Three scenarios Three scenarios can give indications of the wide range of roles NHRIs could play and actions they could take in relation to extra-territorial human rights cases and situations. Each scenario is hypothetical but it is based on recent actual experiences. In each scenario, an individual NHRI would need to examine its own law to determine whether and how any particular action is possible. The individual law of each individual NHRI is the enabling and limiting instrument of the NHRI’s action. Scenario 1: Situation of armed conflict An armed conflict is being fought between the armed forces of Country A and armed groups. The fighting is occurring both inside Country A and outside it. The Security Council has passed a small number of binding resolutions concerning the conflict, demanding a ceasefire, the provision of humanitarian aid and the release of detainees, including hostages, and imposing the basis of a permanent settlement of the conflict. The parties have not complied with these resolutions. The General Assembly has passed many more resolutions that are non-binding but fully consistent with the resolutions of the Security Council. Country A has rejected these resolutions. At the request of the General Assembly, the International Court of Justice has issued an advisory opinion addressing the legal issues underlying the conflict. The Court has expressed its non-binding but authoritative opinion on the mandatory obligations of Country A and all other States under international law. It has held that activities associated with the conflict violate international law, including the UN Charter, the International Covenant on Civil and Political Rights, the International Covenant on Economic, Social and Cultural Rights, the Geneva Conventions and customary international law. The Court is also dealing with the situation in a contentious case between Country A and other States. It has made binding orders of provisional measures but Country A has ignored those orders. The International Criminal Court is also conducting an investigation into the acts and practices of the individual leaders and combatants of Country A and the armed groups to determine criminality under the Rome Statute. The Court has issued arrest warrants for certain leaders and combatants of Country A and of the armed groups. Country B is not directly involved in the fighting but it has historically been close to Country A and it supports Country A in UN forums. Country B has a defence attaché in its embassy in Country A who liaises with the armed forces of Country A, including in relation to defence-related trade between Country A and Country B. A number of citizens of Country B are fighting in the armed forces of Country A. It is illegal under the laws of Country B for citizens of Country B to fight in armed groups but it is not illegal for them to fight in the armed forces of another State. Fighting for the armed forces of Country A raises the possibility that citizens of Country B are implicated in the commission of war crimes. Country A and Country B have also had longstanding economic and trade relations. Country B has an official trade representative in its embassy in Country A whose responsibility is to promote trade and investment between the two States. Manufacturing corporations in Country B produce goods that are exported to Country A. Those goods include steel for use in the production of weapons and ammunition in Country A, aiding its war effort. Certain non-government organisations in Country B raise money to send to organisations in Country A to aid its war effort and to support activities that the International Court of Justice has found to be unlawful. 42 National action on international issues