after gaining its sovereignty, the country experienced a mutiny and was embroiled in political chaos known as the Congo Crisis between 1960 and 1965.[1]
On 11 July 1960, Moïse Kapenda Tshombe declared Katanga, the south-east region of the country, an independent state. The state received little support and was continuously afflicted by ethnic rivalries that resulted in its dissolution in 1963, forcing its reintegration. In September 1960, Colonel Joseph Désiré Mobutu with the support of the Belgian and United States governments led a coup, taking control of the government.[2] In January 1961, Lumumba was shot by a firing squad of Katangan rebels with the assistance of Belgian officials. The country was divided along federal, ethnic and ideological lines as well as fighting over resources which resulted in an estimated 100,000 civilians killed.
In 1965, army chief Mobutu Sese Seko with the support of the US Central Intelligence Agency led the country’s second coup. Once in power, Mobutu suspended the Constitution and proclaimed himself as the head of state.[3] His presidency was characterised as a dictatorship and marked by corruption and misappropriation of funds, radicalisation of the economy through “Zairianisation” policies, exploitation of public resources, forced displacement, and gross human rights violations including widespread sexual violence. In 1967, Mobutu established the Popular Movement of the Revolution (Mouvement Populaire de la Révolution, or MPR), which often at the behest of the president carried out many human rights abuses. In 1971, Mobutu renamed the country the Republic of Zaire as one of his many acts to nationalise and decolonise the country.
In 1991, Mobutu established a multi-party democracy, appointing a new transitional government.[4] The country experienced relative stability until 1994, when the genocide in Rwanda spilled over into Congolese territory, with many Hutu fighters fleeing to the Democratic Republic of the Congo. This resulted in an intra-state conflict with fighters from Uganda, Rwanda and Angola.[5]
In October 1996, Laurent-Désiré Kabila led an insurgency in Zaire, beginning the first Congolese war. He was backed by the Alliance of Democratic Forces for the Liberation of Congo (Alliance des Forces Démocratiques pour la Libération du Congo-Zaire, or AFDL), composed of four revolutionary groups: the People’s Revolutionary Party (Parti de la Révolution Populaire, or PRP); the National Resistance Council for Democracy (Conseil National de Résistance pour la Démocratie, or CNRD); a Lumumbist guerilla group led by André Kisase Ngandu; a group of Congolese Tutsi led by Déogratias Bugera; and the Revolutionary Movement for Liberation of Zaire (Mouvement Révolutionnaire pour la Liberation du Zaire, or MRLZ).[6]
In May 1997, the rebels overthrew Mobutu and the first Congo war ended. Kabila became president and renamed the country the Democratic Republic of the Congo. In August 1998, intra-state armed conflict continued. Fighters from Rwanda, Uganda, Chad, Angola, Sudan, Namibia and Zimbabwe invaded the country, beginning the second Congo war known as the Great African War or the Second African World War.[7] The war lasted five years, with widespread sexual violence, killings and forced displacement. The leading rebel groups were the Rwanda-backed Rally for Congolese Democracy (Rassemblement Congolais pour la Démocratie, or RCD), which gained control over large areas of the country, and the Uganda-backed Movement for Liberation of Congo (Mouvement de Libération du Congo, or MLC). In 1999, the conflict reached a stalemate, and the country was divided into three areas, one controlled by the government and the others controlled by the two rebel groups.
In 1999, the Organization of African Unity (now the African Union) negotiated a ceasefire in Lusaka, Zambia. However, the agreement failed and armed violence continued. On 16 January 2001, Kabila was assassinated by one of his bodyguards and was succeeded by his son Joseph Kabila. By 2002, violence died down and peace talks involving the warring groups reopened. On 2 April 2003, as the final act of the Inter-Congolese Dialogue held in South Africa, the Sun City Agreement was signed by warring groups, ending the war. An interim government was established, and leaders of the main rebel groups were sworn in as vice presidents while Joseph Kabila remained president.
In 2004, rebel leader Laurent Nkunda launched a campaign of mass killings, rape and destruction, resulting in the country’s third major armed conflict. During this period, a new Constitution was established but violence escalated, displacing thousands of Congolese. In November 2006, Joseph Kabila won the presidential election, but the insurgency continued. In November 2011, Kabila won again in a widely disputed election. Political upheaval followed and in January 2015 dozens were killed in protests against electoral law changes that would allow Kabila to stay in power indefinitely. In December 2017, conflict in the country reached new levels, with 1.7 million people forced to flee their homes.
On 24 January 2019, Felix Tshisekedi, leader of Union for Democracy and Social Progress (Union pour la Démocratie et le Progrès Social, or UDPS), was elected president and met with protests from rival political groups. In 2022, the human rights minister launched national consultations for a new transitional justice initiative to address gross human rights violations and institute necessary reforms.[8] However, political instability and armed conflict continues in the country.
Transitional justice-related efforts in the Democratic Republic of the Congo have included prosecutions, traditional justice mechanisms and a truth commission.
Sovereign National Conference
The constitutional revision law of 25 November 1990 established a multi-party system and initiated the country’s first transitional initiative: the Sovereign National Conference (Conférence National Souveraine, or CNS). After Constitutive Act No. 91-097 of 11 April 1991, the CNS was created as a forum for institutional reform, regime change and human rights protection. It included 2,842 delegates and held roughly 23 commissions and 100 sub-commissions with the objective to investigate past human rights violations and provide recommendations.[9] The two most significant commissions were the National Commission Dealing with Cases of Assassinations and Human Rights Violations (Commission Nationale des Assassinats et des Violations des Droits de l’Homme) and the National Commission of Ill-gotten Gains or National Commission of Properties Acquired Fraudulently (Commission Nationale des Biens Mal Acquis).
The Assassinations Commission was mandated to investigate violations related to assassinations and other serious abuses committed by state security services between 1965 and 1971 and from 1971 to 1992. The commission detailed five main cases of human rights violations during this period and named Mobutu and his collaborators as the principal perpetrators. The commission made a number of recommendations; however, Mobutu dismissed them and any real opportunities for reform and accountability were derailed.
The Ill-Gotten Gains Commission was tasked to investigate property acquired fraudulently and provide recommendations to recover property to victims, including the state, whose land/property had been unjustly taken following diversion, spoliation or unjust enrichment by official or private persons.[10] The commission suffered with underfunding, a lack of collaboration from the state, and minimal access to official documents. The commission made a number of findings, completed a list of offenders and provided recommendations. However, it did not have any judicial capacities; thus, there were no criminal prosecutions.
Mobutu rendered the entire CNS process obsolete when he amended the Constitution to establish alternative institutions to delegitimise the CNS. The CNS officially operated until December 1992.
Barza Inter-Communautaire
Stemming from an eastern Congolese custom, the Barza Inter-Communautaire was a local conflict mediation structure used after the 1996–1997 North Kivu armed conflict.[11] The conflict resolution mechanism was a traditional reconciliation process that involved nine ethnic groups, Hunde, Hutu, Kato, Kumu, Nande, Nyanga, Tembo, Tutsi and Twa, and functioned to resolve ethnic disputes, particularly issues related to land ownership. With the persistent conflict, the mechanism’s ability to mitigate ethnic tensions waned, resulting in its collapse in 2005.
Military Tribunals
Since 2002, military tribunals have had jurisdiction to try crimes under international human rights law committed after 1996. There were a number of difficulties with prosecuting high-ranking officials, as many perpetrators occupied (and continue to occupy) high-level positions in the army. By 2008, only a dozen cases concerning low-level officials had been tried. Corruption and political interference represent an enormous challenge in prosecuting those most responsible for serious crimes. In 2013, civil courts were given the autonomy to try serious crimes. However, many identified perpetrators hold senior government positions, making any progress towards criminal accountability difficult.
Truth and Reconciliation Commission
In December 2002, the Comprehensive Peace Agreement established the framework for a truth commission.[12] The Truth and Reconciliation Commission (Commission Vérité et Réconciliation, or CVR) was met with numerous political and technical obstacles, with one year passing before it started functioning.
On 30 July 2004, Article 160 of the Transitional Constitution enacted a mandate (Law No. 04/018) for the CVR. The truth commission’s mandate involved the promotion of national unity by examining the political, economic and social impacts of conflict from the country’s 1960 independence to the signing of the peace agreement. The commission was also expected to recommend reparations for victims of the conflict. It was composed of 21 commissioners, including eight officers and 13 provincial representatives. A representative of civil society was expected to chair while others’ membership was dependent on their participation in the Inter-Congolese Dialogue.[13]
Despite its perceived progress, the commission’s efforts were undermined by continued conflict and the inaccessibility of war-affected communities. Also, a number of the elected commissioners were members of armed groups who were responsible for many of the crimes committed during the conflict. The external and internal fighting, lack of political trust, fears around witness testimony, and impunity for crimes paralysed the commission. The CVR operated for almost four years without conducting any hearings. In 2007, the final report was presented to parliament, but it did not include any findings and had very few recommendations, which did not directly address crimes or demand accountability.
Gender
Throughout the periods of conflict in the country, sexual violence has been used as a strategy of war by armed actors. The systematic use of sexual violence and use of child soldiers by armed groups meant the targeting of women and girls and boys.[14] Sexual violations including rape, gang rape, witnessed sexual violence of family members, and forced incest have been systematically used as a means of repression and terror. Armed groups also use sexual violence to capture resources such as territory by controlling inhabitants through terror.[15] Significantly, the normalisation of public sexual violence and impunity for these crimes has seen the rise of civilians perpetrating sexual violence outside of periods of conflict, particularly in previously conflict-affected regions.[16]
Persistent armed conflict in the country has conditioned a militarised masculinity that contributes to the pervasive sexual violence. Previously held conceptions of gender framed masculinity through roles and actions such as being breadwinners, paying dowry and having physical strength, with an emphasis on high sex drive and physicality. However, the conflict and economic and socio-political fragility made these gendered roles unattainable. This resulted in the operation of violence, particularly sexual violence, to attain power for men who see it as a means to re-achieve certain aspects of their masculinity.[17]
Sexual violence disproportionately affects Congolese women and girls as they serve as representatives of their communities, with many being subjected to injury to humiliate them and in extreme cases to terminate future procreation.[18] Significantly, men and boys are also victims of sexual violence. Sexual violations include forced sexual intercourse (oral and penetrative), sexual torture such as genital mutilation, insertion of objects in genitalia, forced nudity, forcing men to rape their female and male family members, and men being forced to watch either rebels or soldiers rape their wives, daughters or other family members.[19]
While men are the dominant perpetrators of sexual violations, women are also identified as perpetrators. The pervasiveness of sexual violence sees men sexually violate other men and women sexually violate women and men. Same as men and boys, women and girls are abducted and are combatants within armed groups. Women and girls perform domesticated roles within combatant camps, including as nurses, wives, cooks and mothers, but they are also fighters. A survivor of one of the many combatant camps states that “women who were raped for years are now raping other women.”[20] Women also perform rape and other sexual violence crimes against men, including performing oral sex or forcing men to have sex with them.
Unfortunately, efforts towards justice and accountability for rape and other sexual violations have been inadequate. Although rape and sexual violence are outlawed in the country, judges routinely encourage out-of-court settlements for sexual crimes. Also, great stigmatisation and revictimisation of sexual violence victims results in many refusing to testify about their sexual assaults. Women survivors of sexual violence often experience rejection and stigma from both the household and their communities, with many considered “spoiled and “non-marriage material” as a consequence of being raped.[21] The rape of men is considered a rejection of one’s masculinity, referencing the previously held roles and actions of Congolese masculinity. Their dominant status within the household is considered threatened by the violence of sexual assault.
The government in collaboration with other states, international organisations and local organisations is involved in a number of initiatives to address conflict-related sexual violence. In 2013, the United Nations Joint Human Rights Office in collaboration with the Federal Republic of Brazil set up a project to encourage a comprehensive reparations programme. It offered five grants to local organisations to provide conflict-related sexual violence survivors with psychosocial support, medical insurance, school fees, and training and supplies for small businesses.[22] Local women’s rights organisations play a significant role in protecting women and girls and advocating for gender equality through peacebuilding initiatives and women’s involvement in peace and dialogue processes.[23]
International Actors
Numerous regional and international actors have been involved in the country’s conflicts as well as its attempts for peace. On 10 July 1999, African states involved in the second Congo war, including the Democratic Republic of the Congo, Angola, Namibia, Zimbabwe, Rwanda and Uganda, signed a ceasefire agreement in Lusaka, Zambia. The 1999 Lusaka Ceasefire Agreement terms included establishing mechanisms for the return of normal governing institutions in the Democratic Republic of the Congo.[24]
In the same year, the United Nations launched a peacekeeping operation in the country, the United Nations Mission in the Democratic Republic of the Congo (MONUC). This mission was mandated to observe the ceasefire agreement. MONUC was replaced with another peacekeeping operation, the United Nations Organisation Stabilisation Mission in the Democratic Republic of the Congo (MONUSCO), in July 2010. In March 2013, the Force Intervention Brigade (FIB) was adapted to MONUSCO as the military apparatus of the peacekeeping mission. The FIB was composed of South African Development Community (SADC) members, including South Africa, Tanzania and Malawi, and was mandated to fight against armed rebel groups, particularly the Rwanda-backed M23 rebels.[25]
In 1997, the United Nations secretary-general organised an investigative team to record and develop reports on human rights violations perpetrated during the 1996–1997 war. This was followed by a number of investigative missions led by the United Nations in 2000, probing human rights violations committed across the different conflicts. In 2007, the Security Council passed a resolution for Congolese authorities to establish a vetting mechanism to account for violations perpetrated by army and other security officers. In 2008, the Office of the High Commissioner for Human Rights launched its own investigation into human rights violations committed between 1993 and 2003. A report published in 2010 listed numerous acts of widespread and systematic violence and assessed the judiciary’s ability to handle these crimes.
In 2002, regional states and armed groups signed the Global and Inclusive Accord that proposed an all-inclusive power-sharing transition arrangement through the cessation of hostilities.[26] On 2 April 2003, the African Union as well as SADC facilitated the Sun City talks that resulted in the Sun City Agreement. The numerous peace agreements as well as the regional and international involvement in the country’s peacebuilding contributed to the success of the 2006 multi-party elections.[27]
Despite the moments of peace, the country still experienced widespread armed fighting, particularly in Kivu Province. After the National Congress for the Defence of the People (Congrés National pour la Défense du People, or CNDP) rebellion in Kivu between 2006 and 2009, two peace agreements were signed in Goma, the Acte d’Engagement and the Goma Peace Agreement in January 2008 and March 2009, respectively. The AU, the UN and the EU, particularly Belgium, France, the Netherlands, Sweden and the United Kingdom, had significant diplomatic representation in the peace processes of Goma.
Following the rise of the Rwanda-backed rebel group M23, the AU, the EU, the UN and the US initiated a number of transitional initiatives. On 20 November 2012, after M23 took control of the city of Goma, the International Conference of the Great Lakes Regions coordinated the leading peacebuilding actors to negotiate peace. This resulted in the Nairobi Declaration of December 2013, which laid out a process of disarming and demobilising M23 as well as holding its fighters accountable. Despite these steps forward, the regional peace process failed.[28]
The resolutions of the Inter-Congolese Dialogue called for the UN to establish a court for the Democratic Republic of the Congo, to try cases of “genocide, crimes against humanity, war crimes and mass violations of human rights committed or presumed committed since 1960, as well as during the two wars of 1996 and 1998.” As a signatory of the Rome Statute, the Democratic Republic of the Congo became the focus of the first investigation of the International Criminal Court (ICC).
In March 2006, the ICC issued its first arrest warrant against Thomas Lubanga for enlisting and conscripting child soldiers. On 14 March 2012, Lubanga was found guilty and sentenced to a total of 14 years of imprisonment.[29] He was also instructed to pay reparations to his victims. In 2007, the court issued two more arrest warrants for war crimes and crimes against humanity against Mathieu Ngudjolo Chui, leader of the National Integrationist Front (Front des Nationalistes et Intégrationnistes, or FNI), and Germain Katanga, also known as Simba, the alleged commander of the Patriotic Resistance Force in Ituri (Force de Resistance Patriotique en Ituri, or FRPI).
The Congolese government arrested and transferred the alleged perpetrators to the ICC. On 18 December 2012, the court acquitted Chui. On 7 March 2014, Katanga was found guilty and sentenced to a total of 12 years’ imprisonment for being an accessory to one count of crimes against humanity and four counts of war crimes.[30] He was also ordered to provide reparations to his victims.
In April 2008, the court issued an arrest warrant against Bosco Ntaganda, deputy chief of staff of the CNDP. Although Ntaganda initially evaded arrest, he handed himself over to the ICC on 22 March 2013. In 2019, following conviction, he was sentenced to 30 years in prison for 13 counts for war crimes and five counts of crimes against humanity committed in the Ituri district between 2002 and 2003.[31]
In 2005, the International Commission of Jurists (ICJ) found Uganda liable for human rights violations and other crimes committed in the eastern regions during Uganda’s military invasion of the Democratic Republic of the Congo between 1998 and 2003. In accordance with the ICJ judgment, Uganda was ordered to pay USD 325 million in reparations.[32]
In 2008, the Trust Fund for Victims launched its first phase of assistance programmes for victims of crimes falling within the jurisdiction of the ICC. The programme provided physical rehabilitation to mutilated victims and survivors of sexual and gender-based violence, psychological rehabilitation, school assistance, income-generating activities, and community peacebuilding and reconciliation for conflict resolution and reintegration. It intends to attend to up to 20,000 direct beneficiaries.[33]
Sources
[1] Dieudonné Tshiyoyo, ‘Democratic Republic of Congo: Road to political transition,’ Electoral Institute of Southern Africa, 2006, https://www.eisa.org/pdf/drc2006background.pdf
[2] Human Rights Watch, ‘DR Congo: Chronology,’ August 21, 2009, https://www.hrw.org/news/2009/08/21/dr-congo-chronology#_Independence
[3] Julien Bobineau, ‘The History of the Democratic Republic of Congo: An introduction,’ in The Democratic Republic of the Congo: Problems, progress and prospects, ed. Phillip Greg and Julien Bobineau (Berlin: LIT Verlag, 2016), 11-28.
[4] Human Rights Watch, 2009.
[5] Shola Lawal, ‘A guide to the decades-long conflict in Democratic Republic of the Congo,’ Al Jezeera, February 21, 2024, https://www.aljazeera.com/news/2024/2/21/a-guide-to-the-decades-long-conflict-in-dr-congo
[6] Adeleke O. Ogunnoiki, ‘Armed conflict in resource-endowed African states: A case study of the Democratic Republic of Congo (DRC),’ International Journal of Advanced Academic Research, Vol. 5, No. 1 (2019).
[7] Harish Venugopalan, ‘Understanding the conflict in Congo,’ Observer Research Foundation, no. 139 (2016).
[8] Carine Dikiefu Banona, ‘Important step toward justice in DR Congo?’ Human Rights Watch, March 11, 2022, https://www.hrw.org/news/2022/03/11/important-step-toward-justice-dr-congo-0
[9] Shirambere P. Tunamsifu, ‘Transitional justice processes in Africa: The case of the Democratic Republic of the Congo,’ Centre for the Study of Violence and Reconciliation, 2018, https://www.csvr.org.za/wp-content/uploads/2016/06/DRC-Case-Philippe-Tunamsifu.pdf
[10] Shirambere P. Tunamsifu, ‘The colonial legacy and transitional in the Democratic Republic of the Congo, Accord, ’ ACCORD, December 12, 2022, https://www.accord.org.za/ajcr-issues/the-colonial-legacy-and-transitional-justice-in-the-democratic-republic-of-the-congo/
[11] Phil Clark, ‘Ethnicity, leadership and conflict mediation in Eastern Democratic Republic of Congo: The case of the Barza Inter-Communautaire,’ Journal of Eastern African Studies, Vol. 2, No. 1 (2002).
[12] United States Institute of Peace, ‘Truth commission: Democratic Republic of Congo,’ July 1, 2003, https://www.usip.org/publications/2003/07/truth-commission-democratic-republic-congo
[13] Laura Davis and Priscilla Hayner, ‘Difficult peace, limited justice: Ten years of peacemaking in the DRC,’ International Center for Transitional Justice, March, 2009, https://www.ictj.org/sites/default/files/ICTJ-DRC-Difficult-Peace-2009-English.pdf .
[14] Elyse J. Thulin, Andrew Lustig, Violette Perrotte, Marx Lwabanya and Tyler Evans, ‘Male and female perceptions and experiences of sexual and gender-based violence in South Kivu, Eastern DRC,’ Journal of Interpersonal Violence, Vol. 37, No. 11–12 (2022).
[15] Giulia Pasquinelli, Nathalie Ndimubanzi and Douce Namwezi, ‘They came together not to be silenced: Gender-based violence in conflict and the role of women’s rights organisations,’ Kvinna till Kvinna, 2023, https://kvinnatillkvinna.org/wp-content/uploads/2023/08/The-Kvinna-till-Kvinna-Foundation-they-came-together-not-to-be-silenced-gender-based-violence-in-conflict-the-role-of-womens-rights-organisations.pdf
[16] Malokele Nanivazo, ‘Sexual violence in the Democratic Republic of Congo,’ WIDER, April, 2012, https://www.wider.unu.edu/publication/sexual-violence-democratic-republic-congo
[17] Eli Mechanic, ‘Why gender still matters: Sexual violence and the need to confront militarized masculinity. A case study of the conflict in the Democratic Republic of the Congo,’ Impact Transform, December, 2004, https://impacttransform.org/wp-content/uploads/2017/09/2004-Dec-Why-Gender-Still-Matters-Sexual-Violence-and-the-Need-to-Confront-Militarized-Masculinity-A-Case-study-of-the-conflict-in-t.pdf
[18] Ibid.
[19] Mervyn Christian, Octave Safari, Paul Ramazani, Gilbert Burnham and Nancy Glass, ‘Sexual and gender-based violence against men in the Democratic Republic of Congo: Effects on survivors, their families and the community,’ Medicine, Conflict and Survival, Vol. 27, No. 4 (2011); Ines Yagi, Judith Malette, Timothee Mwindo and Buuma Maisha, ‘Characteristics and impacts of conflict-related sexual violence against men in the DRC: A phenomenological research design,’ Social Sciences, Vol. 11, No. 34 (2022).
[20] Jessica Hatcher, ‘Congo’s forgotten curse: Epidemic of female-on-female rape,’ Time, December 3, 2013, https://world.time.com/2013/12/03/congos-forgotten-curse-epidemic-of-female-on-female-rape/
[21] Katherine Albutt, Jocelyn Kelly, Justin Kabanga and Michael VanRooyen, ‘Stigmatisation and rejection of survivors of sexual violence in eastern Democratic Republic of the Congo,’ Disasters, Vol. 42, No. 2 (2017).
[22] OHCHR, ‘Access to justice and reparations for victims of sexual violence in the Democratic Republic of the Congo,’ November 29, 2013, https://www.ohchr.org/en/stories/2013/11/access-justice-and-reparations-victims-sexual-violence-democratic-republic-congo
[23] Kvinna till Kvinna, ‘Standing up against gender-based violence in the Democratic Republic of the Congo,’ December 13, 2023, https://kvinnatillkvinna.org/2023/12/13/standing-up-against-gender-based-violence-in-the-democratic-republic-of-the-congo/
[24] Herbert Weis, ‘War and peace in the Democratic of the Congo,’ Current African Issues, No. 22 (2000).
[25] Peter Fabricius, ‘Reinventing the Force Intervention Brigade,’ Institute for Security Studies, December 4, 2020, https://issafrica.org/iss-today/reinventing-the-force-intervention-brigade
[26] United Nations Peacemaker, ‘Global and Inclusive Agreement on Transition in the Democratic Republic of Congo,’ December 16, 2002, https://peacemaker.un.org/drc-agreementontransition2002
[27] Sadiki Koko, ‘Peace at last? Appraisal of the Addies Ababa Peace and Security Cooperation Framework and the United Nations Security Council Resolution 2098 for the Democratic Republic of the Congo,’ ACCORD, July 12, 2013, https://www.accord.org.za/ajcr-issues/peace-at-last/
[28] Ogunnoiki, 30.
[29] International Criminal Court, ‘Lubanga case: The Prosecutor v. Thomas Lubanga Dyilo. ICC-01/04-01/06,’ https://www.icc-cpi.int/drc/lubanga
[30] International Criminal Court, ‘Katanga case: The Prosecutor v. Germani Katanga. ICC-01/04-01/07,’ https://www.icc-cpi.int/drc/katanga
[31] Human Rights Watch, ‘Bosco Ntaganda,’ 2019, https://www.hrw.org/topic/international-justice/bosco-ntaganda
[32] Rory Carroll, ‘Court orders Uganda to pay Congo damages,’ The Guardian, December 20, 2005, https://www.theguardian.com/world/2005/dec/20/congo.uganda
[33] Trust Fund for Victims, ‘Democratic Republic of the Congo,’ n.d., https://www.trustfundforvictims.org/en/locations/democratic-republic-congo