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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.
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In addition, the PTC ruled that rape per sewas 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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