[JURIST] The International Criminal Tribunal for the former Yugoslavia (ICTY) [official website] on Friday dismissed [judgment, PDF] the appeal [text, PDF] against the imposition of a court-appointed lawyer by former Bosnian Serb leader Radovan Karadzic [case materials; JURIST news archive]. Last month, Karadzic appealed the imposition of a court-appointed lawyer [JURIST reports] claiming his right to "legal assistance of his own choosing" under Article 21(4)(d) of the Statute of the ICTY and the Appeals Chamber ruling [texts, PDF] in Prosecutor v. Seselj was being violated. Because Karadzic chose to represent himself, the Appeals Chamber found that he "does not enjoy any rights that are derived from choosing to be represented by legal counsel." They also stated that:

Karadzic's persistent obstructive behaviour has made it necessary, in the interests of justice, to limit his right to self-representation by assigning counsel to represent his interests,

noting "that the right to self-represent is not absolute and may be subject to certain limitations." Karadzic's trial is set to resume on Monday, March 1.

In December, the Trial Chamber rejected Karadzic's motion [JURIST reports] challenging the legitimacy of the court. In November, the ICTY denied a motion [JURIST report] filed by Karadzic requesting appellate review of the court's decision to assign standby counsel. The ICTY began Karadzic's trial in absentia in October after Karadzic failed to appear [JURIST reports] in court. Karadzic had announced that he planned to boycott [JURIST report] his trial because he had not been given adequate time to prepare a defense. The ICTY has also repeatedly rejected [JURIST report] Karadzic's argument that he should be immune from trial based on an alleged agreement with former UN ambassador Richard Holbrooke. Karadzic faces 11 charges [amended indictment, PDF], including genocide and murder, for war crimes allegedly committed during the 1992-1995 Bosnian genocide [PPU backgrounder]. In June, the ICTY said that Karadzic's trial was expected to conclude in early 2012 [JURIST report]. His trial is planned to be the tribunal's last.