Nobody here is claiming that Croatia had a plan or a policy to drive someone away. Those were members of the joint criminal enterprise, Tieger said, adding that no one was disputing that Croatian civilians had suffered in the war too.

He said that on 4 August 1995 the Croatian army launched Operation Storm with a view to reclaiming territory under Serb control since 1991.

The intent to liberate is not contentious, but the intent by the political leaders to use that circumstance to eliminate the Serb population of the Krajina region is, said Tieger.

Towns and villages including Knin, Benkovac, Obrovac and Gracac found themselves under shellfire from 5 am. The people living there and international observers realised that the attacks were aimed at civilians and civilian targets... No place was safe, the prosecutor said.

He added the local population did not know that the attacks were the result of a command by General Ante Gotovina to target towns as well, or that the command was the result of a meeting between then Commander-in-Chief Tudjman and his associates, including then Defence Minister Gojko Susak, Gotovina and General Mladen Markac, a meeting which discussed the importance of driving civilians away.

That objective was achieved, said Tieger.

He corroborated his assertion with Tudjman's statement shortly after the operation was launched that a Croatia had been created that would last for centuries.

After the majority of Serbs fled, the Croatian leadership introduced administrative and other measures preventing Serbs from coming back, Tieger said, adding Serb houses and farmland were looted and set on fire by Gotovina's and Markac's soldiers, while civilians were killed.

A climate of non-punishment began, he said.

The prosecutor went on to say that General Ivan Cermak denied that crimes were taking place or downplayed them, while international observers were denied access or it was monitored, and that no measures were imposed to prevent or punish crimes.

The trial chamber has envisaged four days for closing statements.

The Prosecutor's Office of the International Criminal Tribunal for the former Yugoslavia has charged Gotovina, Cermak and Markac with crimes committed during and in the wake of Operation Storm as part of a joint criminal enterprise aimed at driving away the Serb population, and has asked that they be found guilty and sentenced to 17-27 years' imprisonment.

Defence teams have asked that their clients be acquitted.