According to the indictment, submitted on 27 September by Chief Prosecutor Carla Del Ponte and confirmed yesterday, Mr. Milosevic participated in a joint criminal enterprise between at least August 1991 and June 1992 to forcibly remove the majority of the Croat and other non-Serb population from approximately one-third of the territory of the Republic of Croatia, an area he planned to include in a new Serb-dominated State.

The indictment says that Mr. Milosevic, as President of the Republic of Serbia, exercised "effective control or substantial influence over the participants of the joint criminal enterprise and, either alone or acting in concert with others, effectively controlled or substantially influenced the actions of the Federal Presidency of the Socialist Republic of Yugoslavia and later the Federal Republic of Yugoslavia, the Serbian Ministry of Internal Affairs (MUP), the Yugoslav People's Army (JNA), the Serb-run Territorial Defence (TO) staff in the relevant territories, and the Serb volunteer groups."

The indictment alleges that Serb forces, comprised of the JNA and local TO, police and paramilitary units, attacked and took control of towns, villages and settlements in the "Serbian Autonomous District ("SAO") Krajina", the "SAO Western Slavonia", and the "SAO Slavonia, Baranja and Western Srem" regions, as they were known to the Serb leaders.

After the takeover, the Serb forces, in co-operation with the local Serb authorities, established a regime of persecutions designed to drive the Croat and other non-Serb civilian population from these territories, according to the indictment. This regime included the extermination, wilful killing or murder of hundreds of Croat and other non-Serb civilians, including women and elderly persons, the deportation or forcible transfer of at least 170,000 Croat and other non-Serb civilians and the arrest and unlawful confinement or imprisonment under inhumane conditions of thousands of Croat and other non-Serb civilians.