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Factors in the Balancing Exercise

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Illicitly Obtained Evidence at the International Criminal Court

Part of the book series: International Criminal Justice Series ((ICJS,volume 4))

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Abstract

Under Article 69(7) of the ICC Statute, not all legal violations committed during investigations lead to the exclusion of thereby tainted evidence. Instead, evidence is only excluded where such a violation has a specific negative impact on the proceedings of the ICC, namely because either the evidence lacks reliability or because its admission “would be antithetical to and would seriously damage the integrity of the proceedings”. We have seen in Chap. 4 that the wording of Article 69(7) of the ICC Statute, while indicating a mandatory exclusionary rule at first sight, is ultimately a discretionary rule due to fact that these additional requirements were included in the provision. We have also seen in Chap. 4 that the exclusion of illicitly obtained evidence should be guided by the integrity theory, meaning the idea that the exclusion of evidence should serve the maintenance of the integrity of the Court. Under this theory, the exercise of the discretion granted under Article 69(7) of the ICC Statute requires the Court to strike a balance between the interests of ‘due process’ and ‘effective law enforcement’. In order to guide this balance, this chapter will discuss a number of factors that may militate in favour of either one of these two poles.

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Notes

  1. 1.

    Prosecutor v. Lubanga (Decision on the confirmation of charges), ICC (Pre-Trial Chamber), decision of 29 January 2007, para 84. Also see Prosecutor v. Mbarushimana (Decision on the confirmation of charges), ICC (Pre-Trial Chamber), decision of 16 December 2011, para 61.

  2. 2.

    See Sect. 4.3.2.2.5.

  3. 3.

    See Jalloh v. Germany, ECtHR, decision of 11 July 2006 (Application no. 54810/00), paras 119 and 122; see also Sect. 3.2.4.

  4. 4.

    For Germany, see German Constitutional Court (BVerfG), decision of 31 January 1973, BVerfGE 34, p. 250; see also Sect. 3.3.1. For the English approach, see Regina v. Khan, Court of Appeal of England and Wales, decision of 15 June 1992, [1993] Crim. L.R. 54; see also Sect. 3.3.3.

  5. 5.

    Regina v. Grant, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 353, para 84. See also Sect. 3.3.4.

  6. 6.

    In favour, Scharf 2008, p. 169.

  7. 7.

    See in particular Sect. 2.2.3.

  8. 8.

    Prosecutor v. Brđanin (Decision on the Defence “Objection to Intercept Evidence”), ICTY (Trial Chamber), decision of 3 October 2003, para 7. Similar, see Prosecutor v. Karadžić (Decision on the accused’s Motion to exclude intercepted conversations), ICTY (Trial Chamber), decision of 30 September 2010, para 10. See also Safferling 2012, p. 501.

  9. 9.

    Prosecutor v. Lubanga (Decision on the admission of material from the “Bar Table”), ICC (Trial Chamber), decision of 24 June 2009, para 44.

  10. 10.

    See Sect. 4.3.2.2.5.

  11. 11.

    See Prosecutor v. Lubanga (Judgment on the Appeal of Mr. Thomas Lubanga Dyilo against the Decision on the Defence Challenge to the Jurisdiction of the Court pursuant to Article 19(2)(a) of the Statute of 3 October 2006), ICC (Appeals Chamber), decision of 14 December 2006. See also, Prosecutor v. Lubanga (Decision on the consequences of non-disclosure of exculpatory materials covered by Article 54(3)(c) agreements and the application to stay the prosecution of the accused, together with certain other issues raised at the Status Conference on 10 June 2008), ICC (Trial Chamber), decision of 13 June 2008; Prosecutor v. Lubanga (Redacted Decision on the Prosecution’s Urgent Request for Variation of the Time-Limit to Disclose the Identity of Intermediary 143 or Alternatively to Stay Proceedings Pending Further Consultations with the VWU), ICC (Trial Chamber), decision of 8 July 2010.

  12. 12.

    Prosecutor v. Lubanga (Decision on the admission of material from the “Bar Table”), ICC (Trial Chamber), decision of 24 June 2009, para 44.

  13. 13.

    See Sect. 4.3.1.

  14. 14.

    Prosecutor v. Lubanga (Decision on the admission of material from the “bar table”), ICC (Trial Chamber), decision of 24 June 2009, para 41; confirmed by Prosecutor v. Katanga and Chui (Decision on the Prosecutor's Bar Table Motions), ICC (Trial Chamber), decision of 17 December 2010, para 64.

  15. 15.

    See Sect. 3.1.3.

  16. 16.

    See Sect. 3.1.3.

  17. 17.

    See Trüg 2003, p. 230; Rogall 1979, p. 29 et seq., see also Sect. 3.3.1.

  18. 18.

    See Regina v. Grant, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 353, para 79. Also see Sect. 3.3.4.

  19. 19.

    Jalloh v. Germany, ECtHR, decision of 11 July 2006 (Application no. 54810/00), para 121.

  20. 20.

    Regina v. Keenan, Court of Appeal of England and Wales, decision of 26 April 1989, [1990] 2 Q.B. 54.

  21. 21.

    See in particular Prosecutor v. Brđanin (Decision on the Defence “Objection to Intercept Evidence”), ICTY (Trial Chamber), decision of 3 October 2003, para 61; see also Sect. 3.1.4.

  22. 22.

    See Sect. 3.2.4.

  23. 23.

    On the English jurisprudence, see Regina v. Keenan, Court of Appeal of England and Wales, decision of 26 April 1989, [1990] 2 Q.B. 54; Regina v. Absolam, Court of Appeal of England and Wales, decision of 1 July 1988, [1988] Cr. App R. 332. See also Mellifont 2007, pp. 85–86. With respect to Canada, see Regina v. Grant, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 353, para 76. See also Stuart 2010, p. 318. On the German jurisdiction, see Sect. 3.3.1.

  24. 24.

    On this systematic of the U.S. exclusionary rule, see Sect. 3.3.2.

  25. 25.

    Alamuddin 2010, p. 301 et seq.

  26. 26.

    Prosecutor v. Lubanga (Decision on the admission of material from the ‘bar table’), ICC (Trial Chamber), decision of 24 June 2009, para 35.

  27. 27.

    Prosecutor v. Lubanga (Decision on the admission of material from the ‘bar table’), ICC (Trial Chamber), decision of 24 June 2009, fn. 67 to para 35.

  28. 28.

    Prosecutor v. Lubanga (Decision on the admission of material from the ‘bar table’), ICC (Trial Chamber), decision of 24 June 2009, para 47.

  29. 29.

    Prosecutor v. Lubanga (Decision on the admission of material from the ‘bar table’), ICC (Trial Chamber), decision of 24 June 2009, para 35.

  30. 30.

    Similar, Ambos 2010, p. 370. But see Edwards 2001, p. 339, who seems to reject the significance of whether the violation was serious.

  31. 31.

    Slobogin 2013, p. 20 et seq.

  32. 32.

    See Sect. 3.1.4.

  33. 33.

    See Sect. 4.3.3.4.

  34. 34.

    See Sect. 4.1.

  35. 35.

    Alamuddin 2010, p. 303; Triffterer 2008—Piragoff, Article 69, para 71.

  36. 36.

    See Sect. 4.3.3.5.3.

  37. 37.

    See A. and Others v. Secretary of State for the Home Department, House of Lords, decision of 8 December 2005, [2005] UKHL 71, paras 37 and 38 with further references.

  38. 38.

    A. and others v Secretary of State for the Home Department, Court of Appeal of England and Wales, decision of 11 August 2004, [2004] EWCA Civ 1123.

  39. 39.

    A. and Others v. Secretary of State for the Home Department, House of Lords, decision of 8 December 2005, [2005] UKHL 71, see in particular para 51. For a comprehensive discussion of this decision, see Thienel 2006, p. 401 et seq.

  40. 40.

    Klamberg 2013, p. 402.

  41. 41.

    See for instance Alamuddin 2010, p. 303, who quotes Prosecutor v. Nchamihigo (Decision on the Prosecutor’s Application to Admit into Evidence the Transcript of the Accused’s Interview as a Suspect and the Defence’s Request to Hold a Voir Dire), ICTR (Trial Chamber), decision of 5 February 2007, para 21: “It is well settled that a statement taken from a suspect would not be admitted into evidence at his trial if its rights during the investigation were not respected”. Similarly, see McKeever 2010, p. 627, who quotes Prosecutor v. Delalić et al., (Decision on Hazim Delic’s Motions Pursuant to Rule 73), ICTY (Trial Chamber), decision of 1 September 1997, para 15: “The principle that confessions made by accused persons in the absence of their volition and arising from threats, inducement or hope of favour by persons in authority is inadmissible in evidence is well settled […]”.

  42. 42.

    Ambos 2010, p. 383.

  43. 43.

    See Sect. 3.2.2.

  44. 44.

    Jalloh v. Germany, ECtHR, decision of 11 July 2006 (Application no. 54810/00), para 105: [I]ncriminating evidence—whether in the form of a confession or real evidence—obtained as a result of acts of violence or brutality or other forms of treatment which can be characterised as torture—should never be relied on as proof of the victim’s guilt, irrespective of its probative value.” See also Gäfgen v. Germany, ECtHR, decision of 1 June 2010 (Application no. 22978/05), para 167. The adverse effect of statements gained under torture on trial fairness can also be based on the right against self-incrimination, see Ambos 2010, p. 384; Thienel 2006, p. 404. This right is not explicitly mentioned in Article 6 of the ECHR. It appears however in Article 14(3)(g) of the ICCPR and has been held to be implied in the general right to a fair trial under Article 6(1) of the Charter, see Thienel 2006, p. 356.

  45. 45.

    Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, signed on 10 December 1984, entered into force on 26 June 1987, available at http://www.un.org/documents/ga/res/39/a39r046.htm (last visited: October 2013).

  46. 46.

    See Werle 2012, para 154. See also Sect. 2.3.2.2.

  47. 47.

    Thienel 2006, p. 365.

  48. 48.

    Werle 2012, para 157.

  49. 49.

    Roberts 2001, p. 757.

  50. 50.

    See GA Resolution 32/62 of 8 December 1977, available at http://www.un.org/Depts/dhl/resguide/r32.htm (last visited: October 2013).

  51. 51.

    UN GA Res. 59/182, para 6, available at http://www.un.org/ga/search/view_doc.asp?symbol=A/RES/59/182&Lang=E (last visited: October 2013). Altogether, see Thienel 2006, p. 365.

  52. 52.

    Thienel 2006, p. 365. See also Association Against Torture, ‘APT Background Paper on the Exclusionary Rule’, Background Bulletin, 2012, available at: http://www.apt.ch/en/evidence-obtained-through-torture/ (last visited: October 2013).

  53. 53.

    Werle 2012, para 156.

  54. 54.

    For a good example of this approach, see Nicaragua v. The United States of America (Case concerning military and paramilitary activities in and against Nicaragua), ICJ, decision of 27 June 1986, see in particular para 186 on the problem of inconsistent state behaviour.

  55. 55.

    For international criminal law, see Werle 2012, para 159.

  56. 56.

    Thienel 2006, p. 365.

  57. 57.

    Werle 2012, p. 155.

  58. 58.

    On the history of the Khmer Rouge torture evidence, see Scharf 2008, p. 136 et seq.

  59. 59.

    Prosecutor v. IENG Thirith (Order on the use of statements which were or may have been obtained through torture), ECCC (Office of the Co-investigating judges), decision of 28 July 2009. Other than for the ICC, UNCAT is directly applicable as a treaty to the ECCC. The ECCC formally remain part of the Cambodian domestic legal order and as such, they are bound by Cambodian law, see Zahar and Sluiter 2008, pp. 12 and 280. Cambodia has ratified the Convention in 1992, see the respective entry in the United Nations Treaty Collection, available at http://treaties.un.org/Pages/ViewDetails.asp?src=TREATY&mtdsg_no=IV-9&chapter=4&lang=en (last visited October 2013).

  60. 60.

    McKeever, p. 617.

  61. 61.

    Prosecutor v. IENG Thirith (Order on the use of statements which were or may have been obtained through torture), ECCC (Office of the Co-investigating judges), decision of 28 July 2009, paras 24 et seq. See also Safferling 2001, p. 503 et seq.

  62. 62.

    Prosecutor v. IENG Thirith (Order on the use of statements which were or may have been obtained through torture), ECCC (Office of the Co-investigating judges), decision of 28 July 2009, paras 24 et seq. With respect to deterrence, the ECCC Order refers to the lapse of time passed since the events took place, see para 24. The reliability concerns in turn are rejected with the assurance that the judges would take into account the problematic origin of the statements when evaluating the evidence, see para 28. Following a rather civil law oriented approach, the question of reliability is thus basically deemed a problem of weight rather than of admissibility.

  63. 63.

    Prosecutor v. IENG Thirith (Order on the use of statements which were or may have been obtained through torture), ECCC (Office of the Co-investigating judges), decision of 28 July 2009, para 24.

  64. 64.

    Scharf 2008, p. 154.

  65. 65.

    Ambos 2010, p. 381.

  66. 66.

    See Article 7(1)(f); Article 8(2)(a)(ii), alt. 1; Article 8(2)(c)(I), alt. 4 of the ICC Statute.

  67. 67.

    Similar, Ambos 2010, p. 381; McKeever 2010, p. 622.

  68. 68.

    On this distinction, see Sect. 4.3.2.2.5.

  69. 69.

    See Alamuddin 2010, p. 303.

  70. 70.

    See Sect. 4.3.3.3.

  71. 71.

    For a detailed explanation, see United States v. Lee, United States Court of Appeals for the Second District, decision of 7 June 2013, No. 12-0088-cr. See also Ambos 2010, p. 373; Scharf 2008, p. 152 et seq.

  72. 72.

    See United States v. Fernandez-Caro, United States District Court for the Southern District of Texas, decision of 2 September 1987, 677 F.Supp 893 (1987), with further references. This seems to be a further indication of the, albeit limited, recognition of integrity concerns for the U.S. exclusionary rule; see also Sect. 3.3.2.

  73. 73.

    See Sect. 4.3.2.2.3.

  74. 74.

    But see Gallant 1999, p. 719, who refers to the doctrine and suggests that the involvement of OTP could be the decisive factor for drawing a line between admissible and non-admissible evidence under Article 69(7) of the ICC Statute.

  75. 75.

    Regina v. Harrer, Supreme Court of Canada, decision of 19 October 1995, [1995] 3 S.C.R. 56, para 13. On the application of the Canadian Charter where Canadian officials are involved in enforcement measures abroad, see Rennie and Rothschild 2009, p. 127 et seq.

  76. 76.

    See Sect. 4.2.2.2.5.

  77. 77.

    See Sect. 4.3.3.4.

  78. 78.

    Prosecutor v. Delalić et al. (Decision on Zdravko Mucic’s Motion for the Exclusion of Evidence), ICTY (Trial Chamber), decision of 2 September 1997, paras 46 et seq.

  79. 79.

    See Alamuddin 2010, p. 301.

  80. 80.

    See Sect. 4.3.3.1.

  81. 81.

    Alamuddin 2010, p. 301. See also Gallant 1999, p. 719; Sluiter 2002, p. 226.

  82. 82.

    See for instance Prosecutor v. Mrkšić (Decision Concerning the Use of Statements Given by the Accused), decision of 9 October 2006; Prosecutor v. Barayagwiza (Decision), ICTR (Appeals Chamber), decision of 3 November 1999, para 61. See also Alamuddin 2010, p. 301; Sluiter 2002, p. 226.

  83. 83.

    Prosecutor v. Lubanga (Decision on the admission of material from the ‘Bar Table’), ICC (Trial Chamber), decision of 24 June 2009, para 47.

  84. 84.

    See Sect. 4.2.

  85. 85.

    On such contracts, see Prosecutor v. Lubanga (Judgment pursuant to Article 74 of the Statute), ICC (Trial Chamber), decision of 14 March 2012, paras 203, 204.

  86. 86.

    Prosecutor v. Lubanga (Judgment pursuant to Article 74 of the Statute), ICC (Trial Chamber), decision of 14 March 2012, para 185.

  87. 87.

    Prosecutor v. Lubanga (Judgment pursuant to Article 74 of the Statute), ICC (Trial Chamber), decision of 14 March 2012, para 191.

  88. 88.

    Given the prospect of relocation for victims, there is a danger that witnesses may be motivated to give false testimony by pointing out the financial benefits, see Buisman 2013, p. 60 et seq.

  89. 89.

    Prosecutor v. Lubanga (Judgment pursuant to Article 74 of the Statute), ICC (Trial Chamber), decision of 14 March 2012, para 191.

  90. 90.

    Prosecutor v. Haraqija and Morina (Decision on Haraqija and Morina’s Second Request for a Declaration of Inadmissibility and Exclusion of Evidence), ICTY (Trial Chamber), decision of 24 November 2008, para 20, 26; Prosecutor v. Haraqija and Morina (Judgment), ICTY (Appeals Chamber), decision of 23 July 2009, para 28; Prosecutor v. Brđanin (Decision on the Defence “Objection to Intercept Evidence”), ICTY (Trial Chamber), decision of 3 October 2003, para 63. See also Sect. 3.1.4.

  91. 91.

    See Sect. 3.3.1.

  92. 92.

    See Regina v. Walsh, Court of Appeal of England and Wales, decision of 13 July 1989, [1990] 91 Cr. App R. 161; Regina v. Alladice, Court of Appeal of England and Wales, decision of 8 May 1988, [1988] WL 624104. See also Mellifont 2007, p. 86. See also Sect. 3.3.3.

  93. 93.

    See Regina v. Grant, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 353, para 75; see also Sect. 3.3.4.

  94. 94.

    See United States v. Leon, United States Supreme Court, decision of 5 July 1984, 468 U.S. 897 (1984). See also Arizona v. Evans, United States Supreme Court, decision of 1 March 1995, 514 U.S. 1 (1995); more recently Herring v. United States, United States Supreme Court, decision of 14 January 2009, 07-513 (2009); see also Sect. 2.3.2.

  95. 95.

    Similar Alamuddin 2010, pp. 231 and 305.

  96. 96.

    Eberdt 2011, pp. 73 and 82.

  97. 97.

    German Federal Supreme Court (BGH), decision of 12 April 2005, Neue Juristische Wochenschrift 2005, p. 1917 et seq.

  98. 98.

    Meyer-Goßner 2013, Section 98, para 7.

  99. 99.

    United States v. Leon, United States Supreme Court, decision of 5 July 1984, 468 U.S. 897 (1984).

  100. 100.

    Regina v. Harrison, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 494, para 22.

  101. 101.

    Regina v. Grant, Supreme Court of Canada, decision of 17 July 2009, [2009] 2 S.C.R. 353, para 75. For a similar assessment with respect to domestic exclusionary rules in general, see Slobogin 2013, p. 19.

  102. 102.

    Meyer-Goßner 2013, Section 98, para 7.

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    Petra Viebig

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Viebig, P. (2016). Factors in the Balancing Exercise. In: Illicitly Obtained Evidence at the International Criminal Court. International Criminal Justice Series, vol 4. T.M.C. Asser Press, The Hague. https://doi.org/10.1007/978-94-6265-093-0_5

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