United Nations Fact-finding Mission on the Gaza Conflict during public hearings in Geneva. UN Photo / Jean-Marc Ferré in cases of foreign occupation or invasion, the mandate required the commission/mission to investigate the actions of only one party, for example, in Lebanon (2006), where the mandate required investigation only into Israel’s actions in Lebanon. As explained in its report, the Commission considered that an inquiry into the Israeli Defense Forces required that account be taken of the conduct of the opponent. However, the Commission considered that it could not construe its mandate to include investigations into the actions of Hezbollah in Israel, as “to do so would exceed the Commission’s interpretative function and would be to usurp the Council’s powers”.50 In Gaza (2009), where the resolution of the Human Rights Council requested the Mission to investigate violations by one party,51 the President of the Council,52 in announcing the establishment of the Fact-Finding Mission and in his letters appointing the members, required them “to investigate all violations of international human rights law and international humanitarian law that might have been committed at any time in the context of the military operations that were conducted in Gaza during the period from 27 December 2008 and 18 January 2009, whether before, during or after.”53 This broadened the scope of the mandate to include all relevant parties. Where mandates have included inquiries into violations of international humanitarian law, commissions/missions have applied such law to all parties to an armed conflict, including non-State armed groups. Similarly, commissions/missions have applied relevant 50 51 “Report of the Commission of Inquiry on Lebanon pursuant to Human Rights Council resolution S-2/1” (A/HRC/3/2), paras. 14 and 15. Human Rights Council resolution S-9/1, para. 14. 52 Public statement of 15 June 2009 by Amb. Martin Uhomoibhi, President of the Human Rights Council. 53 “Report of the United Nations Fact-Finding Mission on the Gaza Conflict” (A/HRC/12/48), para. 151. GUIDANCE AND PRACTICE 15