intention of the perpetrators did not specifically intend to commit genocide, are a grey area. William Schabas makes the point that genocidal massacres are criminal offences under international law as a crime against humanity, and during an armed conflict under the laws of war. However he points out that international prosecutions for individual acts are not covered by the Rome Statute (which brought into existence the International Court of Justice) because crimes against humanity must be "widespread or systematic" and war crimes usually have to have a threshold above the individual crime "in particular when committed as part of a plan or policy or as part of a large-scale commission of such crimes". Irving Louis Horowitz is critical of Kuper's approach. He cites Kuper's use of the term genocidal massacre to describe the inter-communal violence during the partition of India and during The Troubles in Northern Ireland. Hirsh states "to speak of [these] as genocidal in a context of religious competition and conflict risks diluting the notion of genocide and equating it with any conflict between national, religious, or racial groups". Definitions This is a list of scholarly definitions of genocide massacre, a phrase coined by Leo Kuper. See also Outline of Genocide studies Notes References Further reading Bibliography of Genocide studies Massacre Genocidal massacres