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Submission to the International Criminal Tribunal for the
former Yugoslavia, requesting the investigation and
indictment of Prime Minister Tony Blair, Foreign Secretary
Robin Cook and Defence Secretary George Robertson of the
United Kindgom for serious violations of international
humanitarian law committed in the territory of the former
Yugoslavia

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BACKGROUND

1. On 24 March 1999, the North Atlantic Treaty Organisation
(NATO) commenced military operations against the Federal
Republic of Yugoslavia, with the stated aim of deterring
human rights violations in the Kosova region of Yugoslavia.
Operations began at 8p.m. Manned aircraft were used from
the start of the military mission, initially in concert
with ship-launched cruise missiles. During the first few
days of military operations, attacks were directed largely
against the air-defence systems of the Federal Republic,
including anti-aircraft missile batteries, radar and
command-and-control facilities. By the end of March, NATO
aircraft were mostly attacking wider military targets,
including army headquarters, ammunition dumps, and
airfields. However, as the Yugoslav government continued to
refuse to accede to NATO�s demands, the list of targets was
enlarged to include fuel depots, oil refineries
(specifically those in Novi Sad and Pancevo) and government
offices; and by 4 April 1999, power stations and
communications links, including roads, tunnels, bridges and
railway links were openly targeted, including those not
inside the region of, or in the vicinity of, Kosova. By 23
April, attacks were being launched against television
studios and transmitters.

This shift from attacking military targets to attacking
civilian infrastructure and objects is apparent in both
announcements of the NATO spokesman and NATO Heads of
Government on the one hand, and also in the nature of the
sites in the Federal Republic of Yugoslavia attacked on the
other. On 20 April 1999, Mr Tony Blair, Prime Minister of
the United Kingdom, said in the Press Conference at NATO HQ
in Brussels:
"I think it is extremely important that all of us do
everything in our power to make sure that the economic
measures that we are taking against Serbia are effective
and our attacks of course have done immense damage to the
lines of communication, the lines of supply, the oil
refineries and the oil supplies of the Milosevic regime."
(emphasis added)

Mr George Robertson, UK Secretary of State for Defence,
stated:
"At the outset of the air campaign, NATO Ministers
collectively agreed to certain categories of targets--the
first of which was, self-evidently, the Yugoslav air
defences. We subsequently agreed to widen the range of
targets to include strategic assets such as bridges,
barracks and headquarters." (House of Commons, 19 April,
Hansard, col.667, p.830).

Dr James Shea, Spokesman of NATO and Deputy Director of
Information and Press, made similar statements on attacking
economic and telecommunications targets shortly afterwards.
On 21 April 1999, also at NATO HQ in Brussels, Dr Shea
said:
"[A]ny aspect of the power structure is considered as a
legitimate target by NATO, the power structure, and of
course in dictatorial societies it becomes progressively
impossible to distinguish between the party and the state,
as we all know, they become conflated with each other, and
this is also the party headquarters which contains the
propaganda too of the ruling socialist party and that is
enough for us to consider that to be a wholly legitimate
target."

More clearly, the increased volume of attacks on civilian
infrastructure can be detected in the chronology of NATO
attacks, which forms Annex I to this submission. The first
attacks on bridges occurred on 1 April 1999, with the
strikes on the Varadin Bridge over the Danube. On 3 April,
the Republican and Federal Ministry of the Interior in
Belgrade was severely damaged by NATO attacks, and damage
was done to the building of the Institute for Security of
the Ministry of the Interior in Banjica. On 4th and 5th
April, numerous road and railway bridges throughout the
Federal Republic of Yugoslavia were directly targeted.
Electric power stations, oil refineries and fuel storage
sites were also targeted. Industrial sites and factories
were primary targets on 15 April, and have continued to be
so. TV transmitters and the Radio Televizija Srbija (RTS)
Studio were targeted later in April. Such instances will be
described in greater detail below (see paragraph 7), and a
case will be made that many such attacks constitute serious
violations of international humanitarian law, amounting to
a breach of a rule protecting important values, and with
grave consequences for persons with interests in the
infrastructure so destroyed.

A further stage in NATO's campaign can be seen on the night
of 2 May 1999, when five major electricity stations were
bombed, cutting off power to approximately 70% of the
Yugoslav population. NATO spokesperson, James Shea, said:
"the fact that the lights went out across 70% of the
country I think shows that NATO has its finger on the light
switch in Yugoslavia now and we can turn the power off
whenever we need to and whenever we want to". (Press
Conference, NATO HQ, Brussels, 3 May 1999).

In addition to these deliberate attacks on civilian
infrastructure and objects, there are a great number of
attacks which caused direct physical harm and death to
civilians, often with no associated military benefit, and
which were subsequently claimed by NATO to be the result of
mistaken targeting. Instances of this nature include the 29
March bombing of two refugee centres in Nis, managed by
CARE Australia on behalf of the UN High Commissioner for
Refugees, killing 9 refugees; the 8 April bombing of the
town of Chubria, leaving one woman dead and five injured;
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 10 passengers
and wounding 16; and 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 individuals. In all these stated cases,
NATO claimed that the civilian deaths were the result of
accidents, even apologising in many of the cases for
"collateral damage". However, NATO�s operational doctrine
did not change at any point, despite the clear and
disproportionate danger to civilians that arose from that
doctrine. Moreover, even though it was claimed in certain
cases that the pilot was not able to determine what his
targets were but fired missiles nevertheless, no
disciplinary action was taken against those pilots. In such
cases, it is clear that a superior had reason to know that
his subordinates were about to commit acts in which all
feasible measures were not being taken to prevent civilian
casualties, but failed to take necessary and reasonable
measures to prevent these acts; or knew that his
subordinates had committed such acts and failed to punish
the perpetrators thereof. Such acts constitute a serious
violation of the laws and customs of war, and the superior
may be held to be criminal responsible for them.



THE ACCUSED

2. Anthony Charles Lynton Blair was born on 6 May 1953. He
trained in law, and became a barrister in 1976. He became
Member of Parliament for Sedgefield in 1983, and has
retained this constituency since. He became Prime Minister
of the United Kingdom in May 1997.

Robin Finlayson Cook, son of Peter Cook, was born on 28
February 1946. He has been a Member of Parliament since
1974. He is currently Member of Parliament for the
constituency of Livingston. He has been Secretary of State
for Foreign and Commonwealth Affairs since May 1997.

George Islay MacNeill Robertson, son of George P.
Robertson, was born on 12 April 1946. He worked as a trades
union organiser from 1969 until 1978. He was elected to
Parliament in 1978, and is currently Member of Parliament
for Hamilton South. He has been Secretary of State for
Defence since May 1997.



GENERAL ALLEGATIONS

3. As the three individuals in the government of the United
Kingdom with primary responsibility for NATO�s actions in
Yugoslavia, Mr Anthony Blair, Mr Robin Cook and Mr George
Robertson have committed serious violations of the laws and
customs of war, and are thus liable under Article 3 of the
Statute of the International Criminal Tribunal for the
former Yugoslavia for breaches thereof. As persons who have
planned, instigated and ordered the execution of violations
of the laws and customs of war, they hold individual
criminal responsibility under Article 7(1) of the Statute.
Moreover, as persons who, knowing that their subordinates
both were about to commit such acts, and subsequently had
done so, failed to take necessary and reasonable measures
to prevent such acts and to punish the perpetrators
thereof, they hold "command responsibility" under Article
7(3) of the Statute.

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