In the International Criminal Tribunal for Rwanda (ICTR) case Prosecutor v. Musema, the trial chamber held that an individual could be found guilty solely for the crime of conspiracy to commit genocide even if no genocide takes place.
Dalton, Taylor Reeves
"Counterfeit Conspiracy: The Misapplication Of Conspiracy As A Substantive Crime In International Law,"
ILSA Journal of International & Comparative Law: Vol. 17
, Article 1.
Available at: https://nsuworks.nova.edu/ilsajournal/vol17/iss1/1