State responsibility has been on the agenda of the International Law Commission since its earliest days. Nearly fifty years ago, in 1949, the Commission identified state responsibility as one of fourteen topics in international law ready for codification. Only in 1956, however, did the Commission, with F.V. Garcia Amador as special rapporteur, begin in earnest its state responsibility codification project. Garcia Amador, whose work focused on the responsibility of states toward aliens on their territory, submitted a number of reports through 1961, but limited discussion was devoted to the topic. A review of the early history of the Commission's state responsibility project, as well as other efforts at codification of this area of law, may be found in the ILC's 1969 Yearbook

On September 6, 2018, Pre-Trial Chamber I of the International Criminal Court (Court) issued its “Decision on the ‘Prosecution's Request for a Ruling on Jurisdiction Under Article 19(3) of the Statute.’” The decision is notable both for the procedural posture—the Prosecution submitted its request prior to opening a preliminary examination—and the majority's conclusion that the Court may exercise territorial jurisdiction over alleged deportation from Myanmar, a nonstate party to the Rome Statute of the International Criminal Court (Rome Statute or Statute), to a state party, Bangladesh.