International Criminal Tribunal for the former Jugoslavia and International Criminal Tribunal for Rwanda convicted in last years some persons for the Crime of Genocide. This crime, named “the Crime of the Crimes”, wherever it is committed, produces normally several types of ‘denial’. This essay debates the changing nature of the conduct of ‘denial’, asking whether the conduct is (only) denial of facts – like the denial of the Shoah- or denial of its juridical definition.
