A special Chamber convened by order of the Vice-President of the International Criminal Tribunal for the former Yugoslavia (ICTY) has, by two to one, upheld a defense motion for disqualification of Judge Frederik Harhoff from the Prosecutor v. Vojislav Šešelj case. The disqualification is based on a letter that Harhoff wrote dated June 6, 2013, which the special Chamber found demonstrated an unacceptable appearance of bias in favor of conviction.  In the letter, which became publicly available through the media and the Internet, Judge Harhoff criticized a number of recent ICTY Appeals Chamber and Trial Chamber Judgments, and claimed that the President of the Tribunal was exerting pressure on his colleagues in deliberations. In his dissent, Judge Liu noted that the letter was "undoubtedly improper" but considered that he was "not persuaded in the present circumstances that a reasonable, informed observer would reasonably apprehend bias on the part of Judge Harhoff in favour of conviction based on the [l]etter."