Hostname: page-component-68c7f8b79f-lqrcg Total loading time: 0 Render date: 2026-01-13T01:50:00.107Z Has data issue: false hasContentIssue false
  • English
  • Français

Safeguarding rangers in conflict zones: Bridging humanitarian and environmental law

Published online by Cambridge University Press:  07 January 2026

Jérôme de Hemptinne Open the ORCID record for Jérôme de Hemptinne [Opens in a new window]
Jérôme de Hemptinne*
Affiliation:
Assistant Professor, Utrecht University, Utrecht, the Netherlands
*
Email: j.dehemptinne@uu.nl
Rights & Permissions [Opens in a new window]

Abstract

Rangers are indispensable to the management and protection of fragile ecosystems, especially when these come under threat from armed conflict. Yet, in such circumstances, rangers themselves become highly vulnerable as their responsibilities – such as preventing the plunder of natural resources or disrupting the trafficking of endangered species – frequently bring them into confrontation with parties to the conflict. Despite the critical nature of their work, international humanitarian law (IHL) provides them with no special safeguards beyond the general protection afforded to civilians. While certain analogies with IHL’s protection for relief personnel or civil defence actors might be drawn to extend an additional layer of legal security, it remains unclear whether these could be applied in practice to rangers. It is therefore crucial to examine relevant international environmental norms and principles – particularly those protecting areas of exceptional ecological value – in order to assess whether they could offer a more robust protective framework during warfare, thereby reinforcing the protection of the vital environmental functions that rangers perform.

Keywords

rangersbiodiversity hot spotsrelief personnelcivil defence personnelinternational humanitarian lawinternational environmental law

Information

Type
Research Article
Information
International Review of the Red Cross , First View , pp. 1 - 21
Creative Commons
Creative Common License - CCCreative Common License - BY
This is an Open Access article, distributed under the terms of the Creative Commons Attribution licence (http://creativecommons.org/licenses/by/4.0), which permits unrestricted re-use, distribution and reproduction, provided the original article is properly cited.
Copyright
© The Author(s), 2026. Published by Cambridge University Press on behalf of International Committee of the Red Cross.

Introduction

Rangers – whether designated as national park guards, conservation officers, nature conservators or wildlife guards, or under other titles (hereafter collectively referred to as “rangers”)Footnote 1 – are dedicated professionals responsible for the management, protection and conservation of natural resources and ecosystems, particularly in protected areas such as national parks or wildlife reserves.Footnote 2 Their role is essential in ordinary circumstances and becomes even more critical during crisis, as fragile ecosystems face heightened risks and their responsibilities shift to encompass a wider range of duties.Footnote 3 Rangers patrol and monitor wildlife populations and habitats, combat poaching and other forms of illegal resource exploitation, and work closely with local communities whose livelihoods are often closely linked to conservation areas and are disrupted by insecurity.Footnote 4 They also serve as educators and mediators, developing strategies to prevent and manage tensions at the intersection of human activity and wildlife.Footnote 5 In this multifaceted capacity, they embody a unique blend of ecological stewardship, law enforcement and community engagement, making them indispensable to conservation efforts.

In carrying out these vital functions, rangers often operate under precarious conditions with minimal institutional and financial support, exposing them to profound risks, especially when safeguarding high-value endangered species such as elephants, tigers, lions, gorillas and rhinoceroses.Footnote 6 These vulnerabilities are exacerbated in regions affected by armed conflict. Rangers must contend not only with organized criminal networks that exploit wartime instability to drive the illicit wildlife trade, but also with armed groups that seize protected areas to conceal themselves, prepare attacks, and extract resources through mining, poaching or other activitiesFootnote 7 that often fund ongoing military operations, including the acquisition of weapons. In such contexts, rangers increasingly shoulder functions far beyond those of traditional conservation. They are called upon to protect local populations living in or near protected areas from armed attacksFootnote 8 and, in some instances, to manage the organized relocation of those populations when national armed forces are unable to do so. Their role may expand further when they become involved in broader security or military operations – for instance, by assisting State armed forces in counterinsurgency efforts due to their intimate knowledge of the terrain, or by being directly mobilized by these authorities as military reserves or paramilitary forces to conduct operations against non-State armed groups.Footnote 9 These extraordinary demands render the use, or even the perceived use, of force by rangers a fraught and delicate matter, frequently sowing mistrust and hostility among local communities.Footnote 10 As a result, the boundary between their civilian and military roles becomes increasingly blurred. As rangers’ civilian status erodes, so too does their protection, leaving them highly vulnerable to deliberate targeting by armed actors who may regard them as legitimate military objectives.

Under international humanitarian law (IHL) – which limits the effects of armed conflict by protecting those not or no longer actively participating in hostilities and by restricting the means and methods of warfare – rangers are classified as civilians and are therefore protected from attack except during periods when they directly engage in hostilities.Footnote 11 Unlike medical personnel,Footnote 12 civil defence unitsFootnote 13 or humanitarian relief workers,Footnote 14 however, rangers do not enjoy any special or elevated protective status. This legal positioning reflects the core purpose of IHL: to safeguard civilians and civilian objects – including the natural environment – from the effects of hostilities. IHL is not, however, designed to regulate the conservation of natural areas as such, nor the specific duties performed by rangers in this context. These considerations are more appropriately addressed through complementary legal regimes, most notably international environmental law (IEL). Indeed, IEL – which informs the interpretation of IHL and, under certain conditions, remains applicable during armed conflictFootnote 15 – provides a robust normative framework for the protection of areas of high biodiversity value and underscores the essential role of competent actors in safeguarding these critical ecosystems.

This article examines how IHL and IEL can be combined to strengthen the legal protection of rangers beyond the safeguards afforded by their civilian status. It begins by analyzing the IHL regime and its limitations, before considering how IEL can complement and reinforce these protections. The discussion then turns to the specific obligations that may be imposed on non-State armed groups with respect to rangers in non-international armed conflicts (NIACs). The article concludes with a critical evaluation of the overall legal framework currently available to rangers in situations of armed conflict.

Uncovering how IHL protects – or could protect – rangers

Before examining in depth how rangers may be considered under IHL, it is important to recall that, although this body of law does not explicitly mention rangers or provide them with specific safeguards, it does afford protection to the natural environment during armed conflict. The environment is not only considered civilian in character – meaning that no part of it may be directly attacked unless it constitutes a military objectiveFootnote 16 – but is also subject to specific protections, including the prohibition of using methods or means of warfare that are intended, or may be expected, to cause widespread, long-term and severe damage.Footnote 17 Moreover, IHL allows areas of particular environmental importance or fragility – where rangers typically operate – to be designated, by agreement between the parties to the conflict, as demilitarized zones.Footnote 18 Such designations prohibit military activity within those areas, including the placement of military objectives or the targeting of such objectives, thereby reinforcing both environmental protection and the safety of those engaged in conservation efforts. IHL does not, however, require the establishment of such zones. Nonetheless, the protection of areas of particular environmental importance or fragility, even in the absence of formal designation, is always ensured by the rules governing the conduct of hostilities, including the principles of distinction, proportionality and precaution, as well as the prohibition against causing widespread, long-term and severe damage to the environment.Footnote 19

Within this framework, the safeguarding of rangers’ specific functions – beyond their general protection as civilians – could be seen as a functional corollary of the existing IHL obligations to ensure protection of the natural environment given that their role is indispensable to the effective implementation of ecological protection. Ensuring the safety of rangers in the performance of their duties may thus be regarded as a natural extension of – and necessary for – protecting the environment itself, consistent with IHL’s overarching aim of securing individuals in accordance with their status and functions.Footnote 20 It is against this backdrop that the legal position and functions of rangers must be carefully assessed – a complex task, as will be shown, given the diverse circumstances in which they may find themselves during hostilities.

Rangers have traditionally been employed by ministries responsible for the environment, forestry or wildlife, as well as by non-governmental organizations, private conservation bodies and local communities, or they may operate on a volunteer basis.Footnote 21 In this capacity, they are generally regarded as civilians and are afforded protection against direct attack. This protection, however, is not absolute: Article 51(3) of Additional Protocol I to the Geneva Conventions (AP I) provides that civilians lose their protection “unless and for such time as they take a direct part in hostilities”, a principle also reflected in customary IHL.Footnote 22 The practical implications for rangers can thus be considerable if their activities are considered direct participation in hostilities between opposing parties to a conflict. Routine operations grounded in ordinary law enforcement – such as apprehending poachers, confiscating illicit equipment or dismantling trafficking networks – are not typically designed to affect the military capacity of a belligerent in support of another party to the conflict and therefore do not qualify as participation in hostilities. These actions are motivated by environmental conservationFootnote 23 rather than the pursuit of military advantage over a party to the conflict, and the protection owed to rangers as civilians therefore remains intact. By contrast, in exceptional circumstances, offensive undertakings such as actively preventing a belligerent from financing weapons through illegal wildlife trafficking or providing intelligence that directly enables or determines the timing, location or success of military operations may amount to participation in hostilities, provided that the three cumulative criteria of threshold of harm, direct causation and belligerent nexus are satisfied.Footnote 24 To consider these criteria in turn, the threshold of harm requirement could be met where disrupting a trafficking network or transmitting operational intelligence materially weakens a belligerent’s military capacity. The direct causation criterion, meanwhile, would be fulfilled where this weakening is attributable to the rangers’ actions – for example, if they themselves seize a shipment of trafficked animals or supply real-time intelligence used to plan or execute an attack. Finally, a belligerent nexus would exist if these operations were undertaken not merely to protect wildlife but specifically to undermine a belligerent’s ability to finance or sustain its military operations, thereby supporting the opposing party to the conflict. In practice, however, meeting this last criterion is particularly difficult; it requires demonstrating that the rangers’ actions were undertaken not only to harm one belligerent but also with the specific intent of supporting the other. In such circumstances, the rangers’ conduct could, at least temporarily, deprive them of civilian protection and render them lawful targets under IHL.

This analysis highlights the delicate balance that rangers must handle: routine conservation and law enforcement activities preserve their civilian status, whereas sustained or offensive engagements with armed actors that meet the established criteria may constitute direct participation in hostilities, temporarily altering the protection afforded to them under IHL. Such a balance is becoming increasingly difficult to maintain in conflict-affected regions like Kivu in the Democratic Republic of the Congo, where rangers are progressively drawn into what has been termed “green militarization”, the pursuit of conservation objectives through military-style strategies.Footnote 25 These strategies aim to achieve environmental protection goals by adopting tactics, organizational structures and operational methods traditionally associated with armed forces.Footnote 26 Rangers may undergo formal military training, carry heavy firearms and deploy advanced technologies – including surveillance drones, night-vision equipment and armoured vehicles – to deter or confront poachers and transnational criminal networks.Footnote 27 In addition to conventional patrols, operations that may be carried out in support of, or in coordination with, armed forcesFootnote 28 typically involve intelligence-gathering, the strategic disruption of illicit trafficking routes, and rapid-response interventions. This development reflects a broader shift from passive conservation toward proactive, security-oriented enforcement.Footnote 29 Yet this militarization of conservation comes at a cost – the blurring of boundaries between conservation responsibilities and military roles not only exposes rangers to greater physical danger but also compromises the integrity of their mandate.Footnote 30 In armed conflict contexts, when rangers are perceived as siding with one party to the conflict, their credibility is called into question, eroding community trust and provoking hostility from the opposing party; when their work appears driven by security or political agendas rather than the impartial protection of biodiversity, their credibility is likewise diminished.Footnote 31 The repercussions of this extend far beyond the rangers themselves, resulting in a double loss: weakened safeguards for endangered wildlife and reduced resilience of local communities whose survival depends on fragile ecosystems.Footnote 32

It is important to emphasize, however, that despite this growing militarization, most rangers do not, a priori, meet the criteria under IHL to qualify as combatants or to benefit from prisoner of war protections in situations of international armed conflict (IAC). With limited exceptions,Footnote 33 they are neither formally incorporated into a State’s regular or irregular armed forcesFootnote 34 nor placed under the “responsible command” of a party to the conflict.Footnote 35 Moreover, there appear to be no reported instances in which such a party has been formally notified, as required by Article 43(3) of AP I, that rangers, acting in their capacity as an armed law enforcement agency, have been incorporated into the armed forces. Likewise, in NIACs, rangers are rarely part of State armed forces and are even less commonly involved in carrying out a “continuous combat function”Footnote 36 for non-State armed groups.

Finally, as noted above, although rangers carry out tasks that are essential to the protection of vulnerable ecosystems and the communities that depend upon them and face heightened risks of violence, they are not granted any special protection beyond the general safeguards afforded to civilians under IHL. That being said, the functions performed by rangers may be viewed as closely aligned with humanitarian objectives. By preserving ecosystems and species of ecological significance, managing protected areas and preventing the illicit exploitation of natural resources that can sustain or exacerbate hostilities, rangers contribute not only to environmental stability but also to the fulfilment of “essential civilian needs”, including access to clean water, food security, and a healthy environment. This observation provides a compelling basis for considering whether the special protection regime afforded to relief personnel under Article 71 of AP I and customary international lawFootnote 37 could, by analogy, extend to rangers. While Article 71 traditionally applies to actors engaged in strictly defined humanitarian relief, its underlying rationale – to protect individuals performing work indispensable to civilian survival – invites reflection on the inherently humanitarian character of conservation activities. This is all the more persuasive in light of growing evidence underscoring the interdependence between ecological integrity and human survival, particularly in conflict-affected regions where communities depend directly on natural resources for their livelihoods and resilience.Footnote 38 In the same spirit, both the United Nations Human Rights CouncilFootnote 39 and the United Nations General AssemblyFootnote 40 have recognized that safeguarding ecosystems is integral to the realization of fundamental human rights, including the rights to life, health, water and food.

Extending the protection afforded to relief personnel to rangers would serve two essential purposes. First, it would reinforce the credibility and legitimacy of rangers’ conservation functions during warfare. Second, it would help ensure that their ecological tasks are carried out with the support of belligerents and without interference or threats to their mission, personnel or equipment, provided they act strictly within their conservation mandate. Such reasoning flows directly from Article 71 of AP I, which stipulates that relief personnel approved by a party to the conflict shall “be respected and protected” (para. 2) and shall, “to the fullest extent practicable”, be assisted by each party, except for reasons of imperative military necessity (para. 3). Were such recognition to be granted to rangers, it could entail the use of distinctive emblems, explicit protection of their equipment and guarantees of safe passage, measures that would facilitate essential conservation functions such as anti-poaching operations, habitat monitoring, environmental restoration and protected area management.

At the same time, the mandate of rangers aligns closely with the civil defence regime established by Articles 61–67 of AP I. Civil defence personnel are individuals tasked with protecting the civilian population from the dangers of hostilities or disasters by carrying out activities such as detecting and marking dangerous areas, decontaminating affected zones, conducting rescue operations, firefighting, providing medical assistance and safeguarding essential services.Footnote 41 Many of the tasks performed by rangers – combating wildfires, mitigating environmental hazards, ensuring the continuity of vital natural resources or evacuating local communities – fall squarely within this framework. This alignment is further illustrated by the fact that, in certain countries such as Nigeria,Footnote 42 rangers have been formally incorporated into civil defence units. Such recognition implies that rangers and their equipment, as civil defence personnel and apparatus, should benefit from heightened protection under IHL, enabling them to carry out their duties effectively. That protection, however, would not be absolute. Civil defence organizations and personnel are protected only when they are assigned by a party to the conflict to perform, and are exclusively engaged in, civil defence tasks.Footnote 43 Their protection is lost – after a warning that remains unheeded – if they commit, or are used to commit, acts harmful to the enemy outside their proper functions. This would include, for example, misusing civil defence status to shield military objectives, engaging directly in combat operations or transmitting military intelligence. Importantly, Article 65(3) of AP I specifies that carrying light individual weapons solely for maintaining order or self-defence does not constitute an act harmful to the enemy, and civil defence personnel do not lose their protection on this basis. However, in areas where hostilities are taking place or are likely to take place, parties must endeavour to limit such weapons to handguns in order to help ensure that the distinction between civil defence personnel and combatants is maintained. This is particularly relevant to rangers, who are often armed to protect themselves and others against poachers or armed criminal groups. Recognizing rangers as civil defence personnel would therefore accommodate their limited use of weapons while preserving their protection under IHL, provided their activities remain strictly defensive, aimed at maintaining order and non-combatant in nature. Such recognition would also signal clearly to belligerents that the mere possession of weapons does not render rangers lawful military targets. Furthermore, rangers would not lose their protection if they cooperated with military personnel in the performance of their civil defence tasks, or if military personnel were attached to their organization,Footnote 44 an arrangement that may often occur in practice. Finally, while engaged exclusively in their civil defence duties, civil defence organizations and their personnel, facilities and equipment are entitled to display the international distinctive sign of civil defence.Footnote 45 This measure is particularly important for rangers operating in conflict-affected areas, as it enables clear identification and reduces the risk of being mistakenly targeted.

It may therefore be argued that the protective regimes applicable to relief personnel and, even more so, to civil defence personnel could, by analogy, be extended to rangers, given the comparable nature of their functions. This interpretation, however, remains subject to important limitations. First, such an expansive interpretation remains far from settled in doctrine or practice. Second, the regime applicable to relief personnel could itself be strengthened: although it requires that such personnel be respected and protected, and that parties to the conflict refrain from interfering with their activities except for reasons of imperative military necessity, it offers little further clarification as to the precise content and scope of these obligations. Finally, neither regime was conceived with rangers in mind, and the respective protections found therein may therefore fail to encompass the distinct functions carried out by rangers or to address the particular risks inherent in the performance of conservation duties.

Enhancing rangers’ protection through IELFootnote 46

Although IHL remains highly relevant for protecting rangers as civilians – and, as suggested above, as relief or civil defence personnel – IEL can offer an additional layer of protection. Indeed, this regime is specifically designed to address the complex conservation and protection roles that rangers perform during armed conflict. By imposing affirmative obligations on States to preserve biodiversity – particularly in areas of high ecological value – IEL not only provides a normative foundation for safeguarding those entrusted with ecosystem stewardship but also establishes a legal imperative to adopt concrete and effective measures to that end. Integrating IHL’s humanitarian rationale with IEL’s ecological requirements thus offers a more coherent and resilient framework for preserving both rangers and the biodiversity they defend in times of war.

Drawing upon this premise, IEL can strengthen the protection of rangers in two complementary ways.Footnote 47 First, IEL can inform the interpretation of IHL under the Vienna Convention on the Law of Treaties,Footnote 48 particularly through the principle of systemic integration.Footnote 49 This principle allows IHL treaties to be interpreted in light of “any relevant rules of international law applicable in the relations between the parties”,Footnote 50 including those contained in IEL. Such an approach could serve to align the IHL protection regimes applicable to relief personnel and civil defence workers with the environmental functions performed by rangers. For instance, IEL – particularly certain widely ratified multilateral environmental agreements (MEAs) – could inform a purposive interpretation of the notion of “relief actions” under Article 71(1)–(2) of AP I. This interpretation would encompass environmental interventions indispensable to human survival, rather than confining relief to orthodox humanitarian modalities, in light of the interdependence between ecosystems and human well-being. Indeed, this interconnection is explicitly acknowledged in the preambleFootnote 51 to the Convention on Biological Diversity (Biodiversity Convention),Footnote 52 which underscores the intrinsic link between human welfare and ecosystem health; in the Convention on Wetlands of International Importance Especially as Waterfowl Habitat (Ramsar Convention),Footnote 53 as reinforced by the Changwon Declaration on Human Well-being and Wetlands,Footnote 54 which highlights the importance of wetland protection for human benefit; in the preamble of the Convention Concerning the Protection of the World Cultural and Natural Heritage (World Heritage Convention),Footnote 55 which recognizes that safeguarding natural and cultural heritage of outstanding universal value is a duty owed to all humanity, thereby implying benefits for human prosperity; and in the preamble of the Revised African Convention on the Conservation of Nature and Natural Resources (African Convention),Footnote 56 which affirms the connectedness between natural resources, human security and economic development. In the same vein, by acknowledging the intrinsic bond that exists between environmental integrity and human well-being, these MEAs could inform an interpretation of the tasks performed by civil defence personnel to include not only those directly aimed at protecting the civilian population against the dangers of hostilities or disasters – as formally envisaged in Article 61(a) of AP I – but also environmental functions undertaken by rangers that are indispensable to safeguarding human welfare. Such duties entail the protection and restoration of potable water sources, the prevention and remediation of pollution incidents and the conservation of natural areas that underpin local livelihoods and food security. In doing so, IEL would help ensure that the vital environmental roles underpinning human survival are recognized as integral to humanitarian relief and civil defence operations.

Second, beyond contributing to the interpretation of IHL, most MEAs are widely regarded as remaining applicable during armed conflict, unless they expressly provide otherwise.Footnote 57 While the present study does not engage with the broader doctrinal debates concerning the applicability of MEAs during warfare, nor with the complex question of how IHL and IEL norms interact in such circumstances, it is important to clarify one point. The instruments referred to in the previous paragraph, insofar as they are relevant to this analysis, are assumed to remain in force during armed conflict.Footnote 58 Indeed, the World Heritage Convention, the Ramsar Convention and the African Convention provide for their applicability during armed conflict, either expressly or by inference.Footnote 59 By contrast, the Biodiversity Convention and the Convention on International Trade in Endangered Species (CITES)Footnote 60 are formally silent on the matter, but are nonetheless generally presumed to continue in force during warfare.Footnote 61 It should, however, be noted that notwithstanding the general applicability of these instruments, two exceptions may arise: first, when it is expressly stated that a specific rule, or part thereof, does not apply; and second, when the application of a specific rule, for which no exemption is specified, would be incompatible with a rule of IHL, a determination that must be made on a case-by-case basis.Footnote 62 We will return briefly to this last point below.

That being said, the applicability of MEAs to the work of rangers is more complex than it may initially appear. As with instruments of IHL, most MEAs make no explicit reference to rangers; however, MEAs differ fundamentally from IHL because of the distinct scopes and purposes of these bodies of law. Whereas IHL does not set out obligations to establish protected areas (leaving their creation entirely voluntary, as noted above), MEAs impose detailed, affirmative duties aimed at environmental protection and conservation, including explicit obligations to designate, manage and monitor protected areas through concrete and effective measures.Footnote 63 The Biodiversity Convention, for instance, obliges States to establish systems of protected areas where necessary,Footnote 64 to regulate and manage biological resources both within and beyond those areas so as to ensure their conservation and sustainable use,Footnote 65 and to rehabilitate and restore degraded ecosystems and threatened species through the development and implementation of appropriate management strategies.Footnote 66 Similarly, the Ramsar Convention requires parties to create nature reserves on wetlands,Footnote 67 to integrate wetland conservation into national planning and implementation processes, and to “promote personnel in the fields of wetland research, management, and wardening”.Footnote 68 The African Convention obliges States to adopt and implement measures to achieve the objectives of the ConventionFootnote 69 – which include “fostering the conservation and sustainable use of natural resources”Footnote 70 – and “to establish, maintain, and extend, as appropriate, conservation areas”.Footnote 71 The World Heritage Convention goes further still, mandating that States identify, protect, conserve, present and transmit to future generations designated cultural and natural sitesFootnote 72 – an obligation that includes, where such mechanisms are absent, the creation of services equipped with appropriate personnel and resources to carry out these functions.Footnote 73 While CITES does not explicitly address protected areas, it lays down complementary obligations relevant to this context; for example, it requires parties to adopt domestic measures ensuring the effective protection of listed species.Footnote 74

Ultimately, the concrete implementation of conservation, protection and management obligations depends on States making adequate resources available, including trained personnel and institutional support. Rangers occupy a central position in this framework: they are the front-line agents through whom States give practical effect to their IEL treaty commitments. It therefore follows that States must not only entrust rangers with protective responsibilities but also ensure that they are equipped to discharge them safely and effectively. This requirement becomes particularly acute in situations of armed conflict, where the risks facing rangers intensify, making it essential that protective measures be tailored to the specific nature of their work and the volatile environments in which they operate. In this regard, both the World Heritage CommitteeFootnote 75 and the International Union for Conservation of Nature (IUCN)Footnote 76 – key actors in the implementation of the World Heritage Convention and Biodiversity Convention respectively – stress that protected areas affected by armed conflict require strengthened ranger protection, enhanced staffing and training, increased resources and support, and improved security protocols, highlighting that safeguarding rangers is an essential element of States’ broader conservation obligations.

Building on these institutional expectations, guidance may be drawn, inter alia, from emerging best practices such as those reflected in the Draft Protected and Conserved Area Rangers Convention.Footnote 77 Essential protections for rangers include formal recognition of their protected status, authorization to display official emblems, guarantees of safe passage and assistance, secure means of transport and communication, and dedicated facilities for conservation planning and operations. Equally indispensable are operational safeguards; these include clearly defined protocols for engagement with armed actors, comprehensive logistical support, contingency planning,Footnote 78 personal protective equipment, and reliable medical and emergency response systems. Strong accountability mechanisms must address crimes committed against rangers as well as, where relevant, those perpetrated by them. These mechanisms should be supported by a clear disciplinary framework and by robust recruitment and vetting processes designed to prevent violations.Footnote 79 Rangers should also be provided with official identification, and in conflict zones, light individual weapons such as handguns for self-defence where authorized. In parallel, rangers must receive law enforcement training aligned with international human rights standards, ensuring that the legal framework governing their conduct is fully understood. Pre-deployment training should further encompass cultural awareness, non-violent strategies, rules of engagement and de-escalation techniques.Footnote 80 Where weapons are authorized, rangers should also be rigorously trained in their safe and lawful use.Footnote 81

In this context, it can be contended that States will be able to discharge their obligations under the above MEAs only if they ensure that rangers are both operationally capable and adequately protected. Consequently, ensuring rangers’ security is not merely a matter of policy choice but a legal imperative deriving from the duty to conserve biodiversity, particularly in areas of exceptional ecological value when threatened by warfare. Absent such measures, rangers would be unable to prevent the illegal exploitation of natural resources, including endangered species, or to secure the sustainable management of ecosystems and wetlands, thereby exposing States to potential breaches of their IEL commitments. Within this framework, the security and operational capacity of rangers are not ancillary considerations but essential components of States’ overarching duty to ensure the effective governance of ecological systems.

Nevertheless, it should be noted that the protection afforded by MEAs may be impeded during armed conflict for two principal reasons, one legal and the other practical. On the one hand, from a legal perspective, as recalled above, this protective framework may be displaced, in whole or in part, by the specific IHL rules, including those governing the conduct of hostilities, which may, in certain circumstances, constitute the lex specialis.Footnote 82 For instance, when rangers move beyond conservation and law enforcement functions and take a direct part in hostilities, they may forfeit their civilian protection for the duration of their direct participation and may be lawfully targeted while so engaged. The same logic applies where rangers are treated as civil defence personnel: if their actions are acts harmful to the adversary outside their proper tasks, in addition to losing their protection under IHL, they may likewise lose the protections that would otherwise be afforded by environmental instruments. Even then, however, IHL preserves important safeguards. As noted above, protection under this body of law may cease only after a warning specifying a reasonable time limit has been given and ignored.Footnote 83 Certain acts, such as cooperating with the military in civil defence tasks or carrying light weapons for self-defence, are explicitly not considered harmful.Footnote 84 These exceptions are particularly important because rangers often work closely with the military and carry weapons while performing conservation duties in conflict zones.

On the other hand, from a practical standpoint, active hostilities may frequently impair States’ ability to honour the obligations contained in MEAs. Because many obligations to protect ecologically important areas are obligations of due diligence,Footnote 85 their fulfilment depends on States’ institutional and operational capacity. In practice, capacity constraints may entirely prevent the deployment of rangers, require their withdrawal – particularly when their safety cannot be guaranteed – or lead to the militarization of conservation through the provision of military equipment to rangers or the deployment of armed forces alongside them. As noted above, such militarization – whether through arming rangers or integrating military units into conservation operations – not only undermines the civilian nature of protected area management but also jeopardizes the civilian status of the rangers themselves. This blurring of roles complicates the distinction between combatants and civilians and increases the risk that rangers will be perceived as, or become, participants in hostilities, particularly when they provide direct support to armed forces or are otherwise directly involved in military operations.

Taken together, these considerations call for the establishment of finely tuned, context-specific protections and mandates for rangers: preserving their operational capacity is vital to fulfilling States’ environmental obligations, but such measures must be crafted with care to avoid blurring the civilian–combatant divide and thereby producing adverse legal or operational effects.

Protecting rangers in non-international armed conflicts

The final issue concerns the scope of non-State armed groups’ obligations to respect and protect rangers in NIACs. In NIACs, as in situations of IAC, rangers are, in principle, civilians and may not be deliberately targeted by either State or non-State forces, except for such time as they take a direct part in hostilities.Footnote 86 Unless special agreements are concluded between belligerents to grant them additional protection, as encouraged by Article 3 common to the four Geneva Conventions, rangers do not benefit from any distinct status comparable to that afforded to civil defence personnel in IACs. Additional Protocol II (AP II) creates no such regime in NIACs, and customary law does not recognize one, though some commentators have argued that it should.Footnote 87 Extending protection to rangers by analogy with humanitarian relief personnel is also more problematic in NIACs under treaty law. Unlike in the context of IACs, AP II contains no explicit provision granting such personnel heightened protection. Still, under customary international law, humanitarian relief personnel in NIACs must also be respected and protected.Footnote 88 In this regard, the commentary to Rule 31 of the ICRC Customary Law Study has underlined that Article 18 of AP II requires the organization of relief actions for civilians in need, which necessarily entails respect and protection for the humanitarian relief personnel carrying them out so that they can perform their duties effectively.Footnote 89 By extension, it could be argued that rangers should benefit from similar reinforced protection, given the proximity of their functions to those of relief personnel; whether such a framework can legitimately be applied to rangers remains unsettled, however.

The absence of a dedicated IHL-based protective regime for rangers makes the potential application of IEL frameworks to armed groups all the more significant, as a means of strengthening rangers’ protection beyond that afforded by their civilian status. That said, this approach raises both legal and practical challenges. Legally, States are often reluctant to extend IEL obligations to non-State armed groups, fearing that doing so could confer de facto legitimacy upon them.Footnote 90 Nonetheless, persuasive – albeit contested – arguments suggest that IEL may bind not only States but also non-State armed groups, insofar as the latter exercise effective territorial control and assume quasi-governmental functions.Footnote 91 Undoubtedly, States bear the primary responsibility for ensuring that rangers are respected and protected from armed groups, including by deploying the necessary military means, enabling them to carry out their conservation duties – for example, by providing logistical support, securing access to protected areas or maintaining environmental monitoring – and arresting or prosecuting those responsible for acts of violence against them. At the same time, non-State armed groups with de facto control over territory may also be bound under IEL to respect rangers and refrain from interfering with their conservation activities.

From a practical standpoint, critics may contend that even if environmental obligations formally applied to non-State armed groups, they would often remain ineffective in practice, since such groups frequently lack the material capacity to comply. This objection, however, warrants qualification. Most environmental obligations relevant to the conservation and management of protected areas – which indirectly enhance the protection of rangers – are obligations of due diligence. They must therefore be implemented to the maximum extent feasible in the prevailing circumstances.Footnote 92 In principle, non-State armed groups that exercise territorial control and possess sufficient institutional capacity to administer protected areas could assume responsibility for ensuring the protection of rangers. That said, one must admit that rangers are unlikely to cooperate directly with non-State armed groups engaged in hostilities against State actors, as they generally operate under the authority of the State, either as public officials or as employees of organizations whose mandates and legitimacy stem from their association with State institutions. Any direct collaboration with a non-State actor opposing the State would almost certainly sever that relationship and could be perceived as disloyal, or even tantamount to treason. Nonetheless, in situations where State authorities are absent from key biodiversity areas, conservation authorities may, in practice, find themselves compelled to negotiate with the non-State armed groups controlling those territories in order to secure at least a minimum level of protection for these sites.Footnote 93

Concluding observations

Under IHL, rangers are protected first and foremost as civilians and might, by analogy, be assimilated to civil defence or humanitarian relief personnel. This, however, remains essentially a de lege ferenda proposition. Moreover, as civil defence personnel are not expressly protected in NIACs, such assimilation of rangers cannot be sustained in that context. By contrast, IEL provides a complementary framework that safeguards the ecosystems in which rangers operate and regulates activities, such as wildlife trafficking, that lie at the core of their mission. In principle, therefore, while not explicitly provided in MEAs, a protective regime recognizing the role of rangers and ensuring their safety could be derived from those instruments, as such a regime is necessary to implement the obligations they contain. Yet this approach hinges on contested questions concerning IEL’s applicability during armed conflict, particularly regarding the complex interaction of MEAs’ provisions with parallel IHL obligations. These challenges are particularly acute in NIACs, where the notion of extending environmental obligations to non-State armed groups remains contentious. Even where such obligations are recognized, expecting these groups – even those with territorial control and quasi-State structures – to protect State-mandated rangers will often be unrealistic, given the latter’s affiliation with authorities that armed actors seek to challenge.

Against this backdrop, integrating the protection of rangers into ongoing reflections on strengthening the protection of essential service providers in armed conflictFootnote 94 would be highly valuable. Just as providers of water, energy and other critical services are indispensable to civilian populations and face heightened risks in wartime, rangers perform an equally vital role in safeguarding biodiversity hot spots that are frequently targeted for their resources, in preventing poaching and illegal logging, and in maintaining ecosystem services – such as clean water, fertile soil, carbon sequestration and climate regulation – that directly underpin human health, food security and community resilience.Footnote 95 Extending to rangers the recommendations developed for essential service providers – including operational continuity plans, improving visibility, cultivating relationships with local actors to build resilience, negotiating safe passage, and dedicating staff to monitor risks and coordinate protective measuresFootnote 96 – would not only enhance their safety but would also help to ensure that their indispensable work continues to support both ecological integrity and the survival and welfare of the human populations that depend on the ecosystems they protect.

Footnotes

*

I would like to extend my deep gratitude to the members of the editorial team, as well as to the legal advisers of the International Committee of the Red Cross, for their numerous and insightful comments during the preparation of this article. Any remaining errors are mine alone. I am also sincerely grateful to Keith Begg (Operations Director, Niassa Carnivore Project, https://niassalion.org), Jonathan Churcher (General Manager, International Ranger Federation), Chris Galliers (President, International Ranger Federation) and Lars Scharfe (European Representative, International Ranger Federation) for generously sharing their perspectives on the extremely difficult circumstances currently faced by rangers operating in conflict-affected areas, particularly in Africa.

The advice, opinions and statements contained in this article are those of the author/s and do not necessarily reflect the views of the ICRC. The ICRC does not necessarily represent or endorse the accuracy or reliability of any advice, opinion, statement or other information provided in this article.

References

1 See the list of titles used to designate rangers in the Appendix (Terminology) of the Ranger Code of Conduct, 2021, p. 10, available at: www.internationalrangers.org/wp-content/uploads/2023/07/Ranger-Code-of-Conduct-Version-1.0_English1.pdf (all internet references were accessed in December 2025). The Ranger Code of Conduct is a globally developed set of professional and ethical standards issued by the International Ranger Federation (IRF) – a global organization representing ranger associations and supporting rangers worldwide – to guide rangers’ conduct in protecting wildlife, ecosystems and local communities. Its development followed a broad, multi-stakeholder consultation process conducted after the 2019 Chitwan Declaration at the World Ranger Congress. The IRF has formally adopted the Code in its regulations, making it part of the Federation’s guiding framework for the global ranger community. Since then, the Code has been promoted via the Universal Ranger Support Alliance (URSA) – a coalition of leading conservation non-governmental organizations (NGOs) and the IRF working together to professionalize and support the global ranger workforce – and progressively adopted by ranger associations, NGOs and conservation organizations as a guiding template to adapt in local contexts. See, in this regard, the IRF Regulations, 14 November 2022, p. 2, available at: www.internationalrangers.org/wp-content/uploads/Regulations-IRF-as-Revised-November-14-2022.pdf; URSA, Action Plan for Supporting Implementation of the IRF’s Chitwan Declaration and Furthering the Professionalization of Rangers (2021–2025), available at: www.internationalrangers.org/wp-content/uploads/2023/11/URSA-Action-Plan_English-updated-2.pdf.

2 Ranger Code of Conduct, above note 1, p. 6. See also World Wide Fund for Nature (WWF), “Rangers and Conservation”, available at: www.worldwildlife.org/our-work/wildlife/rangers-and-conservation/.

3 See Chris Galliers et al., “Conservation Casualties: An Analysis of On-Duty Ranger Fatalities (2006–2021)”, PARKS, Vol. 28, No. 1, 2022, p. 39; Britt Thielen, Rohit Singh, Chris Galliers and Jonathan Churcher, “Protecting Those Who Protect: Rangers and Labour Rights”, International Union Rights, Vol. 32, No. 1, 2025, p. 25; Sue Stolton et al., “Essential Planetary Health Workers: Positioning Rangers within Global Policy”, Conservation Letters, Vol. 16, No. 4, 2023, pp. 3–4.

4 For a list of functions performed by rangers, see Rangers Code of Conduct, above note 1, p. 6. See also WWF, above note 2; Rohit Singh et al., “The Vital Role of Rangers in Conservation”, Parks Stewardship Forum, Vol. 37, No. 1, 2021, pp. 129–130.

5 R. Singh et al., above note 4, p. 130.

6 See, e.g., Laurel Neme, “For Rangers on the Front Lines of Anti-Poaching Wars, Daily Trauma”, National Geographic, 27 June 2014, available at: www.nationalgeographic.com/animals/article/140627-congo-virunga-wildlife-rangers-elephants-rhinos-poaching.

7 See Britta Sjöstedt, “The Role of Multilateral Environmental Agreements in Armed Conflict: ‘Green-Keeping’ in Virunga Park. Applying the UNESCO World Heritage Convention in the Armed Conflict of the Democratic Republic of the Congo”, Nordic Journal of International Law, Vol. 82, No. 1, 2013, p. 132. See also Emmet Livingstone, “The Rangers Turning the DRC’s ‘Triangle of Death’ Back into a Thriving Wildlife Reserve”, The Guardian, 20 August 2024, available at: www.theguardian.com/environment/article/2024/aug/20/drc-wildlife-reserve-upemba; Tristan McConnell, “The Bloody Toll of Congo’s Elephant Wars”, GQ, 16 April 2018, available at: www.gq.com/story/inside-the-ivory-wars; Sasha Jesperson, “Illicit Wildlife Crime: Entrenched in the Crime, Conflict, and Terror Nexus”, RUSI Commentary, 23 July 2014, available at: www.rusi.org/explore-our-research/publications/commentary/illicit-wildlife-crime-entrenched-crime-conflict-and-terror-nexus. For a thorough analysis of the application of IHL to illegal activities undertaken by organized criminal groups – including wildlife trafficking – in armed conflicts, see the issue of the Review devoted to organized crime (Vol. 105, No. 923, 2023) and in particular the interview with Ghada Waly, “(Transnational) Organized Crime and Corruption in Conflict Settings”, pp. 610–614.

8 On the extensive roles played by rangers in Virunga National Park, Democratic Republic of the Congo, see Britta Sjöstedt, The Role of Multilateral Environmental Agreements, Hart, Oxford, 2020, p. 230.

9 International Union for Conservation of Nature (IUCN), Conflict and Conservation, Nature in a Globalised World Report No 1, Gland, 2021, p. 20, available at: https://portals.iucn.org/library/sites/library/files/documents/FRS-001-En.pdf

10 See Tafadzwa Mushonga, “The Militarisation of Conservation and Occupational Violence in Sikumi Forest Reserve, Zimbabwe”, Conservation and Society, Vol. 19, No. 1, 2021, pp. 5–6.

11 Protocol Additional (I) to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of International Armed Conflicts, 1125 UNTS 3, 8 June 1977 (entered into force 7 December 1978) (AP I), Arts 48, 51.

12 AP I, Arts 12–18. See also Geneva Convention (I) for the Amelioration of the Condition of the Wounded and Sick in Armed Forces in the Field of 12 August 1949, 75 UNTS 31 (entered into force 21 October 1950), Arts 24–26; Geneva Convention (IV) relative to the Protection of Civilian Persons in Time of War of 12 August 1949, 75 UNTS 287 (entered into force 21 October 1950), Art. 20; AP I, Art. 15.

13 AP I, Arts 61–67.

14 Ibid., Art. 71.

15 See the normative process described in Raphaël van Steenberghe, “The Interplay between International Humanitarian Law and International Environmental Law: Towards a Comprehensive Framework for a Better Protection of the Environment in Armed Conflict”, Journal of International Criminal Justice, Vol. 20, No. 5, 2022; Raphaël van Steenberghe, “International Environmental Law as a Means for Enhancing the Protection of the Environment in Warfare: A Critical Assessment of Scholarly Theoretical Frameworks”, International Review of the Red Cross, Vol. 105, No. 924, 2023. See also Anne Dienelt, Armed Conflicts and the Environment: Complementing the Laws of Armed Conflict with Human Rights Law and International Environmental Law, Springer, Cham, 2022, pp. 277–281; Karen Hulme, “Using Environmental Law to Enhance Biodiversity and Nature Conservation during Armed Conflict”, Journal of International Criminal Justice, Vol. 20, No. 5, 2022.

16 UNGA Res. 77/104, “Protection of the Environment in Relation to Armed Conflicts”, 7 December 2022, Annex (PERAC Principles), Principles 13(3), 14; Jean-Marie Henckaerts and Louise Doswald-Beck (eds), Customary International Humanitarian Law, Vol. 1: Rules, Cambridge University Press, Cambridge, 2005 (ICRC Customary Law Study), Rule 43 and commentary, p. 143, and State practice thereto, available at: https://ihl-databases.icrc.org/en/customary-ihl/rules. For fuller detail, see ICRC, Guidelines on the Protection of the Environment in Armed Conflict: Rules and Recommendations Relating to the Protection of the Natural Environment under International Humanitarian Law, with Commentary, Geneva, 2020 (ICRC Guidelines), para. 18 and Rule 5, available at: www.icrc.org/en/publication/4382-guidelines-protection-natural-environment-armed-conflict. See also Helen Obregón Gieseken and Vanessa Murphy, “The Protection of the Natural Environment under International Humanitarian Law: The ICRC’s 2020 Guidelines”, International Review of the Red Cross, Vol. 105, No. 924, 2023, p. 1187.

17 AP I, Arts 35(3), 55(1); ICRC Customary Law Study, above note 16, Rule 45. See also PERAC Principles, above note 16, Principle 13(2); ICRC Customary Law Study, above note 16, Rule 44.

18 AP I, Art. 60; PERAC Principles, above note 16, Principle 14. PERAC Principle 18 protects such areas from attack in addition to any additional agreed protections. See also ICRC Guidelines, above note 16, para. 208; ICRC, International Humanitarian Law and the Challenges of Contemporary Armed Conflicts: Building a Culture of Compliance for IHL to Protect Humanity in Today’s and Future Conflicts, Geneva, September 2024, pp. 51–52. See also A. Dienelt, above note 15, pp. 298–303; Jérôme de Hemptinne, “Increasing the Safeguarding of Protected Areas Threatened by Warfare through International Environmental Law”, International Review of the Red Cross, Vol. 105, No. 924, 2023, pp. 1397–1400.

19 ICRC Guidelines, above note 16, Recommendation 17.

20 See e.g. ICRC Customary Law Study, above note 16, Rule 25 and commentary, adopting the same reasoning regarding the protection of medical personnel in NIACs under Article 3 common to the four Geneva Conventions (common Article 3), which requires that the wounded and sick be collected and cared for. Although common Article 3 does not explicitly mention medical personnel, their protection is understood as “implicit in common Article 3 …, which requires that the wounded and sick be collected and cared for, because the protection of medical personnel is a subsidiary form of protection granted to ensure that the wounded and sick receive medical care”. The rule that medical personnel must be respected and protected is explicitly stated in Article 9 of Protocol Additional (II) to the Geneva Conventions of 12 August 1949, and relating to the Protection of Victims of Non-International Armed Conflicts, 1125 UNTS 609, 8 June 1977 (entered into force 7 December 1978) (AP II). See also Alexander Breitegger, “The Legal Framework Applicable to Insecurity and Violence Affecting the Delivery of Health Care in Armed Conflicts and Other Emergencies”, International Review of the Red Cross, Vol. 95, No. 889, 2014, p. 91.

21 See R. Singh et al., above note 4, p. 130.

22 ICRC Customary Law Study, above note 16, Rule 6.

23 In line with this, rangers’ activities are considered law enforcement operations and are governed by human rights obligations and standards (rather than IHL rules governing the conduct of hostilities). This is reflected in the rule of the Ranger Code of Conduct (above note 1, p. 9) entitled “Use of Force”, which states: “My primary goal is to communicate and to proactively engage to change the behaviour of those in breach of laws or regulations. I will only use force as a last resort. This will be the minimum force necessary to make a situation safe and will always be proportionate to the threat I face as I perform my duty within the law. I am responsible and accountable for any use of force and must consider this prior to any action.”

24 Nils Melzer, Interpretative Guidance on the Notion of Direct Participation in Hostilities under International Humanitarian Law, ICRC, Geneva, 2009, pp. 46–64.

25 IUCN, above note 9, p. 20. See also Ivan Mugyenzi Ashaba and Esther Marijnen, “‘We Are Soldiers Now’: Green Militarism and (Foreign-Assisted) Military Training in Conservation”, International Affairs, Vol. 101, No. 2, 2025, pp. 568–570; Christopher Day, William Moreto and Riley Ravary, “Ranger/Soldier: Patterns of Militarizing Conservation in Uganda”, Journal of Eastern African Studies, Vol. 17, No. 1–2, 2023, pp. 57–59; Rosaleen Duffy, “Waging a War to Save Biodiversity: The Rise of Militarized Conservation”, International Affairs, Vol. 90, No. 4, 2014, p. 833–834.

26 See the references cited in above note 25.

27 See the references cited in above note 25.

28 B. Sjöstedt, above note 8, pp. 232–233. As Sjöstedt observes in the context of the Democratic Republic of the Congo, the situation became particularly complex when rangers and the army, despite conducting joint patrols, clashed over the army’s illegal exploitation of natural resources within Virunga National Park (p. 233), and when joint conservation operations were informally conducted not only with national armed forces but also with the UN Organization Stabilization Mission in the Democratic Republic of the Congo, which had received a mandate to combat the illegal exploitation and trade of natural resources using military means (pp. 235–238).

29 Elaine (Lan Yin) Hsiao, Adrian Garside, Doug Weir and Andrew J. Plumptre, “Protected Zones in Context: Exploring the Complexity of Armed Conflicts and Their Impacts on the Protection of Biodiversity”, International Review of the Red Cross, Vol. 105, No. 924, 2023, pp. 1418–1419.

30 Rosaleen Duffy et al., “Why We Must Question the Militarization of Conservation”, Biological Conservation, Vol. 232, 2019, pp. 68–69.

31 Ibid. See also E. Hsiao et al., above note 29, p. 1418.

32 R. Duffy et al., above note 30, pp. 68–69.

33 On how the Wildlife Service has been integrated into South Soudan’s “Organized Forces”, see Christopher Day and Adrian Garside, “Wildlife Management in South Sudan, 1901–2012: Conservation amidst Conflict”, African Studies Review, Vol. 67, No. 3, 2024, p. 627.

34 Geneva Convention (III) relative to the Treatment of Prisoners of War of 12 August 1949, 75 UNTS 135 (entered into force 21 October 1950), Art. 4(1)–(2).

35 AP I, Art. 43(1).

36 On the notion of “continuous combat function”, see N. Melzer, above note 24, pp. 31–35.

37 ICRC Customary Law Study, above note 16, Rule 31. It is important to note that Rule 31 according to which “[h]umanitarian relief personnel must be respected and protected” applies in both international and non-international armed conflicts.

38 UN Environment Programme (UNEP), “Damage to Gaza Causing New Risks to Human Health and Long-Term Recovery – New UNEP Assessment”, press release, 18 June 2024, available at: www.unep.org/news-and-stories/press-release/damage-gaza-causing-new-risks-human-health-and-long-term-recovery; Geneva Environment Network, “Human Rights, Biodiversity and the Role of Geneva”, 20 March 2025, available at: https://www.genevaenvironmentnetwork.org/resources/updates/human-rights-biodiversity-and-the-role-of-geneva/.

39 HRC Res. 48/13, “The Human Right to a Clean, Healthy and Sustainable Environment”, 18 October 2021. On the importance of protecting the environment in war through international human rights law, see Daniil Ukhorskiy, “Environmental Destruction in War: A Human Rights Approach”, EJIL: Talk!, 19 June 2023, available at: www.ejiltalk.org/environmental-destruction-in-war-a-human-rights-approach/.

40 UNGA Res. 76/300, “The Human Right to a Clean, Healthy and Sustainable Environment”, 28 July 2022.

41 AP I, Art. 61(a).

42 See Nigeria Security and Civil Defence Corps, “FG Creates Agro Rangers, Set to Deploy 3,000 to Farms, Ranches”, available at: https://nscdc.gov.ng/fg-creates-agro-rangers-corps-set-to-deploy-3000-to-farms-ranches/.

43 AP I, Art. 62(1).

44 Ibid., Art. 65(2)(b).

45 Ibid., Art. 66.

46 The application of international human rights law in armed conflict could also reinforce the protection of rangers. Although this falls beyond the scope of the present article, it is worth noting that human rights obligations are generally structured around a tripartite duty to respect, protect and fulfil. This framework increasingly encompasses the right to a healthy environment, which has gained growing recognition in international law. Under the duty to respect, States must refrain from interfering with rangers’ work, ensuring that they are not targeted, obstructed, intimidated or harassed. The duty to protect requires States to shield rangers from third-party threats, including non-State armed groups, poachers and organized criminal networks, through robust legal frameworks, effective investigations, prosecutions and operational security. The duty to fulfil obliges States to take proactive measures, providing rangers with adequate training, equipment and institutional support to manage protected areas, deter illicit activities and monitor fragile ecosystems, even amid armed conflict. On the application of these tripartite obligations to human rights, in particular the right to health, in armed conflict situations, see Katherine H. A. Footer and Leonard S. Rubenstein, “A Human Rights Approach to Health Care in Conflict”, International Review of the Red Cross, Vol. 95, No. 889, 2013, pp. 179–180.

47 R. van Steenberghe, “The Interplay between IHL and IEL”, above note 15, p. 1135. See also K. Hulme, above note 15, pp. 1161–1163, and in particular on protected areas, pp. 1169–1171.

48 Vienna Convention on the Law of Treaties, 1155 UNTS 331, 23 May 1969 (entered into force 27 January 1980), Arts 31–32.

49 Ibid., Art. 31(3)(c).

50 Ibid.

51 According to R. van Steenberghe, “The Interplay between IHL and IEL”, above note 15, p. 1130, the concerns reflected in the preambles of specific MEAs may help highlight the significance of particular environmental elements and can consequently inform the interpretation of corresponding IHL provisions.

52 Convention on Biological Diversity, 1760 UNTS 79, 5 June 1972 (entered into force 29 December 1993) (Biodiversity Convention), Preamble. The Biodiversity Convention has been ratified by 196 parties. Its preamble expressly acknowledges that the contracting parties are “[a]ware that conservation and sustainable use of biological diversity is of critical importance for meeting the food, health and other needs of the growing world population, for which purpose access to and sharing of both genetic resources and technologies are essential”.

53 Convention on Wetlands of International Importance Especially as Waterfowl Habitat, 996 UNTS 245, 2 February 1971 (entered into force 21 December 1975) (Ramsar Convention), Art. 3. The Ramsar Convention has been ratified by 172 parties.

54 The Changwon Declaration on Human Well-being and Wetlands was adopted in 2008 at the 10th Meeting of the Conference of the Contracting Parties to the Ramsar Convention on Wetlands (COP10) in Changwon, Republic of Korea. It links wetland conservation with human well-being, climate change mitigation, water security and sustainable development, reinforcing the Ramsar Convention’s goal of promoting the wise use of wetlands for both people and nature. Ramsar Convention Secretariat, Changwon Declaration on Human Well-being and Wetlands, COP10, 2008, available at: www.ramsar.org/sites/default/files/documents/library/cop10_changwon_english.pdf.

55 Convention Concerning the Protection of the World Cultural and Natural Heritage, 1037 UNTS 151, 16 November 1972 (entered into force 17 December 1975) (World Heritage Convention), Art. 11(4). The World Heritage Convention has been ratified by 195 parties. Its preamble notes that “the existing international conventions, recommendations and resolutions concerning cultural and natural property demonstrate the importance, for all the peoples of the world, of safeguarding this unique and irreplaceable property, to whatever people it may belong”.

56 Revised African Convention on the Conservation of Nature and Natural Resources, 1001 UNTS 3, 11 July 2003 (entered into force 23 July 2016) (African Convention), Art. XV(2). The African Convention has been ratified by 17 African States. Its preamble reaffirms “that States are responsible for protecting and conserving their environment and natural resources and for using them in a sustainable manner with the aim to satisfy human needs according to the carrying capacity of the environment”.

57 See R. van Steenberghe, “The Interplay between IHL and IEL”, above note 15, p. 1135; K. Hulme, above note 15, pp. 1177–1179.

58 See ICRC Guidelines, above note 16, paras 29–36.

59 Report of the Sixty-Third Session of the International Law Commission, UN Doc A/66/10, 2011, Annex E, pp. 361–362; ICRC Guidelines, above note 16, para. 31. For an analysis of the specific provisions that directly or indirectly provide for their applicability during armed conflict, see UNEP, Protecting the Environment during Armed Conflict: An Inventory and Analysis of International Law, Nairobi, 2009, pp. 35–39.

60 Convention on International Trade in Endangered Species of Wild Fauna and Flora, 993 UNTS 243, 3 March 1973 (entered into force 1 July 1975) (CITES). CITES has been ratified by 185 parties.

61 ICRC Guidelines, above note 16, para. 32. The International Law Commission’s (ILC) Draft Articles on the Effects of Armed Conflicts on Treaties specify in Article 7 and their Annex an indicative list of treaties, including those “relating to the international protection of the environment”, whose subject matter suggests that they remain in force, fully or partially, during armed conflict. ILC, “Draft Articles on the Effects of Armed Conflicts on Treaties”, Yearbook of the International Law Commission, Vol. 2, Part 2, 2021, p. 139. See also Karen Hulme, War Torn Environment: Interpreting the Legal Threshold, Brill Nijhoff, Leiden and Boston, MA, 2004, pp. 140–144.

62 As noted by the ICRC, “[t]his potential incompatibility between a rule of international environmental law and IHL must be considered on a rule-by-rule basis, but where a rule of international environmental law is more protective of the natural environment than the parallel rule of IHL, this difference should be interpreted as incompatibility only if there are clear reasons for doing so”. ICRC Guidelines, above note 16, para. 33. See also K. Hulme, above note 15, pp. 1161–1163

63 See A. Dienelt, above note 15, pp. 307–312.

64 Biodiversity Convention, above note 52, Art. 8(A).

65 Ibid., Art. 8(c).

66 Ibid., Art. 8(f).

67 Ramsar Convention, above note 53, Art. 4(1).

68 Ibid., Art. 4(5).

69 African Convention, above note 56, Art. IV.

70 Ibid., Art. II(2).

71 Ibid., Art. XII(1).

72 World Heritage Convention, above note 55, Art. 4.

73 Ibid., Art. 5(b).

74 CITES, above note 60, Art. VIII.

75 See e.g. World Heritage Committee (WHC), “State of Conservation of the Properties Inscribed on the World Heritage List”, Decision 41 COM 7, 41st Session of the World Heritage Committee, Krakow, 2017, pp. 140–141, available at: https://whc.unesco.org/en/decisions/6940/. It is interesting to note that under Article 22 of the World Heritage Convention, above note 55, the WHC can provide crucial international assistance, including training for staff and specialists and the provision of equipment that the State concerned lacks. B. Sjöstedt, above note 8, pp. 228–231, offers a notable example of this mechanism in practice, showing how it was used in Virunga National Park to strengthen ranger protection amid a highly complex security context.

76 See e.g. IUCN, Resolutions and Recommendations: World Conservation Congress, Barcelona, 5–14 October 2008, Recommendation 4.119, available at: https://portals.iucn.org/library/sites/library/files/documents/WCC-4th-005.pdf; IUCN, “Strengthening Institutional and Societal Capacities for Protected Area Management in the 21st Century”, Recommendations of the 5th IUCN World Parks Congress, Durban, 8–17 September 2003, Recommendation 5.01, para. 2(b), available at: www.uicnmed.org/web2007/CDMURCIA/pdf/durban/recommendations_en.pdf.

77 IRF, Draft Protected and Conserved Area Rangers Convention, Arts 3, 4, available at: www.internationalrangers.org/wp-content/uploads/2023/11/URSA-Report-Protected-and-conserved-area-rangers-convention-Final.pdf. The Draft Convention, developed by the IRF, seeks to establish global labour, welfare and professional standards for rangers safeguarding protected and conserved areas.

78 See Andrew J. Plumptre, “Lessons Learned from On-the-Ground Conservation in Rwanda and the Democratic Republic of the Congo”, Journal of Sustainable Forestry, Vol. 16, No. 3–4, 2008, p. 88.

79 IUCN, above note 9, p. 20.

80 IRF, above note 77, Art. 4(2). This provision explicitly states that “[p]rior to any deployment that may reasonably be expected to involve potential conflict with any individuals or groups, including criminal or armed groups, the rangers concerned shall receive sufficient training on the location, culture, individuals or groups concerned and on the implications and appropriate strategies pertaining to the use of force, including appropriate use of force, strategies that prioritise non-physical force, restrictions on the use of force, and rules of engagement. Such training shall include appropriate techniques around the graduated use of force, and on escalation, and de-escalation techniques. Where rangers are armed, they shall be properly trained on the type and model of weapon they will carry. In all situations where force is used, rangers shall file a report with their supervisors.” See also K. Hulme, above note 15, pp. 1173–1174.

81 IRF, above note 77, Art. 4(2).

82 ICRC Guidelines, above note 16, para. 33. See also Daniëlla Dam-de Jong, “From Engines for Conflict into Engines for Sustainable Development”, in Rosemary Rayfuse (ed.), War and the Environment: New Approaches to Protecting the Environment in Relation to Armed Conflict, Brill Nijhoff, Leiden and Boston, MA, 2014, pp. 909–910.

83 AP I, Art. 65(1).

84 AP I, Art. 65(2)–(3).

85 For instance, the obligation contained in Article 8 of the Biodiversity Convention, above note 52, on protected areas applies “as far as possible and as appropriate”. Accordingly, it is usually considered to be an “obligation of conduct” imposing a “due diligence standard”, rather than an “obligation of result” guaranteeing a specific outcome without a margin of appreciation. This does not mean, however, that this obligation is of a purely political nature. As rightly emphasized by Fauchald, “[i]t merely indicates that the commitments are subject to countries’ ability to perform the duties and that states have broad discretion regarding how to achieve compliance”. Ole Kristian Fauchald, “International Environmental Governance and Protected Areas”, Yearbook of International Environmental Law, Vol. 30, 2019, p. 107. In other words, the obligations remain legally binding, with the caveat reflecting flexibility in implementation rather than a diminution of their legal character.

86 ICRC Customary Law Study, above note 16, Rule 6.

87 As noted by Arnold and Zimmermann, “[d]ue to the growing recognition of civil defence, as part of the general effort to provide protection to the civilian population and individual civilians against the dangers resulting from military operations, … protection of civil defence should also be complied with during non-international armed conflict”. Roberta Arnold and Dominik Zimmermann, “Civil Defence”, Max Planck Encyclopedia of International Law, March 2008, para. 3.

88 ICRC Customary Law Study, above note 16, Rule 31.

89 Ibid., Rule 31 commentary.

90 See e.g. Jérôme de Hemptinne, “Animals as Part of the Environment”, in Anne Peters, Jérôme de Hemptinne and Robert Kolb (eds), Animals in the International Law of Armed Conflict, Cambridge University Press, Cambridge, 2022, p. 118.

91 For the argument based on legislative jurisdiction, see R. van Steenberghe, “The Interplay between IHL and IEL”, above note 15, pp. 1144–1146, which builds on Jann K. Kleffner, “The Applicability of International Humanitarian Law to Organized Armed Groups”, International Review of the Red Cross, Vol. 93, No. 882, 2011, pp. 445–449. For the argument based on international human rights law, See J. de Hemptinne, above note 18, pp. 1404–1405.

92 See J. de Hemptinne, above note 18, p. 1405.

93 E. Hsiao et al., above note 29, p. 1419. See also Elaine (Lan Yin) Hsiao, “Protecting Protected Areas in Bello: Learning From Institutional Design and Conflict Resilience in the Greater Virunga and Kidepo Landscapes”, Goettingen Journal of International Law, Vol. 10, No. 1, 2020, pp. 82–83.

94 ICRC and Norwegian Red Cross, Keeping the Lights On and the Taps Running: Protecting and Facilitating Safer Access for Essential Service Providers in Armed Conflict, Oslo, 2024. See also Caroline Baudot, Tobias Ehret, David Kaelin and Marnie Lloydd, “Beyond Infrastructure: The Protection of Essential Services Personnel in the Spirit of International Humanitarian Law”, International Review of the Red Cross, Vol. 108, No. 931, 2026. It is noteworthy that the line of reasoning developed by Baudot et al. in support of enhanced protection for individuals providing essential services may, mutatis mutandis, be transposed to rangers. The protection of such personnel constitutes a coherent and normatively sound extension of the safeguards that IHL accords to “objects indispensable to the survival of the civilian population”, just as the protection of rangers may be conceived as a logical corollary of the protection that IHL confers upon the natural environment. See also Marnie Lloydd, Caroline Baudot, Peter Herby and Tobias Ehret, “Protecting Essential Service Personnel is a Vital Part of Humanitarian Action”, Humanitarian Law and Policy Blog, 10 October 2024, available at: https://blogs.icrc.org/law-and-policy/2024/10/10/protecting-essential-service-personnel-is-a-vital-part-of-humanitarian-action/.

95 See Rohit Singh et al., above note 4, p. 130. See also Moses Olinga, “How Improving Ranger Welfare Can Help Us Fight the Climate Crisis”, International Fund for Animal Welfare, 30 July 2024, available at: www.ifaw.org/uk/people/opinions/improving-ranger-welfare-fight-climate-crisis.

96 ICRC and Norwegian Red Cross, above note 94, pp. 13–14.