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The Functional Beginning of Belligerent Occupation

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Michael Siegrist

Part B: Feasibility of the Application of the Functional Beginning of Belligerent Occupation Theory

II. Core Guarantees Applicable to both the Territories of the Parties to the Conflict and Occupied Territories

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  • 191  See above at p. 21.
  • 192  Final Record, Vol. II, at p. 821.
  • 193  Heading of Section I of Part III of the Fourth Geneva Convention.
  • 194  See Kolb, Ius…, at pp. 366 to 367; Dörmann/Colassis, International…, at p. 300, who seem to accept (...)

1With regard to the fundamental guarantees laid down in Articles 27 to 34 of the Fourth Geneva Convention, two interpretations seem possible. As argued above,191 it seems that the drafters distinguished between aliens in the territory of a belligerent State, on the one hand, and the population of an occupied territory, on the other, and that Articles 27 to 34 of the Fourth Geneva Convention were intended to be provisions common to these two situations only.192 Also, the plenipotentiaries must have assumed that every protected person finds him or herself either in the territory of an enemy State (as an alien) or in occupied territories, because otherwise, as will be seen in this section of the present paper, an unacceptable gap in protection would exist for some people. On the other hand, one can argue that the heading “Provisions common to the territories of the parties to the conflict and to occupied territories”193 indicates that the articles of Section I of Part III of the Fourth Geneva Convention apply not only in a party’s own territory to the conflict (with regard to aliens) and occupied territories, but also on the territory of another party to the conflict that has been invaded.194

2Depending on which of the two above-mentioned interpretations one adopts, the potential gap in protection caused by not applying the functional beginning of belligerent occupation theory would vary. If one adopted the latter interpretation that these core guarantees apply to the territories of the parties to a conflict regardless of whether or not a state of occupation has been established, no gap in protection would exist with regard to these core guarantees. The functional beginning of belligerent occupation theory is, however, of paramount importance to prevent gaps in protection if one follows the interpretation suggested in the travaux préparatoires.

3Despite overlaps with the next section of this paper, an entire section is devoted to these core guarantees.

1. Treatment: General observations - Article 27 of the Fourth Geneva Convention

  • 195  See Pictet, Commentary..., Article 27, at p. 200, explaining that the preamble should have made re (...)
  • 196  Arai-Takahashi, Yutaka, The Law of Occupation: Continuity and Change of International Humanitarian (...)

4Article 27 of the Fourth Geneva Convention is the opening article of Section I of Part III applicable to the territories of the parties to the conflict and to occupied territory. It represents, together with Articles 31 to 34 of the Fourth Geneva Convention, a sort of a mini human rights convention by setting out the fundamental rights of protected persons.195 As Arai-Takahashi noticed, the articles of Section I indeed seem to “largely correspond to the catalogue of human rights which are non-derogable and peremptory in nature”.196

5Article 27 of the Fourth Geneva Convention lays down three core guarantees relating to:

    • 197  See Article 27(1) of the Fourth Geneva Convention.

    The respect for the fundamental rights of protected persons, which includes the principles calling for the respect of person, honour, family rights, religious convictions and practices, manners and customs as well as an obligation of humane treatment;197

    • 198  See Article 27(2) of the Fourth Geneva Convention.

    The protection of women by denouncing attacks on their honour in general and forms of sexual violence in particular;198

    • 199  See Article 27(3) of the Fourth Geneva Convention.

    The right of equality and non-discrimination.199

  • 200  See Pictet, Commentary..., Article 27, at p. 200.
  • 201  See Final Record, Vol. II, at p. 821.

6These core guarantees proclaim the basic principles upon which the whole 1949 Geneva Conventions are founded.200 By denying protected persons these core guarantees one would come very close to a perversion of the 1949 Geneva Conventions and their protective purpose. It is hardly conceivable that the drafters, when stating that Part III of the Fourth Geneva Convention would govern only the situations in which aliens are in the territory of a belligerent State and that of the inhabitants of occupied territory,201 wanted to exclude people from the protection of Section I of Part III of the Fourth Geneva Convention during an invasion phase. On the contrary, they must have assumed that every protected person would be either an alien in the territory of a belligerent State or in occupied territory, the latter being understood in terms of the wider meaning given by the functional beginning of belligerent occupation theory.

  • 202  See Article 27(4) of the Fourth Geneva Convention.
  • 203  See Pictet, Commentary..., Article 27, at p. 207.

7Moreover, Article 27 of the Fourth Geneva Convention does not only bestow rights and liberties upon protected persons. Its fourth paragraph also takes into account the various military considerations that can arise as a result of an armed conflict and authorises the parties to the conflict to “take measures of control and security”.202 The parties to the conflict are left with great discretion with regard to their choice of measures, as long as they respect the fundamental rights of the persons concerned and are not otherwise contrary to the Fourth Geneva Convention.203 This right somewhat balances out the duties imposed on a party to the conflict.

8Having said this, one can conclude that Article 27 of the Fourth Geneva Convention, considering the negative nature of the duties embodied therein, that is to say the duty to respect, as well as its reservation in regard to security measures, must be applied at all times and in any place where a party to the conflict deals with protected persons or takes measures which could affect them in a way contrary to the provision.

2. Danger zones - Article 28 of the Fourth Geneva Convention

  • 204  Article 28 of the Fourth Geneva Convention.
  • 205  Pictet, Commentary..., Article 28, at p. 209.
  • 206  For prisoners of war see Article 23 of Geneva Convention (III); for medical units and establishmen (...)
  • 207  See Article 51(7) of the 1977 Additional Protocol I.
  • 208  See Henckaerts/Doswald-Beck, Customary International Humanitarian Law, Volume I: Rules (Cambridge: (...)

9Article 28 of the Fourth Geneva Convention lays down that “the presence of a protected person may not be used to render certain points or areas immune from military operations”.204 This provision thus codifies the prohibition of the use of protected persons as of human shields and “applies to the belligerents’ own territory as well as to occupied territory”.205 The seventh paragraph of Article 51 of the 1977 Additional Protocol I develops and clarifies the multiple rules of the 1949 Geneva Conventions prohibiting the use of protected persons and objects as shields against military operations.206 The former extends the scope of application to all civilians and also covers “movements” of the civilian population or civilian individuals as well.207 Furthermore, the prohibition of the use of human shields is also an established rule of customary international humanitarian law as described in the recent study conducted by the ICRC.208

10This multitude of rules prohibiting the use of human shields underlines the general validity of this principle. Furthermore, it should be noted that the formal application of Article 28 of the Fourth Geneva Convention already during the invasion phase does not involve any additional obligations for a party to the conflict as the latter remains bound by the other rules relating to human shields. Compliance with these provisions results in a de facto compliance with Article 28 of the Fourth Geneva Convention. Hence, the application of Article 28 of the Fourth Geneva Convention should not be contingent upon an exaggerated formalism whether or not belligerent occupation within the traditional meaning has been established. The article can be applied without difficulties in a party to the conflict’s own territory as well as on foreign enemy territory from the beginning of invasion.

3. Prohibition of coercion - Article 31 of the Fourth Geneva Convention

11Article 31 of the Fourth Geneva Convention, which is applicable to both the territories of the parties to the conflict and to occupied territories, declares that:

 “No physical or moral coercion shall be exercised against protected persons, in particular to obtain information from them or from third parties.”

  • 209  Pictet, Commentary..., Article 31, at p. 220.
  • 210  Ibid.

12Article 31 of the Fourth Geneva Convention is the pendant to Article 44 of the 1907 Hague Regulation. Yet, the former has extended the protective scope of the latter as it is more general and prohibits coercion for any purpose or reason.209 It should be noted that the prohibition of coercion does not prevent the questioning of protected persons in order to obtain information, for instance, about the army of the adversary. Furthermore, the prohibition of coercion applies only to the extent that “force is permitted whenever it is necessary to use it in the application of measures taken under the Convention”.210

  • 211  Ibid.
  • 212  See ICTY, Naletilićcase, supra note 48, at para. 221.

13In stating “[...] the custom [...] that an invasion army may force the inhabitants of an occupied territory to serve as ‘guides’ is now forbidden”,211 it seems that the Commentary applies an approach which does not require a state of occupation for Article 31 of the Fourth Geneva Convention to apply. Indeed, this approach seems to be warranted because otherwise a significant gap in protection of civilians would exist. In any case, Article 31 of the Fourth Geneva Convention presupposes that a protected person is actually in the hands of an invading army. From that moment onwards the provision becomes applicable in accordance with the functional beginning of belligerent occupation theory.212 Compliance with Article 31 of the Fourth Geneva Convention, containing such a fundamental principle of humanity, from the outset of hostilities cannot present a real burden for a party to a conflict. Hence, no reasonable argument can be put forward that would justify physical or moral coercion of protected persons before a state of occupation has been established.

14Moreover, the line between physical or moral coercion and cruel treatment and torture (prohibited by common Article 3 of the 1949 Geneva Conventions), is a very thin one. Allowing physical or moral coercion during an invasion phase comes with a great risk of abuse easily leading to cruel treatment or torture.

4. Prohibition of measures causing physical suffering or extermination - Article 32 of the Fourth Geneva Convention

  • 213  See Pictet, Commentary..., Article 32, at p. 221.
  • 214  Yutaka Arai-Takahashi, The Law..., at p. 280.
  • 215  See Article 147 of the Fourth Geneva Convention.
  • 216  See Henckaerts/Doswald-Beck, Customary..., Rules 89 to 92, at p. 311 onwards.
  • 217  See Articles 8(2)(a)(i) to (iii), 8(2)(b)(x) and 8(2)(b)(xxi) of the Rome Statute.
  • 218  See Article 7(1) of the Rome Statute.

15The prohibition of acts causing physical suffering or extermination of protected persons in the hands of a High Contracting Party reinforces the general principles relating to the protection of fundamental rights as set out in Article 27 of the Fourth Geneva Convention.213 According to one author the article is a “reflection of crimes against humanity committed by Axis powers against the civilian populations in invaded and occupied territories during World War II”.214 It is thus not surprising that the prohibited measures falling within the scope of Article 32 of the Fourth Geneva Convention are generally considered grave breaches of the Fourth Geneva Convention.215 The condemnation of these egregious acts is so strong that they also have been taken up in Article 3 common to the 1949 Geneva Conventions, Article 75 of the 1977 Additional Protocol I and form part of customary international humanitarian law as well.216 Furthermore, they also constitute war crimes under the Rome Statute of the International Criminal Court217 and may amount to crimes against humanity if they are “committed as part of a widespread or systematic attack directed against any civilian population”.218

  • 219  See Final Record, Vol. II, at p. 717.
  • 220  Ibid., at. p. 719; Pictet, Commentary..., Article 32, at p. 222.
  • 221  See Final Record Vol. II B, at pp. 407 - 410.
  • 222  See above at pp. 24 to 25.

16What has been argued with regard to Article 28 of the Fourth Geneva Convention also holds true for the prohibition of measures causing physical suffering or extermination. Consequently, there is no evident reason to justify not applying Article 32 of the Fourth Geneva Convention already during the invasion phase. Although it was proposed at the time of drafting that the article should cover the “whole civilian population, whoever and wherever they were”,219 mostly Western States feared an interference with the 1907 Hague Regulations and the majority voted for a text limited to protected persons in the hands of a High Contracting Party.220 The intention of the drafters was to show clearly that the article would not apply to the conduct of military operations.221 As discussed above the functional beginning of occupation theory does not interfere with the rules on the conduct of hostilities, the latter being lex specialis, but only requires that the provisions of the Fourth Geneva Convention apply from the moment that a hostile army has control over the protected person.222

17Therefore one can conclude that control over the person must be sufficient for the application of Article 32 of the Fourth Geneva Convention.

5. Principle of individual responsibility and prohibition of collective penalties - First paragraph of Article 33 of the Fourth Geneva Convention

  • 223  See Pictet, Commentary..., Article 33, at p. 225; Article 50 of the 1907 Hague Regulations.
  • 224  Article 33(1) of the Fourth Geneva Convention.
  • 225  See Pictet, Commentary..., Article 33, at pp. 225 to 226.
  • 226  Cassese, Antonio, International Criminal Law, 2nd edition (Oxford: University Press, 2008), at p. (...)
  • 227  See Henckaerts/Doswald-Beck, Customary..., Rule 102, at p. 372 onwards.
  • 228  See Article 25 Rome Statute; Article 6 of the Statute of the Special Court for Sierra Leone; Artic (...)
  • 229  Henckaerts/Doswald-Beck, Customary..., Rule 102, at p. 373.
  • 230  Sandoz, Yves; Swinarski, Christophe; Zimmermann, Bruno (eds.), Commentary on the Additional Protoc (...)
  • 231  See Henckaerts/Doswald-Beck, Customary..., Rule 103, at p. 374 onwards.

18Article 33 of the Fourth Geneva Convention is derived from Article 50 of the 1907 Hague Regulations, which prohibits penalising persons for acts for which they are not responsible.223 The first paragraph enshrines the principle of individual criminal responsibility and prohibits collective penalties and “all measures of intimidation or of terrorism”.224 The words quoted were chosen to make clear that the prohibition of collective penalties does not only include those penalties repressing breaches of the law but also any intimidatory or terroristic measures intended to prevent hostile acts.225 The principle of individual criminal responsibility, according to which no one shall be held accountable for an act he or she has not personally committed or co-perpetrated,226 is also set down as a fundamental guarantee in paragraph (4)(b) of Article 75 of Additional Protocol I, reflecting customary international humanitarian law,227 and is a maxim for all recent international tribunals.228 Furthermore, the principle also seems to be upheld in “most, if not all, national legal systems”.229 Likewise, the prohibition of collective penalties, which includes not only criminal sanctions but “sanctions and harassment of any sort, administrative, by police action or otherwise” as well,230 is recognised as a fundamental guarantee in paragraph 2(d) of Article 75 of Additional Protocol I and considered to reflect customary international humanitarian law.231

19Because of this strong and wide incorporation of these principles in international and national law, it would seem odd not to apply the first paragraph of Article 33 of the Fourth Geneva Convention already during the invasion phase. A power that is in a position to impose penalties on protected persons prior to the establishment of a state of occupation, understood in its traditional sense, must not be exempt from applying the principle of individual criminal responsibility or the prohibition of collective penalties.

6. The prohibition of pillage - Second paragraph of Article 33 of the Fourth Geneva Convention

  • 232  See Articles 28 and 47 of the 1907 Hague Regulations.
  • 233  See Pictet, Commentary..., Article 33, at p. 226.
  • 234  See Henckaerts/Doswald-Beck, Customary..., Rule 52, at p. 182 onwards.

20The Hague Regulations contain the prohibition of pillage in two separate provisions: in Article 28 under Section II relative to the conduct of hostilities; and in Article 47 applicable in occupied territories.232 The Fourth Geneva Convention took up this old principle of international law and underlined its absolute character.233 Furthermore, the prohibition of pillage is also recognised as being part of customary international humanitarian law.234

  • 235  Pictet, Commentary..., Article 33, at p. 226.

21The prohibition of pillage applies to both the “territory of a Party to the conflict as well as occupied territories” and protects all types of property, that is to say both private and public property.235 Since the prohibition explicitly applies to hostilities and occupied territory it is only logical that pillage must be prohibited at any stage of an armed conflict and thus, in application of the functional beginning theory, also during the early stages of invasion outside the battlefields.

7. Reprisals - Third paragraph of Article 33 of the Fourth Geneva Convention

  • 236  Shaw, International Law..., at p. 1129.

“Reprisals are acts which are in themselves illegal and have been adopted by one state in retaliation for the commission of an earlier illegal act by another state.”236

  • 237  For the conditions see: Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 515 onwards.
  • 238  See Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 513.

22Although belligerent reprisals may be legitimate under certain circumstances as an enforcement measure,237 the categories of persons and objects that can be the subject of reprisals have continuously been reduced during the past century and there seems to be a trend to outlaw them altogether.238

  • 239  Pictet, Commentary..., Article 33, at p. 228.
  • 240  See Articles 51(6) and 52(1) 1977 Additional Protocol I respectively.
  • 241  See Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 513 onwards.
  • 242  See Ibid., Rules 146 and 147 respectively, p. 519 onwards.

23The third paragraph of Article 33 of the Fourth Geneva Convention prohibits reprisals against protected persons and their property in the territory of a party to the conflict and occupied territories. It is a prohibition “essentially based on the protection of the human person”239 and is in itself a form of collective punishment, outlawed under the first paragraph of Article 33 of the Fourth Geneva Convention. Belligerent reprisals during the conduct of hostilities, by way of attacks against the civilian population or civilians and civilian objects, are also outlawed by the 1977 Additional Protocol I.240 While the customary status of the prohibition of reprisals against civilian persons and objects during the conduct of hostilities remains controversial, customary international humanitarian law imposes strict conditions on belligerent reprisals in general,241 and completely prohibits reprisals against protected persons and objects in the hands of an adverse party.242

24The protection of protected persons would suffer a severe blow if one were to accept that the prohibition of reprisals against protected persons and their property only applies to the own territory of a High Contracting Party and to belligerent occupation in the traditional sense. This would create a gap in protection for the period between the beginning of the invasion and the establishment of a state of occupation. Here, the application of the functional approach of occupation would dispel any doubts that reprisals against protected persons and their property is unlawful in all circumstances.

8. Hostages - Article 34 of the Fourth Geneva Convention

  • 243  Article 1 of the International Convention against the Taking of Hostages of 17 December 1979.

25Hostage-taking consists in the seizure or detention of a person (the hostage), combined with threats to kill, to injure or to continue to detain the hostage “in order to compel a third party [...] to do or abstain from doing any act as an explicit or implicit condition for the release of the hostage”.243

  • 244  See Arai-Takahashi, The Law..., at p. 293 onwards; Dinstein, The International..., at p. 151 onwar (...)
  • 245  ICJ, Armed Activities case, supra note 54, at para. 218.
  • 246  See Article 147 of the Fourth Geneva Convention.
  • 247  See Henckaerts/Doswald-Beck, Customary..., Rule 96, p. 334 onwards.

26After World War II, and the controversial decision of the American Military Tribunal at Nuremberg in the Wilhelm List and Others case (the HostageCase) of 1948 in particular, the prohibition of hostage-taking was substantially developed in treaty law and in customary international law as well.244 Article 34 of the Fourth Geneva Convention prohibits in an absolute manner the hostage-taking of protected persons in enemy or occupied territory. The taking of hostages is also prohibited as one of the minimum safeguards by common Article 3(1)(b) of the Geneva Conventions, applicable to international and non-international armed conflicts245, and is reiterated as a fundamental guarantee in Article 75(2)(b)(c) of the 1977 Additional Protocol I. The taking of hostages is also a grave breach of the Fourth Geneva Convention246and is recognised as a war crime under Article 8(2)(a)(viii) of the Rome Statute. State practice in the post-World War II era has firmly established the prohibition of hostage- taking as part of customary international humanitarian law.247

27The prohibition of hostage-taking has become so firmly entrenched in international humanitarian law and international criminal law that it would be odd to deny the application of Article 34 of the Fourth Geneva Convention already during the invasion phase. Considering that the taking of hostages requires control or authority over the protected persons concerned, as well as over the place where the hostage is held, there is a strong argument in favour of an application of Article 34 of the Fourth Geneva Convention according to the theory of the functional beginning of belligerent occupation.

Notes

191  See above at p. 21.

192  Final Record, Vol. II, at p. 821.

193  Heading of Section I of Part III of the Fourth Geneva Convention.

194  See Kolb, Ius…, at pp. 366 to 367; Dörmann/Colassis, International…, at p. 300, who seem to accept that Articles 27 to 34 of the Fourth Geneva Convention would apply in all situations, including invasion.

195  See Pictet, Commentary..., Article 27, at p. 200, explaining that the preamble should have made reference to certain rules representing "the basis of universal human law". However, the plenipotentiaries adopted another text for the preamble and hence Articles 27 and 31 to 34 of the Fourth Geneva Convention must be regarded as the rules laying down the "basis of universal human law".

196  Arai-Takahashi, Yutaka, The Law of Occupation: Continuity and Change of International Humanitarian Law, and its Interaction with International Human Rights Law (Leiden; Boston: Nijhoff, 2009), at p. 270.

197  See Article 27(1) of the Fourth Geneva Convention.

198  See Article 27(2) of the Fourth Geneva Convention.

199  See Article 27(3) of the Fourth Geneva Convention.

200  See Pictet, Commentary..., Article 27, at p. 200.

201  See Final Record, Vol. II, at p. 821.

202  See Article 27(4) of the Fourth Geneva Convention.

203  See Pictet, Commentary..., Article 27, at p. 207.

204  Article 28 of the Fourth Geneva Convention.

205  Pictet, Commentary..., Article 28, at p. 209.

206  For prisoners of war see Article 23 of Geneva Convention (III); for medical units and establishments see Article 19 of Geneva Convention (I) and Article 12 of Geneva Convention (II).

207  See Article 51(7) of the 1977 Additional Protocol I.

208  See Henckaerts/Doswald-Beck, Customary International Humanitarian Law, Volume I: Rules (Cambridge: Cambridge University Press, 2005), Rule 97, at p. 337.

209  Pictet, Commentary..., Article 31, at p. 220.

210  Ibid.

211  Ibid.

212  See ICTY, Naletilićcase, supra note 48, at para. 221.

213  See Pictet, Commentary..., Article 32, at p. 221.

214  Yutaka Arai-Takahashi, The Law..., at p. 280.

215  See Article 147 of the Fourth Geneva Convention.

216  See Henckaerts/Doswald-Beck, Customary..., Rules 89 to 92, at p. 311 onwards.

217  See Articles 8(2)(a)(i) to (iii), 8(2)(b)(x) and 8(2)(b)(xxi) of the Rome Statute.

218  See Article 7(1) of the Rome Statute.

219  See Final Record, Vol. II, at p. 717.

220  Ibid., at. p. 719; Pictet, Commentary..., Article 32, at p. 222.

221  See Final Record Vol. II B, at pp. 407 - 410.

222  See above at pp. 24 to 25.

223  See Pictet, Commentary..., Article 33, at p. 225; Article 50 of the 1907 Hague Regulations.

224  Article 33(1) of the Fourth Geneva Convention.

225  See Pictet, Commentary..., Article 33, at pp. 225 to 226.

226  Cassese, Antonio, International Criminal Law, 2nd edition (Oxford: University Press, 2008), at p. 33; Pictet, Commentary..., Article 33, at p. 225.

227  See Henckaerts/Doswald-Beck, Customary..., Rule 102, at p. 372 onwards.

228  See Article 25 Rome Statute; Article 6 of the Statute of the Special Court for Sierra Leone; Article 6 of the Statute of the International Tribunal for Rwanda; Article 7 of the ICTY Statute.

229  Henckaerts/Doswald-Beck, Customary..., Rule 102, at p. 373.

230  Sandoz, Yves; Swinarski, Christophe; Zimmermann, Bruno (eds.), Commentary on the Additional Protocols of 8 June 1977 to the Geneva Conventions of 12 August 1949 (Geneva: ICRC, 1987), [cited: Commentary AP], at para. 3055.

231  See Henckaerts/Doswald-Beck, Customary..., Rule 103, at p. 374 onwards.

232  See Articles 28 and 47 of the 1907 Hague Regulations.

233  See Pictet, Commentary..., Article 33, at p. 226.

234  See Henckaerts/Doswald-Beck, Customary..., Rule 52, at p. 182 onwards.

235  Pictet, Commentary..., Article 33, at p. 226.

236  Shaw, International Law..., at p. 1129.

237  For the conditions see: Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 515 onwards.

238  See Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 513.

239  Pictet, Commentary..., Article 33, at p. 228.

240  See Articles 51(6) and 52(1) 1977 Additional Protocol I respectively.

241  See Henckaerts/Doswald-Beck, Customary..., Rule 145, at p. 513 onwards.

242  See Ibid., Rules 146 and 147 respectively, p. 519 onwards.

243  Article 1 of the International Convention against the Taking of Hostages of 17 December 1979.

244  See Arai-Takahashi, The Law..., at p. 293 onwards; Dinstein, The International..., at p. 151 onwards.

245  ICJ, Armed Activities case, supra note 54, at para. 218.

246  See Article 147 of the Fourth Geneva Convention.

247  See Henckaerts/Doswald-Beck, Customary..., Rule 96, p. 334 onwards.

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