More recently, the 1998 Rome Statute of the International Criminal Court characterized human shielding as a war crime. regarding Human Shields’ (2004) 84(5) Military Review 26, 26–7. This tactic has produced clear costs and only marginal gains for Saddam, yet he repeatedly … In mid-November 1997, Saddam enticed or coerced thousands of Iraqi men, women, and children to volunteer as human shields at his presidential palaces and Iraqi industrial sites. In this legal analysis Irnela Silnović, Master student in International Security and Law, seeks to investigate the legal status of human shields and whether human shields should merely be seen as collateral damage in an armed conflict. This chapter explores the international humanitarian law governing the use of human shields, a tragically prevalent tactic in contemporary warfare. Of more concern is the issue of how the use of human shields affects an attacker’s obligations. This practice is often referred to as "human sea attack" by the Nationalist Chinese. It begins by setting forth the express prohibitions on the use of human shields. The Parties to the conflict shall not direct the movement of the civilian population or individual civilians in order to attempt to shield military objectives from attacks or to shield military operations. Putting Noncombatants at Risk: Saddam's Use of "Human Shields" In past confrontations with the West, Iraqi President Saddam Husayn has used thousands of foreign and Iraqi civilians as human shields in bids to manipulate domestic and international opinion and deter military action against his regime. 3 See, eg, Douglas H Fischer, ‘Human Shields, Homicides and House Fires: How a Domestic Law Analogy Can Guide International Law regarding Human Shield Tactics in Armed Conflict’ (2007) 57 American University Law Review 479, 485; Marsha V Mills, ‘War Such voluntary shields are not morally liable to collateral harm, though less is required to justify collateral harm to them than to justify collateral harm to involuntary shields or to civilians who are merely in the wrong place at the wrong time. Likewise, the House passed a resolution claiming that “Hamas has been using civilian populations as human shields” and calling on “the international community to recognize and condemn Hamas’ breaches of international law through the use of human shields.” This hasn’t happened, however, because – despite widespread condemnation of other war crimes by Hamas – the international community has failed to … human shields at Iraqi strategic sites during periods of increased tension with the UN and the United States.