Beyond the farmland: classifying Fulani herdsmen attacks in Nigeria’s middle belt as international crimes
Oriola O Oyewole
Afe Babalola University, Ado Ekiti; African Regional Forum Liaison Officer, IBA War Crimes Committee
A crisis hiding in plain sight
In the early hours of 23 June 2018, gunmen descended on the Berom farming village of Gashish in Barkin Ladi, Plateau State, Nigeria. At least 86 were confirmed dead, with credible witness estimates exceeding 200, predominantly women, children, and elderly men who could not flee. Homes were burnt. Farms were destroyed. Survivors described coordinated attacks from multiple directions lasting several hours.1 Nigerian security forces arrived, by most accounts, only after the killing was done.2 The events in Gashish are not isolated; they represent a persistent pattern observable across Benue, Plateau, Kaduna, Taraba, Zamfara, and Nassarawa States for over a decade.
The Global Terrorism Index 2015 ranked Fulani militants as the world’s fourth deadliest terrorist group, recording 1,229 deaths; a 20-fold increase from 63 deaths in 2013.3 Officially verified incident data indicates fatalities exceeding 19,000 since 1999, while the Middle Belt Forum asserts that cumulative deaths between 2011 and 2023 surpass 50,000 – indicative of significant underreporting where victims are frequently interred without formal documentation.4
The persistence of the ‘farmer-herder conflict’ paradigm in official Nigerian discourse warrants more than methodological criticism. While resource competition and climate-induced migration are documented contributory factors,5 their invocation as the primary explanatory framework operates to depoliticise what the evidence increasingly suggests is a directed campaign. As Prosecutor v Tadić established before the ICTY, the legal characterisation of violence is not merely descriptive but constitutive; it determines jurisdiction, fixes criminal responsibility and defines remedial obligations.6 A framing that positions the state as an exasperated bystander to a symmetrical dispute forecloses the legal responses the crisis demands. This article contends that what is occurring constitutes crimes against humanity under Article 7 of the Rome Statute and, in specific cases, genocide under Article 6.
The anatomy of the attacks: systematic, not spontaneous
The farmer-herder framing collapses under scrutiny. Resource conflicts are typically reactive, localised and bilateral.7 What the evidence from the Middle Belt discloses is none of these things.
Coordination and weaponry
Attacks characteristically commence in darkness, are executed from multiple entry points and deploy sophisticated weaponry, including AK-47 assault rifles that traditional nomadic herders have not historically carried.8 Survivors across Benue, Plateau, and Kaduna describe attackers arriving in military-style formations, suggesting planning and command structures.9
Ethnic and religious targeting
Victims are overwhelmingly indigenous Christian farming communities: Berom, Tiv, Tarok and Jukun peoples. Muslim Fulani communities in identical geographic areas remain largely untouched. Churches are deliberately targeted.10 In the Agatu massacres of February 2016, a Muslim survivor testified before the United States Congress that the mosque in his village was spared while every church was destroyed, and that he was released upon reciting a Qur’anic verse.11 Five hundred churches have been destroyed in Benue State alone.12 Attacks have been documented on Christmas carollers, New Year’s Day worshippers and priests celebrating Mass.13 The systematic preservation of mosques and destruction of churches, alongside statistical disproportion in Christian fatalities,14 is not consistent with resource competition. It is consistent with targeted persecution.
Permanent displacement
Following the January 2018 escalation, an estimated 300,000 civilians were compelled to abandon their homes.15 Attacked communities rarely resettle; those attempting to return face repeated assaults. Vacated land is occupied by Fulani cattle settlers who cultivate displaced communities’ farmland, rename territories and consolidate physical control. In Plateau State alone, 102 formerly indigenous communities have been occupied and renamed since 2001: Rotchun is now Rafin Acha, Dankum is Mahanga, Hywa is Lugere.16 In Southern Kaduna, over 2,316 square miles of fertile land have been forcibly seized since 2016, leaving affected Christian communities to subsist as internally displaced persons on humanitarian assistance.17 The International Human Rights Commission has characterised this sequence, attack, displacement and quiet occupation, as systematic land grabbing,18 an assessment receiving implicit executive concession from President Tinubu, who acknowledged at a town hall in Makurdi that the crisis required confronting ‘land grabbing’.19 The Tiv paramount ruler characterised the violence as ‘a full-scale genocidal invasion and land-grabbing campaign’.20 This is not conflict; it is demographic engineering; the operational definition of ethnic cleansing.
These patterns satisfy the ‘widespread or systematic attack’ threshold under Article 7 of the Rome Statute.21 On 11 December 2020, the International Criminal Court's (ICC's) Office of the Prosecutor concluded that all statutory criteria for a formal investigation had been met,22 having separately acknowledged in its 2018 Preliminary Examination Report that Fulani militia attacks fell within its scope.23 Yet no formal investigation has been opened. As of March 2024, the Deputy Prosecutor was engaged in further complementarity discussions,24 while Amnesty International characterised the ongoing inaction as ‘intolerable’ and ‘a betrayal of victims’.25
Legal threshold: genocide and crimes against humanity
Nigeria ratified the Rome Statute in 2001. The issue is not jurisdictional ambiguity but prosecutorial inaction. Genocide Watch, the leading international genocide early-warning organisation founded by Professor Gregory Stanton, who drafted the United Nations’ genocide prevention framework, has formally designated Nigeria at active risk of genocide and classified Fulani militia attacks as genocidal massacres, concluding that the violence satisfies the organisational and intentional criteria that distinguish genocide from generalised political violence.26 The United Kingdom's All-Party Parliamentary Group for International Freedom of Belief concluded that certain Fulani militia factions demonstrate clear intent to target Christians and the physical symbols of Christian identity.27
It should be acknowledged that the genocide characterisation is not without academic dissent. Pérouse de Montclos has argued that the genocide narrative is empirically overstated and risks misrepresenting a complex multi-causal conflict, noting that the genocide characterisation requires proof of specific intent that current evidentiary records do not yet conclusively establish in a court-ready form.28 However, that scholarly contestation does not militate against formal judicial examination; rather, it reinforces the necessity of it. The appropriate institutional response to a genuine evidentiary dispute about whether conduct satisfies the dolus specialis threshold under Article 6 of the Rome Statute is not continued institutional silence; it is independent, impartial investigation by the body constitutionally mandated to resolve precisely that question. In Prosecutor v Krstić, the ICTY affirmed that the dolus specialis requirement, specific intent to destroy a protected group, must be the only reasonable inference from the totality of evidence, a determination that is irreducibly a judicial function.29 In Prosecutor v Akayesu, the ICTR established specific intent as the critical distinguishing element of genocide.30 Regarding crimes against humanity, Prosecutor v Kunarac provided authoritative appellate analysis of the ‘widespread or systematic’ threshold.31
The impunity design: three structural failures
The perpetuation of Middle Belt violence is equally the product of a coherent framework of state-level institutional failure spanning prosecutorial dysfunction, legislative subversion and deliberate narrative management.
Prosecutorial collapse
Despite a documented body count of thousands, the Nigerian state’s prosecutorial response has been defined by a categorical refusal to investigate, arrest, or charge perpetrators; a dereliction that Amnesty International concluded directly incentivises further violence by signalling to perpetrators that organised killing carries no legal consequences.32 The specific pathologies are well-documented: security forces withdrawn from communities hours before known attacks; suspects identified by survivors and never arrested; cases opened and silently closed; and witnesses subjected to intimidation without protective intervention.33 This prosecutorial vacuum functions not as negligence but as structural complicity, with direct implications under Article 28 of the Rome Statute, which extends criminal responsibility to superiors who knew or had reason to know of crimes and took no meaningful action.34 In Prosecutor v Halilović, the ICTY affirmed that effective control and knowledge of subordinate crimes, combined with failure to prevent or punish, establishes superior responsibility.35
Legislative obstruction
Several Middle Belt state governments enacted Open Grazing Prohibition Laws beginning in 2016, providing legislative mechanisms to regulate nomadic movement. The federal government’s response was to obstruct rather than consolidate, advancing the Rural Grazing Areas (RUGA) policy in 2019, subsequently rebranded as the National Livestock Transformation Plan (NLTP), each proposing to gazette contested indigene land to herder communities without prior consultation with state governors holding constitutional land-trusteeship authority.36 The NLTP was widely perceived as favouring Fulani pastoralists and creating further barriers to land use and access for indigenous farming communities; a perception reinforced when it emerged the federal government had secretly gazetted 5,000 hectares per state without public knowledge or gubernatorial consent.37 Whatever the NLTP’s stated development rationale, its political effect was to systematically neutralise state-level legislative protections at precisely the moment those protections were most urgently needed.
Narrative control
The third and arguably most consequential structural failure is the management of the violence’s public characterisation. Federal authorities, including former President Muhammadu Buhari, consistently framed episodes of mass killing as bilateral ‘clashes’ attributable to resource competition, a framing that distributes responsibility symmetrically between attacker and victim and deprives the violence of the directional intentionality required to trigger international legal scrutiny.38 Buhari’s administration was repeatedly documented as having failed to arrest any suspect following multiple high-casualty attacks, including the February 2016 Agatu massacres in which a national secretary of a Fulani advocacy group publicly acknowledged the attacks were a reprisal operation; still no charges followed.39 The Institute for Security Studies observed that the Fulani crisis received systematically fewer government resources and less executive attention than the Boko Haram insurgency, a disparity multiple scholars attributed to ethnic proximity between the executive and the perpetrating group.40 As Mamdani demonstrated in the Rwandan context, official reframing of organised ethnic violence as reciprocal communal disorder is a classical mechanism of perpetrator-adjacent state obstruction, operating to insulate perpetrators from accountability by presenting violence as politically ungovernable rather than judicially cognisable.41 Shaw and Waldorf identify this as a foundational tension in transitional justice design: top-down institutional processes routinely impose conflict characterisations that serve state interests in stability and elite protection over victims’ interests in truth and accountability.42
The call for action
The window for meaningful accountability is not infinite. Witnesses die, evidence degrades, and exhausted communities lose faith in institutions. The following measures are imperative:
- ICC formal investigation: The ICC Prosecutor must immediately advance the Nigerian situation from preliminary examination to formal investigation. The evidence base – satellite imagery, attack patterns, mass graves and survivor testimony – is sufficient. The complementarity principle does not shield states unwilling to prosecute. Nigeria demonstrates textbook unwillingness.43
- UN Commission of Inquiry: The UN Human Rights Council should establish an independent commission mandated to investigate Middle Belt attacks, document perpetrators, and recommend accountability mechanisms.
- Evidence preservation: Organisations, including the Syrian Justice and Accountability Centre and Physicians for Human Rights, have developed replicable models for preserving evidence in conflict zones. These must be deployed in the Middle Belt immediately, prioritising mass graves. Every unexcavated grave destroys a chain of custody.44
Conclusion: the promise of international law
For over a decade, violence in Nigeria’s Middle Belt has proceeded in plain sight. The body count exceeds conflicts that have commanded sustained international attention. What has been missing is not evidence but institutional courage to name the crimes correctly and act accordingly.
International criminal law was not designed for selective application based on geopolitical expediency. Its foundational promise, forged after the Holocaust and operationalised through the Rome Statute, is that no atrocity, regardless of location or victim identity, passes without consequence.
If that promise means anything, it must mean something in Barkin Ladi, in Logo and in Mambilla. The farming communities of the Middle Belt are not requesting charity. They are demanding that the law, the same law international legal professionals build careers defending, be applied to them. That is the minimum they deserve. That is what justice requires.45
Notes
1 Marie-Therese Nanlong, Peter Duru, Kingsely Omonobi and Emma Una, ‘120 Killed, Houses Burnt in Fresh Plateau Bloodbath’, Vanguard News (25 June 2018), available at: www.vanguardngr.com/2018/06/120-killed-houses-burnt-in-fresh-plateau-bloodbath; ‘Scores Killed as Gunmen Attack Plateau Villages’ The Guardian Nigeria (Lagos, 24 June 2018), available at: https://guardian.ng/news/scores-killed-as-gunmen-attack-plateau-villages. Accessed 8 June 2026.
2 Ibid.
3 Institute for Economics and Peace, Global Terrorism Index 2015 (November 2015), pp 4, 45–48.
4 International Crisis Group, ‘Herders against Farmers: Nigeria’s Expanding Deadly Conflict’ (Africa Report No 252, 19 September 2017), available at: www.crisisgroup.org/rpt/africa/nigeria/252-herders-against-farmers-nigerias-expanding-deadly-conflict; International Crisis Group, ‘Stopping Nigeria’s Spiralling Farmer-Herder Violence’ (Africa Report No 262, 26 July 2018), available at: www.crisisgroup.org/rpt/africa/nigeria/262-stopping-nigerias-spiralling-farmer-herder-violence. Accessed 8 June 2026.
5 See n 4 above (International Crisis Group, ‘Herders Against Farmers’); Nsemba E Lenshie, Kelechi Okengwu, Confidence N Ogbonna and Christian Ezeibe, ‘Desertification, Migration, and Herder-Farmer Conflicts in Nigeria: Rethinking the Ungoverned Spaces Thesis’ (2021) 32(8) Small Wars & Insurgencies 1221 https://doi.org/10.1080/09592318.2020.1811602; Nsemba Edward Lenshie and Polycarp K Jacob, ‘Climate Change and Migratory Patterns of Fulani Herdsmen in Nigeria’ (2025) 17(1) International Journal of Climate Change Strategies and Management 422, available at: www.emerald.com/ijccsm/article/17/1/422/1250035/Climate-change-and-migratory-patterns-of-Fulani. Accessed 8 June 2026.
6 Prosecutor v Tadić (Jurisdiction) IT-94-1 ICTY Appeals Chamber (2 October 1995) para 70, available at: www.refworld.org/jurisprudence/caselaw/icty/1995/61438. Accessed 8 June 2026.
7 Thomas F Homer-Dixon, Environment, Scarcity, and Violence (Princeton University Press 1999), available at: https://press.princeton.edu/books/paperback/9780691089799/environment-scarcity-and-violence; Thomas F Homer-Dixon, ‘Environmental Scarcities and Violent Conflict’ International Security, vol 19(1), 5; International Crisis Group, Stopping Nigeria’s Spiralling Farmer-Herder Violence (Africa Report No 262, 26 July 2018).
8 Amnesty International, ‘Harvest of Death: Three Years of Bloody Clashes between Farmers and Herders in Nigeria’ (December 2018), available at: www.amnesty.org/en/documents/afr44/9503/2018/en; European Union Agency for Asylum, Country Guidance: Nigeria (EUAA October 2021) s 3.4, available at: www.euaa.europa.eu/publications/country-guidance-nigeria; Immigration and Refugee Board of Canada, ‘Nigeria: Fulani Herdsmen – Motivations, Modus Operandi and Recruitment Methods’ (NGA106152.E, August 2018), available at: www.ecoi.net/en/document/2004432.html. Accessed 8 June 2026.
9 Ibid, Amnesty International, 'Harvest of Death'.
10. Human Rights Watch, ‘“Leave Everything to God”: Accountability for Inter-Communal Violence in Plateau and Kaduna States, Nigeria’ (HRW 12 December 2013), available at: www.ecoi.net/en/document/2004432.html. Accessed 8 June 2026.
11 Ibid.
12 US Department of State, Bureau of Democracy, Human Rights and Labor, ‘Nigeria 2018 International Religious Freedom Report’ (2019), available at: www.state.gov/wp-content/uploads/2019/05/NIGERIA-2018-INTERNATIONAL-RELIGIOUS-FREEDOM-REPORT.pdf. Accessed 8 June 2026; Emmanuel Ogebe, ‘Testimony before the Tom Lantos Human Rights Commission’ (US House of Representatives, 11 May 2016).
13 Open Doors UK, ‘Written Evidence Submitted to the Foreign Affairs Committee’ (UK Parliament 2021), available at: https://committees.parliament.uk/writtenevidence/36727/html. Accessed 8 June 2026.
14 See n 4 above (International Crisis Group, ‘Stopping Nigeria’s Spiralling Farmer-Herder Violence’); Open Doors, World Watch List 2026: Nigeria Country Report (January 2026), available at: www.opendoors.org.au/world-watch-list/nigeria; All-Party Parliamentary Group for International Freedom of Belief, Nigeria: Unfolding Genocide? (UK APPG 2020), available at: www.opendoors.org.au/world-watch-list/nigeria. Accessed 8 June 2026.
15 See n 4 above. (International Crisis Group, ‘Stopping Nigeria’s Spiralling Farmer-Herder Violence’).
16 ‘How herdsmen seized, renamed 102 Plateau communities — Rwang Pam’, Vanguard News (12 December 2021), available at: www.opendoors.org.au/world-watch-list/nigeria; Douglas Burton, ‘Fulani Terrorists Aided in Land Grabbing by Secret Amnesty Deals’, Truth Nigeria (2025), available at: https://truthnigeria.com/2025/07/fulani-terrorists-aided-in-land-grabbing-by-secret-amnesty-deals. Accessed 8 June 2026.
17 Ibid.
18 Mike Odeh James, ‘Nigerian Christians Gunned Down by Fulani Militias’ (Genocide Watch, 24 December 2025), available at: www.genocidewatch.com/single-post/nigerian-christians-gunned-down-by-fulani-militias. Accessed 8 June 2026.
19 ‘Benue Killings: We’ll Confront Land-Grabbing Head-On to Bring Peace – Tinubu’, Vanguard News (Lagos, 19 June 2025), available at: www.vanguardngr.com/2025/06/benue-killings-well-confront-land-grabbing-head-on-to-bring-peace-tinubu. Accessed 8 June 2026.
20 Tor Tiv HRM Professor James Ortese Iorzua Ayatse, quoted in Yonas Dembele, ‘The Violence in Nigeria’s Middle Belt Has Long Historical Roots’, Africa at LSE (11 August 2025), available at: https://blogs.lse.ac.uk/africaatlse/2025/08/11/the-violence-in-nigerias-middle-belt-has-long-historical-roots. Accessed 8 June 2026.
21 Rome Statute of the International Criminal Court (adopted 17 July 1998, entered into force 1 July 2002) 2187 UNTS 3, Art 7. Available at: https://legal.un.org/icc/statute/english/rome_statute(e).pdf. Accessed 8 June 2026.
22 ICC Office of the Prosecutor, ‘Statement of the Prosecutor, Fatou Bensouda, on the Conclusion of the Preliminary Examination of the Situation in Nigeria’ (11 December 2020), available at: https://examination-situation-nigeria. Accessed 8 June 2026.
23 ICC Office of the Prosecutor, Report on Preliminary Examination Activities 2018 (ICC November 2018) paras 210–226, available at: www.icc-cpi.int/sites/default/files/itemsDocuments/181205-rep-otp-PE-ENG.pdf. Accessed 8 June 2026.
24 ICC Office of the Prosecutor, ‘Statement of the Conclusion of Deputy Prosecutor Mame Mandiaye Niang’s Official Visit to Abuja, Nigeria’ (ICC, March 2024), available at: www.icc-cpi.int/news/statement-icc-office-prosecutor-conclusion-deputy-prosecutor-mame-mandiaye-niangs-official. Accessed 8 June 2026.
25 Matt Cannock (Amnesty International), quoted in ‘After the ICC Assembly, the Elephants Remain in the Room’, Justice Info (9 December 2025), available at: www.icc-cpi.int/news/statement-icc-office-prosecutor-conclusion-deputy-prosecutor-mame-mandiaye-niangs-official. Accessed 8 June 2026.
26 Gregory H Stanton, ‘Genocide in Nigeria 2025: US Options to Prevent It’ (Genocide Watch, December 2025), available at: www.genocidewatch.com/single-post/genocide-in-nigeria-2024-u-s-options-to-prevent-it. On Stanton’s authorship of the UN genocide prevention framework, see Gregory H Stanton, ‘The Ten Stages of Genocide’ (Genocide Watch, 1996, revised 2016), available at: www.genocidewatch.com/tenstages. Accessed 8 June 2026.
27 All-Party Parliamentary Group for International Freedom of Belief, Nigeria: Unfolding Genocide? (UK Parliament, 2020). Accessed 8 June 2026.
28 Marc-Antoine Pérouse de Montclos, ‘From the US to Nigeria: How a ‘Christian Genocide’ Narrative Is Being Manufactured’ Afrique XXI (2 May 2025), available at: https://afriquexxi.info/spip.php?page=recherche&lang=en&recherche=Marc-Antoine+P%C3%A9rouse+de+Montclos%2C+%E2%80%98From+the+US+to+Nigeria%3A+How+a+%E2%80%98Christian+Genocide%E2%80%99+Narrative+Is+Being+Manufactured; see also Gonzalo del Arco Ortiz, 'Beyond "Christian Genocide": The Real Roots of Criminal Violence in Nigeria' (The New Humanitarian, 5 March 2026), available at: www.thenewhumanitarian.org/analysis/2026/03/05/beyond-christian-genocide-real-roots-criminal-violence-nigeria; for the leading ethnographic treatment of how farmer-pastoralist violence on the Jos Plateau is categorised and narrated as a security threat, see Adam Higazi, 'Farmer-Pastoralist Conflicts on the Jos Plateau, Central Nigeria: Security Responses of Local Vigilantes and the Nigerian State' (2016) 16(4) Conflict, Security & Development 365, available at: www.tandfonline.com/doi/full/10.1080/14678802.2016.1200314. Accessed 8 June 2026.
‘Christian Genocide in Nigeria? Assessing the Validity of Trump-Era Claims’ The Dialectics (14 November 2025). Accessed 8 June 2026.
29 Prosecutor v Krstić (Appeal Judgment) IT-98-33-A (19 April 2004) paras 19–20.
30 Prosecutor v Akayesu (Judgment) ICTR-96-4-T (2 September 1998) para 498.
31 Prosecutor v Kunarac, Kovač and Vuković (Appeal Judgment) IT-96-23 and IT-96-23/1-A (12 June 2002) paras 85–98; see also Prosecutor v Katanga (Judgment pursuant to Article 74) ICC-01/04-01/07 (7 March 2014) paras 1098–1176; see n 8 above (Amnesty International, 'Harvest of Death').
32 See n 8 above (Amnesty International, ‘Harvest of Death’); see also Amnesty International USA, ‘Statement on Violence in Nigeria’s Middle Belt’ (Written Statement to the Tom Lantos Human Rights Commission, 17 December 2020).
33 See n 4 above (International Crisis Group, ‘Stopping Nigeria’s Spiralling Farmer-Herder Violence’) 14–18.
34 Rome Statute of the International Criminal Court 1998, Art 28.
35 Prosecutor v Halilović (Trial Judgment) IT-01-48-T (16 November 2005) paras 56, 59, 65–66, 73; Prosecutor v Mučić and Others (Čelebići) (Trial Judgment) IT-96-21-T (16 November 1998) para 378.
36 International Crisis Group, ‘Ending Nigeria’s Herder-Farmer Crisis: The Livestock Reform Plan’ (Africa Report No 302, May 2021) 5–7, available at: www.ecoi.net/en/file/local/2050898/302-ending-nigerias-herder-farmer-crisis+%281%29.pdf; Africa Center for Strategic Studies, ‘The Growing Complexity of Farmer-Herder Conflict in West and Central Africa’ (October 2022), available at: https://africacenter.org/publication/growing-complexity-farmer-herder-conflict-west-central-africa. Accessed 8 June 2026.
37 Chukwuebuka Nwankwo, ‘Out of Frame: Invisibilisation of Non-Human Nature in Media Framing of a Land Conflict Transformation Policy in Nigeria’ (Taylor & Francis Online, 2024), available at: www.tandfonline.com/doi/citedby/10.1080/23743670.2024.2430237?scroll=top&needAccess=true; David Villah Dan-Azumi, ‘The Farmer–Fulani Herdsmen Clashes and the Socio-Economic Development of North-Western Nigeria’ (2025) 24(1), African Journal on Conflict Resolution, available at: www.accord.org.za/ajcr-issues/the-farmer-fulani-herdsmen-clashes-and-the-socio-economic-development-of-north-western-nigeria-a-case-study-of-southern-kaduna. Accessed 8 June 2026.
38 See n 4 above (International Crisis Group, ‘Herders Against Farmers’) 1–4; on juridical consequences of bilateral-framing, see Payam Akhavan, Reducing Genocide to Law: Definition, Meaning, and the Ultimate Crime (CUP 2012), available at: www.cambridge.org/core/books/reducing-genocide-to-law/747B8753EBBE58FC8D27A969BE563B1B; Payam Akhavan, ‘The Crime of Genocide in the ICTR Jurisprudence’, (2005) 4(1) Journal of International Criminal Justice 989, available at: https://doi.org/10.1093/jicj/mqi060. Accessed 8 June 2026.
39 See n 4 above (International Crisis Group, ‘Stopping Nigeria’s Spiralling Farmer-Herder Violence’) 9.
40 Institute for Security Studies, ‘Herdsmen Crisis Underscores Nigeria’s Complex Security Threats’ (ISS Africa, 2018), available at: https://issafrica.org/iss-today/herdsmen-crisis-underscores-nigerias-complex-security-threats; Ugwu et al (citing Akinkuotu 2016; Okoli 2016; ICG 2017 for the proposition that administration-wide complacency was ‘often attributed to Buhari’s Fulani ethnic origins’). Accessed 8 June 2026.
41 Mahmood Mamdani, When Victims Become Killers: Colonialism, Nativism, and the Genocide in Rwanda (Princeton University Press 2001) 8–12.
42 Rosalind Shaw and Lars Waldorf, ‘Introduction: Localizing Transitional Justice’ in Shaw, Waldorf and Hazan (eds), Localizing Transitional Justice: Interventions and Priorities after Mass Violence (Stanford University Press 2010) 3, 6–9, available at: www.sup.org/books/anthropology/localizing-transitional-justice. Accessed 8 June 2026.
43 William Schabas, Genocide in International Law (2nd edn, CUP 2009), available at: www.cambridge.org/core/books/genocide-in-international-law/8DBF9888184D74C00B6D87DA479260E7. Accessed 8 June 2026; Mohamed El Zeidy, ‘The Principle of Complementarity’ (2002) 23(4) Michigan Journal of International Law 869–975.
44 UN Human Rights Council, ‘Report of the independent international commission of inquiry on Syria Arab Republic’ (February 2014), available at: www.refworld.org/reference/countryrep/unhrc/2014/20894. Accessed 8 June 2026; Physicians for Human Rights, ‘Forensic Evidence Collection Protocols’ (2016).
45 Samantha Power, A Problem from Hell: America and the Age of Genocide (Basic Books, 2002), available at: https://samanthapower.com/books/a-problem-from-hell-america-and-the-age-of-genocide; David Scheffer, ‘Genocide and Atrocity Crimes’ (2006) 1(3) Genocide Studies and Prevention 229, available at: https://digitalcommons.usf.edu/gsp/vol1/iss3/3. Accessed 8 June 2026.