Slav and Soviet citizens under the Nazi occupation, and the Holodomor were not, legally, genocide. In his book he summarizes the legal opinions regarding the status of the atrocities committed in Bosnia, deeming them ethnic cleansing and not genocide, stating that "Ethnic cleansing is also a warning sign of genocide to come. Genocide is the last resort of the frustrated ethnic cleanser." Schabas also criticises the United Nations General Assembly for recognising ethnic cleansing as genocide. In March 1993, Schabas co-authored the Report of the Commission of Inquiry into Human Rights Violations in Rwanda. In a later book, War Crimes and Human Rights (Cambridge University Press, 2008), Schabas states that the killings by the Khmer Rouge in Cambodia during the late 1970s lacked "the ethnic dimension that is part of the essence of the crime [of genocide]." Schabas took the same position in 2001 in his article "Cambodia: Was it Really Genocide?" Further, while he strongly condemns the atrocities in Darfur in War Crimes and Human Rights, Schabas says that they should not be labelled genocide because "the summary execution" of non-Arabs in Darfur "does not establish genocidal intent." In War Crimes and Human Rights he also criticises the International Criminal Tribunal for the Former Yugoslavia for finding a joint criminal enterprise to commit genocide in Srebrenica. In 10 to 12 December 2019, Schabas represented the Myanmar government, protecting Myanmar genocide with his expertise in the International Court of Justice (ICJ) hearing in Peace Palace in The Hague, Netherlands. His appearance before the ICJ defending Burmese Government accused of committing genocide on Rohingya Muslim minority drew criticism and condemnation from individuals and organizations involved in human rights protection. Phil Robertson, Deputy Asia Director at Human Rights Watch, stated: "William Schabas is basically selling out the Rohingya for some Myanmar gov’t $$$. Really the worst sort of behavior, how totally immoral and two-faced". Stephen J Rapp, a former United States war crimes ambassador who works at the Holocaust museum, who contended saying it as, "We have heard this morning from my friend Bill Schabas, I was just with him 10 days ago. I prosecuted genocide, we obtained convictions for this crime. He is wrong about the law: this was a genocide." Schabas stated: "Both sides have a right to have competent representation. If people don’t understand that, that’s not my problem." Middle East conflict Statements In 2011, the same year Schabas