# Example — verifying a single citation end-to-end

A worked example of the verification workflow applied to one citation. This shows the discipline in action; it is illustrative, not a script to follow mechanically.

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## The request

The user is drafting a memo and writes:

> "As the ICTY first held, the Srebrenica massacre of July 1995 constituted genocide. Can you give me the citation with the paragraph?"

## Step 0 — Identify the document(s) implicated

The proposition is "Srebrenica = genocide, first so held by the ICTY". The case that established this at trial is **Krstić** (IT-98-33). There are two candidate documents: the Trial Judgment (IT-98-33-T, 2 August 2001) and the Appeal Judgment (IT-98-33-A, 19 April 2004). The user said "first held", which points to the Trial Chamber. But note a subtlety to confirm: the Appeals Chamber refined Krstić's own *mode of liability* (from committing to aiding and abetting genocide) while affirming that genocide *occurred* at Srebrenica. So the precise claim and the precise paragraph matter.

## Step 1 — Plan the citation

One citation is needed: the Krstić Trial Judgment, for the proposition that the Srebrenica massacre constituted genocide. If the memo also asserts something about Krstić's individual liability, a second citation (the Appeal Judgment) will be needed, because the holding on his liability changed on appeal.

## Step 2 — Verify with the fallback ladder

1. **irmct.org / case page.** Search the case list for Krstić. Confirm: case number IT-98-33, ICTY, Trial Chamber judgment 2 August 2001, Appeals Chamber judgment 19 April 2004. Existence verified.
2. **Case Law Database (cld.irmct.org).** Query the finding "Srebrenica genocide". The CLD points to the relevant paragraphs of the Trial Judgment where the Chamber concluded that the intent to destroy the Bosnian Muslims of Srebrenica as a group was established. Note the paragraph range the CLD identifies.
3. **Open the Trial Judgment** (via irmct.org / legacy icty.org / legal-tools.org) and read the identified paragraphs to confirm the proposition is stated there — **paragraph verified**.

If the CLD or the judgment cannot be reached in-session, drop to: confirm existence and the holding-in-substance from the case page (content verified), and tell the user the paragraph was not confirmed.

## Step 3 — Draft

> The Trial Chamber in *Prosecutor v. Krstić* held that the massacre of the Bosnian Muslim population of Srebrenica in July 1995 constituted genocide: *Prosecutor v. Krstić*, Case No. IT-98-33-T, Judgment (Trial Chamber), 2 August 2001. On appeal, the Appeals Chamber affirmed that genocide was committed at Srebrenica while revising the basis of Krstić's own liability to aiding and abetting genocide: *Prosecutor v. Krstić*, Case No. IT-98-33-A, Judgment (Appeals Chamber), 19 April 2004.

(If paragraph verification succeeded, add the paragraph numbers. If it did not, state that the paragraph was not confirmed in this session.)

## Step 4 — Self-audit

- Is "first held" accurate? Krstić was the first ICTY judgment to characterise Srebrenica as genocide — confirm this framing against the record rather than asserting primacy from memory; if not confirmable, soften to "held".
- Is the trial vs appeal distinction respected? Yes — the draft separates the genocide-occurred holding (trial, affirmed on appeal) from the mode-of-liability holding (revised on appeal). This is exactly the kind of distinction that a memorised citation would blur.
- Diacritics correct? Krstić. Yes.

## The lesson

The danger here was not inventing a case — Krstić is well known — but **overstating what the cited document holds** and **blurring the trial/appeal distinction**. The verification step is what catches that. The output is honest about its verification level and precise about which chamber held what.