# Example — verifying an SCSL citation end-to-end

A worked example for the forced-marriage finding in the AFRC Appeal Judgement.

## The request

The user is writing on forced marriage as a crime against humanity and asks:

> "What's the citation for the SCSL's first holding that forced marriage is a crime against humanity? With the paragraph numbers?"

## Step 0 — Identify the document

The proposition rests on the **AFRC Appeal Judgement** — *Prosecutor v. Brima, Kamara and Kanu*, Case No. SCSL-04-16-A, Appeals Chamber, **22 February 2008**.

**Important context (Trap 5):** the *Trial Chamber* did **not** recognise forced marriage as a distinct crime — it subsumed forced marriage into sexual slavery. The Appeals Chamber **reversed** this and recognised forced marriage as an "other inhumane act" under Statute Art. 2(i). A citation to the Trial Judgement of 20 June 2007 for this proposition would be incorrect.

## Step 1 — Plan the citation

The user wants the case, the paragraphs, and the propositional content. The form:

> *Prosecutor v. Brima, Kamara and Kanu*, Case No. SCSL-04-16-A, Judgement (Appeals Chamber), 22 February 2008, paras 175-203.

The Appeals Chamber held forced marriage to be an "other inhumane act" crime against humanity, distinct from sexual slavery, by reference to the conjugal nature of the imposed relationship and the attendant duties imposed on the victim.

## Step 2 — Verify

1. **rscsl.org/AFRC.html.** Locate the AFRC case page. The Appeal Judgement of 22 February 2008 is listed as the principal Appeal-stage document.
2. **Open the Appeal Judgement PDF.** Confirm the date (22 February 2008), the case number (SCSL-04-16-A), the Chamber (Appeals Chamber).
3. **Locate the forced-marriage discussion.** The relevant section discusses the Trial Chamber's classification and the Appeals Chamber's reasoning for recognising forced marriage as a distinct "other inhumane act". Paragraphs 175-203 (approximate range — verify exact paragraphs against the text).

**Content verified.** For specific quotations, fetch the relevant paragraphs and confirm exact wording.

## Step 3 — Draft

> The SCSL Appeals Chamber in the AFRC case was the **first international tribunal to recognise forced marriage as a distinct crime against humanity** under the category of "other inhumane acts" (Statute Art. 2(i)). The Trial Chamber had subsumed forced marriage into sexual slavery; the Appeals Chamber reversed, reasoning that forced marriage involves distinct conduct — the imposition of a conjugal relationship with attendant duties (forced labour, forced childbearing, social stigma) — that is not exhausted by sexual slavery. *Prosecutor v. Brima, Kamara and Kanu*, Case No. SCSL-04-16-A, Judgement (Appeals Chamber), 22 February 2008, paras 175-203. The holding was subsequently affirmed in the RUF Trial Judgement (2 March 2009), the Taylor Trial Judgement (18 May 2012), the ECCC Case 002/02 Trial Judgement (16 November 2018), and the ICC's *Ongwen* Trial Judgment (4 February 2021).

## Step 4 — Self-audit

- Case number SCSL-04-16-A — correct (AFRC, Appeals stage).
- Date 22 February 2008 — verified.
- Chamber (Appeals Chamber) — correct.
- Trap 5 avoided — the holding is attributed to the Appeals Chamber, not the Trial Chamber.
- Subsequent applications correctly cited.

## The lesson

The audit catches **Trap 5** — the forced-marriage holding is an *Appeals Chamber* development; the Trial Chamber declined to recognise it. The honest output identifies the procedural posture correctly and traces the subsequent international acceptance of the holding.