On February 12, 2015, in a Chamber judgment [3], the European Court of Human Rights (the Court) ruled in Sanader v. Croatia that not providing a defendant convicted in absentia of crimes against humanity a real possibility for retrial is a violation of the right to a fair trial under Article 6(1) of the European Convention on Human Rights [4]. According to the press release [5], based on eye witness testimony, Mile Sanader, a Croatian and Serbian national, was tried, convicted, and sentenced to twenty years in prison for taking part in the 1991 shooting of twenty-seven prisoners of war by a group of Serb paramilitary forces. Upon learning of his conviction by the Croatian court, Sanader denied committing the crime and requested the reopening of his case. The Croatian authorities dismissed his request and Sanader submitted an application to the Court arguing the dismissal was a violation of Article 6 of the Convention. The Court found that Sanader “had no knowledge of his prosecution and of the charges against him and that he had not attempted to evade trial or waive his right to appear in court” and “had no opportunity to challenge the factual findings of the judgment by which he had been convicted.” The Court ruled that despite the two possibilities for retrial suggested by the Croatian authorities, there had been a violation of Article 6 as “Sanader had not been provided with sufficient certainty with the opportunity of obtaining a fresh determination of the charges against him by a court in full respect of his defence rights.”