THE LEGAL FRAMEWORK FOR THE PROTECTION OF HUMAN

RIGHTS IN ARMED CONFLICTS.

BLJ5.5 INTERNATIONAL LAWAND

INSTITUTIONS

SUBMITTED BY:
SHREE PAWAR
UID: UGJ21-47

B.A LL. B (HONOURS IN ADJUDICATION AND JUSTICING)

SEMESTER- V
ACADEMIC SESSION: 2022-2023

SUBMITTED TO:
DR. SHILPA JAIN
(ASSOCIATE PROFESSOR OF LAW)

MAHARASHTRA NATIONAL LAW UNIVERSITY NAGPUR

“NEVER THINK THAT WAR, NO MATTER HOW NECESSARY, NOR HOW
JUSTIFIED, IS NOT A CRIME.”

INTRODUCTION

Most of the times during Armed conflicts the human rights get infringed at large. Armed
conflicts and wars are not new to humans, human right is being violated since centuries.
From Napoleonic wars, World wars, Anglo Maratha wars, war of Russia and Ukraine and
many more are examples where humans at large were killed, and human rights was violated.
After World War I efforts were made to control the wars and conflicts, league of nations and
Geneva convention was formed, it was an effort to control the war and conflicts but was not
that effective to control the World War II.

To stop all the wars and maintain the peace and security, 50 representatives from states
around the world came together and formed the United Nations. United Nations is since then
(1945) has been a successful organisation, although there were disputes and conflicts between
the countries but to a large extent it is controlled.

The three international laws which focuses on War, conflicts, victims or wars, in today's era
are International Human rights law, humanitarian law and refugee law. These international
laws are made with a goal to protect the human dignity wherever there is a violation of basic
human rights.

Does UN have the power to deal with international and non-international armed conflicts
which results in humanitarian issues? Article 1 of the UN charter mentions about maintaining
peace and security. Also, the article 55 mentions that UN should encourage “to promote and
encourage respect for human rights and for fundamental freedoms for all.” In my view
“human rights and for fundamental freedoms for all” includes protection of human rights in
armed conflicts and implementing international humanitarian law.1

1
The United Nations and International Humanitarian Law: The International Committee of the Red Cross and
the United Nations’ involvement in the implementation of international humanitarian law - ICRC. (n.d.). The
United Nations and International Humanitarian Law: The International Committee of the Red Cross and the
United Nations’ Involvement in the Implementation of International Humanitarian Law - ICRC.
https://www.icrc.org/en/doc/resources/documents/misc/57jmuk.htm
INTERNATIONAL HUMAN RIGHTS LAW AND INTERNATIONAL
HUMANITARIAN LAW

The international human rights law is comparatively new concept than the humanitarian laws.
Phases of development of Humanitarian laws are Geneva (1864), Brussels (1874), The Hague
(1899, 1907) and Geneva (1949 and 1977). Human rights law was formed after the formation
of Universal declaration of human rights on December 1948.

HUMAN RIGHTS LAW

International human rights law is a system of international norms designed to protect and
promote the human rights of all persons. These rights, belong to every human being,
regardless of their differences such as race, class, sex, etc. In the form of treaties, general
principles, and customary international law, they are frequently articulated and protected by
the law. The foundation of human rights law is UN charter and Universal Declaration of
Human Rights, these documents lay down an obligation for state to protect Individuals from
violation of human rights2. Human rights include both rights and duties. International human
rights law outlines States' duties to take certain actions or refrain from taking specific actions
to advance and defend the basic freedoms and rights of individuals or groups. It is defined as
a inherit right of every human being and should not be violated under any circumstance.
individuals have certain rights and protections even during hostilities.

The international community over the years has developed a comprehensive framework of
legally binding human rights treaties. Examples include the International Covenant on Civil
and Political Rights (ICCPR), the International Covenant on Economic, Social, and Cultural
Rights (ICESCR), the Convention on the Rights of the Child (CRC), and the Convention
Against Torture (CAT), (CEDAW) among others. Each treaty addresses specific areas of
rights and responsibilities for states parties. International Human rights bodies continuously
monitors the human rights violation. UNHRC is also one of the major organisations which
addresses the concerns and spread awareness globally. India with many countries have
ratified these legal frameworks of human rights, for example CEDAW3, India has
implemented the guidelines of CEDAW in POSH act of 2013 and has recognised many rights
mentioned in the CEDAW.
2
https://www.un.org/en/about-us/udhr/foundation-of-international-human-rights-law
3
https://nhrc.nic.in/sites/default/files/Women%E2%80%99s%20Rights%20in%20India
%20complete_compressed.pdf (Visited on 01. August 2023).
There are some human rights which are non-derivable, meaning that they cannot be
suspended even in times of emergency, including armed conflicts. These rights include the
right to life, freedom from torture, and the right to be free from slavery or servitude.4 Many
countries including India has adopted this principle of non-derivability, In India right to life
under article 21 cannot be taken away even in case of emergency. Also, the principle of Due
Diligence Obligations states that the States have a duty to prevent and investigate human
rights violations committed by their own forces or by non-state actors within their
jurisdiction. This includes holding perpetrators accountable for their actions.

HUMANITARIAN LAW

international humanitarian law (IHL) also known as the law of armed conflict, is a body of
international law that regulates the conduct of armed conflicts and seeks to mitigate the
impact of warfare on civilians and combatants. Humanitarian law seeks to strike a balance
between military necessity and humanitarian considerations, with the aim of minimizing the
suffering and preserving the dignity of individuals affected by armed conflicts. Humanitarian
law is designed to provide humanitarian protections to those affected by armed conflicts,
regardless of their nationality, and it applies to both international and non-international armed
conflicts. The aim is to protect those who are no longer participating in the hostility.

The international series on treaties of Geneva convention has formed a base of humanitarian
law. It was first established in 1864 and is developing over the years. Two additional
protocols were adopted in 1977 to supplement the Geneva Conventions. International law of
humanitarian is part of “ius in bello” which means the law of how force may be used
(regulates the conduct of parties engaged in armed conflicts). Using force is prohibited under
the UN charter, whether their action of using forces is justified or not is not relevant the
humanitarian law is to be applied then also.

In contrast to international human rights law, international humanitarian law does not
establish universal rights that are universally applicable to all individuals at all times. Instead,
the specificity of the four Geneva Conventions lies in their application to different categories
of protected persons, setting out the minimum standard of treatment required for each
category.5 Consequently, the applicable law varies depending on the type of armed conflict
4
Article 6(1) of the 1966 International Covenant on Civil and Political Rights
5
Fleck, Dieter, ed. The Handbook of International Humanitarian Law. 2nd ed. New York: Oxford University
Press, 2008.
(international or internal), the situation of occupied territories or besieged areas, and the
specific group of individuals involved (such as wounded or sick, civilians, women, children,
internees, prisoners of war, etc.). The differentiation in applicable law ensures that the
protection and treatment provided correspond to the particular circumstances and
characteristics of each group.

RELATION BETWEEN INTERNATIONAL HUMAN RIGHTS AND

INTERNATIONAL HUMANITARIAN LAW.

Introduction

For years It was construed that the international Human rights law will be applied in peace
and international humanitarian law will be applied at times when there is an armed conflict
situation, but the modern international law does not recognise this difference. The human
rights law is recognised as a inherit right of all human beings and therefore this law continues
to apply in the situation of war and peace. Rights of humans cannot be silent when human
needs them the most. Also, nothing in the human rights accord implies that they will be
inapplicable in the war situation.6 Thus, these two bodies of law are obligatory in an armed
conflict situation.7

Differences In Humanitarian Law And Human Rights Law

International humanitarian law (IHL) has a wider scope than international human rights law
in certain aspects. Unlike international human rights law, which primarily focuses on the
protection of individuals, IHL extends its coverage to encompass various entities and objects.
This includes not only persons but also livestock, civilian objects, cultural property, the
environment, and other elements affected by armed conflicts.

States have a legal obligation to adhere to and uphold both international humanitarian law
(IHL) and international human rights law. To comply with IHL, a state must enact domestic
legislation to implement its obligations, train its military personnel accordingly, and

6
See general comments Nos. 29 (2001) on states of emergency (art. 4), para. 3, and 31 (2004) on the nature of
the general legal obligation imposed on States Parties to the Covenant, para. 11.
7
K. (n.d.). Counter-Terrorism Module 6 Key Issues: Relationship between IHL & intern. human rights law.
Counter-Terrorism Module 6 Key Issues: Relationship Between IHL & Intern. Human Rights Law.
https:////www.unodc.org
prosecute those who commit serious violations of such law. Similarly, international human
rights law also requires a state to adopt appropriate measures, including legislative actions, to
enforce its rules and punish any breaches.8 IHL draws its foundation from various treaties,
such as the Geneva and Hague Conventions, Additional Protocols, and agreements
addressing specific methods and means of warfare, like bans on blinding laser weapons,
landmines, chemical, and biological weapons. Additionally, customary international law
plays a significant role in IHL.

On the other hand, international human rights law is more intricate and encompasses regional
treaties in addition to global instruments. The primary global legal instrument in this area is
the Universal Declaration of Human Rights, which the UN General Assembly adopted in
1948. Other global treaties include the International Covenant on Civil and Political Rights,
the International Covenant on Economic, Social and Cultural Rights, as well as conventions
addressing torture and other cruel or inhuman treatment, racial discrimination, discrimination
against women, and the rights of the child.

In an armed conflict situation international human rights law acts as a complimentary to

international humanitarian law.

Similarities Between International Humanitarian Law And Human Rights Law

There are numerous similarities between international human rights law (IHRL) and
international humanitarian law (IHL), with the most significant being their shared
commitment to upholding human life and dignity. Both IHRL and IHL are guided by the
principle of humanity, which aims to protect vulnerable individuals, ensuring their well-being
and rights. For example, IHL safeguards wounded, sick, and unarmed individuals, civilians,
and prisoners of war, while IHRL provides protection for children, women, people with
disabilities, and other vulnerable groups.

Additionally, both IHRL and IHL emphasize the importance of providing adequate care to
individuals. IHRL addresses the right to food and healthcare, as stated in Article 25 of the
Universal Declaration of Human Rights, while the International Committee of the Red Cross
is responsible for humanitarian efforts in times of conflict. Both bodies of law establish
similar obligations for state responsibility and individual criminal responsibility for heinous
acts such as war crimes, genocide, and crimes against humanity. These shared principles and

8
A. Alexander. “A short history of International Humanitarian Law”. European Journal of International Law,
Vol.26, 2015, pp.109-138.
obligations reflect the mutual aim of both IHRL and IHL to promote respect for human
rights, preserve human dignity, and protect individuals in various situations, including armed
conflicts.9

GENEVA CONVENTION

The Geneva Conventions are a set of four international treaties that form the core of
International Humanitarian Law (IHL). They provide comprehensive protections for
individuals who are not or are no longer participating in hostilities during armed conflicts.
The primary objective of the Geneva Conventions is to ensure that the principles of humanity
are upheld, even during armed conflicts. The conventions specifically focus on the protection
of human rights and dignity during times of war.

KEY ASPECTS OF THE GENEVA CONVENTIONS IN PROTECTING HUMAN

RIGHTS IN ARMED CONFLICTS:

Protection of Wounded and Sick Soldiers (First Geneva Convention):

The First Geneva Convention, adopted in 1864, focuses on the protection of wounded and
sick soldiers on the battlefield. It obligates parties to the conflict to provide medical care and
treatment for wounded and sick combatants, irrespective of their nationality. Medical
personnel, including doctors and nurses, are protected under the First Geneva Convention and
are allowed to provide care without fear of attack. Details of wounded, sick and dead person
should be recorded and if they are found on the other side then they should be transmitted to
the side which they belong to with care and caution.

The wounded and sick soldiers shall be protected and respected in all circumstances. They
should be treated humanely with no discrimination and violence or torture on them is strictly
prohibited under this convention.

Protection of Shipwrecked and Medical Personnel at Sea (Second Geneva Convention):

The Second Geneva Convention, adopted in 1906, extends protections to shipwrecked

soldiers at sea and to medical personnel aboard military vessels. It outlines the obligations of
parties to render assistance to those in distress at sea. This convention also states that the
ambulance or the hospital ships shall in no situation be attacked but should be respected and
9
Elena Temelkovska, The Human Rights Law and the International Humanitarian Law –Origins, Similarities,
Differences and Interactions, International Journal of Sciences: Basic and Applied Research (IJSBAR)
protected. Medical personnel are to be allowed to carry out their duties without interference
and are protected from attack. It extends protections to members of the armed forces who fall
into the specified categories, as well as to the medical personnel who care for them.

Treatment of Prisoners of War (Third Geneva Convention):

The Third Geneva Convention, adopted in 1929 and updated in 1949, provides
comprehensive protections for prisoners of war (POWs). It sets out guidelines for their
humane treatment, ensuring that they are treated with dignity and respect. Article 25 and 23
mentions that POWs must be provided with adequate food, shelter, and medical care. They
are protected from torture, cruel treatment, and degrading punishment (article 17). This
convention defines POWs as members of the armed forces of a party to the conflict who have
fallen into the hands of the enemy, as well as members of militias and volunteer corps
forming part of such armed forces. Article 13 section 1 provides for the humane treatment for
POWs. Article 118 section 2 states that the wounded and sick persons should be immediately
repatriated.

Protection of Civilians (Fourth Geneva Convention):

The Fourth Geneva Convention, adopted in 1949, focuses on the protection of civilians
during armed conflicts, whether international or non-international.

It prohibits acts of violence against civilians, including murder, torture, and rape. It also
forbids collective punishment, hostage-taking, and deportations.

The Fourth Geneva Convention emphasizes the need for parties to distinguish between
civilian populations and military targets, ensuring that civilians are not subjected to
unnecessary harm.

Additional Protocols to the Geneva Conventions:

In addition to the original four conventions, there are Additional Protocols that further
strengthen the protection of human rights in armed conflicts:

Protocol I (Additional to the Geneva Conventions of 1977): Protocol I applies to

international armed conflicts, which are conflicts between two or more states. It seeks to
enhance the protection of victims in such conflicts. It complements and supplements the
protections provided by the First, Second, and Third Geneva Conventions. It prohibits acts of
violence against civilians, including murder, torture, and rape. It also emphasizes the
principle of distinction between civilian populations and military targets, ensuring that
civilians are not subjected to unnecessary harm.

Article 51 - Protection of Civilians and Civilian Objects:

Section 4: This section emphasizes the principle of distinction, stating that “Indiscriminate
attacks are prohibited.” It prohibits attacks that are not directed at a specific military objective
or those that may cause incidental harm to civilians or civilian objects that is excessive
compared to the anticipated military advantage.

Section 5: This section outlines the general protection of civilians, stating that “Civilians and
civilian objects shall not be the object of attack.” It also prohibits acts of violence or threats
of violence intended to spread terror among the civilian population.

Article 52 - General Protection of Cultural Objects and Places of Worship:

Section 3: This section emphasizes the protection of cultural objects and places of worship. It
prohibits any act of hostility directed against such objects, which are of great importance for
the cultural heritage of peoples.

Article 79 - Protection of Journalists:

Section 1: Recognising the protection of journalists and media personnel who are covering
armed conflicts. It states that “Journalists engaged in dangerous professional missions in
areas of armed conflict shall be considered as civilians.”

Protocol II (Additional to the Geneva Conventions of 1977): This protocol applies to non-
international armed conflicts, which are conflicts occurring within the territory of a single
state. These conflicts involve government forces and non-state armed groups or between such
armed groups.

Article 4 - Fundamental Guarantees:

Section 2: This section outlines the fundamental guarantees for persons who do not take a
direct part in hostilities. It prohibits violence to life and person, in particular, murder,
mutilation, cruel treatment, and torture.

Article 13 - Protection of the Civilian Population:

Section 1: This section emphasizes the general protection of civilians affected by non-
international armed conflicts. It states that "The civilian population and individual civilians
shall enjoy general protection against the dangers arising from military operations."

Article 16 - Protection of Persons Not Taking Part in Hostilities:

Section 1: This section obliges parties to the conflict to treat humanely all persons who are
not or are no longer taking part in hostilities. It prohibits violence to life and person, in
particular, murder, cruel treatment, and torture.

Article 18 - Civilian Hospitals:

Section 3: This section outlines the protection of civilian hospitals during non-international
armed conflicts. It states that civilian hospitals may not be the object of attack or subjected to
any act of violence.

Implementation Of the Convention:

The Geneva Conventions are universally ratified, meaning that they apply to all states,
whether they are parties to a specific conflict or not. Violations of the conventions are
considered war crimes under international law and can be prosecuted by international
criminal tribunals, such as the International Criminal Court (ICC). This Conventions have
played a crucial role in promoting the principles of humanity, respect for human rights, and
the protection of vulnerable individuals during armed conflicts. They are an essential part of
the international legal framework aimed at mitigating the impact of war on civilians and
upholding human rights, even in times of strife.

INTERNATIONAL CRIMINAL COURT

It is a crime to violate the international human rights law and humanitarian law under
international criminal law. The International Criminal Court (ICC) plays a crucial role in
addressing serious violations of humanitarian laws and international human rights law that
occur during armed conflicts. The ICC is a permanent international court established in 2002
by the Rome Statute to prosecute individuals for the most serious crimes of international
concern, including genocide, war crimes, crimes against humanity, and the crime of
aggression.
The ICC has jurisdiction over war crimes committed during both international and non-
international armed conflicts. War crimes include serious violations of international
humanitarian law, such as deliberate attacks on civilians, torture, inhumane treatment, and
unlawful killings of combatants or civilians. ICC can prosecute individuals, including
military and political leaders, who bear the greatest responsibility for war crimes committed
during armed conflicts. It aims to hold perpetrators accountable and provide justice to
victims. It operates on the principle of complementarity, which means that it can only
intervene if a country is unwilling or unable to genuinely investigate and prosecute war
crimes within its own legal system. This principle encourages states to take responsibility for
prosecuting such crimes domestically. The ICC also has jurisdiction over crimes against
humanity, which include widespread or systematic attacks against civilian populations during
armed conflicts. These crimes can be prosecuted regardless of whether the conflict is
international or non-international. It's important to note that the ICC's jurisdiction is not
retroactive, meaning it can only prosecute crimes committed after the entry into force of the
Rome Statute on July 1, 2002. Additionally, the ICC can only prosecute individuals from
states that are parties to the Rome Statute or cases that are referred to the Court by the United
Nations Security Council.

https://www.un.org/en/global-issues/international-law-and-justice

https://www.un.org/en/our-work/uphold-international-law

THE CASE OF ITURI CONFLICT

Ituri conflict is the best example of involvement of International Criminal Court in armed
conflicts, where ICC acted against the leader of Union of Congolese Patriots (UPS), Thomas
Dyilo. This was the first successful prosecution made by the ICC and therefore the most
celebrated decision.

Ituri Conflict

The Ituri conflict was a part of the larger Second Congo War (1998-2003) that engulfed the
DRC. Ituri, a resource-rich region in the northeastern part of the country, witnessed intense
fighting among various ethnic militias and rebel groups vying for control over the area's
valuable resources.

Thomas Lubanga Dyilo was the leader of the UPC, one of the armed groups operating in
Ituri. He was prosecuted under articles 8(2)(e)(vii)10 and 25(3)(a)11 of the Rome statute and
accused of conscripting and enlisting child soldiers under the age of 15 to fight as soldiers in
the ranks of his militia. This use of child soldiers in armed conflict is considered a war crime
under the Rome Statute, the treaty that established the ICC. Also, the Article 77(2) of The
Geneva convention protocol I states:

“The Parties to the conflict shall take all feasible measures in order that children who have
not attained the age of fifteen years do not take a direct part in hostilities”12

In 2004, the ICC's Office of the Prosecutor initiated an investigation into the situation in the
DRC, including crimes committed in Ituri. Thomas Lubanga was one of the first individuals
to be charged by the ICC, and he became the first person to stand trial at the ICC in 2009.
The prosecutors submitted that “The crimes occurred in the context of an armed conflict not
of an international character.” The chamber held that the accused was found guilty beyond
reasonable doubt, Lubanga was charged with three counts of war crimes conscripting and
enlisting children under the age of 15 years into armed forces, using them to actively
participate in hostile activities, and committing war crimes of recruiting and conscripting
minors of age under15 years into an armed group. In March 2012, The International Criminal
Court (ICC) convicted Thomas Lubanga guilty of the war crimes allegations levelled against
him. He was sentenced to 14 years in jail in July 2012. Lubanga's sentence considered the
amount of time he had previously spent in custody since his arrest in 2006.13

The Lubanga case was a historic moment for the ICC, since it was the first successful
prosecution and conviction of a war criminal since the Court's formation in 2002. The case
raised public attention to the issue of child soldiers and highlighted the International Criminal
Court's role in holding people accountable for serious breaches of international law in armed
conflicts.

With this significantly important case of Lubanga the importance of ICC was highlighted in
pursuing justice and establishing responsibility for severe crimes committed during armed

10
Article 8 (2)(e)(vii) of the Rome Statute of the International Criminal Court
11
Article 25(3)(a) of the Rome statute of the International Criminal Court
12
Article 77(2) of The Geneva convention protocol I
13
The Prosecutor v. Thomas Lubanga Dyilo ICC-01/04-01/06
situations. It emphasised the significance of dealing with crimes against children in war
circumstances, as well as the role of international law in safeguarding vulnerable people. The
case cemented the ICC's position as a critical organisation for combating impunity and
enforcing international criminal law principles.14

STATE RESPONSIBILITY FOR VIOLATIONS OF INTERNATIONAL HUMAN

RIGHTS LAW AND INTERNATIONAL HUMANITARIAN LAW

State responsibility for breaches of international human rights and humanitarian law has been
a fundamental principle in international law for a considerable time. This responsibility is
rooted in the principle of Pacta Sunt Servanda, which signifies that all valid treaties are
binding upon the parties, and they must be faithfully executed.15 Furthermore, the
International Law Commission's draft articles on State responsibility emphasize the general
principle that any breach of a State's international obligations constitutes an international
wrongful act, leading to the State's responsibility.

It is essential to bear in mind that a State is held accountable for violations of international
human rights and humanitarian law during armed conflicts if the violations can be attributed
to the State. Such violations include actions committed by its government organs, including
its armed forces, or by individuals or entities empowered to exercise elements of
governmental authority. Additionally, the State can be held responsible for violations
committed by individuals or groups acting under its direction, control, or instructions or those
violations that the State acknowledges and adopts as its own conduct.16

Moreover, a state can be held responsible for a lack of due diligence if it fails to prevent or
punish violations of international human rights and humanitarian law committed by private
actors. In this regard, a state's failure to take appropriate action in response to such violations
can result in international responsibility.

Both international and regional jurisprudence have established that when a state is found
responsible for violations of international human rights and humanitarian law, it is obligated
to take certain measures to address the damage caused and prevent future violations. These

14
Michael E. Kurth, The Lubanga Case of the International Criminal Court: A Critical Analysis of the Trial
Chamber’s Findings on Issues of Active Use, Age, and Gravity, Goettingen Journal of International Law 5
(2013) 2, 431-453
15
Vienna Convention on the Law of Treaties, art. 26.
16
See Yearbook of the International Law Commission, 2001, vol. II (Part Two), p. 26.
measures can include providing reparations to the victims and their families, giving
assurances of non-repetition, and implementing legal mechanisms to prevent future abuses.
While it is generally accepted that states should be held responsible and pay reparations for
violations of international humanitarian law, there has been disagreement among domestic
courts regarding the entitlement of individual victims to claim such reparations based on
international humanitarian law.

In the case of Bosnia and Herzegovina v. Serbia and Montenegro, the International Court of
Justice (ICC) held that that Serbia had not followed the international obligation to prevent
and prosecute the act of genocide. The Court decided that Serbia had to “take effective steps
to ensure full compliance with its obligation under the Convention on the Prevention and
Punishment of the Crime of Genocide and to transfer individuals accused of genocide or any
of those other acts for trial by the International Criminal Tribunal for the former Yugoslavia,
and to cooperate fully with that Tribunal”.17

It is important to emphasize that, according to international law, holding an individual

accountable for serious violations of international human rights and humanitarian law does
not absolve the state from its international responsibility. In other words, the actions and
accountability of individuals do not excuse the state from its obligations and liability under
international law.18

International Armed Conflict

Conclusion

Bibliography

Kathryn McNeilly, ‘If Only for a Day’: The Universal Declaration of Human Rights, Anniversary
Commemoration and International Human Rights Law, Human Rights Law Review, Volume 23, Issue 2, June
2023, ngad003, https://doi.org/10.1093/hrlr/ngad003

17
Application of the Convention on the Prevention and Punishment of the Crime of Genocide (Bosnia and
Herzegovina v. Serbia and Montenegro), Judgment, I.C.J. Reports 2007, p. 43.
18
Article 25.4 of Rome Statute of the International Criminal Court
Skwarzyński, Michał & Orzeszyna, Krzysztof & Tabaszewski, Robert. (2023). International Human Rights
Law.