You may have missed this! Looks like the Kenya media did.

We thought, then, that we’d share with you this document which outlines Judge Hans-Peter Kaul’s ‘dissenting opinion’ in full, a ‘public document’ dated March 2011, regarding Ruto, Kosgey and Sang and why the ICC, in his opinion, had no jurisdiction and questioning the validity of the ‘crimes against humanity’ charge.

In the document, he states that he “is not convinced that there are reasonable grounds to believe that the crimes alleged … were committed pursuant to the policy of an organisation“.