On 18 December 1992 , the United Nations General Assembly resolution 47/121 in its preamble deemed ethnic cleansing to be a form of genocide stating : On 12 July 2007 , in its judgement on the '' Jorgić v. Germany '' case , the European Court of Human Rights noted that : In 2001 , the International Criminal Tribunal for the Former Yugoslavia ( ICTY ) judged that the 1995 Srebrenica massacre was genocide . In the unanimous ruling '' Prosecutor v. Krstić '' , the Appeals Chamber of the International Criminal Tribunal for the former Yugoslavia ( ICTY ) , located in The Hague , reaffirmed that the Srebrenica massacre was genocide , the Presiding Judge Theodor Meron stating : In September 2006 , former Bosnian Serb leader Momcilo Krajišnik was found guilty of multiple instances of crimes against humanity , but while the ICTY judges found that there was evidence that crimes committed in Bosnia constituted the criminal act of genocide ( '' actus reus '' ) , they did not establish that the accused possessed genocidal intent , or was part of a criminal enterprise that had such an intent ( '' mens rea '' )
Srebrenica massacre
Srebrenica massacre
Bosnian genocide