Guinea

On 22 December 2008, Captain Moussa Dadis Camara took power in a bloodless coup, which ended fifty years of rule characterised by undemocratic governance and the systematic violation of human rights under two successive presidents, Ahmed Sékou Touré (1958 to 1984) and Lansana Condé (1984 to 2008). Despite his promise to introduce democratic reforms, Dadis Camara instead entrenched military rule, committed widespread human rights violations, and failed to hold long-promised elections.

 

On 28 September 2009, tens of thousands of opposition supporters gathered in Conakry Stadium. At 11:30 am, several hundred members of the security forces entered the stadium and opened fire on the crowd, killing at least 156 people and injuring or sexually assaulting more than 1400 others. In the days that followed, security forces continued to commit rape, murder and looting in neighbourhoods primarily populated by opposition supporters. The Guinean authorities and security forces engaged in a cover-up of the massacre, destroying evidence and removing bodies.

 

An International Commission of Inquiry mandated by the UN Secretary General concluded that crimes against humanity were committed in widespread and systematic attacks by state security forces against the civilian population on September 28 and in the following days. The Commission confirmed that at least 156 persons were killed, hundreds of persons were tortured or suffered other inhumane treatment, and at least 109 women were subjected to rape and other acts of sexual violence, including mutilation and sexual slavery. 

A parallel civil society investigation led by Human Rights Watch concluded that the crimes were not the actions of a rogue group of soldiers but an organised and coordinated attack on civilians. Investigations into these crimes were initiated at both the national and international level.

The country’s first free and fair presidential elections, which were held in December 2010 while Dadis Camara was outside the country recovering from an assassination attempt, were won by opposition leader Alpha Condé, first freely elected president of the country. Although he pledged to implement democratisation and strengthen the rule of law, his tenure was marred by accusations of corruption and political violence, which continued to be perpetrated during regional and national elections. 

In 2020, Condé secured a third term as president, following a constitutional referendum boycotted by the opposition. However, on 5 September 2021, Condé was ousted by an elite army unit led by Commander Mamady Doumbouya, who was sworn in as interim president on 1 October 2021. On 17 January 2026, Doumbouya officially took office as president of the country after winning the widely criticised 2025 Guinean presidential elections.

Commentary & Reports

United Nations Security Council (2009) Report of the International Commission of Inquiry mandated to establish the facts and circumstance of the events of 28 September 2009 in Guinea (EN/FR)

In October 2009 the UN Secretary General established an international commission of inquiry into the events of 28 September 2009. The Report concluded that the Guinean security forces committed crimes against humanity during the attack and in the days that followed.  

Human Rights Watch “Bloody Monday: The September 28 Massacre and rapes by Security Forces in Guinea” 2009 (EN/FR)

In the immediate aftermath of the September 2009 attacks, Human Rights Watch conducted an in-depth investigation into the events, basing their research on interviews with 240 witnesses.  

Accountability in Guinea

Priorities and challenges for strengthening accountability for international crimes in Guinea

FOLLOW THE TIMELINE BY CLICKING ON THE ARROWS​
1 October 2003
Guinea comes under International Criminal Court jurisdiction

Guinea deposits its instrument of ratification to the Rome Statute on 14 July 2003, and giving the ICC has jurisdiction over Rome Statute crimes committed on the territory of Guinea or by Guinean nationals from 1 October 2003 onwards.

 
 
 
22 December 2008
Long-time president Lansana Conté dies in office

Conté, a soldier, led Guinea from 1984 after taking over in a coup d'Etat until his death.

 
 
 
23 December 2008
"Christmas Coup"

Hours after the announcement that Lansana Conté has died, Captain Moussa Dadis Camara read a statement on behalf of the Conseil National de la Démocratie et du Développement (CNDD) announcing that the constitution had been dissolved. A day later, Captain Camara was announced the President of the CNDD and with Camara promising "credible and transparent presidential elections by the end of December 2010." Sékouba Konaté becomes the vice president and minister of defense.

28 September 2009
Stadium massacre

More than 150 peaceful protesters are massacred, hundreds more wounded, and more than a hundred women are victims of rape and other forms of sexual violence by security forces during an opposition rally at a stadium in Conakry. Security forces continue to commit abuses for several days in neighbourhoods largely inhabited by opposition supporters.

 
14 October 2009
International Criminal Court prosecutor indicates that the situation in Guinea is under preliminary examination

Guinea's then-minister of foreign affairs travels one week later to The Hague to meet with the ICC Office of the Prosecutor, where he tells ICC Deputy Prosecutor Fatou Bensouda that Guinea’s justice system is “able and willing” to handle the investigation and prosecution of the stadium crimes domestically

 
30 October 2009
United Nations commission of inquiry established

An international commission of inquiry, proposed by the African Union and the Economic Community of West African States (ECOWAS), is established by UN Secretary-General Ban Ki-moon.

 
 
 
3 December 2009
Assassination attempt

Moussa Dadis Camara is shot by Lieutenant Abubakar "Toumba" Diakite. Diakite commanded Guinea’s presidential guard, also known as the Red Berets. In an interview with Radio France International  he shot Camara on 3 December because the junta leader wanted him to take the blame for a massacre of pro-democracy demonstrators.

17 December 2009
International commission of inquiry issues final report

The commission concludes that at least 156 people were killed or had disappeared, and at least 109 women were victims of rape and other forms of sexual violence.

 
15 January 2010
Sékouba Konaté takes over duties
January 2010
National commission issues report

The National Independent Commission of Inquiry established by the Guinean authorities concludes that murders, rapes, and forced disappearances have been committed.

 
 
January 2010
International Criminal Court representatives visit Guinea for the first time

Since its first visit in 2010, the ICC has conducted regular visits to Guinea—averaging roughly twice a year—to assess progress in the investigation and press for further advances.

 
8 February 2010
Domestic panel of judges appointed to investigate crimes committed

Panel quickly charge Abubakar “Toumba” Diakité, Guinea’s self-proclaimed president Moussa Dadis Camara's aide-de-camp, for his alleged role in crimes committed in the stadium massacre and rapes.

 
 
May 2010
Civil action from civil society groups

The International Federation for Human Rights and the  Guinean Organization for the Defense of Human Rights and the Citizen (OGDH) L'Organisation Guinéenne de Défense des Droits de l'Homme et du Citoyen initiate a partie civile action on behalf of victims’ associations and dozens of individual victims of the 28 September 2009 crimes.

 
27 June 2010
Cellou Dalein Diallo leads after first round of presidential elections

Diallo, who was Prime Minister of Guinea from 2004 to 2006, took the lead after the first round of delayed elections.

 
7 November 2010
Alpha Condé wins 2010 presidential elections in second round

After a delayed run-off vote, long-time opposition leader Alpha Condé wins the election beating Diallo in the second round.  

 
21 December 2010
Alpha Condé assumes office as president
August 2011
Provisional Commission for Reflection on National Reconciliation (CPRN) established by President Condé

Two leading religious figures head the commission, Elhadj Mamadou Saliou Camara, the Grand Imam of Conakry Mosque, and Monseigneur Vincent Coulibaly, Archbishop of Conakry. The commission issues its report in 2016, resulting in amendments to Law on National Reconciliation. Civil society groups express concern that little progress has been made towards implementing the foreseen reconciliation process in the period since.

 
1 February 2012
Minister charged

Moussa Tiégboro Camara, minister in charge of fighting drug trafficking and organised crime, is charged for his alleged role in crimes committed during the stadium massacre and rapes. Investigations were essentially suspended, however, from May to September 2012, due to serious shortcomings in resources available to the panel of investigative judges.

 
February 2013
Torture indictments

The Governor of Conakry, Commander Sékou Recso Camara, and General Nouhou Thiam, Chef of the General Staff of the Armed Forces, were indicted for ‘acts of torture’ committed in October 2010 under the transitional government of General Sékouba Konaté. Governor Camara was dismissed from his post the following month. Though not directly related to the 2009 Stadium massacre, the indictment of two high-level military and political actors for grave crimes committed under the former regime was an important step towards ending impunity. The trial has been delayed multiple times, with the most recent postponement in 2018.

30 April 2013
First indictment for 2009 stadium massacre and its aftermath

A Guinean gendarme was arrested and charged with rape in connection with the September 2009 stadium massacre and its aftermath. As the first indictment of an accused perpetrator of sexual violence during those events, the charging of the unnamed officer was a significant step in the judicial process. However, in a 2019 statement, the Office of the UN Special Representative on Sexual Violence in Conflict emphasised that perpetrators of sexual violence committed during the 2009 attacks still had not faced justice. 

 
27 June 2013
Presidential security minister charged

Lt. Col. Claude “Coplan” Pivi, Minister for Presidential Security and leader of the ‘red beret’ presidential guard, was charged for his alleged role in the crimes committed in the stadium in September 2009. Pivi was not put on leave from his government post despite the charges against him.

January 2014
Cheick Sako appointed justice minister

The appointment of Justice Minister Cheick Sako is widely credited with helping to energise progress in the investigation. Sako’s appointment leads to an increase in the number of security force members questioned.

 
11 May 2015
Moussa Dadis Camara announces candidacy for 2015 elections

The former president announced his candidacy despite being under investigation for crimes against humanity committed during the 2009 stadium massacre. At the time of the announcement, Guinean courts had issued an indictment requesting that Burkina Faso extricate Camara back to Guinea.

 
June 2015
Ex-soldier accused of acts of torture at military camp

Accusations of torture against protesters detained at the military camp Koundara in the weeks following the 2009 stadium massacre lead to the arrest and charging of an ex-soldier. The case is significant as the first pertaining to crimes committed in the aftermath of September 28 against "dozens" of persons illegally detained and tortured in the detention centres and barracks.

8 July 2015
Former President Moussa Dadis Camara questioned

Former President Camara is questioned in Burkina Faso, where he remains in exile, and charged by the Guinean judges for his alleged role in crimes committed in the stadium.

 
 
 
11 October 2015
Alpha Condé wins second term as president
7-11 April 2016
National consultations on transitional justice held around the country

As with their counterparts established in Togo and Burundi, their aim was to allow the Guinean population to talk about which mechanisms of the transitional justice system should be implemented with a view to national reconciliation. Over 9,000 people are consulted. It is determined that the needs expressed as a priority by the Guineans questions related to the right to historic truth and the right to justice, along with a reparations strategy, in particular through the state’s official recognition of the crimes perpetrated under the different regimes in power in Guinea since 1958.

 
July 2016
New Penal Code and New Penal Procedure Code adopted by the National Assembly

Crimes against humanity, genocide, persecution and torture now feature in the Guinean Penal Code, in which the prescribed penalty for the most serious crimes is life in prison. The new criminal code also eliminates the death penalty and explicitly outlaws torture for the first time. However, human rights watchdogs note that the criminal code categorised a number of acts that fall within the international definition of torture as merely “inhuman and cruel,” a category that does not carry any explicit penalties in the code. In practice, security forces continue to engage in torture and other forms of physical violence with apparent impunity.

16 December 2016
Abubakar “Toumba” Diakité arrested in Dakar

Diakité, on the run since December 2009, is arrested in Senegal. Toumba commanded Guinea’s presidential guard, also known as the Red Berets, at the time of the 2009 crimes.

 
 
 
10 February 2017
President Macky Sall of Senegal signs Diakité extradition order
12 March 2017
Diakité extradited from Senegal to Guinea

He is incarcerated at Conakry prison facility and efforts are made to ensure that he has a clean and secure individual cell that complied with international detention standards.

 
14 March 2017
Diakité indicted

A panel of investigative judges questions Diakité at the end of March 2017.

 
29 December 2017
Diakité investigation is complete

Justice minister Cheick Sako announces that the investigation has been referred for trial in Conakry. More than a dozen suspects are charged, and Diakité is in Guinea’s custody after Senegal extradited him. In the course of its investigation, the panel of judges took a number of concrete and progressive steps to identify the most responsible perpetrators of the crimes committed. These steps include the interrogation and indictment of high-ranking officials, in Conakry and abroad; the interview of key witnesses, including government officials and opposition leaders; and the hearing of over 400 victims, of which approximately 50 are victims of sexual violence. In its closing orders decision, the panel of judges refers 13 of the 15 individuals indicted throughout the investigation to the Tribunal of Dixinn, the territorially competent jurisdiction in Conakry.

April 2018
Steering committee appointed

Minister Sako appoints a steering committee to organise the trial. Initially supposed to meet once a week, the committee only meets sporadically and has not yet set a trial date, raising concerns about the lack of progress.

 
May 2019
Cheick Sako resigns as justice minister

Mohamed Lamine Fofana takes over as justice minister after Sako resigns. Hopes are pinned on him and President Conde to ensure the trial date is set and that the victims have the chance to see justice done.

 
 
June 2019
Supreme Court dismisses civil complaints

Guinea’s Supreme Court dismissed appeals by civil parties petitioning against the outcome of the investigation into the 2009 stadium massacre, an investigation initially closed two years before, in 2017. The appellant civil parties issued their complaint after charges were dropped against two prominent suspects and the initial charge of crimes against humanity was requalified to charges of ordinary crimes. The Supreme Court’s decision cannot be appealed, officially closing the investigation into crimes committed in relation to the September 2009 stadium attack and removing the final judicial obstacle to opening the long-awaited trial of those most responsible.

29 October 2019
Trial date promised

During a visit to Conakry by representatives from the Office of the Prosecutor of the International Criminal Court, Justice Minister Fofana announces that the Diakité trial will take place at the latest in June 2020. Challenges remain, including the construction or adaptation of a courtroom to host the trial, the appointment and training of magistrates, and the setting-up of a communication and security plan for all the actors involved in the proceedings.

22 March 2020
Constitutional referendum

The new constitution reset presidential term limits (normally two terms), allowing president Alpha Condé to run for a third term.

 
19 June 2020
Mory Doumbouya named minister of justice
9 October 2020
ICC issues warning and reminder

A week before the 2020 presidential election, International Criminal Court Prosecutor Fatou Bensouda issues a statement noting reports of pre-election violence and growing ethnic tensions in Guinea. She warns that "anyone who commits, orders, incites, encourages or contributes, in any other way, to the commission of Rome Statute crimes, is liable to prosecution either by Guinean courts or by the ICC." She also reminds the authorities that if trials for the September 2009 stadium massacre fail to materialise, then it will be her obligation to open an investigation.

18 October 2020
Alpha Condé wins third term as president
5 September 2021
Mamady Doumbouya leads coup to oust Condé

Condé is ousted by an elite army unit led by Commander Mamady Doumbouya, who was sworn in as interim president on 1 October 2021.

28 September 2022
Start of the Conakry trial

On the 13th anniversary of the 28 September 2009, stadium massacre, the trial of 11 accused persons including Moussa Dadis Camara finally opened in the capital Conakry. The culmination of a long and much delayed process, the trial is being held in an Ad hoc tribunal that was specially constructed for the trial. The accused persons face charges including murder, assassination, rape, torture, kidnapping, arson, looting, among others.

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Domestic accountability

In February 2010, five months after the stadium massacre, the Minister of Justice appointed a panel of judges to investigate crimes committed during and in the immediate aftermath of the attack. Working under difficult conditions and with minimal resources, the investigation made slow but significant progress, finally completing its work seven years later, in December 2017. The investigation led to a number of charges and arrests, in some cases involving high-ranking officials, such as Secretary of State, Colonel Moussa Tiégboro Camara, the Governor of Conakry, Sékou Resco Camara, and former president, Captain Moussa Dadis Camara.

On 28 September 2022, on the 13th anniversary of the stadium massacre, the trial of 11 accused persons including Moussa Dadis Camara finally opened in the capital Conakry., The trial, which marked the culmination of a long and much delayed process, was held before a specially constituted Ad hoc tribunal. The accused faced charges of murder, assassination, rape, torture, kidnapping, arson and looting, among others.

At the outset of the proceedings, the defendants were the first to be given the floor, in a case involving 450 civil parties. Given the large number of victims, the trial was broadcasted live in Guinea. Former President Moussa Dadis Camara’s interrogation, which began in December 2023, was the most anticipated but ultimately proved rather disappointing for victims, as he refused to acknowledge any personal responsibility for the crimes.

In the following months, the trial experienced significant delays due to strikes. In May 2023, eight months after the proceedings began, lawyers went on strike after months without pay. Both defence counsel and lawyers representing civil parties requested financial support from the Ministry of Justice, including the creation of a dedicated fund to cover legal fees and improvements to working conditions in the courtroom. When their demands were not met, the lawyers announced the suspension of their participation in the trial. Although the Ministry of Justice finally acceded to their requests, the trial was once again postponed following a general strike by prison guards who demanded, among other things, salary increases.

 

The strikes exposed deeper issues of structural funding constraints affecting the proceedings. Indeed, the original budget of 13.205 billion Guinean Francs (approximately €1.4 million) allocated to the trial ran out after the first eight months, as the proceedings were not initially expected to last longer than that. International partners, including the EU and the US, were called out for failing to deliver the promised financial support.

 

The trial was eventually able to resume in July, but on 4 November 2023, an armed commando extracted four of the main defendants, namely Moussa Dadis Camara, Moussa Tiegboro Camara, Blaise Goumou and Claude Pivi, from Conakry’s central prison. While the first three were returned to custody later that same day, Claude Pivi remained on the run for almost a year before being arrested in Liberia on 17 September 2024. Defence counsel claimed that their clients had been abducted, but it remains unclear whether the incident constituted a kidnapping or a failed jailbreak attempt. This episode greatly increased security concerns; Pivi’s escape in particular exacerbated fears of reprisals among witnesses, leading some of them to withdraw or request to testify behind closed doors. 

 

Despite the many challenges, including strikes, financial and security concerns, the trial concluded on 31 July 2024 with the conviction of former president Moussa Dadis Camara and seven other senior officials for their role in the 2009 stadium massacre, which the Court characterised as crimes against humanity. The eight men received prison sentences ranging from 10 years to life imprisonment and were ordered to pay reparations to the victims, while four other defendants were acquitted. 

 

Although the prosecution had sought life imprisonment for Dadis, he was ultimately sentenced to 20 years in prison. Claude Pivi, who was convicted in absentia before being recaptured, received a life sentence and later died in prison in January 2026 as a result of health complications. Most of the parties to the trial have filed an appeal: the defense because they oppose the reclassification of the charges as crimes against humanity, the civil parties because several victims were excluded from the verdict, and the prosecution because some of the alleged perpetrators were not convicted. However,  the appeal proceedings have not yet moved forward.


In March 2025, nearly eight months after the court verdict, Guinea’s government announced it would cover compensation for the victims of the 2009 stadium massacre, bringing a measure of relief to those affected. While this constitutes a positive development, compensations were only granted to 334 victims under the ruling, leaving many unlisted victims aside. At a press conference held on 28 June 2025, the “Collective of uncompensated victims” denounced the exclusion of numerous victims despite their identification in the proceedings, and called on President Mamadi Doumbouya to ensure that compensation is extended to all victims.

Play Video

Guinea: justice delayed, justice denied?

Olivier Kambala, Peace and Development Adviser in the Office of the United Nations Resident Coordinator in Madagascar, discusses the investigation and prosecution of crimes committed during the attacks of 28 September 2009 at the Conakry stadium. Kambala discusses the progress of investigations in Guinea and the role of the International Criminal Court. Kambala expresses concern about the lack of political will, as well as legal and financial difficulties that have delayed the trial, now scheduled to take place in 2021.

Play Video

International Criminal Justice in West Africa

Roland Adjovi, International Law Advisor for the Global Maritime Crime Programme in West Africa at UNODC, analyses the relationship between national, regional and international judicial mechanisms and their application in West Africa. He also reviews various legal instruments, tools and mechanisms, such as the Malabo Protocol, the African Court on Human and Peoples’ Rights, the International Criminal Court and hybrid courts.

Commentary & Reports

FIDH “Justice, Reconciliation and Legislative Reform: Three Priorities for Rule of Law in Guinea” (2017)

In this report, FIDH documents progress made on strengthening rule of law in Guinea. It expresses concerns over the complexity of the planned trial and the enduring weaknesses in the justice sector. The report finds that the Guinean government must urgently act on preparations, if the trial is to go forward in a timely and credible matter. 

LandInfo “Guinée: La police et le système judiciaire” (2011) 

This report reviews the structure, capacities and shortfalls of the Guinean police and judiciary. It determines that the justice system is slow, chronically underfinanced and lacks independence. Corruption has undermined the legitimacy of the judicial sector, the report finds, often allowing the rich to live above the law.

Human Rights Watch “Waiting for Justice” (2012) 

The report documents the obstacles that contributed to impeding the progress of the investigative commission, pointing to political, institutional and operational challenges. 

Establishing a legal framework for prosecuting international crimes in domestic courts 

Can perpetrators be held to account in Guinea?

Although crimes against humanity were incorporated into Guinea’s Criminal Code in 2016, the accused were initially not charged with international crimes, as the pretrial judges who conducted the seven-year investigation into the stadium massacre did not classify the acts as crimes against humanity, to the disappointment of victims’ groups. In explaining their decision, the judges held that Guinea only acquired statutory jurisdiction to prosecute international crimes in 2016. Hence, in 2010, when the accused were indicted for the crimes of September 2009, the Prosecutor General to the Court of Appeal did not include crimes against humanity.

Although victims’ groups challenged the removal of the crimes against humanity charges, the Supreme Court rejected their petition in June 2019 in a decision that could not be appealed. This ruling was issued despite the United Nations Commission of Inquiry’s characterisation of the massacre as a crime against humanity and the OTP’s preliminary examination opened in October 2009 for the same crimes.

In March 2024, the prosecution requested a reclassification of the charges, a petition supported by the civil parties but opposed by the defence, which argued that this reclassification would amount to retroactive application of the law. The prosecution and civil parties countered that Guinea’s ratification of the Rome Statute in 2003 already bound the state to prosecute international crimes including crimes against humanity. On 20 March 2024, the judges decided to wait until the judgment to rule on whether the events should be reclassified as crimes against humanity, angering the defence lawyers who claimed that this decision violates fair trial rights.

In a historical verdict, the court finally decided to reclassify all of the charges from ordinary crimes to crimes against humanity, marking the first time crimes against humanity have been prosecuted in Guinea.

The court’s decision was welcomed by victims and human rights organisations. Samira Daoud, Amnesty International’s Regional Director for West and Central Africa, stated that:

The court’s decision to reclassify the events as crimes against humanity enabled the gravity of the crimes, including sexual crimes, to be recognised. Despite the delays, Guinea has shown that it was able and willing to prosecute and try those suspected of criminal responsibility for the 28 September 2009 stadium crimes. This is a successful example of complementarity between the ICC and national courts, as it is the first time in Africa that a state investigates, prosecutes and judges itself the highest responsible (sic) for crimes which were under scrutiny by the ICC.”

Commentary & Reports

Diawo Barry “Guinée: la Cour suprême clôt enquête sur les massacre du 28 septembre 2009, une étape de plus vers l’ouverture du procès” (jeune afrique: 26 June 2019) 

In a decision that cannot be appealed, Guinea’s Supreme Court finally closed investigations into the September 28 Stadium massacre in June 2019. Although investigations finished in 2017, the process was reopened by civil parties contesting the requalification of crimes against humanity to ordinary crimes. 

Diawo Barry “Massacre du 28 septembre 2009 en Guinée : deux officiers soupçonnés bénéficient d’un non-lieu” (jeune afrique: 12 January 2018) 

When the panel of investigating judges finished their work in December 2017, conditions were met for a trial to open in Dixinn, outside Conakry. Civil parties were not, however, satisfied with the outcome of the investigation. Charges against two prominent suspects were dropped, and the charge of ‘crimes against humanity’ was ultimately changed to a charge of ‘ordinary crimes’. 

Political Will

The accountability process surrounding the 2009 stadium massacre appeared to reflect genuine political will to deliver justice to the victims, through the indictment of high-level perpetrators and by providing victims with a platform to be heard. Although long delayed, the trial’s verdict marked the culmination of this process, resulting in the conviction of senior officials and high-ranking members of the former government, including former president Moussa Dadis Camara. The government’s announcement that it would begin paying reparations to the victims further reinforced this perception of political will. 

However, on 26 March 2025, two days after announcing the reparation measure, President Doumbouya pardoned former President Moussa Dadis Camara on “health grounds”, raising concerns about Guinean authorities’ respect for due process and the rule of law. The pardon sparked strong criticism from victims and their lawyers, who argued that it undermines the justice process, violates principles of separation of powers, and contradicts efforts to combat impunity. Representatives of victims’ groups and human rights organisations denounced the decision as a political affront to victims’ long pursuit of truth, justice, and reparations, warning that it sends a damaging signal for accountability and human rights in Guinea. 

In addition, almost two years after the end of the trial, the appeal filed by the majority of parties seems to be at a standstill. To date, there have been no hearings or any official communication that would indicate a genuine willingness from the authorities to pursue the judicial process, reinforcing concerns that accountability efforts have stalled.

Lawyers representing civil parties have expressed deep pessimism about the future of the case, with some arguing that the pardon has stripped the proceedings of their substance and rendered an appeal trial meaningless. Several lawyers fear that other convicted officials may also be pardoned and have announced they would refuse to participate in any appeal proceedings while Camara remains free. 

Guinea’s government continues to assure the ICC of its commitment to hold an appeal trial. Following a visit to Conakry in May 2025, ICC Deputy Prosecutor Mame Mandiaye Niang stated that he had received assurances that the appeal proceedings and the implementation of reparations would continue. While the payment of reparations began in July 2025,no concrete steps have been taken to advance the appeal process.

Commentary & Reports

Human Rights Watch “Guinea: Violence During Referendum, Investigate Abuses, Rein in Security Forces” (2020) EN/FR

The report documents recent crackdowns on political opposition by security forces, leading to the death of at least eight people during 2020, including two children. At least forty others were forcibly ‘disappeared’. The report condemns continued impunity for these human rights violations and expresses concern that impunity is a driving force behind the violence.

VOA “Crise politique meurtrière : des clés pour comprendre” (2019)

In a process that appeared politically motivated, eight opposition leaders stood trial for their role in leading demonstrations against President Condé’s efforts to secure a third term. The demonstrations turned deadly when security services used excessive force against demonstrators. The case comes in the wake of increasingly harsh crackdowns on opposition protests over recent years.

Impunity and its consequences

The Guinean government has regularly pledged itself to ensure accountability for the grave crimes committed in September 2009, yet successive governments have continued to be implicated in human rights violations, notably during episodes of electoral violence, with total impunity.

In 2020, following frequent episodes of excessive use of force against protestors by gendarmes and police, the Guinean authorities under Alpha Conde harassed, intimidated and arbitrarily arrested opposition members and human rights defenders with impunity.

The transitional government that assumed power after the 2021 military coup continued this pattern, banning all protests and demonstrations in May 2022 until unspecified electoral campaign periods. Security forces repeatedly used excessive force, including tear gas and live ammunition, to disperse those who defied the ban, resulting in  the death of at least 59 protesters and other civilians since 2022. Guinean authorities also intensified their crackdown on the media, opposition politicians?/groups? and protesters by dissolving or placing dozens of political parties under observation, targeting major opposition figures, revoking media licenses, and arbitrarily arresting numerous journalists and press union leaders. 

In 2025, elections were finally organised after the coup; Doumbouya, who had initially promised not to run for office, won with 86.7% of the votes. Civil society organisations denounced these elections as a “charade”, citing widespread irregularities, including the exclusion of key opposition candidates, the expulsion of poll observers, ballot stuffing, voter intimidation, and an exceptionally low turnout due to widespread voter boycott. 

Human rights monitors contend that a culture of impunity for the perpetrators of human rights violations is a driving force behind worsening cycles of political violence surrounding Guinean elections in recent years, perpetuating instability and undermining democratic processes.

Commentary & Reports

Amnesty International “Guinea: Stadium massacre victims await justice” (2020) (EN/FR)

Ten years after the transition to democracy, impunity largely prevails in Guinea where security forces are implicated in crimes. The completion of a credible investigation into September 2009 crimes raised hopes for justice, but eleven years is ample time to prepare a trial of this scale and as yet no trial has opened. Fears are mounting amongst victims and civil society groups that Guinea ultimately lacks the political will to move forward with prosecutions.

Astrid Chitou “Elusive Justice for Guinea Leaves Open Wounds” (justiceinfo.net: 13 November 2019) 

The article offers insights into the lives of victims and their families. The author highlights that their suffering is not merely the result of ongoing impunity: the victims interviewed explain how their lives were forever changed by debilitating injury and the loss of family breadwinners. There is a continuum, the author argues, between the long wait for justice for the Stadium Massacre and ongoing impunity for death and injury suffered during political protests in the years since. 

FIDH “Guinée: Le temps de la justice?” (2015)  

This report documents progress on national investigations. The authors contend that a continuum exists between ongoing impunity for September 2009 crimes and repeating cycles of electoral violence.

Cellou Dalien Diallo “Guinea: Downfall of Democracy An Interview with Former Prime Minister” (Frieheit.org: 17 April 2020)

This interview with Guinea’s former prime minister offers an analysis of why impunity remains for grave crimes committed by the last regime. Referring to recent political developments such as the constitutional referendum, the former prime minister argues that Guinea has the legal foundation to ensure justice but lacks the political will.

Prosecuting sexual violence

The 2009 stadium massacre was the scene of systematic and extreme acts of sexual and gender-based violence (SGBV). As documented by Human Rights Watch, dozens of women were subjected to rape, gang rape, sexual assault with objects and weapons, and even abductions and sexual slavery, by the Guinean security forces, with several victims killed during or immediately after the assaults. Witness testimonies and medical evidence indicate that these acts were not isolated, but rather formed part of a widespread and organised pattern of sexual violence.

The United Nations International Commission of Inquiry that investigated the 2009 stadium massacre concluded in its final report that at least 109 women were victims of rape, gang rape and sexual slavery during the massacre and its aftermath. However, given the fear of testifying and the stigmatisation, the real number is likely much higher

The trial verdict was widely regarded as a major victory for all victims, including survivors of SGBV. The UN Special Representative on Sexual Violence in Conflict welcomed the verdict as a landmark step in the fight against impunity for survivors of sexual violence, highlighting the first-ever application in Guinea of the Rome Statute, including its provisions on sexual violence. 

Nevertheless, this progress has since partially been undermined by the presidential pardon of Moussa Dadis Camara, as well as prolonged delays in appeal proceedings and the implementation of reparations, raising concerns among survivors and human rights organisations. More broadly, a culture of impunity for SGBV persists in Guinea, as documented in a 2022 Amnesty report, and this despite the military authorities’ public pledge, upon seizing power in 2021, to prioritise the fight against SGBV in the country.

Commentary & Reports

Chappell et al “The Gender Shadow of Complementarity: Lessons from the ICC Preliminary Examinations in Guinea & Colombia” (International Journal of Transitional Justice: 2013)

This article argues that there is a “shadow side” to complementarity in relation to gender justice. Gender biases in the domestic legislation and judicial sector that impede access to justice for victims of sexual violence risk being reproduced under the complementarity principle. Tackling impunity for sexual violence through complementarity should therefore also include a careful examination of gender biases in domestic legal systems by the Prosecutor’s office.

International justice  

Following the events of the September 2009 Conakry Stadium massacre,  the Office of the Prosecutor (OTP) of the International Criminal Court (ICC) opened a preliminary examination into alleged atrocity crimes committed there in October 2009. This covered crimes  “including crimes against humanity of murder; imprisonment or other severe deprivation of liberty; torture; rape and other forms of sexual violence; persecution; and enforced disappearances.” 

The preliminary examination stage serves to determine if situations meet the legal criteria for investigation under the Rome Statute (RS). The examination is guided by Article 53(1) of the RS, which outlines the factors to consider: jurisdiction, admissibility, and the interests of justice. These factors help the Prosecutor decide whether there is a reasonable basis to proceed with an investigation.  

To assess the admissibility of a situation, the ICC evaluates the existence and genuineness of national proceedings in relation to the crimes in question and whether such proceedings are being conducted with a clear intent to bring perpetrators to justice within a reasonable time frame. This is linked to the principle of complementarity which establishes that the ICC can only act if national authorities are unwilling or unable to genuinely investigate and prosecute the crimes.

Complementarity 

In Guinea, the OTP followed  the  strategy of “positive complementarity” by combining encouragement of domestic investigations with close scrutiny of the country’s progress towards prosecutions. “Positive complementarity” refers to a strategy of active engagement by the Court in helping a state fulfil its Rome Statute obligations, whereby states and the ICC are seen as partners who share the common goal of and responsibility for ending impunity for international crimes. Through this approach, the ICC seeks to work more collaboratively with States in order to strengthen domestic accountability processes. 

In this situation, the OTP supported domestic investigations through regular visits, benchmarking steps in the investigation, and building alliances with national institutions. Civil society groups have credited the ICC approach with slowly pushing national investigations forward through a combination of assistance and pressure. The successive Guinean governments, first under Condé and later under Doumbouya, were open to these engagements, actively cooperating with the ICC in a concerted effort to improve Guinea’s international reputation. Avoiding an ICC investigation was an important part of these efforts to improve Guinea’s image as a rights-respecting, democratic nation. 

In 2022, the preliminary examination was closed, as the Prosecutor concluded that the opening of the domestic trial for the events of 28 September 2009 demonstrated that the Guinean authorities were neither inactive, unwilling, nor unable to genuinely investigate and prosecute the alleged crimes. To ensure that this progress would be sustained, the closure was accompanied by the signature of a Memorandum of Understanding with the Guinean authorities, aimed at reinforcing accountability for the crimes committed and deepening ongoing cooperation with the OTP. The ICC considers Guinea to be a successful example of positive complementarity, a position reaffirmed in the ICC Complementarity Policy published in 2024 where Guinea is cited as an example. 

The preliminary examination and targeted support provided by the ICC have had a notable impact, contributing directly to the opening of domestic proceedings and later to the trial and verdict. This marks a significant achievement for the ICC as it successfully culminated in the prosecution of those most responsible at the national level; this could serve as a model approach for positive complementarity in the future. This success was, however, partly diminished by the presidential pardon granted to Dadis Camara by Doumbouya.

Commentary & Reports

Will Colish “The International Criminal Court in Guinea: A Case Study of Complementarity” (Révue Quebecoise de droit international: 2013)

Colish describes the Guinea case as a combination of strong willingness and weak capacity. This combination, Colish contends, makes it an ideal case to analyse the activities and impacts of a ’positive complementarity’ approach. 

Human Rights Watch “Pressure Point: The ICC’s Impact on National Justice” (HRW: 2018)

The report includes Guinea among a series of case studies analysing the impacts of ICC-led global interventions on national level justice processes. The Guinea case illustrates how close engagement with the ICC helped create and reinforce expectations that the domestic judiciary would pursue accountability for the September 28 massacre.

Nour Saadi “La volonté politique et la capacité national : Le massacre du 28 septembre et la Cour pénale international” (CHRLP Working Paper Series Vol. 5 n. 1 2017)  

The ongoing failure to open a domestic trial for the September 28 massacre highlights a potential risk in the ICC’s ‘positive complementarity’ approach. If, in the end, justice is indefinitely postponed in Guinea, the case could be seen as an example of this approach ultimately contributing to inaction in certain circumstances. Such an outcome would hurt the credibility of the ICC Prosecutor’s office in similar contexts going forward. 

ICC Office of the Prosecutor “Report on Preliminary Examination Activities” (ICC: 2020) (EN/FR

The Office of the Prosecutor’s admissibility assessment found that national authorities had made notable progress towards investigations and prosecutions in past years, but that no new steps were taken since Guinea’s failure to meet its self-assigned deadline of June 2020. A benchmarking framework, defined by the Prosecutor’s office and setting clear targets that must be met to avoid an ICC investigation, is forthcoming.