Introduction
The trial of Leon Rupnik and his co-defendants, held in Slovenia in August 1946, was among the first major post-war trials of wartime collaborators in Yugoslavia. What distinguishes this trial is the role film played both in preparing the public for the proceedings and in documenting them. Two documentary films were produced before the trial began, and parts of the trial itself were filmed. Viewed together, these materials cover not only the trial but also earlier stages of the criminal process, including arrest and interrogation.
This contribution is organised as follows. It first provides historical background on the wartime collaboration that led to the trial. It then considers the two pre-trial films and their objectives. Finally, it examines the courtroom footage and demonstrates that, together with the pre-trial films, the surviving visual materials encompass all the major stages of criminal procedure.
Historical background
In April 1941, the Axis powers declared war on Yugoslavia and quickly defeated its militarily. Slovenian territory was then divided among the occupying powers. Germany took the north and east, Hungary took a portion of the east, and Italy took the south. The western parts of Slovenia, which had been part of Italy since the end of the First World War, remained under Italian control.
A resistance movement formed almost immediately. The Communist Party played an increasingly prominent role, partly because it had already been forced underground before the war and therefore had the structures needed to organise clandestine activity. At the same time, conservative circles began moving towards collaboration with the occupiers. For them, the fight against communism was more important than resisting the occupation.
Armed collaboration was strongest in the Italian occupation zone, where the first collaborationist units were established with Italian approval under the Milizia Volontaria Anti Comunista. After Italy surrendered in 1943, Germany took over the former Italian zone and reorganised the collaborationist forces into a new structure: the Slovene Home Guard (Slovensko domobranstvo). This was a paramilitary organisation whose main purpose was to fight the resistance, and which depended entirely on German support.
Flight, Extradition, and the Road to Trial
When Germany collapsed in May 1945, Image 2 German forces in Yugoslavia and the Extradition of Leon Rupnik. occupation zone in Austria. In accordance with the Moscow Declaration of 1943, however, the main collaborators were returned to Yugoslavia to be tried. The new post-war regime had other urgent matters to address first, so the trial was postponed until August 1946. In the meantime, the regime's preparations for the trial also included the use of film.
Documentaries Before the Trial
Between the extradition of the defendants and the start of the trial, two documentary films were produced – one in late 1945 and one in early 1946. Both presented the defendants and the crimes for which they were indicted, to a general audience, aiming to prepare the public for the forthcoming trial, and thus in their eyes, strengthen its legitimacy.
At this point it is worth pointing out that film as a source offers something textual records cannot: the visible presence of the accused, the physical settings of collaboration, and a sense of how events felt to those who lived through them. Where a written indictment lists charges in formal legal language, film shows Rupnik at a podium before crowds, or the bodies of executed hostages, rendering abstract accusations concrete. Unlike court transcripts, which present proceedings in a standardised form, documentary film is shaped by deliberate choices about what to include and what to leave on the editing room floor, and those choices are themselves evidence of how the regime sought to enhance legitimacy. Film also reaches audiences that written records never could, which is precisely why these documentaries were made for cinema audiences rather than lawyers or archivists.
War Criminals Will Be Punished
The first film, whose title conveyed an obvious message, presented five of the main defendants and their alleged crimes. Three of these are particularly important for the purposes of this article.
The first is Leon Rupnik, who gives the trial Image 3 its name. Before the war, he was a general in the Yugoslav Army and was well known to the public for overseeing the construction of defensive fortifications on the Italian border. During the occupation, he served first as mayor of Ljubljana and then as president of the provincial government. He was also honorary president of the Home Guard, which was formed largely due to his efforts. The film charges him with, among other things, deliberately weakening the defensive line he had previously built, treason, collaboration, and helping to form the Home Guard. It is worth noting that the charge regarding the defensive line did not appear in the actual indictment
The second defendant given significant attention is SS General Erwin Rösener, who was responsible for military and police administration across the occupied Slovenian territories. This made him the person ultimately in charge of repressing the resistance. The film focuses particularly on the shootings of civilian hostages that he ordered in response to resistance attacks.
The third defendant of note is Gregorij Image 4 Rožman, the Bishop of Ljubljana, who openly supported collaboration on anticommunist grounds. While the film’s script accused Rožman of instigating and blessing war crimes, these accusations were cut from the final film. The only explanation that survives is a note scrawled in the margin of the script: “too long.” As a result, Rožman appears only briefly, in a caricature at the opening of the film, with no further reference to his role.
Avenge and Punish
The second film is subtitled as a documentary about Leon Rupnik and his crimes, focusing almost entirely on him. Much of it consists of footage recorded by the collaborators themselves, which lends the accusations a certain evidentiary weight, as the evidence appears to come from the defendants’ own records. Two events are presented as the most important evidence against Rupnik. The first is the large anti-communist rally held in Ljubljana in 1944. The film shows footage of Rupnik’s speech, including the part where he states that the only path for Slovenians is a German victory. The second is the Home Guard oath ceremony held in the summer of 1944, whose filmed record demonstrates the scale and formality of the collaboration. This footage also shows Bishop Rožman celebrating mass and blessing the ceremony, which is notable given how little he appears in the first film.
The Trial
The trial began in August 1945, several weeks before the Nuremberg judgment was delivered. The defendants were charged with two offences: treason against the nation and the state, and war crimes. Three of the six defendants were sentenced to death; the other three received sentences of forced labour. The entire proceedings were broadcast on radio, and at least parts of the trial were filmed.
Only a little over four minutes of trial footage have survived, and none retains its original audio. About two minutes were used in a newsreel; the remainder was never publicly shown. Nevertheless, the footage captures several key moments from the proceedings.
The Visual Record of Criminal Procedure
When the pre-trial films and courtroom footage are considered together, they cover an unusually wide range of steps in the criminal process – not only the trial itself but also the earlier pre-trial phase.
The pre-trial films document four stages of the pre-trial proceedings: the handover and arrest of the defendants, shown in footage of Rupnik being extradited to Yugoslavia; identification and fingerprinting; pre-trial detention; and interrogation, shown for both Rupnik and Rösener, with Rösener's signing of his interrogation record also filmed.
The courtroom footage captures five stages of the trial. First, the entry of the defendants and confirmation of their personal details, shown for Rupnik. Second, the reading of the indictment by the chief prosecutor. Third, the questioning of all four defendants present in court. Fourth, the presentation of evidence, including the questioning of a witness and the presentation of a physical exhibit – a poster depicting the largest hostage shooting ordered by Rösener, which I have also identified. Fifth, the pronouncement of the verdict by the president of the senate.
This is a remarkable range of coverage as trials in this period were occasionally filmed for newsreel purposes, but it is rare for such footage to span the entire process from arrest and interrogation to the delivery of the verdict. The Rupnik trial is therefore an important early example of film being used to document criminal proceedings.
Conclusion
The post-war trial of collaborators in Slovenia was as much a media event as a legal one. The two documentary films made before the trial introduced the defendants and their crimes to a broad audience and helped establish a narrative of guilt before the formal proceedings began. The courtroom recordings, though incomplete, captured key moments of the trial: the reading of charges, the questioning of defendants and witnesses, the presentation of evidence, and the delivery of the verdict.
Film served several purposes at once: it was a tool of political legitimation, a means of informing and shaping public opinion, and a way of creating a historical record. The materials surrounding the Rupnik trial also raise questions about what was omitted and why. The near disappearance of Bishop Rožman from the first film, despite the prominent role assigned to him in the script, is one example.
As a historical source, film preserves dimensions of legal proceedings that written records flatten or lose: the demeanour of defendants, the spatial arrangement of power, the atmosphere of the courtroom. Read alongside the indictment and transcript, the surviving footage does not merely illustrate those documents; it interrogates them.
The relationship between law and film in post-war Slovenia raises broader questions about how visual media was used in constructing post-war justice – questions that remain relevant today.
Jožef Krnc
The Ljubljana students worked on a common thematic umbrella in 2025-2026 (From a state of war to a state of peace via (new) communication technologies and media: the establishing of authorities, institutions, laws and the reframing of constitutional values).
Sources
- AS 1086/19, Vojni zločinci bodo kaznovani.
- AS 1086/63, Maščujmo in kaznujmo.
- SI AS 1086/69, Filmski obzornik september 1946.
- SI AS, Proces proti Leonu Rupniku, avgust 1946.
- SI AS 467, Triglav film, box 56, Obzornik september 1946.
- SI AS 467, Triglav film, box 58, Letno poročilo tehničnega oddelka 1945.
- SI AS 467, Triglav film, box 61, Maščujmo in kaznujmo – scenarij filma.
- SI AS 467, Triglav film, box 61, Vojni zločinci bodo kaznovani – scenarij filma
- SI AS 467, Triglav film, box 77 , Poročilo 45-46.
- SI AS 1931, Proces proti Leonu Rupniku, box 547.
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