What are the main issues in international law preventing recognition of the Armenian Genocide?
Introduction:
In 1915, the Ottoman Empire of Turkey embarked on a campaign of deportation, destruction and mass murder which was inflicted upon Armenian people during a brutal and hostile take-over of Armenian territory. The Ottoman government at the time was controlled by the Committee of Union Progress (CUP), otherwise known as the Young Turks, who subjected the people of previously independent Armenia to bouts of unspeakable acts of violence that included hanging, torture, forcible drowning, rape and other forms of despicable behaviour that evidenced fundamental violations of human rights. Many Armenian’s were also displaced and driven from their homes due to intimidation and threats of violence from the Young Turks. Through the atrocities and massacres, an estimated 1.5 million Armenian lives were taken unjustly in a crime that the international system has yet to adequately address. Despite the overwhelming evidence indicating Armenians were the victims of a mass genocide, issues remain in establishing the genocide as an international crime punishable under international law. This essay will attempt to analyse the main problems of applying recognition of the Armenian Genocide in international law through the International Criminal Court. This will attempt to identify the retroactive and definitive limitations of the court in addressing the Armenian Genocide, which occurred more than a century ago. This essay will also question whether the International Criminal Court can be an effective tool in providing justice and reparations to Armenia. Next, the essay will explore how international law is applied by other countries in the West in relation to the Armenian Genocide. This part of the essay will focus on three specific NATO allies, the United Kingdom, the United States and Turkey who all demonstrate opposing views surrounding the formal recognition of the Armenian Genocide. The essay will attempt to identify the numerous implications this entails regarding international law, the criminal justice system and international justice.
Main issues in the International Criminal Court:
The Armenian Genocide was instrumental in aiding the development of an international system to address the issue of genocide and prevent future genocides from occurring. The Armenians have long strived to “attain recognition and reparations” (Jacob, 2014) from the criminal justice system to no avail. The International Criminal Court (ICC) is one example that has been shown to be ineffective at providing justice or relief for victims and survivors of the Armenian Genocide. Jacob (2014) states “the Armenian issue is one of many interwoven dimensions – political, diplomatic, legal and historical”. These dimensions expose the limitations of the ICC frameworks in addressing the crime of genocide in three key areas. The first is the versatile nature of international law itself.
International law is predicated on a set of rules, norms and standards that are generally recognised as binding between nation states. These are normally established through guidelines and mutual conceptual frameworks that govern issues such as war, trade, economic relations and human rights. A problematic area of international law is that the legal obligations that bind states come from a wide range of contrasting sources that include treaties, international customary law and UN resolutions. A consequence of this is that different states tend to take different approaches to their international obligations making it difficult to conclusively apply the law on an ‘international’ scale.
The ICC also displays problems with definitions of genocidal acts. The term genocide has become historically linked with lawyer Raphael Lemkin who coined the term as a categorisation for crimes such as the Armenian Genocide, the Holocaust and other historical atrocities (Douglas, 2017), where a particular group specifically aimed to cause the destruction of another group. The phrase has Greek and Latin origins meaning “Genos (race/tribe) and cide (killing)” (Ifeakandu and Ochem, 2021). A significant limitation concerning the definition of genocide is that “cultural genocide is not a recognised category in the ICC” (Jacob, 2014). Jacob (2014) proposes the act of genocide be categorised “under a newer definition of crime against humanity in the ICC statute”. This would help define crimes of persecution and extermination under a clear category. Ethnic cleansing could also be considered a crime against humanity, as it involves “rendering an area homogenous by use of force or intimidation to remove persons of given groups from that area” (Digital Commons, 2006; Jacob, 2014). Recent developments in human rights research show that sexual violence and forced marriages are now being recognised as “tools of war and genocide” (Gzoyan and Galustyan, 2021). The concept of forced marriage originated with the Armenian Genocide after the Ottoman Empire enforced violent marriages on many Armenian women, forcing them to marry abusive Turkish men. Gzoyan and Galustyan, find that if forced marriages and sexual violence were ‘tools of genocide’, this can help establish a category of “crime against humanity” and therefore provide a clearer definition of the term genocide that can be universally applied.
Another significant issue is the retroactive jurisdiction of the ICC. The ICC is the “first permanent international tribunal with jurisdiction over crimes in 100 countries” (Jacob, 2014). This means “authoritative jurisdiction cannot be applied to countries who are not party to ICC statute” (Jacob, 2014). Turkey is not currently a member of the ICC statute and therefore, “court prosecutors do not have any command over the cases that lie within Turkey’s confines” (HETQ, 2023). Even though evidence can be found of forced deportation and massacres by the Ottoman Empire which were clear violations of article VII of the statute of the ICC, the limitations of the ICC framework prevent any action being taken against Turkey for their part in the atrocities. It has been suggested that a way of overcoming this obstacle would be to “set up another court or international tribunal” (Jacob, 2014) with the appropriate means to further investigate the Armenian Genocide issue.
Moreover, ICC court only “has jurisdiction with respect to crimes committed after the entry of this force into statute” (Jacob, 2014) highlighting the ICC’s inability to effectively apply justice to genocides of the past. The recognition of the Armenian Genocide would mean establishing an international crime which demands reprimand. Schabas (2010) cites “good authority that genocide was a punishable crime” long before the term was coined by Lemkin in 1944 (Douglas, 2017). However, as there are no remaining living suspects “who can be traced to the acts of 1915” (Schabas, 2010) it is impossible to hold the perpetrators accountable through trials and punitive measures. This raises the question of whether the ICC can ever truly be effective at addressing issues surrounding the Armenian Genocide or providing reparations to modern Armenians.
Main issues in the United Kingdom:
There are several issues preventing the United Kingdom’s recognition of the Armenian Genocide through international law. One such issue involves the UK’s ambiguous adherence to international law. It has been recognised that the “UK takes a fundamentally dualist view of international law” (Lord Mance, 2017). This means that the UK tends to see domestic law and international law as separate and apart from each other. “The dualist view leaves it up to each separate state to determine how international rules are applied at national level” (Butchard, 2020). It seems many of the UK’s international commitments are based on domestic legislation rather than being applicable through a top-down hierarchical structure of international law. In the UK, the incorporation of international law into domestic law depends upon two main factors: the acceptance by parliament through legislation, or through judges by way of common law (Lord Mance, 2017). This implies that the provisions of an international treaty such as the Genocide Convention can only effectively take hold if it is “written into or incorporated by domestic law” (Butchard, 2020). Due to the UK’s dualist approach to international law, there are many “international disputes” and “allegations of breaches of international law that are never formally adjudicated or decided upon” (Butchard, 2020).
One of the largest and most controversial of these disputes is the UK’s lack of recognition concerning the Armenian Genocide in 1915. Many UK politicians have advocated for recognition of the atrocities including Baroness Cox, member of the House of Lords, and John Spellar of the Labour Party who recently sponsored a bill to “formally recognise the Armenian Genocide” (UK Parliament, 2022). However, this bill is presently still in the reading stages in the House of Commons, has not yet reached the House of Lords and is therefore still a long way from being finalised or agreed upon.
The UK’s current stance on the Armenian Genocide is that there is an “absence of evidence to show that the Ottoman Administration took a specific decision to eliminate Armenians under their control at the time” (Robertson, 2010). Due to this, British governments have refused to refer to the massacres of 1.5 million Armenians under the definition of genocide. This stance is evidence of the contradictory nature of the UK government regarding international law. This is further highlighted by the fact that the UK were one of the first governments along with France and Russia, to condemn the Armenian massacres in 1915 as a “monumental crime” (Robertson, 2010). Prime Minister at the time, Lloyd George publicly condemned the tragedies, acknowledging that the Armenian population had been significantly reduced under the control of the Ottomans. Winston Churchill was another prominent UK leader who also spoke of the massacres as being “planned and executed for political reasons” (Robertson, 2010).
The Paris Peace Conference in 1919 saw leaders of Britain call for the indictment and prosecution of Turkish leaders for “crimes committed against their own citizens” (Robertson, 2010). Under the Treaty of Versailles, war criminals who perpetuated acts of genocide could be brought to trial and the UK were instrumental in the rounding up of “67 Turkish officials suspected of ordering atrocities” (Robertson, 2010). The officials were held for trial in Malta under Article II of the Genocide Convention. This was the first attempt to apply international justice to the Armenian plight, which failed, as imperial politics took precedence over proceedings. The Turkish Officials were eventually released through diplomatic expediency in exchange for British hostages being held captive in Turkey. This evidence shows that the UK display some historical recognition of the massacres as some form of crime. This, however, is not the case in present-day and some have cited imperial politics as a contributing factor in Britain’s change of stance towards the Armenian Genocide. As a result, this has impacted and defined “British interventionism” regarding Armenia (Ancu Cretu, 2019).
The UK’s current stance is to promote reconciliation between Turkey and Armenia (Gov.UK, 2014) over recognition of the genocidal acts committed. The UK view the Armenian massacres as war or conflict between the nations rather than a genocide and cite the EU’s founding principle of ceasing tensions and conflicts between post-war nations. However, it has been argued that by adopting this approach, the UK are placing strategic alliances over historical tragedies which is detrimental to modern day Armenians. Turkey is a strategic ally to the UK on numerous “international, bilateral and multinational issues” (Gov.UK, 2014). Due to this alliance, it has been claimed that “Britain’s strategic relationship with Turkey has become more important than telling the truth” (The Guardian, 2015). Lehmann, (2023) notes that “foreign influence sometimeshelps shape state repression” and this is an area often overlooked when addressing the UK’s stance on the genocide. The UK has supported numerous projects aimed to promote the ‘normalisation’ of Turkish/Armenian relations which is contradictory as relations between the two are anything but normal. Mediation would call for a mutual agreement and the coming together of both nations to present the case to ICC, which is unlikely due to tensions between the countries.
Main issues in the United States:
Another strategic ally of Turkey is the United States. One of the first cases of interpretation of the Genocide Convention came from the US government who stated that the “Turkish massacres of Armenians” were one of the “outstanding examples of the crime of genocide” (Robertson, 2010). In 2021, US President Joe Biden announced “formal recognition” of the Armenian Genocide based on the mass killing and deportations of a large part of the Armenian population (Baillie, 2021). This decision made the US one of thirty countries to formally recognise the genocide. Others include France, Germany and Canada. The US’ recognition of the Armenian Genocide is a stark contrast to other US allies such as Turkey, Britain and Israel who show no signs of formal recognition (Roache, 2021). Biden’s declaration was said to have “righted a historical wrong” and “underscored US commitment to preventing future instances of genocide and mass atrocities” (Baillie, 2021).
While the declaration is a progressive step, there are still several issues preventing recognition of the Armenian Genocide in international law. It is important to note that while the statement is of extreme historical significance, the House Senate resolution which provides the recognition is not legally binding. Moreover, Roache (2021) highlights the fact that it has taken a hundred plus years for the US to provide said recognition despite being the first country to advocate for it through the Genocide Convention. This has potential psychological effects on those who witnessed the genocide, and may experience “survivor guilt” (Roache, 2021). The recent article by Time identifies that “recognising Armenia’s past without its present is not meaningful”. Roache also notes that the only way that the declaration has any true meaning is if the US take measures to protect “modern day Armenians”. The application of these protection measures for Armenia has become particularly prevalent in relation to the recent Armenia/Azerbaijan conflict over the region of Nagorno-Karabakh.
During this modern conflict, “Russian peace deals demanded that Armenia hand over control of large swathes of territory to Azerbaijan” and “over 40,000 Armenians were permanently displaced” (Roache, 2021). During the 1990s, outbreaks of violence between opposing national groups of both countries were common but tensions remained relatively stable in the area. Stability ensued until 2016 when, “Azerbaijan began invading areas controlled by Armenian backed forces” (Carney, 2020). The Armenia/Azerbaijan conflict has been backed politically and militarily through its Turkish alliance. A BBC report (2021) shows that Turkey’s military prepared Azerbaijan in the weeks preceding the conflict’s escalation. The aspect of Turkish involvement made many Armenians fearful Turkish forces would attempt the slaughter of their people creating situations that resembled past atrocities.
Towards the end of 2022, Azerbaijani forces closed the Lachin Corridor connecting Karabakh and Armenia (Kucera, 2023). Amnesty International (2023) condemned installation of the blockade as an action that would instigate “food and fuel shortages” as well as negatively impact access to health care. The report showed that, “120,000 ethnic Armenian residents were left without access to essential goods and services, including life-saving medication and healthcare” (Ghahramanyan, 2023). Moreover, Azerbaijan was found to have violated their “human rights obligations by taking no action to lift the blockade” (Amnesty International, 2023). Further violations were evidenced when Mayor of Paris, Anne Hildalgo, attempted to provide humanitarian aid in the form of “trucks carrying food, power generators and solar panels” which were halted by the Azerbaijani military (The Insider, 2023). Humanitarian attempts by the Red Cross were also prevented.
Former prosecutor for the ICC, Luis Moreno Ocampo (2023) has suggested the blockade “should be considered genocide under article II of the Genocide Convention: Deliberately inflicting on the group conditions of life that calculated to bring about its destruction”. Simon Maghakyan, human rights activist, and lecturer for international relations at the University of Colorado, has also referred to the ongoing conflict as a modern “cultural genocide” (Time, 2020). Maghakyan’s independent research revealed that Azerbaijan embarked on a thirty-year campaign to “systematically eliminate indigenous Armenian culture in Nakhichevan”, which includes the destruction of over 5,000 “cultural and religious artefacts” (Time, 2020).
US recognition of Armenia’s past genocide may help with the healing of historical wounds (Simmons, 2021) but does little to acknowledge the fact that genocide is also currently a present-day issue for many Armenians. Roache (2021) has recommended the US place sanctions on Turkey and Azerbaijan for their roles in the conflict. The lack of intervention from the US regarding the conflict only further emphasises the complexities of the US’ relationship with international law which is often seen as “inconsistent” and “hypocritical” (García Iommi and Maass, 2022).
Main Issues in Turkey:
Despite often being referred to as the “first major genocide of the 20th century” (Dadrian, 2010), denial of its occurrence has been evident in a lengthy line of Turkish governments with what has been referred to as “defiance and truculence” (Dadrian, 2010). Turkish denial is a significant factor in preventing recognition of the Armenian Genocide in international law. Dadrian (2010) notes that the aftermath of World War 1 saw “the highest authorities of the Turkish government condemn wartime deportations and massacres of Armenians as a crime against humanity”. The post-war Turkish establishment displayed a degree of outrage and guilt regarding their part in the atrocities and outright conceded that “Armenians were killed as part of an extermination programme” (Demirdjian, 2018). The outrage and guilt was ultimately short-lived and did not endure in the same way when compared with Turkish views on the Holocaust.
This change in stance became more prevalent after the decline of the Ottoman Empire and coincided with the rise of the Kemalist movement, post-World War I (Dadrian, 2010). Kemalism is a philosophical ideology based upon the modernisation, reformation and transformation of Turkish society. It was an instrumental part of “Mustafa Kemal Atatürk’s resistance movement in Anatolia” and was also “the ideological basis” behind the Turkish revolution (Killi, 1980). This secular ideology focused on rebuilding Turkey after defeat to the allies, whilst simultaneously removing attention from Turkish war crimes previously committed. This long period of Turkish “nation-building prevented the prospect of restitution, reparation and reconciliation” with Armenia (Demirdjian, 2018).
Dadrian (2010) asserts that the rise of the Kemalist movement was a significant factor in spawning “a new political culture”, centred on denial. The cultivation of denial culture is a substantial hindrance in Turkey’s formal recognition of the massacres, whose views have remained steadfast even in the face of the most glaring of evidence. For instance, Turkish Officials have repeatedly denied any claims regarding a “premeditated plan to annihilate the Armenian population” (Demirdjian, 2018). These claims are often dismissed as untrue. However, evidence can be found to implicate Turkey in “centrally organised mass murder” (Dadrian, 2010), which was orchestrated on political grounds via authority of the Ottomans. Çürüksulu Mahmut, retired General of the Ottoman Empire, stated in a declaration to Senate that the “massacres were ordered by the Committee of Union Progress Party and organised in the Trabson Province by Govenor General Cemal Azmi” (Dadrian, 2010). Moreover, Chamber of Deputies member Hafiz Mehmet also provides evidence through an eye-witness account of “drowning operations”, where vast numbers of Armenians were loaded onto a barge and “thrown into the Black Sea” under the specific orders of General Amzi (Dadrian, 2010). This is a small example of the many atrocities committed against the people of Armenia by Turkey that are considered a prosecutable crime.
Denial culture has seen many modern Turkish governments argue the case that several Turkish soldiers were also killed during the conflict. This view overlooks considerable evidence that Armenians were subject to intense occupation by the Ottoman Empire. Armenians had lived in the Caucasus region of Eurasia as an independent entity for an estimated 3,000 years before the invasions that eventually “absorbed Armenia into the Mighty Ottoman Empire” (History, 2010). This means Turkish soldiers killed by Armenians were likely, acts of self-defence or retaliation for barbaric behaviour first inflicted upon them. Former Turkish President Ahmet Riza openly stated that many Armenians were murdered “on political grounds involving application of an official state policy “(Dadrian, 2010). This is a discrepancy that emanates from denial when assessing causation of deaths. Denial does not account for trying to eradicate large parts of the Armenian population from history, neither can it be utilised to dispute evidence that suggests “the decision to exterminate Armenians was made, in the course of several meetings of the Young Turk Central Committee” (Kervorkian, 2008) which was then carried out by the Turkish military.
Denial still persists in present-day Turkish culture and politics, despite “various judicial decisions, including Turkish courts which acknowledge a policy of massacres and persecution did take place” (Demirdjian, 2018). It has also been found that many “authors and journalists” in Turkey who use the term “genocide” have been subject to harsh prosecution (Roache, 2021). A likely factor in the persistence of denial culture may be the result of the current Turkish Republic being a “continuing state of the Ottoman Empire” (Dumberry, 2014). Due to this, Dumberry has advocated that the crimes of the Ottoman Empire should be absorbed by the Turkish Republic, and that Turkey should be “held accountable” for their role in historic crimes of genocide. Dumberry also highlights the difficulties in assigning responsibility to Turkey due to the aforementioned restrictions of the ICC.
Taking a progressively alternate approach, Demirdjian (2018) proposes that rather than seeking to apply punitive measures for crimes of the past, there may be some value in seeking to apply accountability “to those who instigate hatred against ethnic, religious, or political groups by predicating ‘denial’ of facts established in trial judgements”.
Conclusion:
In conclusion, this essay has sought to analyse and evaluate many of the complexities surrounding the recognition of the Armenian Genocide through international law. The research highlighted the limitations of the ICC to accurately define the term of genocide and to apply international accountability to those who participated in the atrocities. Further issues have been presented concerning the nature of international law and the varying degrees to which countries such the UK, US and Turkey demonstrate adherence to their international legal obligations. This was evident by the UK’s dual approach to international law, The US’ lack of intervention concerning modern human rights violations of Armenians in the Azerbaijan conflict, and the evolution of denial culture in Turkey. Ambiguous adherence to international law has far reaching implications for the international justice system in terms application of justice for the crime of genocide. The international system has been more of a hindrance in establishing recognition of the genocide than it has been useful at providing justice or reparations to Armenian people. Protection of Armenians who face modern forms of genocide in the Azerbaijan conflict is crucial in preventing a repetition of past genocidal acts. While this will not ease the pain of past historical tragedies, the gesture will go a long way to righting some of the terrible wrongs that have been committed against Armenia.
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