A/HRC/11/31 page 9 whether the obligations were actually incumbent upon the organization or the States contributing with military personnel, or upon both. In the context of international humanitarian law, it was considered that responsibility could be attributed to both the international organization and the contributing States. Concerning human rights obligations, it was indicated that the European Court of Human Rights decided in the case of Behrami v. France that human rights obligations could be attributed to international organizations. Experts noted that a similar issue was currently before the European Court in a number of cases. It was nevertheless recalled that, with regard to the United Nations, the Organization as a matter of policy sought to observe the highest standards of behaviour when conducting peacekeeping operations. In this respect, the bulletin of the Secretary-General on the observance by the United Nations forces of international humanitarian law provided some policy guidance as to the fundamental principles and rules of international humanitarian law that applied to United Nations forces when actively engaged in situations of armed conflict as combatants, to the extent and for the duration of their engagement, although this did not reflect the entire body of international humanitarian law obligations applicable to United Nations forces as a matter of international law. Moreover, it was underscored that it should be borne in mind that the Charter of the United Nations recognized the protection and promotion of human rights as one of the fundamental principles of the Organization. Some may argue that, although the United Nations was not a party to international human rights or international humanitarian law treaties, the Organization was nonetheless bound by customary international law. III. THE RELATIONSHIP BETWEEN INTERNATIONAL HUMAN RIGHTS LAW AND INTERNATIONAL HUMANITARIAN LAW (SESSION 2) 20. It was recalled that the discussion on the interaction between human rights law and international humanitarian law was part of a broader legal debate on the question of the fragmentation and unity of international law. On the one hand, there was normative fragmentation owing to the creation of functional areas in international law; on the other, all these areas were highly permeable and closely interrelated, as is the case between human rights law, international humanitarian law, international criminal law, refugee law, disarmament and arms control law, and environment law, among others. It was underscored that, in recent years, there had been the development of a public interest area in international law, in which the individual was at the centre. As a result, recent legal debates had concentrated on developing mechanisms to ensure maximum protection for the individual. For instance, it was recalled that, in a number of cases, one body of law required a renvoi to another body of law, for example common article 3 to the Geneva Conventions, which uses concepts also referred to in the Universal Declaration of Human Rights. Similarly, human rights law on certain occasions needed to be interpreted in the context of international humanitarian law, as done by the International Court of Justice in the context of the advisory opinion on nuclear weapons. 21. It was also recalled that human rights courts, such as the European Court of Human Rights and the Inter-American Court of Human Rights, had developed further the applicable legal framework. The international criminal tribunals, developments in the peace and security sector, and Security Council resolutions, as was the case in resolution 1820 (2008) on violence against women, had further contributed to legal developments.