34 HASSAN v. THE UNITED KINGDOM – JUDGMENT 1. The parties’ submissions (a) The applicant 67. The applicant submitted that Tarek Hassan fell within the United Kingdom’s jurisdiction under Article 1 by virtue of the application of the “effective control of an area” principle, as articulated by the Court in Al-Skeini and Others v. the United Kingdom [GC], no. 55721/07, § 138-140, ECHR 2011. He further submitted that the implication to be drawn from the judgment in Al-Skeini was that the United Kingdom had effective control over South East Iraq following the removal from power of the Ba’ath regime, which had been achieved by 1 May 2003. He pointed out that by 9 April 2003 coalition troops had taken control of Baghdad and that by mid-April 2003, well before the capture of Tarek Hassan, statements made by the British Prime Minister and by the director of operations for the United States Joint Chiefs of Staff indicated that the coalition forces considered the war effectively over. With regard to the criteria identified by the Court as relevant to the question whether a State exercised effective control of an area, namely “the strength of the state’s military presence in the area” and “the extent to which its military, economic and political support for the local subordinate administration provides it with influence and control over the region”, there was no evidence of any significant practical difference between 23 April and 1 May 2003, and no good reason why there should be a difference in the legal position. 68. In the alternative, the applicant argued that jurisdiction was clearly established under the principle of State agent authority. It was the applicant’s submission that, according to the Court’s case-law, jurisdiction on this ground was not dependent on control over a building, area or vehicle but might also arise simply where there was physical control or authority over a person. Such authority and control over individuals did not have to be exclusive or total in order for jurisdiction to arise. Nor was it necessary for the State to be in a position to secure all the Convention rights to the person under its control. On this basis, the Court should reject the Government’s argument that bipartite or joint control was not sufficient for the purposes of Article 1 of the Convention. 69. The applicant submitted that, following his brother’s arrest during the night of 22/23 April 2003, when the latter was taken into the custody of United Kingdom soldiers, it could not realistically be disputed that the United Kingdom had authority and control, and therefore Article 1 jurisdiction, over him. In relation to the period after his admission to Camp Bucca, the United Kingdom continued to exercise authority and control over his detention. In particular, he was identified as a United Kingdom detainee on both the United Kingdom AP3-Ryan database and the United States Camp Buca database. The United Kingdom authorities were responsible for preparing a capture report and a detention report. Immediately upon his