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The accused filed appeals filed against the Co-Investigating Judges' Closing Order. Most of the grounds of appeal were dismissed, but the
Pre-Trial Chamber did apparently require a specification as to the existence of a link between the underlying crimes against humanity and an armed
conflict, confirming that the so-called war nexus (about which we've blogged before) remained an element of crimes against humanity in the Khmer Rouge period. In addition, the PTC ruled that rape per se was not an enumerated
crime against humanity at this time, but it was an "inhumane act" and so remained prosecutable under that moniker.
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