International Criminal Tribunal
to Investigate NATO Leaders
Madam Justice Louise Arbour, Prosecutor,
International Criminal Tribunal for the Former Yugoslavia,
Churchillplein 1, 2501 EW, The Hague, Netherlands.
William J. Clinton, Madeleine Albright and William S. Cohen,
C/o William J. Clinton, President
The White House, 1600 Pennsylvania Ave NW
Washington, District of Columbia 20500, United States of America
Tony Blair, Robin Cook and George Robertson,
C/o Rt. Hon. Tony Blair, Prime Minister
10 Downing St. SW1A 2AA London United Kingdom
Javier Solana, Jamie Shea, Wesley K. Clark, Harold W. German, Konrad Freytag.
D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani and Daniel P. Leaf,
C/o Javier Solana, Secretary General
NATO Headquarters, 1110 Brussels, Belgium
Jean Chrétien, Lloyd Axworthy and Arthur Eggleton,
C/o Jean Chretien, M.P., Prime Minister
House of Commons, PO Box 1103, Ottawa, Ontario K1A 0A6, Canada
Jean-Luc Dehaene, E. Derycke and J.-P. Poncelet,
C/o M. Jean-Luc Dehaene, Premier Ministre
rue de la Loi 16, B-1000 Brussels, Belgium
Vaclav Havel, J. Kavan and V. Vetchy,
C/o Vaclav Havel, President
Office of the President of the C.R., Hrad (Castle), 119 08 Praha 1, Czech Republic
Poul Nyrup Rasmussen, N.H. Petersen and H. Haekkerup,
C/o Poul Nyrup Rasmussen, Prime Minister
Prime Minister`s Office
Christiansborg, Prins Jorgens Gaard 11, DK-1218 Copenhagen, Denmark
Jacques Chirac, Lionel Jospin, H. Védrine and Alain Richard,
C/o M. Jacques Chirac, President de la Republique
Palais de l`Elysee, 55 et 57, rue du Faubourg Saint-Honore, 75008 Paris, France
Gerhard Schröder, J. Fischer and R. Scharping
C/o Gerhard Schoeder, Chancellor
Adenauerallee 141, PA: Briefpost, PLZ 53106, 53113 Bonn, Germany
Kostas Simitis, G. Papandreou and A. Tsohatzopoulos,
C/o Kostas Simitis, Prime Minister
Office of the Prime Minister, Greek Parliament Bldg, Constitution Square, Athens, Greece
Viktor Orban, J. Martonyi and J. Szabo,
C/oViktor Orban, Prime Minister
Kossuth Lajos ter 1-3, 1055 Budapest, Budapest fovaros, Hungary
David Oddsson, H. Asgrimsson and G. Palsson,
C/o David Oddsson, Prime Minister
Office of the Prime Minister, Stjornarradshusinu, 150 Reykjavik, Iceland
Massimo D'Alema, L. Dini and C. Scognamiglio,
C/o Massimo D'Alema, Presidenza del Consiglio dei Ministri (Prime Minister)
Piazza Colonna, 37, 00187 Rome, Italy
Jean-Claude Juncker, J. Poos and Alex Bodry,
C/o Jean-Claude Juncker, Prime Minister
Ministere d`Etat, 4, rue de la Congregation, L-2910 Luxembourg
Willem Kok, J. van Aartsen and F.H.G. de Grave,
C/o Willem Kok, Prime Minister
Binnenhof 20, 2513 AA, Postbus 20001, 2500 EA, The Hague, Netherlands
Kjell Magne Bondevik, K. Vollebæk and D.J. Fjærvoll,
C/o Kjell Magne Bondevik, Prime Minister
Akersgt. 42, blokk H, P.O. Box 8001 Dep, N-0030 Oslo, Norway
Jerzy Buzek, B. Geremek and J. Onyszkiewicz,
C/o Jerzy Buzek, Prime Minister
Prime Minister's Office, al. Ujazdowskie 1/3, 00-583 Warsaw, Poland
Antonio Manuel de Oliveira Guterres, J.J. Matos da Gama and V. Simão,
C/o Antonio Manuel de Oliveira Guterres, Prime Minister
Gabinete do Primeiro-Ministro, Lisboa, Portugal
Jose Maria Aznar, A. Matutes and E. Serra Rexach,
C/o Excmo. Sr. Jose Maria Aznar
Presidente del Gobierno, Complejo de la Moncloa, Edf. Semillas
28071 Madrid, Spain
Bulent Ecevit, I. Cem and H. S. Turk,
C/o Bulent Ecevit, Prime Minister
Office of the Prime Minister, Basbakanlik, 06573 Ankara, Turkey
Professor Michael Mandel, Professor W. Neil Brooks, Professor Judith A. Fudge,
Professor H. J. Glasbeek, Professor Reuben A. Hasson and Sil Salvaterra,
Barrister and Solicitor, Community Legal Aid Services Programme,
Osgoode Hall Law School, York University,
Toronto, Ontario,
Canada M3J 1P3
David Jacobs and Brian Shell, Barristers and Solicitors,
Shell, Jacobs Lawyers
672 Dupont Street,
Suite 401
Toronto, Ontario
Canada M6G 1Z6
Christopher Black, Barrister and Solicitor,
121 Nymark Avenue,
Toronto, Ontario
Canada M2J 2H3
John Philpot, Barrister and Solicitor,
Alariel Legault Beachemin Paquin Jobin Brisson & Philpot
1259 rue Berri suite 1000
Montréal, Québec
Canada H2L 4C7
Fred Stasiuk, Barrister and Solicitor,
296 Mill Road,
Unit B6
Etobicoke, Ontario,
Canada M9G 4X8
Professor Peter Rosenthal, Barrister and Solicitor,
Mathematics Department,
The University of Toronto,
Toronto, Ontario
Professor Roberto Bergalli,
Departament de Dret Penal i Ciences Penals
Universitat de Barcelona,
Av. Diagonal 684 E-08034
Barcelona, Spain
The American Association of Jurists:
Alejandro Teitelbaum,
Permanent Representative to the United Nations in Geneva.
80 Quai Gillet
69004 Lyon, France
Alvaro Ramirez Gonzalez, President,
Del Porton Oriental de la UCA 1 y media cuadra arriba
Apdo Postal 3348
Managua, Nicaragua
Vanessa Ramos,
Secretary General
200 Mercer Street 4E
New York, NY 10012
Beinusz Szmukler,
President, Consultative Council,
Peru 971 8 piso, B
1068 Buenos Aires, Argentina
RE: William J. Clinton, Madeleine Albright, William S. Cohen, Tony Blair, Robin
Cook, George Robertson, Javier Solana, Jamie Shea, Wesley K. Clark, Harold W.
German, Konrad Freytag. D.J.G. Wilby, Fabrizio Maltinti, Giuseppe Marani,
Daniel P. Leaf, Jean Chrétien, Lloyd Axworthy, Arthur Eggleton, Jean-Luc
Dehaene, E. Derycke, J.-P. Poncelet, Vaclav Havel, J. Kavan, V. Vetchy, Poul
Nyrup Rasmussen, N.H. Petersen, H. Haekkerup, Jacques Chirac, Lionel Jospin, H.
Védrine, Alain Richard, Gerhard Schröder, J. Fischer, R. Scharping, Kostas
Simitis, G. Papandreou, A. Tsohatzopoulos, Viktor Orban, J. Martonyi, J. Szabo,
David Oddsson, H. Asgrimsson, G. Palsson, Massimo D'Alema, L. Dini, C.
Scognamiglio, Jean-Claude Juncker, J. Poos, Alex Bodry, Willem Kok, J. van
Aartsen, F.H.G. de Grave, Kjell Magne Bondevik, K. Vollebæk, D.J. Fjærvoll,
Jerzy Buzek, B. Geremek, J. Onyszkiewicz, Antonio Manuel de Oliveira Guterres,
J.J. Matos da Gama, V. Simão, Jose Maria Aznar, A. Matutes, E. Serra Rexach,
Bulent Ecevit, I. Cem and H. S. Turk.
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 persons
or property protected under the 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
(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 bombıIn 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
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
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
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 means of 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 de mining of ports, the
destruction of oil installations, or again with de training, arming and
equipping of the contras.
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
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 not
be 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
(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;
(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
(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 Nüremberg
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
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
(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 the acts 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
THEREFORE we respectfully request that the Prosecutor immediately investigate
and indict for serious crimes against international humanitarian law:
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. Vollebæk, D.J. Fjærvoll
(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
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
W. Neil Brooks
Judith A. Fudge
H. J. Glasbeek
Reuben A. Hasson
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 Gonzalez
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
2) Civilian Victims and
Devastation in NATO Aggression on Yugoslavia (SERBIAINFO -
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 civiliantargets,
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 adio 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
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 bombs
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
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.
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,
rnivrh, 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 infrastructurewhich 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
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"
business centre in Novi Beograd which was hit on 21 and 27 April
1999. 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
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.
Concurrently with the humanitarian, NATO strikes have caused an
environmental catastrophe which is endangering not only the Federal
Republic of Yugoslavia, but also the neighbouring countries and the
entire European continent. Ecology does not recognize boundaries.
The NATO aggressor is thus teetering on the brink of another
Chernobyl in the heart of Europe. The destruction of petrochemical
installations, the warehouses storing semi-processed and finished
products of the chemical industry have already caused significant
adverse effects on the health of the population of the Federal
Republic of Yugoslavia and the neighbouring countries. During some
of the air strikes it was pure luck that an environmental
catastrophe was not provoked spreading all over Europe.
The aggressor's attacks did not spare even huge forests, tourist
centres and the national parks on the mountains of Serbia
(Kopaonik, Zlatibor, Divcibare, Tara, Prokletije, Sara, Fruska Gora). The
ozone layer was depleted by the exhaust gases. The Black Sea, Aegean and
the Adriatic basins, practically the entire Mediterranean, are
threatened by environmental pollution.
Examples: Nitrogen factory in Pancevo, the oil refineries in
Pancevo and Novi Sad, the chemical company "Prva iskra" in Baric and others.
The aggressors' bombings, calculated to provoke the greatest
possible confusion and panic among innocent people, have damaged
many clinical and hospital centres, inflicting not only great
material damage to property (destruction of buildings and expensive
medical equipment), but also causing new health problems and
intensifying psychological traumas among the sick people. The
destruction of all the three bridges in Novi Sad totally cut off
and left, without the supply of water, the largest Yugoslav centre for
the treatment of cardiovascular diseases, to which several million
people gravitate. The Maternity Hospital in Belgrade, and the
biggest hospital in the Balkans (Military Medical Academy Hospital
VMA), and the Orthopaedic hospital of Banjica, the hospitals in
Cuprija and Aleksinac, as well as the medical centres in Pristina
and in many other towns were damaged.
Since the outset of the aggression, NATO has put a stop to the
education of close to one million pupils and students in
Yugoslavia. Over three hundred facilities built for the education and
upbringing of children and young people of all ages were destroyed. This will
inevitably be reflected on the development and social integration
of young people. Hard hit are university centre in Nis (Machine
Engineering, Civil Engineering, Electronical, Technical, Law and
Economics faculties), in Pristina (Agricultural and Machine
Engineering faculty) and Novi Sad (Faculty of Philosophy).


Kosovo and Metohija in particular, but also the entire territory of
the FR of Yugoslavia, is a treasury of European culture and
civilization since ancient times. By violating all international
conventions on the protection of civilization and its heritage, and
in the pursuit of the spirit of aggressive nihilism and new
barbarity, more than 50 monasteries and churches have been severely
damaged thus far, as well as a couple of dozen of other cultural
and historic monuments, some under UNESCO protection. Severe damage was
caused to the monastery of the Patriarchate of Pec (12th century),
Zica (13th century), Decani and Gracanica (14th century, under
UNSECO protection), medieval towns of Zvecan (13th century) and
Smederevo (15th century), Petrovaradin fortress (18th century),
seventeen monasteries on Fruska Gora (15-18th century) and many
other priceless historical monuments. The bombs have even destroyed
many cemeteries all across Yugoslavia.
In NATO attacks, the state-of-the-art weapons have been used, but
also those prohibited under international conventions, such as
cluster bombs and slow activating bombs. In a month-long attacks on
civilian and other facilities in Serbia, NATO aircraft fired more
than 3,500 missiles, including 60 containers with 14,400 cluster
bombs. As many as 3,600 cluster bombs were used in the attacks
against towns in Kosmet - Pristina, Urosevac, Djakovica, Prizren
etc, and many other places and facilities in Serbia. Before the
attacks, radio locators were dropped from the aircraft, found in
the vicinity of many civilian and business facilities in Serbia.
While before the onset of the aggression Albanian terrorists
counted on NATO aircraft as air support to their armed groups, now arming,
equipping and transport of Albanians living in the USA and other
western countries is under way, for actions in the FRY, with a view
to making armed formations from them to serve as ground troops of
the "Alliance". Albanian terrorists are being trained and armed in
the camps in northern Albania - in Tropoje, Kukes and Bajram Curri
(they are trained by British, US and Turkish commandos), and then
illegally infiltrated into Kosovo and Metohija. Such activity, in
direct violation of the resolutions of Security Council, has been
particularly stepped up in April when concrete plans for ground
invasion against the FRY started to be hatched. So far, several
hundred terrorists have been transported from the USA to Albania.
Plans are made to equip, arm and train for coordinated actions with
NATO, around 6,000 Albanians. According to western sources,
Albanian terrorists represent the main source of intelligence for NATO, of
military character or those aimed at spreading propaganda against
our country.
At the moment it is difficult to perceive and evaluate all the
humanitarian, economic, environmental, health and other consequences
of the NATO criminal aggression against the FR of Yugoslavia. The
greatest victim of the aggression is the entire Yugoslav people and
its material and cultural resources. At the same time, the
violation of the Charter of the United Nations, the NATO has created a
precedent which may a cast a shadow over the future of all peoples
and sovereign States. The cause for concern is all the grater
because, by combining pressure and promises, NATO is drawing an
increasing number of countries into its aggression against the FR
of Yugoslavia, which will have long-term negative consequences on the
future relations and co-operation between all Southeast European
countries. Attempts by NATO to justify its brutal aggression by an
alleged care for the refugees may bring about an irreversible
degradation of the United Nations and involve this highest
international forum in the crime against a country which is one of
its founding members.
ON YUGOSLAVIA (April 23,1999)
From the onset of NATO aggression against our country up to 19 April 1999, the
North Atlantic Alliance made over 7,000 criminal attacks against the territory
of the Federal Republic of Yugoslavia. 700 warplanes, of which 530 combat
planes, were used; more than 2000 cruise missiles were launched and over 6,000
tons of explosives were dropped.
About 500 civilians were killed and more than 4,000 sustained
serious injuries e.g.: in Kursumlija: 13 dead and 25 wounded;
in Pancevo: 2 dead and 4 wounded;
in Cacak: one dead and 7 wounded;
in Kragujevac: over 120 workers were wounded during an attack on the car
factory "Zastava";
in Vranje: two dead and 23 wounded;
in Aleksinac: 12 dead and more than 40 wounded;
in Nagavac village, Orahovac municipality: 11 dead and 5 wounded;
in Pristina: 10 dead and 8 wounded;
Grdelicka gorge: 55 killed and 16 wounded;
attack on two refugee columns, with four cruise missiles, on the
Djakovica-Prizren road: 75 killed and 100 wounded, of whom 26 critically;
in the village of Srbica: 10 killed, among whom 7 children;
Belgrade suburb of Batajnica: a three year old girl was killed,and
five civilians wounded.
Three million children are endangered in our country as a result of war and
bombardment by NATO criminals.
After these barbarian attacks hundreds of thousands citizens have
been exposed to poisonous gasses which can have a lasting
consequences on the health of the entire population and the
After the demolition of the Petrovaradin bridge, Novi Sad and
Petrovaradin were cut of water supply (600 000 citizens) since the
main and city pipeline was constructed into the bridge. About one
million citizens in our country are short of water supply due to the
bombardment of NATO aggressors.
About 500 000 workers became jobless due to the total destruction of industrial
facilities all around the country. Two million citizens have no means for
living and cannot ensure the minimum for existence.
Overall material damage is enormous. Preliminary estimates indicate that
barbaric air strikes of the neo-fascist NATO alliance, since the beginning of
the unprovoked aggression on the SR of Yugoslavia,on industrial, commercial and
civil facilities and structures throughout our peace-loving country, have
incurred damages in excess of 10 billion dollars. In the territory of the
northern province of Vojvodine alone, damages have been estimated in excess of
3,5 billion dollars.
The road and railway networks, especially road and rail bridges,
most of which were destroyed or damaged beyond repair, suffered
extensive destruction. The targets of attacks were such
communications as:
1.The Varadin Bridge over the Danube was destroyed (on 1 April
2.The "Sloboda" (Freedom) Bridge over the Danube was destroyed (on 4 April
3.The "Mladosti" (Youth) Bridge over the Danube, connecting Backa
Palanka with Ilok, was damaged (on 4 April 1999);
4.The new railway bridge over the Danube connecting Bogojevo and
Erdut was damaged (on 5 April 1999);
5.The road bridge over the Danube, connecting Bogojevo with Erdut
was damaged (on 5 April 1999);
6.The bridge over the Danube along the Beograd-Novi Sad road, near
Beska, Indjija municipality, was damaged (on 1 April 1999);
7.The road bridge along the Magura Belacevac road, 15 kilometres
from Pristina, suffered extensive damage;
8.The "Zezeljov" Bridge in Novi Sad was damaged (on 5 April 1999);
9.The bridge over the Ibar river, Biljanovac municipality, was
damaged (on 5 - 13 April 1999);
10.The bridge over the Vrbacka river near Jezgrovic was destroyed
(on 5 April 1999);
11.The "Lozno" railway bridge near Usce was destroyed (on 5 April
12.The road bridge on the road leading to Brvenik, near Usce, was
destroyed (on 5 April 1999);
13.The bridge along the Nis-Pristina primary road, near Kursumlija,suffered
extensive damage (on 5 April 1999);
14.The bridge near Zubin Potok was destroyed (on 5 April 1999);
15.The Grdelica gorge railway bridge was damaged (on 12 April 1999);
16.The road bridge over the Kosanica river near Kursumlija was
damaged (on 13 April 1999);
17.The old bridge on the river Rasina in the town of Krusevac (12-13 April
18.The Krusevac-Pojate bridge on the river Zapadna Morava, at the
village of Jasika, was destroyed (on 13 April 1999);
19.The railway bridge on the river Lim, between Priboj and
Prijepolje, near hydroelectric power station Bistrica was destroyed(on 15 April
20.The road bridge on the river Toplica, on the Nis-Pristina road
near the town of Kursumlija, was heavily damaged (14 and 19 April
21.The bridge on the river Ibar, at the village of Biljanovac near
Raska, sustained heavy damages (15.04.1999.);
22.The bridge between Smederevo and Kovin has been destroyed (16
April 1999);
23.The railway bridge on the river Kostajnica, near Kursumlija, has sustained
heavy damages and is out of service (18.04.1999.);
24.The bridge on the river Kosanica, at the village of Selo Visoko,has
sustained heavy damages and is out of service (18.04.1999.);
1.The Kraljevo - Kosovo Polje rail, near Ibarska Slatina;
2.The Belgrade - Bar rail, due to the destruction of the railway
track near the village of Strbce and destruction of the bridge on
the river Lim, between Priboj and Prijepolje;
3.The Kursumlija - Prokuplje rail, near Pepeljevac village;
4.The Kraljevo - Kosovo Polje rail, near Ibarska Slatina;
5.The Nis - Pristina rail, near Kursumlija;
6."Sarpelj" tunnel, near Jerinje village, 15 km north of Leposavic
towards Raska, was destroyed;
7.Railway station in Kraljevo (Bogutovac);
8.Railway station in Kosovo Polje;
9.The Belgrade - Thessaloniki rail, due to the destruction of the
bridge in the Grdelica gorge;
10.Railway station in the town of Biljanovac;
11.Railway track and overpass (Josinacka Banja) near the town of
12.Railway track Kursumlija - Podujevo, due to damages on the
railway bridge at Kursumlija;
1.Ibarska primary road, due to damages to the bridge on the Ibar
river, Biljanovac municipality, and destruction of the road between Pozega and
2.Belgrade-Zagreb highway, near Stari Banovci;
3.Traffic suspended on the Kosovska Mitrovica-Ribarici section of
the Adriatic highway due to the destruction of the bridge over the
Vrbacka river;
4."Jedinstvo" bus station in Vranje sustained extensive damage;
5."Kosmet Prevoz" transporter in Gnjilane (a hangar full of new
6.Kraljevo-Raska primary road;
7.Bus station in Pristina;
8.Traffic has been suspended on the Krusevac-Pojate road due to the destruction
of the bridge on the Zapadna Morava, in the village of Jasika;
9.Traffic has been suspended on the Nis-Pristina road, due to the
fact that the bridge on the river Toplica, near the town of
Kursumlija, has sustained heavy damage;
4. AIRPORTS (7):
"Slatina" in Pristina; "Batajnica" and "Surcin" in Belgrade; Nis
airport; "Ponikve" in Uzice; "Golubovac" in Podgorica, "Ladjevci"
airport near Kraljevo; agricultural and sports airfield in Sombor.
The air strikes have so far destroyed or damaged all over the
Federal Republic of Yugoslavia several thousand economic facilities and
dwellings. In the Leskovac region alone, over 3,500 industrial facilities and
dwellings were either destroyed or damaged.
The devastation of NATO forces was particularly manifest in
Pristina, Novi Sad, Aleksinac, Djakovica, Prokuplje, Gracanica,
Cuprija, etc. Housing blocks on the outskirts of Belgrade - Kijevo
Knecevac, Batajnica, Jakovo, Borca, as well as the area around
Pancevo, were under attack.
The NATO aggressor's attacks targeted the factories and industrial
facilities which directly cater for the needs of the population,
among which are:
1."Lola Utva" agricultural aircraft factory in Pancevo;
2."Galenika" drug factory in Belgrade;
3."Zdravlje" pharmaceutical plant in Leskovac;
4."Sloboda" white goods factory in Cacak;
5."Din" tobacco industry in Nis;
6."Elektronska industrija" factory in Nis;
7."Div" cigarette factory in Vranje;
8.Tubes factory in Urosevac;
9."Jastrebac" machine industry in Nis;
10."Milan Blagojevic" chemical plant in Lucani;
11.Plastics factory in Pristina;
12."Binacka Morava" hydro construction company in Gnjilane;
13."Nova Jugoslavija" printers in Vranje;
14.Facilities of the "Beograd" rail company in Nis;
15.Over 250 commercial and crafts shops in Djakovica were destroyed;
16."Dijana" shoe factory in Sremska Mitrovica;
17."Zastava" car factory in Kragujevac;
18."14 Oktobar" machine factory in Krusevac;
19.Cotton yarn factory in PriStina;
20."Krusik" holding corporation in Valjevo;
21."Ciklonizacija" in Novi Sad;
22."Tehnogas" in Novi Sad;
23."Novograp" in Novi Sad;
24."Gumins" in Novi Sad;
25."Albus" in Novi Sad;
26."Petar Drapsin" in Novi Sad;
27."Motins" in Novi Sad;
28."Izolacija" in Novi Sad;
29."Novokabel" in Novi Sad;
30."Istra" fittings factory in Kula;
31.The port of Bogojevo;
32.Industrial complex "Dvadeset Prvi Maj" in Rakovica;
33.Machine building plant "Industrija Motora Rakovica" in Rakovica;
34.Factory "Jugostroj" in Pancevo;
35.Factory "Frigostroj" in Pancevo;
36.Surface coal mine "Belacevac";
Refineries and warehouses storing liquid raw materials and chemicals intended
for the oil and chemical industry, were hit in Pancevo, Novi Sad, Sombor and
elsewhere, causing large contamination of soil and the air:
1.Fuel storage in Lipovica, which caused a great fire in the Lipovica forest (on 26 March 1999);
2.Oil Refinery in Pancevo - totally demolished (4-16 April 1999);
3."Jugopetrol" installations in Smederevo (on 4-13 April 1999);
4."Jugopetrol" storage in Sombor (on 7 April 1999);
5."Beopetrol" storages in Belgrade and Bogutovac (on 4 April 1999);
6."Beopetrol" fuel storage in Pristina (on 7 April 1999);
7.Fuel storage of the boiler plant in Novi Beograd (on 4 April 1999);
8.Thermo electric power station/boiler plant in Novi Sad (on 5 April1999);
9.Oil Refinery in Novi Sad, storage of bitumen (5 and 6 April 1999);
10.Fuel storage "Naftagas promet" which is located 10 km from Sombor(5 April
11.Naftagas warehouse between Conoplje and Kljaicevo (Sombor);
12.Jugopetrol warehouse in Pristina (on 12 April 1999);
13.Jugopetrol petrol station in Pristina ( on 13 April 1999);
14.Petrochemical industry "DP HIP PETROHEMIJA" in Pancevo totally demolished
(14-15 April 1999);
15.Fertilizer plant "DP HIP AZOTARA" in Pancevo - totally destroyed (14-15
April 1999);
16.Chemical plant "Prva Iskra" in Baric - destruction of the
production line (19 April 1999);
1.PIK "Kopaonik" in Kursumlija;
2.PIK "Mladost" in Gnjilane;
3.Agricultural Complex "Malizgan" in Dolac;
4.Agricultural Complex "Djuro Strugar" in Kula;
5.In forest fires caused by NATO cruise missiles and bombs over 250 hectares of
forests have been burned down;
6.Several thousand hectares of fertile land, many rivers, lakes and underground
waters have been polluted due to the spillage of petrochemical substances, oil
spills and slicks;
NATO aviation also targeted many hospitals and health-care
institutions, which have been partially damaged or totally
destroyed, including:
Hospital and Medical Centre in the territory in Leskovac;
Hospital and Poly-clinic in Nis;
Gerontological Centre in Leskovac;
General Hospital in Djakovica;
City Hospital in Novi Sad;
Gynaecological Hospital and Maternity Ward of the Clinical Centre in Belgrade;
Neuropsychiatric Ward "Dr. Laza Lazarevic" and Central Pharmacy of
the Emergency Centre in Belgrade;
Army Medical Academy in Belgrade;
Medical Centre and Ambulance Centre in Aleksinac;
"Sveti Sava" hospital in Belgrade;
Medical Centre in Kraljevo;
Dispensary on Mount Zlatibor;
Health Care Centre in Rakovica;
Over 190 schools, faculties and facilities for students and children were
damaged or destroyed (over 20 faculties, 6 collages, 40 secondary and 80
elementary schools, 6 student dormitories), including:
Elementary schools "16. oktobar" and "Vladimir Rolovic" in Belgrade;
Day-care centre in settlement Petlovo Brdo in Belgrade;
Two secondary schools in the territory of Nis;
Elementary schools "Toza Markovic", "Djordje Natosevic", "Veljko
Vlahovic", "Sangaj" and "Djuro Danicic" and a day-care centre "Duga" in Novi
Sad and creches in Visarionova Street and in the neighbourhood of Sangaj;
Traffic School Centre, Faculty of Philosophy;
Four elementary schools and a Medical high school in the territory
of Leskovac;
Elementary school in Lucane, as well as a larger number of educationfacilities
in the territory of Kosovo and Metohija;
Faculties of Law and Economics and elementary school "Radoje
Domanovic" in Nis;
Elementary schools in Kraljevo and the villages of Cvetka, Aketa and Ladjevci;
In Sombor: elementary schools "Ivo Lola Ribar", "A. Mrazovic", "N.
Vukicevic" and "Nikola Tesla" in Kljajicevo;
School centre in Kula;
Elementary school and Engineering secondary school centre in
Severe damage to the facilities of the Republican and Federal
Ministry of the Interior in Belgrade (3 April 1999),
Damage to the building of the Institute for Security of the Ministry of the
Interior in Banjica (3 April 1999);
Severe damage to the TV RTS studio in Pristina;
Heavy damage to Hydro-Meteorological Station (Bukulja, near
Post Office in Pristina destroyed (7 April 1999);
Refugee centre in Pristina destroyed (7 April 1999);
"Tornik" ski resort on Mount Zlatibor (on 8 April 1999);
"Divcibare" mountain resort (on 11 April 1999);
"Baciste" Hotel on Mount Kopaonik (on 12 April 1999);
City power plant in the town of Krusevac (12-13 April 1999);
Meteorological Station on Mount Kopaonik damaged (on 13 April 1999);
Four libraries in Rakovica sustained heavy damage: "Radoje Dakic",
"Isidora Sekulic", "Milos Crnjanski" and "Dusan Matic";
Refugee camp "7 juli" in Paracin has sustained heavy damage;
Office building of the Provincial Executive Council of Vojvodina,
Novi Sad;
Several thousand housing facilities damaged or destroyed, privatelyor State
owned, across Yugoslavia - most striking examples being housing blocks in
downtown Aleksinac and those near Post Office in Pristina.
Electrical Power Supply in Batajnica (26 March 1999);
Damage to water supply system in Zemun (5 April 1999);
Damage to a power station in Bogutovac (10 April 1999);
Telephone lines cut off in Bogutovac (10 April 1999);
Damage to a power station in Pristina (12 April 1999);
Damage to Bistrica hydroelectric power station in Polinje (13 April 1999);
1.Jastrebac (Prokuplje)
2.Gucevo (Loznica)
3.Cot (Fruska Gora)
4.Grmija (Pristina)
5.Bogutovac (Pristina)
6.TV transmitter on Mt Goles (Pristina)
7.Mokra Gora (Pristina)
8.Kutlovac (Stari Trg)
9."Cigota" (Uzice)
10."Tornik" (Uzice)
11.Transmitter on Crni Vrh (Jagodina)
12.Satellite station (in Prilike near Ivanjica)
13.TV masts and transmitters (Novi Sad)
14.TV transmitter on Mt Ovcara (Cacak)
15.TV transmitter in Kijevo (Belgrade)
16.TV transmitter on Mt Cer
17.Communications relay on Mt Jagodnji (Krupanj)
1.Monastery Gracanica from 14th century (24 March - 6 April 1999);
2.Monastery Rakovica from 17th century (29 March 1999);
3.Patriarchate of Pec (1 April 1999);
4.Church in Jelasnica near Surdulica (4 April 1999);
5.Monastery of the Church of St. Juraj (built in 1714) in
Petrovaradin (1 April 1999);
6.Monastery of Holy Mother (12th century) at the estuary of the Kosanica in the
Toplica - territory of municipality of Kursumlija (4 April 1999);
7.Monastery of St. Nicholas (12th century) in the territory of the
municipality of Kursumlija (4 April 1999);
8.Monastery of St. Archangel Gabriel in Zemun (5 April 1999);
9.Roman Catholic Church St. Antonio in Djakovica (29 March 1999);
10.Orthodox cemetery in Gnjilane (30 March 1999);
11.Monuments destroyed in Bogutovac (8 April 1999);
12."Kadinjaca" memorial complex (8 April 1999);
13.Vojlovica monastery near Pancevo (12 April 1999);
14.Hopovo monastery, iconostasis damaged (12 April 1999);
15.Orthodox Christian cemetery in Pristina (12 April 1999);
16.Monastery church St, Archangel Michael in Rakovica (16 April
1.Severe damage to the roof structure of the Fortress of
Petrovaradin (1 April 1999);
2.Heavy damage to "Tabacki bridge", four centuries old, in Djakovica(5 April
3.Substantial damage to the building in Stara Carsija (Old street)
in Djakovica (5 April 1999);
4.Destroyed archives housed in one of the Government buildings in
Belgrade (3 April 1999);
5.Memorial complex in Gucevo (Loznica);
6.Memorial complex "Sumarice" in Kragujevac;
7.Vojvodina Museum in Novi Sad;
8.Old Military Barracks in Kragujevac - under the protection of the state (16
April 1999);

Source: Ministry of Foreign Affairs of FR Yugoslavia












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