A/HRC/12/48 page 92 362. The Mission also notes that – as the Government of Israel argues at length225 – there are circumstances under international humanitarian law in which military actions resulting in the loss of civilian life would not be unlawful. These include attacks directed against military objectives that comply with the principles of discrimination and proportionality, but nonetheless kill civilians. They also include the killing of persons who, though not members of an armed group, participate directly in the hostilities. The reportedly exceedingly high percentage of civilians among those killed raises concerns about the precautions taken by Israel in launching attacks as well as the legality of many of the attacks, as elaborated further in this report with regard to the specific incidents investigated by the Mission. 363. The Mission finally notes that it cannot entirely discount the possibility that Palestinian civilians may have been killed as a result of fire by Palestinian armed groups in encounters with the Israeli armed forces, as argued in a submission to the Mission,226 although it has not encountered any information suggesting that this was the case.227 2. Israeli casualties 364. The Israeli Ministry of Foreign Affairs reported that, during the military operations from 27 December 2008 to 18 January 2009, there were four Israeli casualties228 in southern Israel (all adults), of whom three were civilians and one was a soldier.229 In addition, nine Israeli soldiers were killed during the fighting inside the Gaza Strip, four of whom by friendly fire.230 B’Teslem231 confirmed these numbers, stating that during the operations Palestinians killed nine Israelis, of whom three civilians, who were reportedly killed by Qassam and Grad rocket fire, and six members of the security forces, while another four soldiers were killed by friendly fire.232 225 “The operation in Gaza…”, paras. 89–141. 226 “The hidden dimension of Palestinian war casualties…”. This submission is examined in chapter VIII below. The Mission has, however, investigated cases of alleged extrajudicial executions of Palestinians by Palestinian armed groups during the military operations (see chap. XIX). 227 http://www.mfa.gov.il/MFA/Terrorism-+Obstacle+to+Peace/Hamas+war+against+Israel/Israel_strikes_back_ against_Hamas_terror_infrastructure_Gaza_27-Dec-2008.htm. 228 http://www.mfa.gov.il/MFA/Terrorism-+Obstacle+to+Peace/Hamas+war+against+Israel/Victims_Hamas _rocket_fire_Hamas_ends_calm_Dec-2008.htm. 229 http://www.mfa.gov.il/MFA/Terrorism-+Obstacle+to+Peace/Hamas+war+against+Israel/ IDF_soldiers_killed_Operation_Cast_Lead.htm. 230 B’Tselem, “B’Tselem’s investigation of fatalities in Operation Cast Lead”, p. 2, available at: http://www.btselem.org/Download/20090909_Cast_Lead_Fatalities_Eng.pdf. 231 Al-Qassam Brigades’ website reports that, during the conflict, they killed 102 Israeli soldiers (“The outcome of al-Qassam operations during the Battle of al-Furqan” (in Arabic), available at: http://www.alqassam.ps/arabic/ special_files/al-furqan/30.pdf). On 19 January 2009, Abu Obeida, a spokesperson for the group, stated that “Israel lost ‘at least 80 soldiers’ in the fighting”. See al-Arabiya News Channel, “Hamas says only 48 fighters slain in Israel war”, 19 January 2009, available at: http://www.alarabiya.net/articles/2009/01/19/64513.html. The large discrepancy in the data confirms the Mission’s observations below in the report about the reliability of the information about the Gaza military operations posted on websites of al-Qassam and other Palestinian armed groups. 232