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EDAL case summaries

France - Council of State, 26 January 2011, Mr. A., n°312833

Country of Decision: France
Country of Applicant: Rwanda
Keywords: Genocide, Exclusion from protection

Passive complicity in genocide includes a material element and an intentional element, as active complicity does.
Date: 26-01-2011

France - Council of State, 14 June 2010, M. A., n°320630

Country of Decision: France
Country of Applicant: Rwanda
Keywords: Genocide, Family unity (right to), Exclusion from protection

Serious reasons have to be established in order to apply the exclusion clause in Article 1F(a) of the 1951 Refugee Convention, i.e. the material and intentional elements specific to the complicity.
Date: 14-06-2010

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