The subject of this work is the reform debate and legislation pertaining to the facts of the case as set out in §217 of the old version of the German Criminal Code (StGB) from 1870 until its annulment under the Sixth Criminal Law Reform Act (StrRG) on 1 April 1998. This work focuses on providing observations in hindsight. This particularly applies to the motives and legal consequences of the deletion of the facts of the case under the Sixth StrRG, which actually created more issues than it solved. <