PROHIBITION OF USE OF FORCE IN INTERNATIONAL LAW

Prohibition of use of force in International Law

Submitted by:

Divya Raunak (2119), B.A., LL.B. (Hons)

Submitted to:

Mrs. Sugandha Sinha

Faculty of International Law

This final draft is submitted in the fulfilment of the topic “Prohibition of use
of force in International Law”

Chanakya National Law University, Patna

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1. ACKNOWLEDGMENT

I would like to thank my faculty Mrs. Sugandha Sinha, whose assignment of such a pertinent
topic made me work towards knowing the subject with a greater interest and enthusiasm and
moreover she guided me throughout the project.

I owe the present accomplishments of my project to my friends, who helped me immensely with
sources of research materials throughout the project and without whom I couldn’t have
completed it in the present way.

I would also like to extend my gratitude to my parents and all those unseen hands that helped me
out at every stage of my project.

THANK YOU!

NAME-DIVYA RAUNAK

ROLL NO. - 2119

5th Semester (B.A., LL.B.)

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DECLARATION

I hereby declare that the work reported in the B.A., LL.B. (Hons.) project report titled
“Prohibition of use of force in International Law” submitted at Chanakya National Law
University Patna, is an authentic record of my work carried under the mentorship of Mrs.
Sugandha Sinha. I have not submitted this work elsewhere for any other degree or diploma. I am
fully responsible for the contents of my project report.

DIVYA RAUNAK

Chanakya National Law University

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Contents
1. ACKNOWLEDGMENT.....................................................................2

2. INTRODUCTION...............................................................................5

3. THE UN CHARTER AND THE PROHIBITION ON THE USE

OF FORCE.............................................................................................10

4. LEADING CASES............................................................................15

5. CONCLUSION.................................................................................20

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2. INTRODUCTION

The use of force has been a long standing phenomenon in international relations and has been
considered to be directly linked to the sovereignty of states-the limitless power wielded by states
to use all possible means to guard and protect their interests. However, the longer period that war
has been associated with sovereignty of state, the more the issue has turned into a legal
institution by itself. This paper looks at the prohibited and permissible use of force in
International Relations. Developed social awareness has expanded the limits (and even led) to
the right to resort to war. This indeed has abolished the use of force or any form of threats in
relation among nations, this has become a rule of law in international criminal law-its violation
comes with criminal responsibility in the eyes of the international community. However, there
are certain situations in which it is allowed to use force such as for self defense purposes,
humanitarian intervention, and preemptive power inter alia.

In the international community, force has featured as at high levels of decentralization i.e. force
has been use d for different purposes-it has been applied to previous intervention and to punish
for noncompliance according to demand. War is the hardcore form of force and is used to grab
territories or to completely suppress states. Reprisals are also considered as violence in
international relations. Kelsen, war has been considered to be permissible due to existence of
sovereignty among the states.

Prohibition on the use of force 

The United Nations Charter in article 2(4) controls the use of force by member states. The UN
Charter states that;

“All members shall refrain in their international relations from the threat or use of force against
the territorial integrity or political independence of any state, or in any other manner inconsistent
with the purposes of the United Nations.”

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This law has been ratified by all the members and is protected by the United Nations Charter
1945 to prohibit the use of force by states. This was the time when Louse Doswald-Beck was the
secretary general of the International Commission of Jurists. Most scholars have interpreted
Article 2(4) to be banning the use of force as in “territorial integrity or political independence of
states”; the most commonly held opinion is that the above factors are only to reinforce Article
2(4)-which encompasses general prohibitions with exceptions outlined in the Charter such as
self-defense and those in Chapter VII by the United Nations security council. The general
principle is to ban the use of armed forces except in cases where; there is collective action-
pursued to maintain or even enforce peace (Articles 24, 25, and Chapter VII) ; and Article
51which states that, “Nothing in the present Charter shall impair the inherent right to individual
or collective self-defense if an armed attack occurs against a state.” In addition, other cited
reasons that permit the use of force include humanitarian intervention, though this is still
controversial, reprisals, and states’ protection of their nationals in other states.

The United Nations Charter and the International Military Tribunal Statute have been created
with regard to international law. These laws were created by the UN member states in order to
protect succeeding generations from scourges of war. Members resorted that the use of armed
forces was not allowed, save in the interest of all. The UN Charter even though premising on the
past is open to future amendments since the definition of the word ‘war’ has changed (and will
change) over time . One may quickly note that the word ‘war’ is not mentioned in the Charter
only “force” is mentioned together with “enforcement measures”. In addition, total prohibition of
use of force is not indicated since an exemption is given, “in the interest of all”. Somewhat
different is the Article 2, paragraph 4, reads:

“All Members shall refrain in their international relations from the threat or use of force against
the territorial integrity or political independence of any state, or in any other manner inconsistent
with the Purposes of the United Nations.”

In the eyes of most scholars, the term ‘force’ is quickly interpreted as ‘armed force’. This is a
rejection of other types of force such as political and even economic. Sharmasanascvilly argues
that, the different forms of force which can be used by states are prohibited as outlined in Article

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2, paragraph 4 of the UN Charter. The armed forces disturb territorial integrity; however,
political independence is affected in various ways 

Use of force on the following grounds

1. Collective action

The Security Council is authorized to determine the existence of, and take action to address, any
threat to international peace and security. In practice this power has been relatively little-used
because of the presence of five veto-wielding permanent members with interests in a given issue.
Typically measures short of armed force are taken before armed force, such as the imposition of
sanctions. The first time the Security Council authorized the use of force was in 1950 to secure
a North Korean withdrawal from South Korea. Although it was originally envisaged by the
framers of the UN Charter that the UN would have its own designated forces to use for
enforcement, the intervention was effectively controlled by forces under United States command.
The weaknesses of the system are also notable in that the fact that the resolution was only passed
because of a Soviet boycott and the occupation of China's seat by the Nationalist
Chinese of Taiwan.

The Security Council did not authorize the use of significant armed force again until the invasion
of Kuwait by Iraq in 1990. After passing resolutions demanding a withdrawal, the Council
passed Resolution 678, which authorized the use of force and requested all member states to
provide the necessary support to a force operating in cooperation with Kuwait to ensure the
withdrawal of Iraqi forces. This resolution was never revoked.

2. Self defence

Article 51:

Nothing in the present Charter shall impair the inherent right of collective or individual self-
defence if an armed attack occurs against a member of the United Nations, until the Security
Council has taken the measures necessary to maintain international peace and security. Measures
taken by members in exercise of this right of self-defence shall be immediately reported to the
Security Council and shall not in any way affect the authority and responsibility of the Security

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Council under the present Charter to take at any time such action as it deems necessary in order
to maintain or restore international peace and security.

The ICJ held in the Nicaragua Case (Merits) that ‘self-defence would necessitate only measures
which are relative to the armed attack and required to respond to it’ (para. 176). This statement
sets out two important principles in international law relating to the use of force: the principle of
proportionality and the principle of necessity. In this context, proportionality means that the
response to an armed attack must be reflective of the scope, nature and gravity of the attack
itself. On the other hand, the principle of necessity guards against the use of measures which are
excessive and not necessary in response to an armed attack.

The meaning of ‘armed attack’ causes significant controversy in international law. In the
Nicaragua Case and in Legal Consequences of the Construction of a Wall in the Occupied
Palestinian Territory Advisory Opinion ICJ Rep 2004, the ICJ rejected the idea that an armed
attack may include ‘not only acts by armed bands where such acts occur on a significant scale
but also assistance to rebels in the form of the provision of weapons or logistical or other
support’ (Nicaragua Case, para.195). In other words, it is necessary to show that an armed attack
is attributable to a state.

In the Nicaragua Case, Judge Higgins strongly opposed this view and argued that the act
involving the use of force from actors other than a state, such as groups of insurgents or terrorist
groups, may give rise to the exercise of the right of self-defence by the attacked state. This
statement highlights a very contentious issue in modern international relations, namely the use of
force in self-defence against non-state actors.

3. Pre-emptive force

The use of self defense is limited under the international customary law. The permissibility of the
use of force in cases of self defense is hinged on the interpretation of Article 51. There is no right
to pre-emptive self defense when an armed attack has occurred, a state does not have to wait for
an armed attack to actually occur to use force. Thus, a distinction has to be drawn between,
“preventive”, “anticipatory”, and “interventionary” self defense. The ICJ has not ruled out the

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use of pre-emptive armed force to intervene in the case of an imminent armed attack. However,
opinio juris and practice widely suggest that states have no right to preventive self-defense.

4. Protection of nationals

The controversial claim to a right to use force in order to protect nationals abroad has been
asserted by some States. Examples include intervention by the UK in Suez (1956), Israel in
Entebbe (1976) and the USA in the Dominican Republic (1965), Grenada (1983) and Panama
(1989). The majority of States are doubtful about the existence of such a right. It is often claimed
alongside other rights and reasons for using force. For example, the USA intervention in Grenada
was widely considered to be in response to the rise to power of a socialist government. The
danger that this posed to US nationals was doubtful and resulted in condemnation by the General
Assembly. As with the above examples (except the Entebbe incident), the protection of nationals
is often used as an excuse for other political objectives.

5. Humanitarian actions

In recent years several countries have begun to argue for the existence of a right of humanitarian
intervention without Security Council authorization. In the aftermath of the Kosovo crisis in
1999, the UK Foreign Secretary asserted that, "In international law, in exceptional circumstances
and to avoid a humanitarian catastrophe, military action can be taken and it is on that legal basis
that military action was taken." It is very difficult to reconcile this statement with the UN
Charter. When NATO used military force against the Yugoslav state, it did not have
authorization from the Security Council, but it was not condemned either. This is because veto-
wielding countries held strong positions on both sides of the dispute.

Many countries oppose such unauthorized humanitarian interventions on the formal ground that
they are simply illegal, or on the practical ground that such a right would only be ever used
against weaker states by stronger states. This was specifically shown in the Ministerial
Declaration of G-77 countries, in which 134 states condemned such intervention. Proponents
have typically resorted to a claim that the right has developed as a new part of customary law.

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3. THE UN CHARTER AND THE PROHIBITION ON THE USE OF FORCE

In this chapter, the provisions in the Charter relating to the prohibition on the use of force by
States in their relations with each other are discussed. One of the primary goals of the United
Nations (UN), according to Article 1(1) of the UN Charter, is to maintain international peace,
security and stability. One way of achieving this goal is to prohibit the use of force amongst
States. In order to achieve this aim, Article 2(4) contains a prohibition on this use of force.
A system of collective sanctions against any offending State that uses force protects this
prohibition. These sanctions are found in Articles 39 – 51 of the UN Charter.

Before the establishment of the United Nations states were free to decide whether to wage war or
not to wage war against one another. There was no regulation on the States for the use of force.
The only guiding principle on the State was the moral consideration relating to ‘just’ war and
‘unjust’ war. Further the determination of ‘justness’ of the war was based on subjective
interpretation. This allowed states to wage brutal wars against one another.

United Nations after its establishment has been successful in dealing with the use of force by the
states, but it faces criticisms. The criticisms that are faced by the United Nations Charter are that
firstly whether the prohibition of use of force should only continue to be military use of force
and secondly how should States deal with the non state entities such as terrorism organizations
which are not governed by the Charter rules.

Provisions relating to the use of force: The prohibition and exceptions 

Article 1(1) of the UN Charter says that one of the purposes of the Charter is to:

“To maintain international peace and security, and to that end: to take effective collective
measures for the prevention and removal of (1) threats to the peace, and for the (2) suppression

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of acts of aggression or (3) other breaches of the peace, and to bring about by peaceful means…
adjustment or settlement of international disputes or situations which might lead to a breach of
the peace”

In order to maintain international peace and security and to prevent future wars:

(1)  Article 2(3) places an obligation on member States to settle their disputes peacefully.

(2) Article 2(4) prohibits member States from using force in their international relations.

All Members shall refrain in their international relations from the threat or use of force against
the territorial integrity or political independence of any state, or in any other manner
inconsistent with the Purposes of the United Nations.

Article 2 (4) is the essential ingredient of the UN Charter as it provide a better collective security
system. But its interpretation is still debated since certain terms of the Article has not been
explained properly. The scope of prohibition of “the threat of use of force” is not precisely given.

(3)  The prohibition is safeguarded by a system of collective sanctions against any offending
State that uses force. These safeguards are found in Articles 39-51 of the UN Charter.

3.1. Articles 39, 40 and 41 comes into effect when a member State has threaten or used force in
a way that it amounts to a threat to or breach of peace or an act of aggression. Article 39 says:

“The Security Council shall determine the existence of any threat to the peace, breach of the
peace, or act of aggression and shall make recommendations, or decide what measures shall be
taken in accordance with Articles 41 and 42, to maintain or restore international peace and
security.”

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Article 41 allows the Security Council to impose sanctions (financial sanctions, arms
embargoes):

“The Security Council may decide what measures not involving the use of armed force are to be
employed to give effect to its decisions, and it may call upon the Members of the United Nations
to apply such measures. These may include complete or partial interruption of economic
relations and of rail, sea, air, postal, telegraphic, radio, and other means of communication, and
the severance of diplomatic relations.”

3.2. Article 42 gives the Security Council the power to authorize the use of necessary force to
maintain international peace and security. Because the Security Council does not have a military
force of its own, the Security Council authorizes member States to use force on its behalf.

“The Security Council] may take such action by air, sea, or land forces as may be necessary to
maintain or restore international peace and security.”

3.3. Article 51 provides for a member State to use force in self defense when there is an armed
attack against that State.

“Nothing in the present Charter shall impair the inherent right of individual or collective self-
defence if an armed attack occurs against a Member of the United Nations, until the Security
Council has taken measures necessary to maintain international peace and security…”

As discussed, the only exceptions to the prohibition on the use of force in the UN Charter are
found in Articles 42 and 51 of the UN Charter (provisions in Article 53(1) and 107 are not
relevant and we will not discuss them). In addition to this, States have relied on a customary
international law right of self defense, on humanitarian intervention (for example in the 11 day
NATO bombing of Kosovo) and implicit authorization under SC Resolutions (for example,

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NATO bombing of Kosovo and US invasion of Iraq) as a justification to use force against
another State. We will not discuss these aspects in class.

Interpretation of Article 51

The United Nation Charter does not define the term ‘armed attack’. Attack of one territory by the
regular forces of another state by land, sea or space is usually considered as armed attack. But it
is often debated that whether armed attack can only be levied by regular forces. The International
Court Justice defined armed attack as “an attack that occur on a significant scale by armed bands
or groups on behalf of a state as to amount to an actual armed attack conducted by regular armed
forces or its substantial involvement therein”. The International Court of Justice in the Hostages
case had used the term armed attack with regard to “the actual storming of the embassy and the
hostage taking of its personnel”. Since the International Court of Justice work in a consistent
manner, it is to be believed that armed attack in the cases of Nicaragua and Hostages would
come under the scope of Article 51 of the United Nation Charter.

In case of attacks by terrorist Organizations Article 51 permits only States to take self
defence measures. But in today’s scenario states are not the only entities that can use or cause
armed attacks. It can be seen that in the last decades that non state attacks have increased
significantly, attack by terrorist groups and other organizations have increased in large number.
Prohibition of use of force by non state actors is not stated under Article 2(4). This leaves a void
as to whether states can defend themselves when attacked by such non state actors. In order to
act in self defence against a nonState entity, a State against which an armed attack has occurred
has two options. First, it has to show that the attack is conducted by a non- State entity, Secondly
the act is done with actual or implicit knowledge of a State or it is a state sponsored attack.

Anticipatory Self Defence Anticipatory self defense is taken by states when they are confronted
by imminent attack. Such an imminent attack needs to be an armed attack and should be a
controversial one according to Article 51. The UN Charter does not explicitly provide for
anticipatory self defence but as a right it originates from the customary international law
principles. Anticipatory self defence as a doctrine was articulated in the Caroline Case. Two

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criteria were given in regard to permissible use of anticipatory self defence. First was necessity
and the second criterion was proportionality.

After the 9/11 attacks, states have started claiming the right of anticipatory self defence. The
importance of such provision has increased in the international law scenario. The United Nations
Security Council Resolution 1373 had decided on the following-

“States shall take necessary steps to prevent the commission of terrorist acts, including by
provision of early warning to other states by exchange of information; “States shall cooperate
with each other, particularly through bilateral and multilateral arrangements and agreements,
in order to prevent and suppress terrorist attacks and take action against perpetrators of such
acts.”

Mandating States to “take the necessary steps to prevent the commission of terrorist acts
including by provision of early warning to other States by exchange of information” can be
interpreted in many ways. Thus if one Sate provides any early warning to another State that there
is a plan being hatched on its territory, or that of a third State, which is to culminate in an attack
against another State, nothing stops the latter from attacking the group hatching the plan.
Resolution 1373 seems to support such an action fully.

However, the Security Council still requires some evidence before a State can take action to
forestall a terrorist attack. This indicates that anticipatory self defence must be based on real
evidence of an impending attack. Therefore this resolution cannot justify actions based on the
preemptive doctrine, which is a nebulous doctrine that would allow a State to attack another
State not because the latter has an intention to attack it, but because it has a history of violence
towards other States.

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4. LEADING CASES

1. In the case Nicaragua vs United States, the court held that:

 Customary international law allows for exceptions to the prohibition on the use of force, which
includes the right to individual or collective self-defence (see here for a difference between
individual and collective self defense). The United States, at an earlier stage of the proceedings,
had also agreed that the UN Charter acknowledges the existence of this customary international
law right when it talks of the “inherent” right under Article 51 of the Charter (para.193).
 When a State claims that it used force in collective self-defence, the Court would examine the
following:

(1) Whether the circumstances required for the exercise of self-defence existed; and

(2) Whether the steps taken by the State, which was acting in self-defence, corresponds to the
requirements of international law.

 Under international law, several requirements must be met for a State to exercise the right
of individual or collective self-defence:

(1)  A State must have been the victim of an armed attack;

(2)  That State must declare itself as a victim of an armed attack. The assessment on whether an
armed attack had taken place or not, is done by the State who was subjected to the attack. A third
State cannot exercise a right of collective self-defence based that third State’s own assessment;

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(3)  In the case of collective self-defence, the victim State must request for assistance. The Court
held that “there is no rule permitting the exercise of collective self-defence in the absence of a
request by the State which regards itself as the victim of an armed attack”;

(4)  A State that is attacked, does not, under customary international law, have the same
obligation as under Article 51 of the UN Charter to report to the Security Council that an armed
attack happened – but the Court held that “the absence of a report may be one of the factors
indicating whether the State in question was itself convinced that it was acting in self-defence”

2. Caroline Test.

The Caroline test is a 19th-century formulation of customary international law, reaffirmed by

the Nuremberg Tribunal after World War II, which said that the necessity for preemptive self-
defense must be "instant, overwhelming, and leaving no choice of means, and no moment for
deliberation." The test takes its name from the Caroline affair

The terms "anticipatory self-defense", "preemptive self-defense" and "preemption" traditionally

refers to a state's right to strike first in self-defense when faced with imminent attack. In order to
justify such an action, the Caroline test has two distinct requirements:

1. The use of force must be necessary because the threat is imminent and thus pursuing
peaceful alternatives is not an option (necessity);
2. The response must be proportionate to the threat (proportionality).

In Webster's original formulation, the necessity criterion is described as "instant, overwhelming,

leaving no choice of means, and no moment of deliberation". This has later come to be referred
to as "instant and overwhelming necessity"

The principle of self-defense had been acknowledged prior to the Caroline test, but it was notable
for setting out specific criteria by which it could be determined whether there had been a

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legitimate exercise of that right.The test was accepted by the United Kingdom and came to be
accepted as part of customary international law.

The threat or use of force is prohibited by customary international law and the UN Charter when

it is part of a preventive war waged against the territory of any State. In the Lotus case,
the Permanent Court of International Justice decided, "the first and foremost restriction imposed
by international law upon a State is that – failing the existence of a permissive rule to the
contrary – it may not exercise its power in any form in the territory of another
State." The Caroline test was recognized and endorsed by the Nuremberg Tribunal, who adopted
the same words used in the test in judging Germany's invasion of Norway and
Denmark during World War II.

The right of self-defense is permitted, when the conditions of customary international law
regarding necessity and proportionality are met. Article 51 of the UN Charter recognizes "the
inherent right of individual or collective self-defense if an armed attack occurs against a Member
of the United Nations, until the Security Council has taken measures necessary to maintain
international peace and security." The Caroline test applies in cases where Article 51 is not a
permissive rule because a defensive action was taken before an armed attack occurred.

To this day, the Caroline test is considered the customary law standard in determining the
legitimacy of self-defense action. In 2008, Thomas Nichols wrote:

Thus the destruction of an insignificant ship in what one scholar has called a 'comic opera affair'
in the early 19th century nonetheless led to the establishment of a principle of international life
that would govern, at least in theory, the use of force for over 250 years.

3. Balakot Strikes 2019

The United Nations Charter authorises one state to use force in another states territory only in
self-defence or with the approval of the UN Security Council. In addition to self-defence, the
International Law Commissions Articles on Responsibility of States for Internationally Wrongful
Acts permit the extraterritorial use of force by a state if it is executed under certain
circumstances, such as (1) with the other states consent, (2) out of distress, (3) out of necessity,

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(4) as a countermeasure, or (5) in response to situations which are beyond the states reasonable
control (force majeure).

Given the element of subjectivity, it is hardly surprising that almost every instance of the use of
force generates debate and there is often little consensus among various international
stakeholders.[30] Traditionally, these debates have been the sharpest when the target consists of
non-state armed groups, as in this case. However, in light of state practice and certain Security
Council resolutions – particularly the ones adopted in response to the 9/11 attacks – the use of
force against militant groups in self-defence is increasingly considered an accepted norm.

Operation Bandar

12 Mirage 2000 fighter aircraft to attack the Jaish-e-Mohammed terrorist camp in Balakot on
February 26, 2019 by Indian Air Force.

On 14 February 2019, a dastardly terrorist attack was carried out on Indias security personnel, in
the Pulwama district of Kashmir. The Jaish-e-Mohammed (JeM), a United Nations (UN)
designated terrorist organization, claimed responsibility for the attack. The Pulwama attack is the
latest in a long list of attacks, attempted or executed, by the same terrorist outfit against Indian
soldiers and civilians in Kashmir and elsewhere.

The official statement from the Air force after the operation used terms non military pre-emptive
action that clarifies that the target of the attacks was non state actors, and not the military or the
civilian population of Pakistan. This clarification manifests Indias position that the air strikes
sought to simply destroy the terror camps of JeM, without delving into questions of attribution
and state responsibility of Pakistan for the acts of the NSA operating from within its territory.

India’s official statement mentions that the pre-emptive strikes were undertaken in the face of
imminent danger, which was based on credible intelligence that the JeM was planning another
terror attack against the country.It is argued that the usage of the phrase pre-emptive strikes

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hovers between two variations of the right of self-defence – anticipatory and preventive. While
anticipatory self-defence recognises the existence of the right in the face of a manifestly specific
and imminent attack. The concept of preventive self-defence does not seek to rely on any
concrete threat of an armed attack, and operates in the realm of contingency and conjecture (eg.
Japans attack on Pearl Harbour).

Furthermore, solely relying on the phrase imminent danger, in the absence of any concrete
evidence of the imminent threat, not only leaves the lawfulness/legality of the air strikes in
doubt, but also fails to clear the confusion highlighted in the previous paragraph.

India relied on unwilling or unable test as a justification by seeking to establish the unwillingness
or inability on the part of Pakistan in taking action against the JeM despite the sharing of location
intelligence on JeM terror camps, and urging Pakistan to take action against the JeM.

Despite India’s position, the distinction between the attack on the State and the attack on the
non-state actor does not absolve the attacking State from the UN Charter framework on the use
of force. The International Law Association rightly observed that using force within the territory
of another state-even if the forcible measures are limited to strikes against a non-state actor-must
be considered as within the notion of force as it exists in Article 2(4) of the Charter.

India seems to consider its 26 February 2019 aerial strikes at Balakot as non-military and thus do
not attract the legal framework on the use of force, i.e., UN Charter provisions. They may be
considered as law and order measures undertaken on the territory of another State. However, this
requires further clarification from India for the purpose of placing it in a legal context, because
this position is unusual from the standpoint of international law.

The support that India has received for its right to self defence after the Pulwama attack, the
absence of any condemnation by other states as well as the UN subsequent to the Balakot air
strike suggests the recognition of the right of self-defence against non state actors.

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5. CONCLUSION

United Nations was formed to avoid the tragedies of war. The main purpose of the UN is to
promote peace and security among the member States. Article 2(4) prohibits use of force under
and Article 51 is an exception to Article 2(4). Though both the articles provide the circumstances
under which force is prohibited and force can be used, but still it is not void of ambiguities. The
UN Charter is silent as to the role of non-state actors in use of force. Expanding the scope of
Article 51 may lead to the degradation of the fundamental purpose of the United Nation which is
to promote peace and security among the member nation and world. Expanding the scope of
Article 51 may lead to uncheck use of force by States in pretence of their self defence.

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