id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cjgl-10717	Noemí Pérez Vásquez; Liiri Oja	A Change of Narrative: Protecting Sexual and Reproductive Rights in Post-Conflict Criminal Justice	2023	36	.pdf	application/pdf	15560	531	38	B. Dealing with Uncodified Harms in International Criminal Law Despite an increased attention to sexual violence by international criminal courts and the enumeration of a wide range of sexual violence crimes in the Rome Statute, many other types of gender-based violence, including reproductive violence, remain largely invisible in the study and the practice of international criminal law.81 For instance, as Grey notes, the ICC Statute is silent on forced impregnation, forced miscarriage, and persecution on the grounds of pregnancy, examples of crimes that should be included.82 As such, she continues, because reproductive autonomy is a distinct value from sexual autonomy, where possible, conduct which offends this value should be punished as a separate crime.83 77 Id. at 9, 283–284. Human Rights Watch also later established that virtually every Tutsi woman and adolescent girl who survived the genocide had been raped, and the U.N. Special Rapporteur in Rwanda, extrapolating from the number of unwanted pregnancies after the genocide (calculating that 100 cases of rape result in one pregnancy), estimated that the total number of women raped was much higher, ranging from 250,000 to 500,000.43 Despite this, the ICTR neither prosecuted acts of forced pregnancy nor argued that the commission of enforced sterilization and forced contraception without a genocidal intent could be considered a crime under international law.44 In the Akayesu case—the first conviction where an institution recognized rape and sexual violence as a means of perpetrating genocide45—although “rape was not originally included in the charges,” it was later added under the insistence of some judges and civil society.46 In that case, the judgment only touched upon reproductive violence in the context of the genocide in recognizing that forced impregnation could, in some circumstances, amount to the crime of genocide if there is an intent to prevent births within a group.47 We agree with Altunjan in 41 De Vos, supra note 38; Altunjan further argues that, despite the fact that the Trial Chamber also stated that “[t]he systematic rape of women . . .	cache/cjgl-10717.pdf	txt/cjgl-10717.txt