62 INTERNATIONAL LEGAL PROTECTION OF HUMAN RIGHTS IN ARMED CONFLICT Second, it is also difficult to determine whether the results each norm would produce are actually in conflict or not. The Study Group of the International Law Commission suggested that a conflict of norms exists “if it is possible for a party to two treaties to comply with one rule only by thereby failing to comply with another rule.”93 As the International Court of Justice has indicated, in the context of international human rights and humanitarian law in armed conflict, there are situations in which recourse to the principle of lex specialis is necessary to determine the scope of the protections and the standards. As ICRC has recognized, there are circumstances in which provisions of international humanitarian law, such as common article 3 of the Geneva Conventions, “must […] be given specific content by application of other bodies of law in practice.”94 This is, for example, the case of the guarantees of fair trial provided for in article 14 of the International Covenant on Civil and Political Rights, which are far more detailed than the provisions of common article 3 (d) of the Geneva Conventions. Furthermore, many human rights violations that occur during armed conflict are not a direct result of hostilities and should be resolved by applying international human rights law and domestic law. For example, a party to the conflict may take part in violations that are unrelated to the conflict and to which international human rights law applies because they are simply not governed by international humanitarian law. Similarly, even in a country affected by an armed conflict, law enforcement is always governed by international human rights law.95 Moreover, even where   Ibid., para. 24. It provides as an example the relationship between the law of State immunity and the law of human rights to illustrate how two sets of rules can in practice produce different and incompatible results. 94   Jakob Kellenberger, President of the International Committee of the Red Cross, “International humanitarian law and other legal regimes: interplay in situations of violence”, statement to the 27th Annual Round Table on Current Problems of International Humanitarian Law, San Remo, Italy, 4–6 September 2003. Available from www.icrc.org. 95   See, for example, the “Eleventh periodic report of the United Nations High Commissioner for Human Rights on the situation of human rights in the Sudan”, 23 January 2009, dealing with the killing and injuring of civilians on 25 August 2008 by Government security forces in the Kalma camp for internally displaced persons (IDPs) in South Darfur, Sudan. Despite the 93