On January 20, 2022, the First Section of the European Court of Human Rights issued its judgment in Milanković v. Croatia that there was no violation of Article 7 (no punishment without law) of the European Convention on Human Rights when Vladimir Milanković, in his role as Deputy Head of the Police Department, was convicted of war crimes on the basis of command responsibility for his role of failing to prevent those under his command from committing war crimes. According to a press release, the Court, after examining Milanković’s claims that the Basic Criminal Code had not contained the concept of command responsibility and “in any case, the concept of command responsibility could not apply because at the time of the crimes, he had been the deputy head of the local police department and not a member of the military,” ruled that in accordance with previous case law “[the] application of the concept of command responsibility to war crimes committed in an internal armed conflict was already a rule of customary international law in 1991.” The Court concluded that “conviction for war crimes on the basis of command responsibility [has] had a sufficiently clear legal basis in international law at the time of the events, and that [Milanković] should have known that his failure to prevent the crimes committed by the police units under his command would make him criminally liable.”