It is fitting that on December 9, 2024, the Paris court delivered its landmark conviction of Charles Onana and his publisher Damien Serieyx for contesting the Genocide against the Tutsi in Rwanda. This verdict is a powerful reminder of the global commitment to "never again."
Denial of genocide is not a mere intellectual exercise or a debatable opinion; it is a direct threat to the survival and dignity of those targeted for extermination. It seeks to erase their suffering, justify their annihilation, and perpetuate the ideologies that led to their slaughter.
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By denying the facts of genocide, perpetrators and their apologists seek to wipe away its victims from history and pave the way for further violence and marginalization. This practice must be viewed not as a misstep in free speech but as a dangerous ideology rooted in racism and hatred.
Whether it targets Jews through Holocaust denial or Tutsi through denial of the 1994 Genocide against the Tutsi in Rwanda, the consequences are similarly devastating.
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This is why denialism must be seen for what it is: an extension of the genocidal project, as dangerous as the machetes that once cut down Tutsi lives in Rwanda or the gas chambers that extinguished Jews in Nazi Germany.
Denial as an existential threat to humanity
International jurisprudence and historical experience reveal that denialism is not an abstract harm; it is an existential threat. As the UN Human Rights Committee observed in Malcolm Ross v. Canada (2000), hate speech, particularly Holocaust denial, undermines the dignity and security of the targeted group.
By failing to confront such ideologies, societies risk fostering environments where prejudice becomes normalized, and genocidal violence may be reignited. Genocide denial functions as the final stage of genocide itself.
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As Kenneth S. Stern writes in his book Holocaust Denial, "Denying the Holocaust is denying the identity and humanity of the survivors and those who perished. It is a second victimization of the Jews.”
The same logic applies to the denial of the Genocide against the Tutsi. When perpetrators and ideologues like Charles Onana deny the Genocide, they don’t just distort history—they attack the memory, identity, and survival of the Tutsi people.
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Stern, identifies denial as a deliberate form of hate speech, crafted to propagate antisemitism under the guise of intellectual discourse.
Genocide denial against the Tutsi operates in much the same way: masking its malevolence in pseudo-scholarly analysis while perpetuating hatred against survivors and their descendants.
Stern warns, "The denier’s goal is not simply to deny history but to erode the truth itself, creating a world in which the victims are forgotten, and the perpetrators are exonerated.”
The Paris court’s decision aligns with this understanding. By holding Onana accountable, the court reaffirmed that genocide denial is not free speech but a weaponized form of historical distortion.
Genocide denial is not merely offensive; it is dangerous. The UN Human Rights Committee affirmed in Robert Faurisson v. France (1996) that while freedom of expression is fundamental, it is not absolute.
Faurisson, a French Holocaust denier, sought to defend his speech under the guise of academic inquiry.
The Committee rejected his argument, underscoring—the denial or minimization of genocide constitutes an abuse of the right to freedom of expression, as it infringes upon the dignity of victims and undermines public order.
This ruling accentuates the principle that hate speech, including denialism, must be restricted to safeguard human dignity and social harmony.
The legal and moral imperative to act
Genocide denialism thrives where indifference and inaction prevail. The case of Malcolm Ross v. Canada (2000) serves as a cautionary tale. Ross, a Canadian school teacher, was dismissed for publishing antisemitic materials, including Holocaust denial.
The UN Human Rights Committee upheld his dismissal, recognizing that tolerating such hate speech could create a "poisoned environment" for vulnerable groups. This principle extends to the Tutsi survivors of genocide.
Allowing denialism to flourish—whether through books, speeches, or social media—perpetuates the trauma of survivors and emboldens extremists.
The European Union has also recognized the existential threat posed by denialism. Its Framework Decision on Racism and Xenophobia (2007) criminalizes the denial, minimization, or justification of genocide.
As Dan Bilefsky reported in The New York Times of April 19, 2007—this measure reflects a growing understanding that "tolerating denial is tantamount to tolerating the seeds of future atrocities."
The danger of indifference
History warns us of the dangers of indifference. During the Genocide against the Tutsi, the international community stood by as over one million people were slaughtered in just 100 days. Today, the indifference takes a different form: the tacit acceptance of denialism.
Prof. Deborah Lipstadt, whose courtroom battle against Holocaust denier David Irving was immortalized in the film Denial, aptly observed, "Indifference is as dangerous as hate. It signals to the deniers that their lies are acceptable, that their version of history can replace the truth.”
This indifference is evident in the chorus of defenders who rallied behind Charles Onana. From retired French generals to Belgian diplomats and military officers—these individuals lent their credibility to a man whose work distorts the historical record and legitimizes genocide ideology.
The presence of such figures underscores the insidious reach of denialism and the complicity of those who enable it.
As Yassin Tusingwire’s analysis of the ICTR (The Crime of Direct and Public Incitement to Commit Genocide Before the ICTR: A Case of Ngeze Hassan) demonstrates, denialism often intersects with incitement, creating a toxic environment where genocidal ideologies flourish unchecked.
Indifference to denialism adds fuel to this fire. Silence in the face of denial emboldens perpetrators and marginalizes survivors. Denialism feeds into genocidal ideologies, serving as a rallying point for hate groups.
Hassan Ngeze of the genocidaires’ magazine Kangura, for instance, used media not only to incite genocide but also to deny the crimes of perpetrators, attempting to rewrite history while the blood was still fresh.
Denialism, Tusingwire argues, serves a similar function in the post-genocide era by perpetuating the hatred that fueled the initial atrocities. It creates a fertile ground for future violence, normalizing genocidal ideologies and desensitizing society to their dangers.
The EU Framework Decision on Racism and Xenophobia recognized that denial of genocide constitutes incitement to hatred. This recognition stems from the understanding that genocide denial is not an isolated act but part of a continuum that dehumanizes victims, emboldens perpetrators, and prepares the ground for future violence.
The Human Rights Committee in J.R.T. and the W.G. Party v. Canada (1981) stated that expressions of racial superiority or hatred are incompatible with freedom of speech when they undermine the principles of equality and dignity.
Denialism fits squarely within this category—it is not an exercise in free inquiry but an expression of contempt for victims and a denial of their right to exist.
Indifference to denialism is complicity in its effects. Silence emboldens denialists, granting them a veneer of legitimacy and allowing their narratives to seep into mainstream discourse.
As Dan Bilefsky noted, the European Union's framework decision criminalizing genocide denial was adopted precisely because "indifference to such distortions is not neutral—it is harmful.”
Ignoring denialism risks normalizing it, perpetuating the marginalization of victims and creating fertile ground for extremist ideologies.
The conviction of Austrian neo-Nazi Gerd Honsik for Holocaust denial in Spain (2007) and the EU's 2007 Framework Decision criminalizing Holocaust denial highlight a growing international consensus: denialism is not merely a distortion of history but a direct threat to social stability and minority safety.
This sentiment is echoed in Malcolm Ross v. Canada, where the UN Human Rights Committee noted that the state has a duty to protect citizens from hate speech, as it undermines their dignity and security.
Allowing denialists to operate unchecked creates an environment where hate flourishes and violence becomes thinkable.
The Paris court’s conviction of Onana and his publisher, therefore, is not just a legal milestone but a moral necessity. It sends a clear message: those who deny genocide are complicit in its perpetuation.
The role for each and everyone
While legal frameworks are essential, combating denialism requires a collective effort. Civil society, educators, and political leaders must work together to preserve the memory of the Genocide against the Tutsi.
This includes challenging denialist narratives in public discourse, promoting accurate historical education, and supporting survivors in their quest for justice.
Lipstadt reminds us, "The battle against denial is not just about history; it’s about the future. It’s about what kind of society we want to live in.” The conviction of Onana is a step toward building a society that values truth over lies, dignity over hatred, and justice over indifference.
Genocide denial is antisemitism in the context of the Holocaust and anti-Tutsi racism in the context of the 1994 Genocide against Tutsi. As the cases of Faurisson, Ross, and others illustrate, societies have a legal and moral obligation to confront denialism head-on.
Indifference to denialism is not neutral—it is an enabler of harm. As Deborah Lipstadt noted, standing up to denial is not just about preserving history but about protecting the dignity and safety of targeted communities. Denialism is not an exercise in free speech; it is a weapon of hatred and dehumanization.
By holding figures like Onana accountable, the international community reaffirms its commitment to truth, justice, and human dignity. The fight against denialism is far from over, but each victory, like the conviction of Charles Onana, is a step toward ensuring that the horrors of genocide are neither forgotten nor repeated.
A slap in the face of denialists
The Paris court’s judgment is not just a victory for justice but a resounding rebuke to all those who defended or still defend Onana. Their efforts to whitewash history have failed spectacularly.
This ruling exposes their complicity and strips away the veneer of respectability you tried to lend to a man whose work desecrates the memory of the dead.
This conviction is a watershed moment, not just for France but for the global fight against genocide denial.
It paves the way for further action against the purveyors of hate, including infamous publishers like Sources du Nil of Eugene Shimamungu, whose mission is to rehabilitate genocidaires. Let it be a clear message to the Canadian deniers like Judi Rever and Robin Philpot.
It is a warning to DRC politicians who saw a messiah in Onana and a stark reminder that denialism will no longer be tolerated.
As Lipstadt once said, "We cannot afford to ignore the deniers, for their lies are not mere words—they are weapons.” The Paris court has disarmed one such weapon. Now it is up to all of us to ensure that the fight against denialism continues, for the sake of the victims, the survivors, and the future of humanity.