Counter-terrorism involving actions against non-state groups such as Al-Qaeda falls outside the traditional state-to-state structures of international law. However, with the developing concern for human rights protection and the notion of individual responsibility for international crimes, international law has extended its reach to cover terrorism and counter-terrorism. Early arguments in the League of Nations era that an international court should be created to try terrorists did not succeed, and it was not until the 1960s that the United Nations (UN) turned its attention to the matter when faced with Palestinian terrorist atrocities. The Cold War approach was to try and tackle the issue in a state-based, consensual manner, reflecting the traditional values of international law. The post -Cold War era saw new trends by both governments and international organisations in the form of executive-led security/military approaches that challenge international legal paradigms, while also seeing other more consensual, multilateral instruments which take a criminal justice/human rights approach. The development of more coercive responses alongside consensual ones was accelerated by the events of 11 September 2001 (9/11).