Russia has vetoed a plan to set up a tribunal to prosecute whoever is suspected of downing flight MH17 over eastern Ukraine.
The Malaysia Airlines flights is largely believed to have been hit by a surface-to-air missile, killing all 298 people on board.
Ukraine and the West have suggested that separatists backed by Russia or Russian troops themselves were responsible for shooting down the plane.
Moscow has repeatedly dismissed the accusations and state media has suggested that Ukrainian jets were to blame.
The tragedy is being investigated by the Netherlands, Australia, Ukraine, Malaysia and Belgium.
Russian President Vladimir Putin said Moscow would block the proposed tribunal in the United Nations Security Council because there were still "a lot of questions" about the inquiry, to which it has had little access.
The vote at the UN came after last-minute efforts to convince Mr Putin to support the resolution, with the Dutch ambassador to the UN, Karel van Oosterom, tweeting that "it was preferable to make a decision about the tribunal before the facts and charges have been established precisely in order to avoid politicising the prosecution process".
Eleven nations on the 15-member council in favour of the tribunal, while China, Angola and Venezuela abstained.
Malaysia's Transport Minister Liow Tiong Lai said the vote sent a "dangerous message of impunity to the perpetrator of this heinous crime".
Samantha Power, the US ambassador to the UN said: "No veto will stand in the way of this heinous crime being investigated and prosecuted.
"Efforts to deny justice only intensify the pain of the victims' families, who have already endured more than any of us can fathom.
"It is the effect of Russia's veto today."
A preliminary report last year said that the plane had suffered no technical problems before it broke up in the sky after being hit by multiple objects.
But the investigation by the Dutch Safety Board will only establish the cause of the crash, not who is to blame.
A separate inquiry by the Dutch national prosecutor's office aims to decide who is responsible.
