A group lawyers from several countries has laid a formal complaint with the International Criminal Tribunal for the Former Yugoslavia against all of the individual leaders of the NATO countries and officials of NATO itself.

The complaint was initiated by professors from Osgoode Hall Law School of York University in Toronto -- where Tribunal prosecutor Louise Arbour was also a professor before becoming a judge. The group has charged Bill Clinton, Madeleine Albright, Javier Solana, Jamie Shea, Jean Chretien, Art Eggleton, Loyd Axworthy and 60 other heads of state and government, foreign ministers, defense ministers and NATO officials, with war crimes committed in NATO's six-week old bombing campaign against Yugoslavia.

The list of crimes includes «willful killing, willfully causing great suffering or serious injury to body or health, extensive destruction of property, not justified by military necessity and carried out unlawfully and wantonly, employment of poisonous weapons or other weapons to cause unnecessary suffering, wanton destruction of cities, towns or villages, or devastation not justified by military necessity, attack, or bombardment, by whatever means, of undefended towns, villages, dwellings, or buildings, destruction or willful damage done to institutions dedicated to religion, charity and education, the arts and sciences, historic monuments and works of art and science». The complaint also alleges «open violation» of the United Nations Charter, the NATO treaty itself, the Geneva Conventions and the Principles of International Law Recognized by the Nuremberg Tribunal (the latter of which makes «planning, preparation, initiation or waging of a war of aggression or a war in violation of international treaties, agreements of assurances» a crime). Under the Statute «a person who planned, instigated, ordered, committed or otherwise aided and abetted in the planning, preparation or execution of a crime shall be individually responsible for the crime» and «the official position of any accused person, whether as Head of State of Government or as a responsible Government official, shall not relieve such person of criminal responsibility of mitigate punishment.» The complaint points to the bombing of civilian targets and alleges that NATO leaders «have admitted publicly to having agreed upon and ordered these actions, being fully aware of their nature and effects» and that «there is ample evidence in the public statements of NATO leaders that these attacks on civilian targets are part of a deliberate attempt to terrorize the population to turn it against its leadership.» The complaint cites a recent statement of the President of the Tribunal, Judge Gabrielle Kirk McDonald, urging that: «All States and organizations in possession of information pertaining to the alleged commission of crimes within the jurisdiction of the Tribunal should make such information available without delay to the Prosecutor.» The complaint also cites a statement of United Nations High Commissioner for Human Rights Mary Robinson in which she says that «large numbers of civilians have incontestably been killed, civilian installations targeted on the grounds that they are or could be of military application and NATO remains sole judge of what is or is not acceptable to bomb. In this situation, the principle of proportionality must be adhered to by those carrying out the bombing campaign. It surely must be right to ask those carrying out the bombing campaign to weigh the consequences of their campaign for civilians in the Federal Republic of Yugoslavia.» Under the Statue, the Prosecutor is bound to «initiate investigations ex-officio of on the basis of information obtained from any source, particularly from Governments, United Nations organs, intergovernmental and non-governmental organization that a case exists, the Prosecutor is bound to «prepare an indictment containing a concise statement of the facts and the crime or crimes with which the accused is charged under the Statute and transmit it to a judge of the Trial Chamber.» The complaint asks Judge Arbour to «immediately investigate and indict for serious crimes against international humanitarian law» the 67 named leaders and whoever else shall be determined by the Prosecutor's investigations to have committed crimes In the NATO attack on Yugoslavia commencing March 24, 1999. Copies of the charges have been sent to the accused. Participating in the action are 15 layers and law professors as well as the American Association Jurists, a pan American organization of lawyer's, judges, law professors and students, with membership in all countries of the American Continent from Tierra del Fuego to Canada, an NGO with consultativestatus before the Social and Economic Council of the United Nations.

Professor Michael Mandel said in Toronto today: «The bombing of civilians is not only immoral, it is criminal and punishable under the laws governing the Tribunal. You cannot kill a women and child in Belgrade on the theoretical possibility that it might save a woman and child in Pristina.

Even in a legal war you cannot kill civilians and destroy an entire country as a military strategy. But this is an illegal was and the NATO leaders are acting like outlaws. So far they have risked nothing by sending others to their killing and destroying. We believe that they are held individually responsible, as the law requires, they won't feel so free to spill other people's blood.» For further information, please contact in Toronto: Professor Michael Mandel (telephone 4166-736-5039; e-mail mmandel@yorku.ca) or David Jacobs (e-mail david@ShellJacobs.com) in Geneva: Alejandro Teitelbaum (e-mail Assamjur@aol.com)

This is the full legal document as prepared by a group of Canadian lawyers to demand the investigation of NATO's political and military leaders for war crimes. Please circulate widely as it will not surface in the Canadian media. (A copy has been sent to all Canadian MPs.)

WHEREAS the International Tribunal for the Prosecution of Persons Responsible for Serious Violations of International Humanitarian Law Committed in the Territory of the Former Yugoslavia since 1991 was established by the UN Security Council with «the power to prosecute persons responsible for serious violations of international humanitarian law committed in the territory of the former Yugoslavia since 1991 in accordance with the provisions of» its Statute (Article 1);

AND WHEREAS by Article 2 of the said Statute, the Tribunal has the power «to prosecute persons committing or ordering to be committed grave breaches of the Geneva Conventions of 12 August 1949, namely the following acts against pers provisions of the relevant Geneva Convention» including the following:

(a) wilful killing;

(c) wilfully causing great suffering or serious injury to body or health;

(d) extensive destruction and appropriation of property, not justified by military necessity and carried out unlawfully and wantonly.

AND WHEREAS by Article 3 [of] the said Statute,

the International Tribunal shall have the power to prosecute persons violating the laws or customs of war. Such violations shall include, but not be limited to:
(a) employment of poisonous weapons or other weapons to cause unnecessary suffering;
(b) wanton destruction of cities, towns or villages, or devastation not justified by military necessity;
(c) attack, or bombardment, by whatever means, of undefended towns, villages, dwellings, or buildings;
(d) seizure of, destruction or wilful damage done to institutions dedicated to religion, charity and education, the arts and sciences, historic monuments and works of art and science.

AND WHEREAS by Article 6 of the said Statute «the International Tribunal shall have jurisdiction over natural persons pursuant to the provisions of the present Statute;»

AND WHEREAS Article 7 of the said Statute provides for individual criminal responsibility thus:

1. A person who planned, instigated, ordered, committed or otherwise aided and abetted in the planning, preparation or execution of a crime referred to in articles 2 to 5 of the present Statute, shall be individually responsible for the crime.

2. The official position of any accused person, whether as Head of State or Government or as a responsible Government official, shall not relieve such person of criminal responsibility or mitigate punishment.

3. The fact that any of the acts referred to in articles 2 to 5 of the present Statute was committed by a subordinate does not relieve his superior of criminal responsibility if he knew or had reason to know that the subordinate was about to commit such acts or had done so and the superior failed to take the necessary and reasonable measures to prevent such acts or to punish the perpetrators thereof.

4. The fact that an accused person acted pursuant to an order of a Government or of a superior shall not relieve him of criminal responsibility, but may be considered in mitigation of punishment if the International Tribunal determines that justice so requires.

AND WHEREAS Article 8 of the said Statute provides that the territorial and temporal jurisdiction of the Tribunal «shall extend to the territory of the former Socialist Federal Republic of Yugoslavia, including its land surface, airspace and territorial waters. The temporal jurisdiction of the International Tribunal shall extend to a period beginning on 1 January 1991;»

AND WHEREAS by Article 9 of the said Statute «the International Tribunal and national courts shall have concurrent jurisdiction to prosecute persons for serious violations of international humanitarian law committed in the territory of the former Yugoslavia since 1 January 1991» but the International Tribunal «shall have primacy over national courts;»

AND WHEREAS Article 18 of the said Statute provides inter alia that:

1. The Prosecutor shall initiate investigations ex-officio or on the basis of information obtained from any source, particularly from Governments, United Nations organs, intergovernmental and non-governmental organizations. The Prosecutor shall assess the information received or obtained and decide whether there is sufficient basis to proceed.

2. The Prosecutor shall have the power to question suspects, victims and witnesses, to collect evidence and to conduct on-site investigations. In carrying out these tasks, the Prosecutor may, as appropriate, seek the assistance of the State authorities concerned.

4. Upon a determination that a prima facie case exists, the Prosecutor shall prepare an indictment containing a concise statement of the facts and the crime or crimes with which the accused is charged under the Statute. The indictment shall be transmitted to a judge of the Trial Chamber.

AND WHEREAS the President of the Tribunal, Judge Gabrielle Kirk McDonald, in a press release of April 8, 1999, urged that: All States and organisations in possession of information pertaining to the alleged commission of crimes within the jurisdiction of the Tribunal should make such information available without delay to the Prosecutor.

AND WHEREAS on April 30 in Geneva the United Nations High Commissioner for Human Rights Mary Robinson in a speech to the Commission cited a letter from the Prosecutor in which the Prosecutor stated:

The actions of individuals belonging to Serb forces, the Kosovo Liberation Army (KLA), or NATO may come under scrutiny, if it appears that serious violations of international humanitarian law have occurred.

AND WHEREAS High Commissioner Robinson also stated in her speech: In the NATO bombing of the Federal Republic of Yugoslavia, large numbers of civilians have incontestably been killed, civilian installations targeted on the grounds that they are or could be of military application and NATO remains sole judge of what is or is not acceptable to bomb. In this situation, the principle of proportionality must be adhered to by those carrying out the bombing campaign. It surely must be right to ask those carrying out the bombing campaign to weigh the consequences of their campaign for civilians in the Federal Republic of Yugoslavia.

AND WHEREAS NATO has carried out between 5,000 and 10,000 bombing missions over the territories of the former Yugoslavia since March 24, 1999;

AND WHEREAS NATO leaders have openly admitted targeting civilian infrastructure as well as military targets;

AND WHEREAS the list of targets has included fuel depots, oil refineries, government offices, power stations and communications links, such as roads,tunnels, bridges and railway links, including those not inside the region of, or in the vicinity of, Kosovo;

AND WHEREAS in addition to these deliberate attacks on civilian infrastructure and objects, there have been a great number of attacks which have caused direct physical harm and death to civilians;

AND WHEREAS it appears that these bombing missions have directly caused the death of approximately 1,000 civilian men, women and children and serious injury to 4,500 more;

AND WHEREAS instances of this nature include the 12 April bombing of a train travelling from Belgrade to Ristovac as it crossed the bridge spanning the Yuzhna Morava river at the Grdelica gorge, killing at least 10 passengers and wounding 16; the 15 April bombing of a refugee convoy in four separate locations along a 12 mile stretch of the road that runs from Prizren to Djakovica, killing approximately 74 people; the 23 April bombing of Serbian Television editorial offices, killing approximately 15 people; the 27 April bombing of a residential district in Surdulica, killing 16 people including 12 children; and the May 1 bombing of a bus on the Luzan bridge in Kosovo killing at least 34 people including 15 children;

AND WHEREAS, though the above-named NATO leaders have claimed that these incidents were accidents, they have also admitted that they were an inevitable result of their bombing strategy, a strategy which they appear to have continued unmodified and even to have intensified throughout these incidents;

AND WHEREAS there is ample evidence in the public statements of NATO leaders that these attacks on civilian targets are part of a deliberate attempt to terrorize the population to turn it against its leadership;

AND WHEREAS the NATO bombing has done an estimated $100 billion dollars in property damage and completely destroyed or seriously damaged dozens of bridges, railways and railway stations, major roads, airports, including civilian airports, hospitals and health care centres, television transmitters, medieval monasteries and religious shrines, cultural-historical monuments and museums, hundreds of schools, faculties and facilities for students and children, thousands of dwellings and civilian industrial and agricultural facilities;

AND WHEREAS refineries and warehouses storing liquid raw materials and chemicals have been hit causing environmental contamination and exposing the civilian population to the emission of poisonous gases;

AND WHEREAS the NATO bombings have also made use of weapons banned by international convention, including cruise missiles utilizing depleted uranium highly toxic to human beings;

AND WHEREAS credible detailed reports of the civilian death and destruction inflicted by the NATO bombing are attached as an Annex to this Notice;

AND WHEREAS THEREFORE there is abundant evidence that many instances of serious violations of international humanitarian law within the jurisdiction of the Tribunal have been committed by NATO forces in the attack on Yugoslavia commencing March 24 and continuing to this day;

AND WHEREAS this evidence is readily available to the Prosecutor in eyewitness, videotaped, televised and publicly broadcast reports, in press reports and on the Internet, and in the evidence presented by the Federal Republic of Yugoslavia in its current complaint against the NATO countries before the International Court of Justice;

AND WHEREAS all of the above-named persons, Heads of State and Government of the 19 NATO countries, their Foreign Ministers and Ministers of Defence, and officials and military leaders of NATO, have admitted publicly to having agreed upon and ordered these actions, being fully aware of their nature and effects;

AND WHEREAS the above-named persons have acted in open violation of the United Nations Charter, which provides in so far as is relevant:

Article 2.3. All Members shall settle their international disputes by peaceful means in such a manner that international peace and security, and justice, are not endangered.

4. All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state, or in any other manner inconsistent with the Purposes of the United Nations.

Article 33.1. The parties to any dispute, the continuance of which is likely to endanger the maintenance of international peace and security, shall, first of all, seek a solution by negotiation, enquiry, mediation, conciliation, arbitration, judicial settlement, resort to regional agencies or arrangements, or other peaceful meansof their own choice.

Article 37.1. Should the parties to a dispute of the nature referred to in Article 33 fail to settle it by the means indicated in that Article, they shall refer it to the Security Council.

2. If the Security Council deems that the continuance of the dispute is in fact likely to endanger the maintenance of international peace and security, it shall decide whether to take action under Article 36 or to recommend such terms of settlement as it may consider appropriate.

Article 39. The Security Council shall determine the existence of any threat to the peace, breach of the peace, or act of aggression and shall make recommendations, or decide what measures shall be taken in accordance with Articles 41 and 42, to maintain or restore international peace and security.

Article 41. The Security Council may decide what measures not involving the use of armed force are to be employed to give effect to its decisions, and it may call upon the Members of the United Nations to apply such measures. These may include complete or partial interruption of economic relations and of rail, sea, air, postal, telegraphic, radio, and other means of communication, and the severance of diplomatic relations.

Article 42. Should the Security Council consider that measures provided for in Article 41 would be inadequate or have proved to be inadequate, it may take such action by air, sea, or land forces as may be necessary to maintain or restore international peace and security. Such action may include demonstrations, blockade, and other operations by air, sea, or land forces of Members of the United Nations.

Article 51. Nothing in the present Charter shall impair the inherent right of individual or collective self-defence if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security. Measures taken by Members in the exercise of this right of self-defence shall be immediately reported to the Security Council and shall not in any way affect the authority and responsibility of the Security Council under the present Charter to take at any time such action as it deems necessary in order to maintain or restore international peace and security;

AND WHEREAS the International Court of Justice has stated in ruling against United States intervention in Nicaragua: In any event, while the United States might form its own appraisal of the situation as to respect for human rights in Nicaragua, the use of force could not be the appropriate method to monitor or ensure such respect. With regard to the steps actually taken, the protection of human rights, a strictly humanitarian objective, cannot be compatible with the mining of ports, the destruction of oil installations, or again with the training, arming and equipping of the contras.

(CASE CONCERNING THE MILITARY AND PARAMILITARY ACTIVITIES IN AND AGAINST NICARAGUA (NICARAGUA v. UNITED STATES OF AMERICA) (MERITS) Judgment of 27 June 1986, I.C.J. Reports, 1986, p.134-135, paragraphs 267 and 268)

AND WHEREAS the above-named persons, Heads of State and Government of the 19 NATO countries, their Foreign Ministers and Ministers of Defence, and officials and military leaders of NATO have acted in open violation of the NATO Treaty which provides in so far as is relevant:

Article 1. The Parties undertake, as set forth in the Charter of the United Nations, to settle any international dispute in which they may be involved by peaceful means in such a manner that international peace and security and justice are not endangered, and to refrain in their international relations from the threat or use of force in any manner inconsistent with the purposes of the United Nations.

Article 7. This Treaty does not affect, and shall not be interpreted as affecting in any way the rights and obligations under the Charter of the Parties which are members of the United Nations, or the primary responsibility of the Security Council for the maintenance of international peace and security;

AND WHEREAS the above-named persons have acted in open violation of the Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts(Protocol I), 8 June 1977, which provides as follows:

Art 51. -- Protection of the civilian population

1. The civilian population and individual civilians shall enjoy general protection against dangers arising from military operations. To give effect to this protection, the following rules, which are additional to other applicable rules of international law, shall be observed in all circumstances.

2. The civilian population as such, as well as individual civilians, shall notbe the object of attack. Acts or threats of violence the primary purpose of which is to spread terror among the civilian population are prohibited.

3. Civilians shall enjoy the protection afforded by this section, unless and for such time as they take a direct part in hostilities.

4. Indiscriminate attacks are prohibited. Indiscriminate attacks are: (a) those which are not directed at a specific military objective; (b) those which employ a method or means of combat which cannot be directed at a specific military objective; or (c) those which employ a method or means of combat the effects of which cannot be limited as required by this Protocol; and consequently, in each such case, are of a nature to strike military objectives and civilians or civilian objects without distinction.

5. Among others, the following types of attacks are to be considered as indiscriminate: (a) an attack by bombardment by any methods or means which treats as a single military objective a number of clearly separated and distinct military objectives located in a city, town, village or other area containing a similar concentration of civilians or civilian objects; and (b) an attack which may be expected to cause incidental loss of civilian life, injury to civilians, damage to civilian objects, or a combination thereof, which would be excessive in relation to the concrete and direct military advantage anticipated.

Art 79. Measures or protection for journalists 1. Journalists engaged in dangerous professional missions in areas of armed conflict shall be considered as civilians within the meaning of Article 50, paragraph 1.

Article 85 -- Repression of breaches of this Protocol

3. In addition to the grave breaches defined in Article 11, the following acts shall be regarded as grave breaches of this Protocol, when committed wilfully, in violation of the relevant provisions of this Protocol, and causing death or serious injury to body or health: (a) making the civilian population or individual civilians the object of attack; (b) launching an indiscriminate attack affecting the civilian population or civilian objects in the knowledge that such attack will cause excessive loss of life, injury to civilians or damage to civilian objects, as defined in Article 57, paragraph 2 (a) (iii);

5. Without prejudice to the application of the Conventions and of this Protocol, grave breaches of these instruments shall be regarded as war crimes.

AND WHEREAS the above-named persons have acted in open violation of the Principles of International Law Recognized in the Charter of the Nuremberg Tribunal and in the Judgment of the Tribunal, as adopted by the General Assembly of the united Nations (1950), which provide in so far as is relevant:

Principle III. The fact that a person who committed an act which constitutes a crime under international law acted as Head of State or responsible Government official does not relieve him from responsibility under international law.

Principle IV. The fact that a person acted pursuant to order of his Government or of a superior does not relieve him from responsibility under international law, provided a moral choice was in fact possible to him.

Principle VI. The crimes hereinafter set out are punishable as crimes under international law:

(a) Crimes against peace: (i) Planning, preparation, initiation or waging of a war of aggression or a war in violation of international treaties, agreements or assurances; (ii) Participation in a common plan or conspiracy for the accomplishment of any of theacts mentioned under (i).

(b) War crimes: Violations of the laws or customs of war include, but are not limited to, murder wanton destruction of cities, towns, or villages, or devastation not justified by military necessity.

Principle VII. Complicity in the commission of a crime against peace, a war crime, or a crime against humanity as set forth in Principle VI is a crime under international law;

THEREFORE we respectfully request that the Prosecutor immediately investigate and indict for serious crimes against international humanitarian law:

THE FOLLOWING HEADS OF STATE AND GOVERNMENT, MINISTERS OF FOREIGN AFFAIRS AND MINISTERS OF DEFENCE OF THE NATO COUNTRIES: William J. Clinton, Madeleine Albright, William S. Cohen (United States of America), Tony Blair, Robin Cook, George Robertson (United Kingdom), Jean Chrétien, Lloyd Axworthy, Arthur Eggleton (Canada), Jean-Luc Dehaene, E. Derycke, J.-P. Poncelet (Belgium), Vaclav Havel, J. Kavan, V. Vetchy (Czech Republic), Poul Nyrup Rasmussen, N.H. Petersen, H. Haekkerup (Denmark), Jacques Chirac, Lionel Jospin, H. Védrine, Alain Richard (France), Gerhard Schröder, J. Fischer, R. Scharping (Germany), Kostas Simitis, G. Papandreou, A. Tsohatzopoulos (Greece), Viktor Orban, J. Martonyi, J. Szabo (Hungary), David Oddsson, H. Asgrimsson, G. Palsson (Iceland), Massimo D'Alema, L. Dini, C. Scognamiglio (Italy), Jean-Claude Juncker, J. Poos, Alex Bodry (Luxembourg), Willem Kok, J. van Aartsen, F.H.G. de Grave (Netherlands), Kjell Magne Bondevik, K. Vollebøk, D.J. Fjørvoll (Norway), Jerzy Buzek, B. Geremek, J. Onyszkiewicz (Poland), Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama, V. Simão (Portugal), Jose Maria Aznar, A. Matutes, E. Serra Rexach (Spain), Bulent Ecevit, I. Cem and H. S. Turk (Turkey);

AND THE FOLLOWING OFFICIALS AND MILITARY LEADERS OF NATO: Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag, D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani and Daniel P. Leaf;

AND WHOEVER ELSE shall be determined by the Prosecutor's investigations to have committed crimes in the NATO attack on Yugoslavia commencing March 24, 1999.

Respectfully submitted, this 6th day of May, 1999

Michael Mandel (Professor) for W. Neil Brooks, Judith A. Fudge, H. J. Glasbeek, Reuben A. Hasson (Professors), Sil Salvaterra, David Jacobs, Brian Shell, Christopher Black, John Philpot, Fred Stasiuk (Barristers and Solicitors), Peter Rosenthal (Professor, Barrister and Solicitor), Roberto Bergalli (Professor), Alejandro Teitelbaum, Alvaro Ramirez González, Vanessa Ramos, Beinusz Szmukler (American Association of Jurists)

The following are two reports from Ministry of Foreign Affairs of the Federal Republic of Yugoslavia (a designated source of information under Article 18.1 of the Stature of the Tribunal):

1) NATO Crimes Against Civilians and Civilian Infrastructure in the Federal Republic of Yugoslavia (MINISTRY OF FOREIGN AFFAIRS YUGOSLAV DAILY SURVEY -- www.mfa.gov.yu/Bilteni/Engleski/si290499_1-e.html);

and 2) Civilian Victims and Devastation in NATO Aggression on Yugoslavia (SERBIAINFO -- www.serbia-info.com/news/1999-04/23/11210.html)

NATO CRIMES AGAINST CIVILIANS AND CIVILIAN INFRASTRUCTURE IN THE FEDERAL REPUBLIC OF YUGOSLAVIA (April 29, 1999)

The NATO criminal aggression represents the most flagrant violation of the Charter of the United Nations since the inception of the world Organization, a violation of the Helsinki Final Act and the undermining of the very foundations of the international legal order. At the same time, this aggression is a crime against peace, stability and humanity.

The Federal Republic of Yugoslavia has warned on time the United Nations Security Council of a possible aggression, and during the aggression itself it requested that it be immediately halted and most strongly condemned. Had this legitimate request of the Federal Republic of Yugoslavia been met, enormous human sufferings and destruction would have been avoided. The most illustrative examples are given below.

During the last thirty-six days of NATO aggression, the Federal Republic of Yugoslavia has been exposed to extensive civilian destruction, unprecedented in modern history of the world. NATO aggressors have focused their attacks primarily on civilian targets, directly threatening the lives and fundamental human rights of the entire population of the Federal Republic of Yugoslavia. By bombing relentlessly the cities, towns and villages throughout Yugoslavia, the NATO aggressor has killed so far, in nine hundred attacks, more than a thousand civilians, including a great number of children.

Over five thousand people sustained injuries, many of whom will remain crippled for life. At the same time, several thousand private homes and flats have been ruined, mostly in Belgrade, Nis, Cuprija, Aleksinac, Pristina, etc. We shall present the most tragic instances of the killings and plight of the innocent civilian population. Fifty-five passengers were killed and twenty-six injured in an international passenger train on the Belgrade-Thessaloniki line.

More than four hundred civilians were killed by NATO bombs in Kosmet: in the centre of Pristina, in Djakovica, Prizren, Kosovo Polje, Urosevac, Kosovska Mitrovica, in refugee camps in Orahovac and Srbica, Vitina, etc.

Thirteen civilians were killed and twenty-five wounded in an attack on Kursumlija.

Twelve civilians were killed and forty wounded in the bombing of Aleksinac.

Sixteen RTS workers were killed and seventeen wounded in the bombing of the headquarters of this biggest Radio and Television outlets in the FRY. Unfortunately, the final number of victims has not been established yet since more victims have remained buried in the rubble.

In Pancevo, Cacak, Vranje and Nis the number of casualties has been increasing each day.

Children are the most vulnerable category of the population, innocent and defenceless which suffer in particular due to the barbaric bombing of NATO aircraft, which is illustrated by the following examples:

The killing of seven children in Srbica from cluster bombs;

The killing of five children from the Kodza family in the village of Doganovici near Urosevac on 24 April 1999 as a result of the delayed effect of bombs (Edon, aged 3, Fisnik, aged 9, Osman, aged 13, Burim, aged 14 and Vajdet, aged 15. Six other children were also injured in the same incident, two of them were seriously wounded.

The killing of a three-year old Milica Rakic in the Belgrade suburb of Batajnica;

The killing of six children in the refugee centre in Djakovica and 19 children in the refugee column on the Prizren-Djakovica road;

The death of a child in Kosovo Polje; The killing of five years old girl Arta Lugic while her brothers Neron and Egzon and her sister Arijeta were seriously wounded in Lipljane;

The killing of nine children in Kursumlija; The killing of two children in Aleksinac, as well as other numerous examples.

Children are most often victims of the sprinkle cluster bos with delayed effect. The death toll on children would have been even more tragic, had the missile struck the biggest Maternity Hospital in Belgrade (It exploded some thirty metres away from the Hospital).

Particularly tragic is the fate of refugees, who convinced that they should not believe the propaganda ploys on the alleged «ethnic cleansing» decided to return to their homes. Legitimate authorities of the FRY encourage them every day to do so and guarantee their safety. On the occasion of a return of a large group of refugees, on 14 April, on the Djakovica-Prizren road, NATO aircraft killed 75 citizens of the FRY and wounded 111. The attack of NATO aircraft was systematically prepared and lasted for three hours. In this way, NATO has in the most brutal way «demonstrated» that the story of «humanitarian catastrophe» suits it only if it fits in the legitimate aggression on the FRY, as well as that innocent civilians are constantly taken advantage of for NATO interests in the Balkans.

In addition, NATO bombed several refugee camps in which Serbs expelled from Croatia and Bosnia and Herzegovina were accommodated (Djakovica, Pristina, Kursumlija, etc). Several dozens of refugees were killed, mostly children and the frail, ruthlessly ending their tragedy which came about in the wake of the break-up of Yugoslavia.

The aggressors war planes bombed at noon, on 27 April 1999, the residential area of the town of Surdulica. On that occasion 16 citizens were killed (including 12 children), while several dozen were wounded out of which twenty persons remained in hospital for further medical treatment. Hundreds of houses were raised to the ground or damaged. Special teams are still clearing up the debris so that it is not possible at the moment to estimate the real proportions of this notorious crime.

ASSASSINATION ATTEMPT ON PRESIDENT OF THE FEDERAL REPUBLIC OF YUGOSLAVIA SLOBODAN MILOSEVIC

An assassination attempt on the President of the Federal Republic of Yugoslavia on 22 April 1999 represents an organised terrorist act without precedent in the history of modern Europe. This is not only a crime against a Head of a sovereign State, but primarily an attack on the democratically expressed will of a people and thus against the foundations of the democratic values of the civilisation.

Although the residence of the President of the Federal Republic of Yugoslavia was targeted, this attack has also a symbolic meaning as if the targets had been the homes of all Yugoslav citizens. This crime has caused abhorrence and condemnation by international public. However, it is incomprehensible that the United Nations Security Council has remained silent and failed to condemn this terrorist act or the killings of civilians and children.

The destruction of more than ten private radio and television stations, two dozen TV transmitters, as well as the bombing of the Radio and Television of Serbia building on 23 April 1999 represents the biggest aggression against freedom of thought and a disgrace to the civilization at the threshold of a third millennium.

Transmitters at Iriski venac, Krnjaca, Mt Cer, Bukulja, Tornik, Crnivrh, Jasetrebac, Ovcar, Grmija and others were destroyed, so that the transmitter infrastructure at the entire territory of Serbia was severely damaged. Two times in six days the studios and transmitter located at the business centre «Usce» which housed TV stations: BK TV, Pink, Kosava and SOS Channel, as well as several other radio stations were bombed.

Transmitter of the TV station Palma was bombed and destroyed on 28 April 1999.

The satellite station «Yugoslavia» in the village of Prilike near Ivanjica was severely damaged.

The building was demolished taking a heavy toll during the bombing of the largest Radio and TV company in the Balkans with 7000 employees and the state-of-the-art infrastructure which was made available to hundreds of foreign correspondence. The aim of this crime, in which 16 RTS workers were killed and 19 wounded, was more than obvious: to suppress the right to a different opinion and its being publicly expressed with a view to pursuing further war-mongering manipulation with the world public. Clearly, the intention of NATO aggressors is to prevent the world public from learning the extensive scope of their crimes and to impose on the world their totalitarian and single-minded perception.

Many newspapers in the world and renowned journalists have already raised their voice against the propaganda fabrications of the NATO aggressors.

For all champions of the freedom of speech and for all people committed to the right to freedom of expression, this destructive act represents the last warning alarm before NATO generals take control over the aggressors' media.

According to the assessment of experts from Western countries, the damage done to date by NATO air strikes is well in excess of one hundred billion US dollars. By the destruction of factories, business capacities and production facilities, more than half a million people have lost their jobs and over two million of them remained without any kind of income. Destroyed are the industrial complexes in Belgrade, Novi Sad, Kragujevac, Nis, Pancevo, Cacak, Kraljevo, Valjevo, Pristina, Vranje, Kursumlija, Krusevac, Kula, Gnjilane, Sremska Mitrovica and in other towns and cities.

The petrochemical industry of the Federal Republic of Yugoslavia has been totally destroyed, as well as the largest Yugoslav factory of artificial fertilisers. Private entrepreneurs are a particular target of NATO aggression and the most glaring example of it is the destruction of the «Usce» businesscentre in Novi Beograd which was hit on 21 and 27 April1999. That was one of the biggest business centres in the Balkans, which housed more than a hundred newly established private firms in full business expansion, foreign representative offices, seven private Radio and TV stations and one of the most modern poli-clinics in the FRY. The building of this business centre is also one of the landmarks of modern Belgrade.

On the false pretext of «neutralizing the military power of the Federal Republic of Yugoslavia», the NATO aggressor started systematic destruction of the major Yugoslav road and rail traffic routes. About 20 bridges have been totally demolished so far and a few dozen of them have been damaged. Also, several dozen major and local roads, airports, railway tracks, railway stations, etc. have been destroyed. All ruined facilities were part of costly capital investments, into which the resources and the efforts of several generations of Yugoslav citizens were pooled. All the facilities are strategic part of the European traffic infrastructure, and some of them are of historical and cultural importance («The Wailing Bridge» in Novi Sad, on which the Fascists killed several thousand Jews in the Second World War).

About 30 bridges have been destroyed including those at the strategic European E-75 corridor. By the destruction of the bridges on the Danube river the aggressors have blocked the entire river navigation at this traffic artery of the greatest importance for European economy and the shortest link between the Northern and Mediterranean sea (The Rhein-Mein-Danube route). Thus, the European shipping companies suffer each day the damage of over 20 million DM.

Examples: Sloboda Bridge, Wailing Bridge, Zezelj Bridge and the bridge in Beska (all in the city of Novi Sad), several bridges on the Ibar primary road and on the major railway lines.