On 11 March 2006, Slobodan Milošević died in his bed in the UN Detention Unit in The Hague. At the time, he had been on trial for 66 count of genocide, crimes against humanity, grave breaches of the Geneva Conventions and violations of the laws and customs of war. The alleged conduct encompassed more than 7,000 allegations of wrongdoing over eight years of conflict in the former Yugoslavia. Milošević's death left a significant hole in the fabric of the development and solidification of international criminal justice. An emblem of a challenge to the impunity of tyrannical heads of state who commit such atrocities ended lamentably. The trial had lasted over four years and, despite ex post facto statements by the prosecution that its end was only weeks away, in reality it was some months away from being concluded, and yet many more months from a judgement being rendered. The reasons for the trial lasting so long lay in a number of factors, chief among which were the scope of the prosecution case and the refusal to adjust its case strategy; the Appeals Chamber's ruling to join the three indictments (Croatia, Bosnia, and Kosovo) into one gargantuan indictment; issues relating to the self-representation; and the ill health of the accused, which caused interruptions to the trial and required a reduced sitting schedule.

With the passing away of Milošević, many feared – and some hoped – that international criminal justice was experiencing some sort of death itself.