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9.1  |  March to 22 May 2003
The legal framework for the Occupation
It was widely understood by both the US and UK that once they had displaced the
regime of Saddam Hussein, Coalition Forces would exercise authority over – and, under
international law be occupiers in – Iraq. FCO lawyers confirmed on 2 April 2003
that by that date, UK forces were an Occupying Power in that part of Iraq in their
physical control.37
The basic principles of International Humanitarian Law as they apply to military action, in
particular in relation to targeting and the Rules of Engagement, are set out in Section 6.1.
This Box explains the main principles applicable to the occupation of one state by another,
a process which makes it the “Occupying Power”.
As Occupying Powers, the UK and USA were bound by international law on belligerent
Occupation. Its rules are set out in the 1907 Hague Regulations (Articles 42 to 56), the
Fourth Geneva Convention on the Protection of Civilian Persons in Time of War of 1949
(Articles 27 to 34 and 47 to 78) and the 1977 First Protocol to the Geneva Conventions
of 1949 Relating to the Protection of Victims of International Armed Conflicts.
Article 42 of the Hague Regulations defines an Occupation:
“Territory is considered occupied when it is actually placed under the authority of the
hostile army. The occupation extends only to the territory where such authority has
been established and can be exercised.”
In Iraq in April 2003 this meant that, at a minimum, the UK was considered the Occupying
Power in that part of South-East Iraq where its forces were physically present and
exercised authority. The UK’s role alongside the US in ORHA (and then the CPA) raised
questions about whether the UK was also jointly responsible for the actions of those
organisations throughout Iraq.
Article 43 of the Hague Regulations provides that the Occupying Power “shall take all
the measures in his power to restore, and ensure, as far as possible, public order and
safety while respecting, unless absolutely prevented, the laws in force in the country”.
Sir Michael Wood, a former FCO Legal Adviser, told the Inquiry: “While some changes to
the legislative and administrative structure may be permissible if they are necessary for
public order and safety, more wide-reaching reforms of governmental and administrative
structures are not lawful. That includes the imposition of major economic reforms.”38
The Fourth Geneva Convention defines “protected persons” as those who “find
themselves … in the hands of a party to the conflict or Occupying Power of which they
are not nationals”. It sets out a number of detailed provisions on status and treatment
of protected persons; and a number of responsibilities and restrictions that apply to
the Occupying Power in relation to the occupied territory. The provisions of particular
relevance to the UK’s involvement in Iraq are:
Article 54, which prohibits any alteration in the status of public officials should they
abstain from fulfilling their functions for reasons of conscience. It does not affect
the right of the Occupying Power to remove public officials from their posts.
37  Minute Llewellyn to Bristow, 2 April 2003, [untitled].
38  Statement Wood, 15 January 2010, pages 2-3.
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