Ethnic cleansing policies and forced displacement of people affect minority groups, including religious groups, with impressive frequency. In these situations, one of the means of reaction available to the international community is the repression of the extermination of minorities through the prosecution of the perpetrators of such atrocities if they amount to criminal conducts, and, first and foremost, to the crime of genocide.

However, it is not easy to prove the genocide because of the many elements required for its subsistence. On the contrary, less problematic is the recourse to the crime of persecution, which is also applicable to massive and generalised violations of human rights in relation to members of minority groups.

The purpose of this article is to analyse this accusatory “bipolarism” between geno- cide and persecution which characterises, in the perspective of international criminal law, the repression of systematic extermination of minorities, particularly religious minorities.