Claude MUHAYIMANA – Paris appeal court FINALLY confirms his genocide guilt


UPDATE – 27 February 2026
The Paris Appeal court has upheld the original 2021 trial judgement of GUILTY, and the sentence of 14 years, against Claude Muhayimana, the 65 year-old former driver and hotel worker from Kibuye. After nearly nine hours of deliberating, at 7.40 pm on Friday 27 February, the court president Sabine Raczy announced the judgement and sentence. Muhayimana was found to have driven the notorious interahamewe militia to take part in wide scale massacres of Tutsi in the region of Kibuye and the hills of Bisesero. The presiding judge told the accused: “The Court and the jury have found that crimes of genocide and crimes against humanity were committed, through deliberate attacks on life or serious attacks on physical and mental integrity. (…) The court has decided that Claude MUHAYIMANA cannot benefit from the grounds for criminal irresponsibility provided for in Article 122-2 of the Criminal Code. Consequently, the court sentences Claude MUHAYIMANA by an absolute majority to 14 years’ imprisonment for complicity in genocide and crimes against humanity committed at the sites of GITWA, KARONGI and the hills of BISESERO in KIBUYE, Rwanda. The decision is valid as a committal order.”
The hearing was adjourned at 8 p.m.
The three week appeal case began of 3 February, more than four years after his trial. During this period, Muhayimana had spent much of this time not only free but happily enjoying a normal life working in Rouen where he lived. On Monday, local government officials in Rouen announced they were enacting immediate disciplinary proceedings against Muhayimana, who had been employed by them as a road worker with the city. He would receive no compensation! One has to question how the Rouen city council thought it was a good idea to employ a man convicted of complicity in genocide – or perhaps that is what they want their city to be known for?
Unsurprisingly, survivors were also less than impressed with the lenient sentence – 14 years for complicity in genocide and crimes against humanity seems to value Rwandan lives in the most frivolous of ways. Especially when compared to very heavy sentences received by domestic terrorists for killings in France eg the Bataclan attacks.
Muhayimana, who again pleaded innocence, was in tears when the verdict was delivered and was taken off to begin his sentence in Fresnes prison.
Alain Gauthier, whose tireless efforts and that of his wife Dafroza and his civil party organisation (CPCR) which helped to bring the case noted: “This appeal trial was a carbon copy of the first one. What a waste of time! We heard the same witnesses and, above all, the same lies from the defendant, who persists in ignoring the crimes he committed.” Given the dozens of genocide cases still awaiting any form of initial trial, it seems bizarre that time and money is spent rerunning the cases on appeal – all of which so far in the eight cases French justice has heard have just rubber stamped the initial trial findings.’
For a daily account of the appeal case please click HERE to see the CPCR website (in French)
Trial: PARIS ASSIZE COURT November – December 2021
A daily account of Muhayiman’s trial in Paris can be found HERE (pdf).
Claude Muhayimana’s trial took place before the Paris Criminal Court (Cour d’assises) between 22 November and 16 December 2021. Muhayimana was found guilty of complicity in genocide and complicity in crimes against humanity for transporting militiamen to various massacre sites during the genocide. He was sentenced to 14 years’ imprisonment.
Muhayimana was born in 1961 and was a driver at a hotel commonly known ‘Kuri Guest’ in Kibuye town, in western Rwanda. During the 1994 genocide against the Tutsi he was accused of organising the transport of Interahamwe militia to several places where attacks against Tutsis occurred e.g. Nyamishaba School (Karongi district) in April 1994 where Tutsi had sought refuge; He was also accused of having participated in killings carried out in the Kibuye church on April 17, 1994, and the following day in a nearby Gatwaro stadium and Home St. Jean. The massacres resulted in the death of thousands of Tutsi.
Despite witnesses who testified to Muhayimana taking part in the killings, the judges believed the accused when he said he was absent from the Kibuye town area at the time of the massacres there, because he was transporting the body of a dead gendarme to Ruhengeri. The gendarme, called Mwafrica, had himself been killed while taking part in genocidal killings of Tutsi in the hills of Bisesero.
Guilty of Complicity in Genocide – but set free:
Muhayimana appealed the verdict of his December 2021 trial. In a ruling dated 25 August 2022, the Paris Court of Appeal rejected, for the second time, Muhayimana’s request for release while awaiting the appeal hearing. An initial application had been rejected on 23 March 2022.
The Court of Appeal stated that ‘Claude MUHAYIMANA is detained notwithstanding his appeal in application of Article 367 of the Code of Criminal Procedure, the Assize Court’s decision being equivalent to a detention order. Despite the arguments developed in his counsel’s application for release, his pre-trial detention is still the only way to guarantee that he remains at the disposal of the justice system [… …] and to put an end to the exceptional and persistent disturbance of public order caused by the seriousness of the offence, the circumstances of its commission and the extent of the harm caused, in the case of systematic massacres perpetrated on a large scale on part of the Rwandan population because of its ethnicity, which have permeated the collective memory so that release could reactivate the suffering endured […] Finally, the Court notes that Claude MUHAYIMANA was tried at first instance on 16 December 2021. The pre-trial detention does not now appear to be contrary to the requirements of a reasonable time within the meaning of Article 6 & 1 of the European Convention for the Protection of Human Rights and Fundamental Freedoms, particularly in view of the investigations undertaken, in particular abroad, the number of witnesses heard, the numerous interrogations conducted and the complexity of the case. Consequently, the application should be rejected’.
However, four months later, on 6 January 2023 it was announced that despite his conviction for the most serious of all crimes, Muhayimana was to be set free while his appeal was pending. The judicial decision came after two previous refusals (detailed above) and without the civil parties in the case being informed either that the defence had made a third request for their convicted client to be released, or that the case was being heard or the eventual decision. It would seem the ‘seriousness of the offence’ is now no bar to freedom.
A date for Muhayimana’s appeal case has still to be set as of January 2023, and he remains free despite his conviction. Another triumph of French justice.
Case Background:
Muhayimana obtained French citizenship in 2010, He lived in Rouen, France. On 13 December 2011, Rwandan judicial authorities issued an international arrest warrant against Muhayimana for his alleged participation in the Rwandan genocide and requested his extradition from France.
On 29 March 2012, the investigative Chamber of the Rouen Court of Appeals issued a favourable opinion on the issue of Muhayimana’s extradition to Rwanda. The Court considered that the fundamental guarantees of a fair trial and the rights of the defense would be ensured in Rwanda. Muhayimana appealed this decision arguing the opposite. Finally, on 24 February 2014, the French Supreme Court (Cour de Cassation) ruled that Muhayimana could not be extradited because Rwanda’s application was based on laws against genocide that were not in place when the alleged crimes took place.
On 9 April 2014, Muhayimana was arrested in Rouen following a complaint filed in June 2013 by the Collectif des Parties Civiles pour le Rwanda (CPCR). A criminal investigation was launched regarding his alleged role in the genocide committed in the district of Kibuye, and he was placed in pre-trial detention. On 3 April 2015, Muhayimana was released and placed under judicial supervision.
On 9 November 2017, the examining magistrate referred the case to the Criminal Court in Paris (Cour d’Assises) for complicity in genocide and crimes against humanity through aiding and abetting.
The Prosecutor called for the dismissal of the accusations regarding the massacres committed in the Kibuye church and in the Gatwaro stadium, as Muhayimana presented an alibi proving that he was not there during the events. Muhayimana appealed the decision on the referral.
The appeal hearing on the decision to refer the case to the competent court took place on 18 October 2018 before the Investigation Chamber of the Court of Appeals in Paris.
On 4 April 2019, the Court of Appeals confirmed the referral of Muhayimana’s case to the Criminal Court for complicity in crimes against humanity and genocide. The trial, initially scheduled from 29 September to 26 October 2020 was delayed due to the covid-19 pandemic.