This dilemma stems from the widely accepted definition of armed conflict ( ICTY, Tadi? case, Jurisdiction, para.
The issue thus revolves around the question of whether the duration of a conflict should be regarded as an independent criterion for the existence of NIAC or as a part of the intensity criterion. If one presumes that at the end of June 1991 Slovenia was not a sovereign state (thus excluding the IAC possibility), what remains is whether the conflict that lasted only 10 days could be viewed as a NIAC to begin with. There is a controversy as to whether this armed conflict was in fact international (IAC) or non-international in nature.
Its dissolution started with the so-called Ten-Day War, which was fought from 27 June to 7 July 1991 between the Slovenian Territorial Defence and the Yugoslav People’s Army, resulting in some 60 fatalities and 330 wounded.
Both authors of this blog were born in Yugoslavia, a country that no longer exists.
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