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5  |  Advice on the legal basis for military action, November 2002 to March 2003
identified a key question to be whether or not there was a need for an assessment
of whether Iraq’s conduct constituted a failure to take the final opportunity or a
failure fully to co-operate within the meaning of OP4, such that the basis of the
cease-fire was destroyed.
921.  Lord Goldsmith wrote (paragraph 26): “A narrow textual reading of the
resolution suggested no such assessment was needed because the Security
Council had pre-determined the issue. Public statements, on the other hand, say
otherwise.”
922.  While Lord Goldsmith remained “of the opinion that the safest legal course
would be to secure a second resolution”, he concluded (paragraph 28) that
“a reasonable case can be made that resolution 1441 was capable of reviving
the authorisation in resolution 678 without a further resolution”.
923.  Lord Goldsmith wrote that a reasonable case did not mean that if the matter
ever came to court, he would be confident that the court would agree with this
view. He judged a court might well conclude that OPs 4 and 12 required a further
Security Council decision in order to revive the authorisation in resolution 678.
924.  Lord Goldsmith noted that on a number of previous occasions, including
in relation to Operation Desert Fox in Iraq in 1998 and Kosovo in 1999, UK forces
had participated in military action on the basis of advice from previous Attorneys
General that (paragraph 30) “the legality of the action under international law was
no more than reasonably arguable”.
925.  Lord Goldsmith warned Mr Blair (paragraph 29):
“… the argument that resolution 1441 alone has revived the authorisation
to use force in resolution 678 will only be sustainable if there are strong
factual grounds for concluding that Iraq failed to take the final opportunity.
In other words, we would need to be able to demonstrate hard evidence of
non‑compliance and non-cooperation … the views of UNMOVIC and the IAEA
will be highly significant in this respect.”
926.  Lord Goldsmith added:
“In the light of the latest reporting by UNMOVIC, you will need to consider
extremely carefully whether the evidence of non-cooperation and non-
compliance by Iraq is sufficiently compelling to justify the conclusion that Iraq
has failed to take its final opportunity.”
927.  Mr Straw, Mr Hoon, Dr Reid and the Chiefs of Staff had all seen Lord
Goldsmith’s advice of 7 March before the No.10 meeting on 11 March, but it is not
clear how and when it reached them.
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