On April 26, 2012, Trial Chamber II (Chamber) of the Special Court for Sierra Leone (Special Court or Court) in The Hague convicted former Liberian president Charles Ghankay Taylor of crimes against humanity and war crimes committed from November 30, 1996, to January 18, 2002, in the territory of Sierra Leone during its civil war. Specifically, Taylor was found guilty of the crimes against humanity of murder, rape, sexual slavery, enslavement and other inhumane acts, and the war crimes of committing acts of terror, murder, outrages upon personal dignity, cruel treatment, pillage, and conscripting or enlisting children under the age of fifteen years into armed forces or groups or using them to participate actively in hostilities. In a separate judgment rendered on May 30, 2012, the Chamber sentenced Taylor to a single term of fifty years for all the counts on which the accused had been convicted.

The third decision of the House of Lords in the Pinochet matter is significant, because the House of Lords upheld the majority view taken in the first decision: heads of state can, under certain circumstances, be held responsible for gross violations of human rights in the criminal courts of a foreign country. The decision is based on three main pillars. The Lords had, first, to clarify what constitutes an extradition crime under the Extradition Act 1989; second, to construct torture as an international crime; and, finally, to reject the plea of immunity of a former head of state in the context of the international crime of torture.

This decision of the House of Lords is significant because it is the first decision of a major court of an important country refusing to grant a former head of state immunity from adjudication in the context of alleged gross violations of human rights. It is shown that state immunity, diplomatic immunity and head of state immunity are to be distinguished and the rules pertaining to head of state immunity are explained. Whereas the author agrees with the result of Lords' decision, he disagrees with the reasoning because the majority circumvented the immunity question by artificially qualifying the alleged human rights violations of General Pinochet as private acts.