Practice Relating to Rule 6. Civilians’ Loss of Protection from Attack
Section C. Situations of doubt as to the character of a person
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Additional Protocol I
Article 50(1) of the 1977 Additional Protocol I provides: “In case of doubt whether a person is a civilian, that person shall be considered to be a civilian.” 
Protocol Additional to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts (Protocol I), Geneva, 8 June 1977, Article 50(1). Article 50 was adopted by consensus. CDDH, Official Records, Vol. VI, CDDH/SR.41, 26 May 1977, p. 161.

Additional Protocol II (draft)
Article 25(4) of the draft Additional Protocol II, adopted by Committee III of the CDDH, provided: “In case of doubt as to whether a person is a civilian, he or she shall be considered to be a civilian”. 
CDDH, Official Records, Vol. XV, CDDH/215/Rev.1, 3 February–18 April 1975, p. 320.

This draft provision was adopted by consensus by Committee III. 
CDDH, Official Records, Vol. XV, CDDH/215/Rev.1, 3 February–18 April 1975, p. 290, § 121.

Eventually, however, it was deleted in the plenary by consensus. 
CDDH, Official Records, Vol. VII, CDDH/SR.52, 6 June 1977, p. 135.

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Memorandum of Understanding on the Application of IHL between Croatia and the Socialist Federal Republic of Yugoslavia
Paragraph 6 of the 1991 Memorandum of Understanding on the Application of IHL between Croatia and the Socialist Federal Republic of Yugoslavia requires that hostilities be conducted in accordance with Article 50(1) of the 1977 Additional Protocol I. 
Memorandum of Understanding on the Application of International Humanitarian Law between Croatia and the Socialist Federal Republic of Yugoslavia, Geneva, 27 November 1991, § 6.

Agreement on the Application of IHL between the Parties to the Conflict in Bosnia and Herzegovina
Paragraph 2.5 of the 1992 Agreement on the Application of IHL between the Parties to the Conflict in Bosnia and Herzegovina requires that hostilities be conducted in accordance with Article 50(1) of the 1977 Additional Protocol I. 
Agreement between Representatives of Mr. Alija Izetbegović (President of the Republic of Bosnia and Herzegovina and President of the Party of Democratic Action), Representatives of Mr. Radovan Karadžić (President of the Serbian Democratic Party), and Representative of Mr. Miljenko Brkić (President of the Croatian Democratic Community), Geneva, 22 May 1992, § 2.5.

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Argentina
Argentina’s Law of War Manual (1989) states: “In case of doubt about the qualification of a person, that person must be considered to be civilian.” 
Argentina, Leyes de Guerra, PC-08-01, Público, Edición 1989, Estado Mayor Conjunto de las Fuerzas Armadas, aprobado por Resolución No. 489/89 del Ministerio de Defensa, 23 April 1990, § 4.02(1).

Australia
Australia’s Defence Force Manual (1994) states: “In cases of doubt about civilian status, the benefit of the doubt is given to the person concerned.” 
Australia, Manual on Law of Armed Conflict, Australian Defence Force Publication, Operations Series, ADFP 37 – Interim Edition, 1994, § 914.

Australia’s LOAC Manual (2006) states: “In cases of doubt about civilian status, the benefit of the doubt must be given to the person concerned.” 
Australia, The Manual of the Law of Armed Conflict, Australian Defence Doctrine Publication 06.4, Australian Defence Headquarters, 11 May 2006, § 5.33.

The LOAC Manual (2006) replaces both the Defence Force Manual (1994) and the Commanders’ Guide (1994).
Burundi
Burundi’s Regulations on International Humanitarian Law (2007) states: “In case of doubt about the status of a person, that person must be considered to be a civilian.” 
Burundi, Règlement n° 98 sur le droit international humanitaire, Ministère de la Défense Nationale et des Anciens Combattants, Projet “Moralisation” (BDI/B-05), August 2007, Part I bis, p. 82.

Cameroon
Cameroon’s Instructor’s Manual (1992) states: “The benefit of the doubt confers upon a person the status of civilian.” 
Cameroon, Droit international humanitaire et droit de la guerre, Manuel de l’instructeur en vigueur dans les Forces Armées, Présidence de la République, Ministère de la Défense, Etat-major des Armées, Troisième Division, Edition 1992, p. 17.

Cameroon
Cameroon’s Instructor’s Manual (2006) states: “Persons who do not belong to the Armed Forces and do not participate in a ‘levée en masse’ are considered civilians. In situations of doubt, civilian status should be accorded to the person in question.” 
Cameroon, Droit des conflits armés et droit international humanitaire, Manuel de l’instructeur en vigueur dans les forces de défense, Ministère de la Défense, Présidence de la République, Etat-major des Armées, 2006, p. 92, § 352.11; see also p. 134, § 412.11.

Canada
Canada’s LOAC Manual (1999) states: “In case of doubt whether a person is a civilian, that person shall be considered to be a civilian.” 
Canada, The Law of Armed Conflict at the Operational and Tactical Level, Office of the Judge Advocate General, 1999, p. 4–5, § 38.

Canada’s LOAC Manual (2001) states in its chapter on targeting: “In case of doubt whether a person is a civilian, that person shall be considered to be a civilian.” 
Canada, The Law of Armed Conflict at the Operational and Tactical Levels, Office of the Judge Advocate General, 13 August 2001, § 429.

Colombia
Colombia’s Instructors’ Manual (1999) states: “In case of doubt whether a person is civilian or not, that person must be considered to be civilian.” 
Colombia, Derechos Humanos & Derecho Internacional Humanitario – Manual de Instrucción de la Guía de Conducta para el Soldado e Infante de Marina, Ministerio de Defensa Nacional, Oficina de Derechos Humanos, Fuerzas Militares de Colombia, Santafé de Bogotá, 1999, p. 16.

Côte d’Ivoire
Côte d’Ivoire’s Teaching Manual (2007) provides in Book III, Volume 1 (Instruction of first-year trainee officers): “Civilians must not be attacked. A civilian is a person who is not a member of the armed forces. In case of doubt, a person must be treated as a civilian.” 
Côte d’Ivoire, Droit de la guerre, Manuel d’instruction, Livre III, Tome 1: Instruction de l’élève officier d’active de 1ère année, Manuel de l’élève, Ministère de la Défense, Forces Armées Nationales, November 2007, p. 31; see also Droit de la guerre, Manuel d’instruction, Livre III, Tome 2: Instruction de l’élève officier d’active de 2ème année, Manuel de l’instructeur, Ministère de la Défense, Forces Armées Nationales, November 2007, p. 21.

Croatia
Croatia’s LOAC Compendium (1991) states that, in case of doubt, persons have to be considered as civilians. 
Croatia, Compendium “Law of Armed Conflicts”, Republic of Croatia, Ministry of Defence, 1991, p. 6.

Dominican Republic
The Dominican Republic’s Military Manual (1980) states:
All persons participating in military operations or activities are considered combatants [and proper targets for attack]. Those who do not participate in such actions are non-combatants. This distinction is not always easy to make. Uniformed, armed soldiers are easily recognizable. However, guerrillas often mix with the civilians, perform undercover operations, and dress in civilian clothes. Alertness and caution must guide you in deciding who is a combatant. 
Dominican Republic, La Conducta en Combate según las Leyes de la Guerra, Escuela Superior de las FF. AA. “General de Brigada Pablo Duarte”, Secretaría de Estado de las Fuerzas Armadas, May 1980, p. 3.

Hungary
Hungary’s Military Manual (1992) states that, in case of doubt, persons have to be considered as civilians. 
Hungary, A Hadijog, Jegyzet a Katonai, Föiskolák Hallgatói Részére, Magyar Honvédség Szolnoki Repülötiszti Föiskola, 1992, p. 17.

Kenya
Kenya’s LOAC Manual (1997) states: “In case of doubt whether a person is a civilian or not, that person shall be considered a civilian.” 
Kenya, Law of Armed Conflict, Military Basic Course (ORS), 4 Précis, The School of Military Police, 1997, Précis No. 2, p. 10.

Madagascar
Madagascar’s Military Manual (1994) states: “In case of doubt about the status of a person, that person shall be considered to be civilian.” 
Madagascar, Le Droit des Conflits Armés, Ministère des Forces Armées, August 1994, Fiche No. 2-SO, § B.

Netherlands
The Military Manual (1993) of the Netherlands states: “In case of doubt whether a person is civilian, that person is considered to be a civilian.” 
Netherlands, Toepassing Humanitair Oorlogsrecht, Voorschift No. 27-412/1, Koninklijke Landmacht, Ministerie van Defensie, 1993, p. V-2.

The Military Manual (2005) of the Netherlands states: “If there is any doubt whether someone is a civilian, he or she is treated as a civilian.” 
Netherlands, Humanitair Oorlogsrecht: Handleiding, Voorschift No. 27-412, Koninklijke Landmacht, Militair Juridische Dienst, 2005, § 0505.

In its chapter on the protection of the civilian population, the manual states: “If there is any uncertainty whether someone is a genuine civilian, this person is given the benefit of the doubt pending proof to the contrary, and must be treated as a civilian.”  
Netherlands, Humanitair Oorlogsrecht: Handleiding, Voorschift No. 27-412, Koninklijke Landmacht, Militair Juridische Dienst, 2005, § 0805.

Philippines
The Philippine Army Soldier’s Handbook on Human Rights and International Humanitarian Law (2006) notes in its glossary: “Civilian person – means any person who does not belong to the armed forces and does not take part in a ‘levee en masse.’ In case of doubt whether a person is a civilian or not, that person shall be considered as a civilian.” 
Philippines, Philippine Army Soldier’s Handbook on Human Rights and International Humanitarian Law, A Practical Guide for Internal Security Operations, 2006, p. 67, Glossary.

Russian Federation
The Russian Federation’s Regulations on the Application of IHL (2001) states: “In case of doubt whether a person is a civilian, that person shall be considered a civilian.” 
Russian Federation, Regulations on the Application of International Humanitarian Law by the Armed Forces of the Russian Federation, Ministry of Defence of the Russian Federation, Moscow, 8 August 2001, § 1.

South Africa
South Africa’s LOAC Manual (1996) contains a rule identical to that in Article 50(1) of the 1977 Additional Protocol I. 
South Africa, Presentation on the South African Approach to International Humanitarian Law, Appendix A, Chapter 4: International Humanitarian Law (The Law of Armed Conflict), National Defence Force, 1996, § 24(c). This manual is also included in Chapter 4 of the Draft Civic Education Manual of 1997.

South Africa’s Revised Civic Education Manual (2004) states: “In cases of doubt as to whether a person is a civilian or not, that person shall be considered to be a civilian.” 
South Africa, Revised Civic Education Manual, South African National Defence Force, 2004, Chapter 4, § 47(c).

Spain
Spain’s LOAC Manual (1996) contains a rule identical to that in Article 50(1) of the 1977 Additional Protocol I. 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Publicación OR7-004, 2 Tomos, aprobado por el Estado Mayor del Ejército, Division de Operaciones, 18 March 1996, Vol. I, § 4.5.b.(1).

Spain’s LOAC Manual (2007) states: “If there is any doubt about whether a person is a civilian or not, that person must be presumed to be a civilian.” 
Spain, Orientaciones. El Derecho de los Conflictos Armados, Tomo 1, Publicación OR7–004, (Edición Segunda), Mando de Adiestramiento y Doctrina, Dirección de Doctrina, Orgánica y Materiales, 2 November 2007, § 4.5.b.(1).(b).

Sweden
Sweden’s IHL Manual (1991) states: “Where there is doubt whether a person is to be considered as a combatant or as a civilian, the person shall be considered as a civilian.” 
Sweden, International Humanitarian Law in Armed Conflict, with reference to the Swedish Total Defence System, Swedish Ministry of Defence, January 1991, Section 3.2.1.5, p. 42.

United Kingdom of Great Britain and Northern Ireland
The UK LOAC Manual (2004) states: “Civilians are persons who are not members of the armed forces. In cases of doubt, persons are considered to be civilians.” 
United Kingdom, The Manual of the Law of Armed Conflict, Ministry of Defence, 1 July 2004, § 5.3.1.

The manual specifies:
In the practical application of the principle of civilian immunity and the rule of doubt, (a) commanders and others responsible for planning, deciding upon, or executing attacks necessarily have to reach decisions on the basis of their assessment of the information from all sources which is available to them at the relevant time, (b) it is only in cases of substantial doubt after this assessment about the status of the individual in question, that the latter should be given the benefit of the doubt and treated as a civilian, and (c) the rule of doubt does not override the commander’s duty to protect the safety of troops under his command or to preserve the military situation. 
United Kingdom, The Manual of the Law of Armed Conflict, Ministry of Defence, 1 July 2004, § 5.3.4.

United States of America
According to the Report on US Practice, the US military manuals do not adopt the position that in case of doubt a person shall be considered as civilian. 
Report on US Practice, 1997, Chapter 1.1, referring to: Field Manual 27-10, The Law of Land Warfare, US Department of the Army, 18 July 1956, as modified by Change No. 1, 15 July 1976, § 60; Air Force Pamphlet 110-31, International Law – The Conduct of Armed Conflict and Air Operations, US Department of the Air Force, 1976, § 5-3; and The Commander’s Handbook on the Law of Naval Operations, NWP 1-14M/MCWP 5-2.1/COMDTPUB P5800.7, issued by the Department of the Navy, Office of the Chief of Naval Operations and Headquarters, US Marine Corps, and Department of Transportation, US Coast Guard, October 1995 (formerly NWP 9 (Rev. A)/FMFM 1-10, October 1989), § 11.3.

Yugoslavia, Socialist Federal Republic of
The Socialist Federal Republic of Yugoslavia’s Military Manual (1988) states: “In case of doubt a person shall be considered as a civilian until proven otherwise.” 
Yugoslavia, Socialist Federal Republic of, Propisi o Primeri Pravila Medjunarodnog Ratnog Prava u Oruzanim Snagama SFRJ, PrU-2, Savezni Sekretarijat za Narodnu Odbranu (Pravna Uprava), 1988, § 67(3).

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Croatia
On the basis of Croatia’s Constitution (1990) and Defence Law (1993), the Report on the Practice of Croatia states that Article 50 of the 1977 Additional Protocol I is directly applicable in Croatia’s internal legal order. 
Report on the Practice of Croatia, 1998, Answers to additional questions on Chapter 1, referring to Constitution, 1990, Article 134 and Defence Law, 1993, Article 39.

Denmark
Denmark’s Military Criminal Code (1973), as amended in 1978, provides:
Any person who uses war instruments or procedures the application of which violates an international agreement entered into by Denmark or the general rules of international law, shall be liable to the same penalty [i.e. a fine, lenient imprisonment or up to 12 years’ imprisonment]. 
Denmark, Military Criminal Code, 1973, as amended in 1978, § 25(1).

Denmark’s Military Criminal Code (2005) provides:
Any person who deliberately uses war means [“krigsmiddel”] or procedures the application of which violates an international agreement entered into by Denmark or international customary law, shall be liable to the same penalty [i.e. imprisonment up to life imprisonment]. 
Denmark, Military Criminal Code, 2005, § 36(2).

Ireland
Under Ireland’s Geneva Conventions Act (1962), as amended in 1998, any “minor breach” of the 1977 Additional Protocol I, including violations of Article 50(1), is a punishable offence. 
Ireland, Geneva Conventions Act, 1962, as amended in 1998, Section 4(1) and (4).

Norway
Norway’s Military Penal Code (1902), as amended in 1981, provides:
Anyone who contravenes or is accessory to the contravention of provisions relating to the protection of persons or property laid down in … the two additional protocols to [the 1949 Geneva] Conventions … is liable to imprisonment. 
Norway, Military Penal Code, 1902, as amended in 1981, § 108(b).

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Germany
In 2010, in the Fuel Tankers case, the Federal Prosecutor General at Germany’s Federal Court of Justice investigated whether war crimes or other crimes under domestic law had been committed in the course of an airstrike which was ordered by a colonel (Oberst) of the German armed forces against two tankers transporting fuel for the International Security Assistance Force in Afghanistan stolen by the Taliban near Kunduz and which resulted in the deaths of a number of civilians. The Federal Prosecutor General stated:
Pursuant to § 170 para. 2 StPO [Penal Procedure Code], the investigation proceedings which were initiated by the order of 12 March 2010 against Colonel (Oberst) Klein and Company Sergeant Major (Hauptfeldwebel) Wilhelm due to suspected offences under the VStGB [International Crimes Code] and other offences are to be terminated as a result of the investigations conducted and based on the sources of information set out hereafter and on the reasons given in detail hereafter. 
Germany, Federal Court of Justice, Federal Prosecutor General, Fuel Tankers case, Decision, 16 April 2010, p. 1.

The Federal Prosecutor General also stated:
Criminal responsibility under § 211 StGB [i.e. for murder under Germany’s Penal Code]

b)
Colonel (Oberst) Klein’s actions were lawful under international law and therefore justified under domestic criminal law …

cc)
Even considering the fact that the bombing killed civilians to be protected under the international law of armed conflict, the order to attack was lawful under international law.
(1)
… International humanitarian law … prohibits … attacks … against a military objective if at the time of the order to attack the anticipated civilian damage is out of proportion (“excessive” see Art. 51 para. 5 sub-para. b AP [1977 Additional Protocol] I to the anticipated concrete and direct military advantage (see ICRC Customary International Humanitarian Law, 2005 – hereafter ICRC Customary IHL [Study] – p. 46ff). …

(3)
The anticipated civilian collateral damages are also to be assessed from the perspective of the attacker at the time of the attack, rather than with hindsight according to the actual unfolding of events (see also the wording of Art. 51 para. 5 sub-para. b AP I … “may be expected”; ICRC Customary IHL [Study] p. 50 …). … The international law of armed conflict requires that in case of doubt a person is to be considered a civilian (see Art. 50 para. 1 sentence 2 AP I). However, there is no such case of doubt if – as is the case here – there are sufficient indications, considering the concrete circumstances, that the persons concerned are a legitimate objective of a military attack; absolute certainty is not necessary. 
Germany, Federal Court of Justice, Federal Prosecutor General, Fuel Tankers case, Decision, 16 April 2010, pp. 63–66.

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Egypt
On the basis of a proposal submitted by Egypt during the CDDH, the Report on the Practice of Egypt states: “To ensure more protection for civilians, Egypt is of the opinion that in case of doubt as to whether a person is a civilian, he or she shall be deemed to be so.”  
Report on the Practice of Egypt, 1997, Chapter 1.1, referring to Statement by Egypt at the CDDH, Official Records, Vol. IV, CDDH/III/33, 15 March 1974, p. 73.

France
Upon ratification of the 1977 Additional Protocol I, France stated:
The rule set out in the second sentence of the first paragraph of Article 50 [of the 1977 Additional Protocol I] cannot be interpreted as requiring a commander to take a decision which, according to the circumstances and information available to him, might not be compatible with his duty to ensure the safety of the troops under his command or to preserve his military situation, in conformity with other provisions of [the 1977 Additional Protocol I]. 
France, Declarations and reservations made upon ratification of the 1977 Additional Protocol I, 11 April 2001, § 9.

Malaysia
The Report on the Practice of Malaysia refers to the presumption of civilian character, adding that it governed the behaviour of the armed forces during the campaign against the communist insurgency. 
Report on the Practice of Malaysia, 1997, Answers to additional questions on Chapter 1.1.

Nigeria
The Report on the Practice of Nigeria states that a presumption of civilian character is held in case of doubt. It adds that during the Nigerian civil war, “the Federal Forces in situations of such doubt did not off-handedly indict or take away individuals of such doubtful civilian character”. They subjected such individuals to a test, in order to determine
the degree of hardness of … their fingers used in handling the trigger. Those found with hardened fingers were presumed to be soldiers (combatants). Although this is an unscientific method of identification, it nonetheless shows that Nigerian practice does not prima facie attribute the status of combatant to individuals of doubtful civilian character. 
Report on the Practice of Nigeria, 1997, Answers to additional questions on Chapter 1.1.

United Kingdom of Great Britain and Northern Ireland
Upon ratification of the 1977 Additional Protocol I, the United Kingdom expressed its understanding of the presumption of civilian character as only applicable
in cases of substantial doubt still remaining after the assessment [of the information from all sources which is reasonably available to military commanders at the relevant time] has been made, and not as overriding a commander’s duty to protect the safety of troops under his command or to preserve his military situation, in conformity with other provisions of [the 1977 Additional Protocol I]. 
United Kingdom, Declarations and reservations made upon ratification of the 1977 Additional Protocol I, 28 January 1998, § h.

In 2003, during a debate in the House of Commons, the UK Secretary of State for Defence, Mr Hoon, stated in reply to a question by a Member:
Alan Simpson (Nottingham, South): There have been some civilian casualties for which I am sure that even the Secretary of State would accept that there is a clear line of responsibility. They would include the seven women and children who were killed at a checkpoint and the 15 members of a single family who were killed when their lorry was attacked by an Apache helicopter. Will the Secretary of State tell the House whether current UK rules of engagement allow for such attacks on civilians; whether the rules of engagement for UK troops differ from those of US troops; whether he will place in the House of Commons Library the details of the two sets of rules of engagement; and whether he will confirm that, as has happened previously, any UK troops who were involved in instances of unjustified killings of civilians would be likely to face criminal charges?
Mr. Hoon: We do not comment in detail on rules of engagement, and certainly not on those of the United States. I would be a lot more persuaded by my hon. friend’s observations if, at the same time as mentioning the tragic deaths of seven women and children, he had also mentioned the deaths of the four US marines who were killed in a deliberate car bomb attack, perpetrated by a fanatic. In such circumstances, it is perhaps perfectly understandable – although I am not excusing it in any sense at all – that soldiers who are having to deal with a difficult situation at a checkpoint and who know that four of their comrades have been killed in that way are perhaps reacting in a way that we might not want them to. That is not to say that the accounts that have been given, again, by particular journalists are necessarily the only version of events that we should all accept. An investigation is going on into what went on at the checkpoints, and it is important that we await the outcome of that before judging the facts quite so prejudicially. 
United Kingdom, House of Commons, Statement by the Secretary of State for Defence, Hansard, 3 April 2003, Vol. 402, Debates, col. 1085.

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International Criminal Tribunal for the former Yugoslavia
In its judgment in the Galić case in 2003, the ICTY Trial Chamber stated, inter alia:
The presence of individual combatants within the population does not change its civilian character. In order to promote the protection of civilians, combatants are under the obligation to distinguish themselves at all times from the civilian population; the generally accepted practice is that they do so by wearing uniforms, or at least a distinctive sign, and by carrying their weapons openly. In certain situations it may be difficult to ascertain the status of particular persons in the population. The clothing, activity, age, or sex of a person are among the factors which may be considered in deciding whether he or she is a civilian. A person shall be considered to be a civilian for as long as there is a doubt as to his or her real status. The Commentary to Additional Protocol I explains that the presumption of civilian status concerns “persons who have not committed hostile acts, but whose status seems doubtful because of the circumstances. They should be considered to be civilians until further information is available, and should therefore not be attacked”. The Trial Chamber understands that a person shall not be made the object of attack when it is not reasonable to believe, in the circumstances of the person contemplating the attack, including the information available to the latter, that the potential target is a combatant. 
ICTY, Galić case, Judgment, 5 December 2003, § 50.

In the Strugar case before the ICTY in 2003, the accused, a Commander in the Yugoslav People’s Army (JNA), was charged, inter alia, with attacks on civilians as a violation of the laws or customs of war (Article 3 of the 1993 ICTY Statute), for his role in conducting a military campaign against the Dubrovnik region of Croatia. 
ICTY, Strugar case, Third Amended Indictment, 10 December 2003, §§ 14–18, Count 3.

In its judgment in the Dragomir Milošević case in 2007, the ICTY Trial Chamber stated:
The generally accepted practice is that combatants distinguish themselves by wearing uniforms, or, at the least, a distinctive sign, and by carrying their weapons openly. Other factors that may help determine whether a person is a civilian include his or her clothing, activity, age or sex. In cases of doubt whether a person is a civilian, that person shall be considered to be a civilian. As stated in the Commentary on Additional Protocol I, the presumption of civilian status applies to:
“[p]ersons who have not committed hostile acts, but whose status seems doubtful because of the circumstances. They should be considered to be civilians until further information is available, and should therefore not be attacked.” 
ICTY, Dragomir Milošević case, Judgment, 12 December 2007, § 946.

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ICRC
To fulfil its task of disseminating IHL, the ICRC has delegates around the world teaching armed and security forces that: “In case of doubt whether a person is a civilian or not, that person shall be considered as a civilian.” 
Frédéric de Mulinen, Handbook on the Law of War for Armed Forces, ICRC, Geneva, 1987, § 52.

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