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The Report of the Iraq Inquiry
expressly or revive the authorisation in resolution 678 (1990)”, to be “the better analysis
of the resolution”.
115.  Commenting on the way in which Mr Wood had addressed the “second view”, that
resolution 1441 had conditionally authorised the use of force, Ms Adams wrote: “I am not
convinced that he puts the arguments in support of this view at their strongest.”
116.  Setting out an alternative analysis, Ms Adams wrote that “one thing is clearer
following adoption” of resolution 1441:
“… the existence of the ‘revival argument’ did not seem to be doubted within the
Security Council. The whole basis of the negotiation … was that the words ‘material
breach’ and ‘serious consequences’ were code for authorising the use of force.
There is now therefore a much sounder basis for relying on the revival argument
than previously.
“… [T]he question of whether resolution 1441 alone satisfies the conditions for
reviving the authorisation in resolution 678 without a further decision of the Council
is far from clear from the text … It is therefore not easy to ascertain the intention of
the Security Council.”
117.  Ms Adams continued:
“What advice you give … may therefore depend on the view you take as to your role
in advising on use of force issues. For example, you might give a different answer
to the question: what is the better interpretation of resolution 1441? than to the
question: can it reasonably be argued that resolution 1441 is capable of authorising
the use of force without a further Council decision?
“You have previously indicated that you are not entirely comfortable with advising
that ‘there is a respectable argument’ that the use of force is lawful, given your
quasi-judicial role in this area. Previous Law Officers have of course advised in
these terms …”
118.  Ms Adams concluded:
“For my own part, I think that the first view is the better interpretation, but that the
arguments in favour of the second view are probably as strong as the legal case
for relying on the revival argument in December 1998 when the UK participated in
Operation Desert Fox.”
119.  Ms Adams wrote that she understood the statement that Lord Goldsmith’s advice
was not “required now” reflected Mr Straw’s views, and:
“While it is certainly true that definitive advice could not be given at this stage on
whether a further Council decision is required (because such advice would need
to take account of all the circumstances at the time, including further discussions
in the Council), there is no reason why advice could not be given now on whether
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