In the Ntawukulilyayo case, the Trial Chamber of the International Criminal Tribunal for Rwanda, in its Decision of 27 November 2009, held that while a voir dire hearing is not mandatory, where there is any query regarding the qualifications of a proposed expert, or where the scope and definition of their expertise is subject to genuine dispute, such matters may be more appropriately addressed by extending the inquiry by oral examination of the proposed expert witness.
Later, in December 2009, upon a voir dire hearing, the Trial Chamber found that the proposed witness did not possess either the academic qualifications or the professional experience in the area on which he was supposed to testify. Accordingly, the Chamber did not qualify him as an expert in that case.