 A third important complaint against war crime tribunals maintains that they frequently fail to indict all of those who were involved in committing atrocities. According to this charge, courts find it easier to prosecute lower level officials and military personnel, often leaving the more senior figures who devised the violent policies (but do not have actual “blood on their hands”) untouched (Minow 1998: 40–41). To the extent that this complaint is well founded it is devastating, as it suggests that war crime tribunals do not result in a full or coherent exercise of retributive justice (for a comprehensive account see Cryer 2005).  The principle of “Command Responsibility” (CR) originally devised at Nuremberg, and used extensively by the ICTY, has been employed, quite effectively, in order to counter complaints of selectivity. CR allows prosecutors to indict senior officials exclusively on the basis of their military or political leadership role (given the duties of supervision and control attached to that role).