> but in the context of the victim numbers that most past crimes against humanity have had, it sets a relatively low new bar.

Which context is this? If you mean the context of past ICC indictments that isn't true. There are multiple other examples of people indicted for specific acts that resulted in the deaths of a 2 digit numbers of people.

The bar for "war crimes" or "crimes against humanity" isn't the number of people you kill. Though in this case, plenty have been killed, this case is about what can be proved conclusively ebough given who it is against.