On December 18, 2014, the Appeals Chamber of the International Residual Mechanism for Criminal Tribunals (Appeals Chamber) delivered its first appeal judgment [3] in the case of The Prosecutor v. Augustin Ngirabatware, affirming the conviction of Ngirabatware in part.  According to the press release [4], “[t]he Appeals Chamber unanimously affirmed Ngirabatware’s conviction for direct and public incitement to commit genocide. A majority of the Appeals Chamber also affirmed Ngirabatware’s conviction for instigating and aiding and abetting genocide.”  The Appeals Chamber also “unanimously reversed Ngirabatware’s conviction for rape as a crime against humanity under the extended form of joint criminal enterprise” and consequently reduced his sentence to a term of thirty years.  The International Criminal Tribunal for Rwanda convicted Ngirabatware in 2012 and originally sentenced him to thirty-five years imprisonment.