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5  |  Advice on the legal basis for military action, November 2002 to March 2003
the difficulty of relying on the assertions of US officials that the French knew
and accepted what they were voting for when there was little “hard evidence
beyond a couple of telegrams recording admissions by French negotiators that
they knew the US would not accept a resolution which required a further Council
decision”;
“the possibility remains that the French and others accepted OP12 because
in their view it gave them a sufficient basis on which to argue that a second
resolution was required (even if that was not made expressly clear)”; and
the statements made on adoption of the resolution indicated that “there were
differing views within the Council as to the legal effect of the resolution”.182
460.  Lord Goldsmith was advised to state that he remained “of the view that the safest
legal course would be to secure a further Security Council resolution” which, as he had
advised the FCO, need not explicitly authorise the use of force as long as it made clear
that the Council had “concluded that Iraq has not taken its final opportunity”.
461.  Ms Adams advised that he should further state:
“Nevertheless, having regard to the further information on the negotiating history
which I have been given and to the arguments of the US administration which
I heard in Washington, I am prepared to accept – and I am choosing my words
carefully here – that a reasonable case can be made that resolution 1441 is capable
of reviving the authorisation in 678 without a further resolution if there are strong
factual grounds for concluding that Iraq has failed to take the final opportunity.
In other words we would need to demonstrate hard evidence of non-compliance
and non-co-operation.”
462.  Lord Goldsmith was also advised:
that a court “might well conclude” that OPs 4 and 12 did “require a further
Council decision”, but that “the counter view can reasonably be maintained”;
that the analysis applied “whether a second resolution fails to be adopted
because of a lack of votes or because it is vetoed. I do not see any difference
between the two cases”; and
it was “important that in the course of negotiations on the second resolution
we do not give the impression that we believe it is legally required. That would
undermine our case for reliance on resolution 1441”.
463.  There is no No.10 record of the 27 February meeting.
464.  In his record of a telephone call from Lord Goldsmith reporting the meeting,
Mr Brummell wrote that Lord Goldsmith “confirmed that he had deployed in full” the lines
prepared by Ms Adams, with the exception of the reference to the fact that “on a number
182 Minute Adams to Attorney General, 27 February 2003, ‘Iraq: Lines to Take for No 10 Meeting’.
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