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The Report of the Iraq Inquiry
“The further decision need not be in the form of a further resolution. It is possible that
following a discussion under OP12 of the resolution, the Council could make clear
by other means, e.g. a Presidential statement, that it believes force is now justified
to enforce the cease-fire.”
185.  Addressing the principle of proportionality, Lord Goldsmith emphasised that:
“Any force used pursuant to the authorisation in resolution 678:
must have as its objective the enforcement of the terms of the cease-fire
contained in resolution 687 (1990) [sic] and subsequent relevant resolutions;
be limited to what is necessary to achieve that objective; and
must be proportionate to that objective, i.e. securing compliance with Iraq’s
disarmament objectives.
“That is not to say that action may not be taken to remove Saddam Hussein from
power if it can be shown that such action is necessary to secure the disarmament
of Iraq and that it is a proportionate response to that objective. But regime change
cannot be the objective of military action. This should be borne in mind in making
public statements about any campaign.”
186.  As he had promised following the meeting on 22 October, when Mr Blair had asked
about the consequences of a perverse or unreasonable veto “of a second resolution
intended to authorise the use of force”, Lord Goldsmith also addressed other legal bases
for military action.
187.  In her minute of 14 October 2002, Ms Adams had drawn Lord Goldsmith’s attention
to the Law Officers’ advice to Mr Blair in 1997 which identified the possibility that there
could be:
“… exceptional circumstances in which although the Council had not made a
determination of material breach it was evident to and generally accepted by the
international community as a whole that Iraq had in effect repudiated the cease-fire
and that a resort to military force to deal with the consequences of Iraq’s conduct
was the only way to ensure compliance with the cease-fire conditions.”70
188.  Ms Adams added:
“I understand this passage was included in the advice to cover the sort of situation
where the Council was unable to act. But of course the counter view would be that
if the Council has rejected a resolution authorising the use of force, then under the
scheme of the Charter, it cannot be said that force is legally justified.”
70 Minute Adams to Attorney General, 14 October 2002, ‘Iraq: Meeting with David Manning, 14 October’.
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