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6.2  |  Military planning for the invasion, January to March 2003
568.  Lord Goldsmith’s advice of 7 March, which set out his reasoning in considerable
depth, is addressed in detail in Section 5.186
569.  Lord Goldsmith’s conclusions are summarised in the Box below.
Lord Goldsmith’s advice, 7 March 2003
Lord Goldsmith identified three possible bases for the use of military force. He explained
that neither self-defence nor the use of force to avert overwhelming humanitarian
catastrophe applied in this case.
Lord Goldsmith concluded that he remained “of the opinion that the safest legal course
would be to secure the adoption of a further resolution to authorise the use of force”,
and that he had “already advised” that he did “not believe that such a resolution need
be explicit in its terms” if it established that the Security Council had “concluded” that Iraq
had “failed to take the final opportunity offered by resolution 1441”.
Lord Goldsmith added:
“Nevertheless, having regard to the information on the negotiating history which
I have been given and to the arguments of the US Administration which I heard in
Washington, I accept that a reasonable case can be made that resolution 1441 is
capable in principle of reviving the authorisation in 678 without a further resolution.”
Lord Goldsmith added that that would:
“… only be sustainable if there are strong factual grounds for concluding that Iraq
has failed to take the final opportunity. In other words, we would need to be able
to demonstrate hard evidence of non-compliance and non-co-operation. Given
the structure of the resolution as a whole, the views of UNMOVIC and the IAEA
[International Atomic Energy Agency] will be highly significant in this respect. In
the light of the latest reporting by UNMOVIC, you will need to consider extremely
carefully whether the evidence … is sufficiently compelling to justify the conclusion
that Iraq has failed to take the final opportunity.”
570.  Lord Goldsmith stressed, in paragraph 36 of his advice, that the lawfulness of
military action depended on the question of proportionality as well as the existence of
a legal basis:
“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 [1991] and subsequent relevant resolutions;
be limited to what is necessary to achieve that objective; and
must be a proportionate response to that objective, ie securing compliance
with Iraq’s disarmament obligations.”
186  Minute Goldsmith to Prime Minister, 7 March 2003, ‘Iraq: Resolution 1441’.
475
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