Abstract

Kenyan government’s refusal to cooperate had made it too difficult to obtain evidence against him. This led Professor Kontorovich to argue that the ICC’s goal of ending impunity for serious violations of international criminal law is a utopian dream that cannot be achieved given the current state of the world. The dismissal of the case against Kenyatta does, indeed, raise serious questions, but Professor Dutton addresses the ramifications of the Kenyatta case in more detail.

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