Friday, 10 April 2015

LEGITIMACY OF DRONE ATTACKS: WHEN MAY ONE STATE LAWFULLY ATTACK THE CITIZENS OF ANOTHER STATE?


LEGITIMACY OF DRONE ATTACKS: WHEN MAY ONE STATE LAWFULLY ATTACK THE CITIZENS OF ANOTHER STATE?
By M. Anum Saleem[1] and Ayesha Tahir[2]


The legal status and validity of humanitarian intervention and actions of self defense create a great challenge for the global world. "The use of force by and against States remains a persistent Feature of international affairs. NATO forces based in Afghanistan target Taliban fighters based in Pakistan, while Turkish jets strike Kurdish separatists in Iraq, Columbian soldiers attack armed groups in Ecuador, Israeli commandos enter Gaza in their ongoing conflict with Hamas, and various naval powers retaliate against pirates docked in Somalia" (Robinson and Hague)[3]. The after math of 9/11 attacks has been the immense operations carried out by United Sates and NATO against terrorist groups in middle east, Afghanistan and Pakistan and one of the inhumane targeted operation used by United States is of Drone attacks targeted on the Northern Waziristan in Pakistan to target Terrorism groups operating in Pakistan. These attacks are carried out and justified by United States under self defense doctrine. "Since World War II, international law has prohibited States from threatening or using force except in self-defense or pursuant to Security Council authorization".[4]The legality of using force against armed groups on the territory of another State is of pressing concern to the. United States. United States reasons for attacking the territorial integrity of Pakistan can be because justified on self defense but whether International law provides United States with such basis is an ongoing debate.

International law justifies armed attacks on another State under certain conditions. As the UN Charter Article (51)[5], mandates that,

"Nothing in the present Charter shall impair the inherent right of individual or collective self-defense if an armed attack occurs against a Member of the United Nations, until the Security Council has taken measures necessary to maintain international peace and security. Measures taken by Members in the exercise of the right of self-defense shall be immediately reported to the Security Council and shall not in any way affect the authority and responsibility of the Security Council under the Charter to take at any time such action it deems necessary in order to maintain or restore international peace and security".

"The ICJ (International Court of Justice) has only recognized two forms of armed attacks as triggering a right to use defensive force, namely "action by regular armed forces across an international border" and "the sending by or on behalf of a State of armed bands, groups, irregulars or mercenaries, which carry out acts of armed force against another State ... 'or its substantial involvement therein.'

However Leading scholars have concluded that "where a State is not responsible for terrorist attacks, Article 51 may not be invoked to justify measures in self-defense" taken on the territory of the host State".[6] However when attacking Pakistani territories, America has never been able to prove Pakistan's involvement in terrorism activities as a State. It is important to realize that self-defense is a term of art in international law. "The reference in Article 51 to self-defense is to the right of the victim State to use significant offensive military force on the territory of a State legally responsible for the attack. The ICJ has made clear that the armed attack that gives rise to this right of self-defense must be an attack that involves a significant amount of force-it must be more than a mere frontier incident, such as sporadic rocket fire across a border".[7] However Pakistan as a state has never been involved in an attack against United States.

United States claims that terrorist groups of AL-Qaeda remain active along the borders of Afghanistan and Pakistan. However, "Even where militant groups remain active along a border for a considerable period of time, their armed cross-border incursions are not considered attacks under Article 51 giving rise to the right of self-defense unless the State where the group is present is responsible for their actions. In the case of Congo v. Uganda, Uganda sent troops into Congo after years of cross-border incursions by armed groups from Congo into Uganda. Congo, however, was not responsible for the armed groups--it did not control them. Congo's failure to take action against them did not give rise to any right by Uganda to cross into Congo to attack the groups themselves: During the period under consideration both anti-Ugandan and anti-Zairean rebel groups operated in this [border] area. Neither Zaire nor Uganda was in a position to put an end to their activities. However, in the light of the evidence before it, the Court (International court of justice) cannot conclude that the absence of action by Zaire's Government against the rebel groups in the border area is tantamount to--tolerating or-acquiescing in their activities. Thus, the part of Uganda's first counter-claim alleging Congolese responsibility for tolerating the rebel groups prior to May, 1997 cannot be upheld" (16, O'Conne11).[8]

Since United States has been unable to prove substantial involvement of Pakistan as a state in terrorism activities or any armed attack against United States its political integrity cannot be harmed under Article (51). As, "The ICJ ruled in the Nicaragua case in 1986,83 the Congo case in 2005, and Bosnia v. Serbia in 2007 that St state must be in control of a non-state actor group for the state to bear legal responsibility and be the legitimate target of the use of force in self-defense following a significant armed attack. Pakistan has not attacked the United States. The only attack on the United States that could give rise to the right of self-defense since the drafting of the UN Charter had occurred on 9/11. The Security Council stated in Resolution 1368 that those attacks gave rise to the right, but it did not determine who was responsible for the attacks or whether a response in self defense would meet the principles of necessity and proportionality. Pakistan is in no respect responsible for the 9/11 attacks. The United States has no basis, therefore, for attacking in self- defense on Pakistani territory".[9]

Therefore if the State is not involved in or allow an armed attack against another State it cannot be targeted under Article (51) and self-defense doctrine. As in the international court of justice ruling in the case of Israel v. Uganda, when "On July 3-4, 1976, approximately 100 members of the Israeli Defense Forces (IDF) entered Entebbe Airport in Uganda to free 80 Israeli nationals and 25 French Jews held hostage by German and Palestinian hijackers of Air France Flight 139 and their Ugandan supporters. Forty-five Ugandan soldiers, seven hijackers, three hostages, and one IDF officer were killed in the raid. France strongly defended the raid as having "the purpose and the effect of freeing certain Israeli citizens who, together with French citizens, were being subject to the most detestable blackmail [and] . . . threatened with immediate death." The United States, United Kingdom, and Sweden also supported the raid, arguing that it involved only a limited infringement of Uganda's territorial integrity, did not undermine the general prohibition on the use of force, and was limited and proportionate to the purpose of protecting Israeli nationals. But the Soviet Union, China, and a majority of the non­permanent members of the Security Council concluded that the raid was an illegal use of force because Israel was not directly attacked. Indeed, according to the ICJ's reasoning, it seems that the hijacking of a plane and the kidnapping of over 100 people did not constitute an armed attack triggering Israel's legal right of self-defense, and therefore the rescue mission constituted an illegal use of force".[10] Therefore it can be concluded from these rulings that United States attacks on Pakistani territories are illegal as Pakistan itself as a State is not involved in the armed attacks. Furthermore, "When in 2009, Pakistan resorted to major military force; the U.S. needed the express consent of Pakistan to carry out attacks. Pakistan has not expressly invited the United States to assist it in using force. At best there have been mixed signals from Pakistan about officials attitude toward the U.S strikes. Mixed signals do not support a legal claim to the right to kill".[11]

Furthermore it is difficult for United States to justify its claims of self defense as United States in actual is acting under anticipatory self defense. And International law fails to provide any law legalizing an 111 armed attack in a case of anticipatory self defense. Chapter VII also provides in Article 51 that States may respond in self-defense --if an armed attack occurs. However in United States case there has been no armed attack by Pakistan. "The exercise of self-defense can take place only, in the words of Article 51, if an armed attack occurs. Absent an armed attack, a State has no right of self-defense. A State can meet preparations for attack only by preparations to resist. Under the Charter, writes Elilip C. Jessup, former judge of the International Court of Justice (ICJ), alarming military preparations by a neighboring State would justify a resort to the Security Council, but would not justify resort to anticipatory force by the State which believed itself threatened. Self-defense provides protection against illegal use of force and nothing more".[12]

Apart from that, "As stated by Justice. Horace Gray in Paquette Habana, international law is part of our law. The US Constitution, Article I, section 8, clause 10 and Article III, section 2, recognizes that the United States is subject to international law and Congress has the power to define offenses under the law of nations. From the very beginning of our federal republic, US courts have treated customary international law as an integral part of the law of the United States. As Prof Louis Henkin, Columbia University, states, international law is not merely law binding on the United States internationally but it is also incorporated into United States law. Violation of international law becomes a breach of US law that can have a significant impact on us as a nation and as individuals" (Erickson). Furthermore, "American Journal of International Law 41(1947): 878. Sorensen (p. 778) argues that there is no right to the first or anticipatory strike" (Erikson). Therefore if international law is part of US law as well United States illegal use of force through drone attacks would be prohibited by International law as well US Law.

Apart from that by attacking Pakistani territories United States is defying UN charter Article 2(4) which mandates,

"All Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any State, or in any other manner inconsistent with the Purposes of the United Nations".

Thus provisions of this Charter render armed attack against another State illegal and as established earlier that United States self defense doctrine while attacking Pakistani Territories is not justified. United States use of force not only harms the territorial integrity but the political independence of Pakistan as well. United States claims of attacking Armed terrorist groups in Northern Waziristan in Pakistan renders when a large number of non-terrorist civilians are killed in drone attacks. As, "Between 2006 and late 2009, about 20 suspected militant leaders have reportedly been killed in Pakistan during strikes that killed between 750 and 1000 other persons" (O'Connell). Furthermore, "The most important rule respecting the conduct of armed conflict may well be the rule of distinction. Under international law, civilians may not be intentionally targeted. Only members of a State's armed forces during armed conflict or persons taking a direct part the in hostilities of an armed conflict may be targeted. In the ICRC study of customary international humanitarian law, distinction is the first rule:

Rule 1: The parties to the conflict must at all times distinguish between civilians and combatants. Attacks may only be directed against combatants. Attacks must not be directed against civilians.

This rule is supported by a number of legal authorities, including, perhaps most importantly, Additional Protocol I of 1977 to the 1949 Geneva Conventions: Article 43(2) Members of the armed forces of a Party to a conflict (other than medical personnel and chaplains covered by Article 33 of the Third Convention) are combatants, that is to say, they have the right to participate directly in hostilities Article 51(3) Civilians shall enjoy the protection afforded by this section, unless and for such time as they take a direct part in hostilities. Persons with a right to take direct part in hostilities are lawful combatants; those without a right to do so are unlawful combatants. Having the right to participate in hostilities means that the person may/will not be charged with a crime for using force. CIA operatives, like the militants challenging authority in Pakistan, have no right to participate in hostilities and are unlawful combatants" (O' Connell).

As mentioned by Mary O'Connell, "Australian counter-terrorism expert David Kilcullen wrote in The New York Times in March 2009, however, that drones are anything but--precise and the numbers of civilian casualties have not been--limited. He said the U.S. was killing 50 unintended targets for each intended target" (O'Connell). So therefore United States is not only defying International laws of safeguard of political and territorial integrity of another State but the humanitarian laws as well.

In conclusion, the U.S. has used drones in Pakistan to launch major military attacks, attacks only lawful in the course of an armed conflict. The U.S. has not, however, limited its attacks to situations of armed conflict. Moreover, Pakistan has neither requested U.S. assistance in the form of drone attacks nor expressly consented to them. Pakistan's weak civilian authorities have protested on occasion, as much as they dare, presumably. There is no Security Council approval of for drone attacks not does the U.S. have a basis in the law of self defense for attacking inside Pakistan and United States. United States also has a vulnerable stance as it is unable to justify its actions humanitarian law restricting one State to attack another and inflict harm upon its civilians.


[1] LL.B., M.A. Economics (Pb.), LL.M. (Toronto), Advocate High Court, Adjunct Faculty, LUMS CEDR Accredited Mediator, Partner, Saleem and Shiraz, Advocates and Legal Counsel.
[2] Ayesha Tahir is currently a student of BSC Hons. At  LUMS.
[3] Robinson, Paul H., and Adil Ahmad Haque, "Advantaging Aggressors: Justice and Deferrence in International Law." Advantaging Aggressors 3 (2011): n. pag. Harvardnsj org. Harvard College < http://hary ardns .org/wp-content/  uploads/2012/01/Vol.3. Robinson-Haquel.pdf..
[4] Goodman, Ryan, "Humanitarian Intervention and Pretexts for War." THE AMERICAN JOURNAL OF INTERNATIONAL LAW 106 (2006): n.PAG.www.law. Harvard.edu. Harvard College<<http://www.law.Harvard.edu/faculty/rgoodman/pdfs/>RgoodmanHumanitaranInterventionPretextsfor War.pdf >.
[5] "Charter, United Natons, Chapter VII: Action with Respect to Threats to the Peace, Breaches of the Peace and Acts of Aggression." UN News Centre.UN,n.d.<http://www.un.org/ en/documents/charter/chapter7.shtml >.
[6] (Robinson and Haque) supra.
[7] O'Connell, Mary Ellen."Unlawful Killing with Combat Drones A Case study of Pakistan, 2004-2009." Legal Studies ResearchPaperNo.0943(n.d):n.pag.Webspace.untexas.edu.Web.2Mar.2013<https://webspace.utexas,eduirmc2289/LT/Mary%20Ellen%200Connell%20on%20Drones.sdf >.
[8] O'Connell supra.
[9] O'Connell supra.
[10] (Robinson and Hague) supra.
[11] O,Connell supra.
[12] Erickson, Richard J. "Legitimate use of Military Force against State-sponsored International Terrorism."State Sponsored Terrorism (1989): n.pag.www.au.af.mil. The Air University, Nov.2001. http:///www.au.af.mil/au/awc/awegate/au/erickson.pdf> .

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