skip navigation

War Crimes Prosecutor v. Vladimir Kovačević aka "Rambo"

Court District Court in Belgrade, War Crimes Chamber, Serbia-Montenegro
Decision title Indictment
Decision date 26 July 2007
  • War Crimes Prosecutor
  • Vladimir Kovačević aka "Rambo"
Categories War crimes
Keywords War crimes; cultural property; law of armed conflict
back to top


Vladimir Kovačević was a Commander of the Yugoslav Peoples’ Army (JNA)  during the Croatian War of Independence (1991-1995). On 6 December 1991, Kovačević allegedly ordered his troops to bombard the city of Dubrovnik. As a result, two people were killed, three others were seriously wounded, six buildings were destroyed, and 46 buildings were substantially damaged.

In February 2001, Kovačević was officially charged with violation of the laws of war (attack against civilians and civilian objects). Even though Kovačević was initially to be tried at the International Criminal Tribunal for the Former Yugoslavia (ICTY), he was declared mentally sick and not fit to stand trial.

In November 2006, the ICTY referred the case to the authorities of the Republic of Serbia.

On 26 July 2007, the Serbian Office of the War Crimes Prosecutor issued an indictment against Kovačević, charging him with war crimes against civilians.

back to top

Procedural history

On 22 February 2001, the Prosecutor of the International Criminal Tribunal for the Former Yugoslavia (ICTY) issued an indictment against Vladimir Kovačević which was comprised of 16 counts harging him with grave breaches of the Geneva Conventions and violations of the laws or customs of war.

On 25 September 2003 Kovačević was arrested, and on 23 October 2003 he was transferred to the detention center of the ICTY.

On 3 November 2003, Kovačević appeared in Court for the first time but did not enter a plea due to his mental health.

On 2 June 2004, he was provisionally released to Serbia for an initial period of six months for medical reasons (he was diagnosed with paranoid psychosis). His provisional release was extended on 2 December 2004.

In April 2006, due to his mental health problems, Kovačević was found unfit to enter a plea or to stand trial, without prejudice to any further criminal proceedings against him should his mental health condition change.

On 17 November 2006, the case was referred to the authorities of the Republic of Serbia pursuant to Rule 11bis of the ICTY Rules of Evidence and Procedure. Kovačević appealed against the referral decision, but on 28 March 2007 his appeal was dismissed.

back to top

Related developments

In December 2007, the District Court of Belgrade dismissed the indictment against Kovačević because he was declared unfit to stand trial. Kovačević has been accommodated at the Psychiatric Clinic of the Military Medical Academy in Belgrade where he has received the necessary medical treatment.

back to top

Legally relevant facts

Kovačević, as Commander of the Yugoslav Peoples’ Army (JNA) holding the rank of Captain First Class, had direct operational command over the Third Battalion, a component of the 472 (Trebinje) Motorised Brigade.

The ICTY indictment alleged, inter alia, that Kovačević ordered, committed or otherwise aided and abetted the shelling of the old town of Dubrovnik (Croatia) and the surrounding area. Alternatively, the indictment alleged that Kovačević knew or should have known that forces under his command, direction and/or control, or subordinate to him were committing the unlawful acts, and that he failed to take measures to prevent it or to punish the perpetrators.

back to top

Core legal questions

Can Vladimir Kovačević be charged with war crimes against civilians?

back to top

Specific legal rules and provisions

Geneva Convention (IV), 1949:

  • Article 3(1)(1) - Conflicts not of an international character

  • Article 2

  • Article 27 - Treatment I. General observations

Additional Protocol (II) to the Geneva Conventions, 1977:

  • Article 4(1) - Fundamental guarantees

  • Article 4(2)(a) - Fundamental guarantees

  • Article 13 - Protection of the civilian population

  • Article 16 - Protection of cultural objects and of places of worship

Convention for the Protection of Cultural Property in the Event of Armed Conflict with Regulations for the Execution of the Convention, 1954:

  • Article 1(a) - Definition of cultural property 

  • Article 4 - Respect for cultural property

  • Article 6 - Distinctive marking of cultural property

  • Article 19 - Conflicts not of an international character 

Criminal Code of the Socialist Federal Republic of Yugoslavia, 1977:

  • Article 142 - War crime against the civilian population
back to top

Court's holding and analysis

On 26 July 2007, the Serbian Office of the War Crimes Prosecutor issued an indictment against Kovačević. 

The indictment alleged that in the morning of 6 December 1991, ‘Kovačević ordered his troops to open random shell fire at the Old Town of Dubrovnik from artillery weapons and mortars, whereby they targeted civilian subjects, who were not directly involved in the hostilities’ (p. 2). During the attack, the troops also targeted objects protected by international law (historical and architectural monuments).

Furthermore, the indictment alleged that under Kovačević’s command, several hundred missiles were fired at the Old Town of Dubrovnik which resulted in the death of two civilians and the wounding of three others, the complete destruction and burning of six buildings, and substantial damage to 46 buildings and objects.

On the basis of these allegations, Kovačević was charged with war crimes against the civilian population (p. 2).

back to top

Further analysis

S. Pavlovic, ‘Reckoning: The 1991 Siege of Dubrovnik and the Consequences of the “War for Peace”’, York University, Canadian Center for Austrian and Central European Studies, 2001, Vol. 5(1), pp. 55-88.

back to top

Instruments cited

back to top

Additional materials

Case Information sheet - Vladimir Kovačević’, ICTY.

‘Kovačević, Vladimir’, The Hague Justice Portal.

‘Vladimir Kovacevic’,TRIAL.

P. Strugar, ‘Most wanted: 'The Dubrovnik Four'’, BBC News, 22 April 2002.

UhićenVladimirKovačević "Rambo"optužen za napad na Dubrovnik’, Index, 25 September 2003.

Vladimir Kovacevic transferred to the ICTY’, UN ICTY Registry, 23 October 2003.

J. Murphy, ‘Aid Cut Over War Crime Suspects’, CBS News, 1 April 2004.

‘Kovačević deemed unfit to stand trial’, The Hague Justice Portal, 12 April 2006.

‘Serbia's war crimes prosecutor charges ex-army officer in 1991 shelling of Dubrovnik’, Associated Press, 30 July 2007.

Vladimir Kovacevic Rambo Indicted in Serbia’,, 30 July 2007.

back to top

Social media links

‘Crime in Dubrovnik’, Documenta.

Captain Rambo To Undergo Medical Treatment’,Sense Tribunal, 15 March 2004.

‘Vladimir Kovacevic “Rambo” Fit To Stand Trial’, Sense Tribunal, 10 February 2005.

K. J. Heller, ‘ICTY Says Defendant Mentally Unfit to Stand Trial’,Opinio Juris, 18 April 2006.

M. Sung, ‘Former Serbia army officer indicted for 1991 Dubrovnik shelling’, Jurist, 30 July 2007.

Serbian Attack On Dubrovnik (December 1991), Hrvatska, Kroatien’, YouTube, 2 December 2009.