international criminal law to non-State actors (for example, crimes against humanity or genocide).54 With regard to the more complex issue of the relationship between non-State actors and international human rights law, commissions/missions have also called on a number of non-State actors to respect fundamental human rights. For example, the report on Sri Lanka (2010) stated: “With respect to the LTTE [Liberation Tigers of Tamil Eelam], although non-State actors cannot formally become party to a human rights treaty, it is now increasingly accepted that non-State groups exercising de facto control over a part of a State’s territory must respect fundamental human rights of persons in that territory. Various organs of the United Nations, including the Security Council, have repeatedly demanded that such actors respect human rights law. Although the Panel recognizes that there remains some difference of views on the subject among international actors, it proceeds on the assumption that, at a minimum, the LTTE was bound to respect the most basic human rights of persons within its power, including the rights to life and physical security and integrity of the person, and freedom from torture and cruel, inhuman or degrading treatment and punishment.”55 The first report on Libya (2011) stated: “Non-State actors in Libya, in particular the authorities and forces of the National Transitional Council, cannot formally become parties to the international human rights treaties and are thus not formally given obligations under the treaties. Although the extent to which international human rights law binds non-State actors remains contested as a matter of international law, it is increasingly accepted that where non-State groups exercise de facto control over territory, they must respect fundamental human rights of persons in that territory. The Commission has taken the approach that, as NTC has been exercising de facto control over territory akin to that of a governmental authority, the Commission will examine also allegations of human rights violations committed by NTC forces.”56 16 54 See, for example, S/2005/60, Part Three. 55 See “Report of the Secretary-General’s Panel of Experts on Accountability in Sri Lanka”, para. 188. 56 “Report of the International Commission of Inquiry to investigate all alleged violations of international human rights law in the Libyan Arab Jamahiriya” (A/HRC/17/44), para. 62. COMMISSIONS OF INQUIRY AND FACT-FINDING MISSIONS ON INTERNATIONAL HUMAN RIGHTS AND HUMANITARIAN LAW