The lawyers relied on facts established in proceedings before the International Criminal Tribunal for the Former Yugoslavia (ICTY) and United Nations documents.
The Serbs carried out ethnic cleansing in some 50 Bosnian municipalities but it was especially thorough and brutal in eastern Bosnia's Podrinje region, 50 km along the Drina river bordering Serbia, the lawyers said, adding that Muslims were the majority population in the area before the war but virtually no longer existed there after 1995.
Citing verdicts, admissions of guilt and other ICTY sources, attorney Laura Dauban said the former Yugoslav People's Army (JNA), paramilitary troops and Serbia's Territorial Defence, from April 1992 onwards, together with Bosnian Serbs, expelled Muslims from Bijeljina, Foca, Visegrad, Zvornik, Vlasenica, and other municipalities.
Speaking before 15 judges, Dauban described the pattern used in all attacks. The JNA would arm the Serbs, they would declare their authority and demand the Muslims hand over their weapons, after which the JNA and the paramilitaries would seize towns and villages, killing, detaining and expelling people.
Brigitte Stern, another attorney representing Bosnia, spoke of the massive raping of Muslim women whom she said Serb forces used as an instrument of genocide, as established by a 1993 UN General Assembly resolution.
Citing a report by former UN special rapporteur for human rights Tadeusz Mazowietski, she said about 12,000 rapes were committed during the war in Bosnia.
Stern also cited facts established at ICTY trials pointing to widespread sexual violence, not only against women, but also captive Muslim men, based on discrimination and intended to humiliate and shame the victim and the ethnic group as a whole.