In the most recent episode of Israeli attacks on Iran, on Monday, 16 June 2025, Israeli forces struck the headquarters of the Iranian state broadcaster in Tehran. In a post on X, the Israeli Defence Minister immediately claimed responsibility, stating
‘The propaganda and incitement broadcasting authority of the Iranian regime was attacked by the IDF […]. We will defeat the Iranian dictator everywhere.’
This statement implies that the broadcasting studio was considered a legitimate target. While this might align with Clausewitz’s view that the enemy’s morale is a legitimate military target, it raises the question of whether such an interpretation is valid under modern international law. In short, it is not – at least not unless the studio is deemed to pose an imminent military threat or is intended for military use, or is directly inciting serious crimes under international law.
The Protection of Journalists under International Humanitarian Law
The most relevant regulations on the protection of persons in armed conflict are found in the four Geneva Conventions of 1949 and their two Additional Protocols. As part of international humanitarian law, their applicability begins as soon as an armed conflict exists. Regardless of one’s view on the legality of the use of force ab initio, it is evident that Israel and Iran are currently involved in an international armed conflict. This post is based on this premise.
Of the four Geneva Conventions of 1949 only Article 4(A)(4) of the Third Geneva Convention relative to the Treatment of Prisoners of War addresses media personnel. This article extends the protections afforded to prisoners of war in the case of capture to war correspondents accompanying armed forces. Given the limited protection for journalists vis-à-vis their vital societal role in reporting on armed conflicts, the UN General Assembly in 1970 passed a resolution calling for enhanced protection of journalists under IHL. This led to the adoption of a draft International Convention on the Protection of Journalists Engaged in Dangerous Missions by the UN Economic and Social Committee – though it was never ratified. Nonetheless, it influenced the inclusion of such provision in Article 79 of the Additional Protocol I to the Geneva Conventions (AP I), which provides that journalists must be considered civilians and, as such, are entitled to full protection. The content of this provision was reaffirmed by UN Security Council Resolution 1783 and is now regarded as customary international law.
The Scope of Protection Awarded
Article 79 of AP I does not define the term ‘journalist’. However, Article 2(a) of the aforementioned draft convention helps clarify this, defining a journalist as any ‘correspondent, reporter, photographer, film cameraman or press technician who has that status by virtue of their country’s law or practice.’ This yields a broad definition. Furthermore, Article 79 of AP I requires that journalists be engaged in a ‘dangerous professional mission in the area of armed conflict’ – a term that covers typical journalistic activities conducted in an area affected by hostilities: conducting interviews, recording, or transmitting materials to the public.
If these conditions are met, journalists enjoy the same protection as civilians under Article 50 of AP I. They must not be indiscriminately targeted, and all feasible measures must be taken to ensure their safety. This remains true, even when a journalist is embedded with the armed forces, accompanies armed forces or takes advantage of their logistic support. Under Article 52 of AP I, this protection also extends to equipment used by journalists, provided these are considered civilian in nature. In case of doubt, the presumption of Article 52(3) of AP I applies. Thus, the protection covers cameras, broadcasting equipment, as well as broadcasting facilities.
Exemptions to the Rule
Israel’s characterisation of the Iranian broadcaster as a ‘propaganda and incitement machine’ raises the legal question of when such facilities may lawfully be targeted for disseminating propagandist material. And indeed, a limitation arises when Article 79(1) of AP I is read in conjunction with Article 51(3) of AP I: if a civilian – more specifically, a journalist – takes a direct part in hostilities, their protection ceases. A similar reading applies to journalists’ equipment under Article 52(2) of AP I, where protection ends if the object is used for military purposes.
It must thus be assessed when a journalist’s actions constitute ‘direct participation’ in hostilities or whether media facilities are being used for military objectives – and in particular, whether propagandistic activities meet this threshold. The definition of military objectives in Article 52(2) requires that the object, by its nature, location, purpose, or use, makes an effective contribution to military action and that its destruction offers a definite military advantage. This high standard is rarely met by media facilities. Conceivable cases include dual-use scenarios, such as using TV transmitters for military communications or repurposing the building as military command post.
In evaluating propagandistic material, the ICTY’s Final Report to the Prosecutor by the Committee Established to Review the NATO Bombing Campaign Against the Federal Republic of Yugoslavia offers guidance. In considering the legality of NATO’s bombing of Yugoslavian TV stations, the report stated that whether media constitutes a legitimate target is debatable and concluded that disseminating propaganda to support a war effort is not sufficient on its own. However, the report left open the possibility that if media forms the ‘central nervous system’ maintaining a regime and perpetuating conflict, it might be considered a legitimate military objective. Nevertheless, the ICTY ultimately reaffirmed the overarching legal standard of AP I for attacks on civilians and civilian objects, namely that an attack must effectively contribute to military operations and provide a definite military advantage. While propagandistic messages can bolster civilian morale, they usually fail to meet this criterion – a conclusion that runs counter to Clausewitz’s assertion. Therefore, this exception can almost under all circumstances be considered factually irrelevant.
However, the ICTY noted one final exception, independent of military objectives: when the media explicitly incites the commission of serious crimes under international law. Specifically, it cited the use of the media during the Rwandan genocide of 1994 as an example, referring to the Rwandan Radio-Télévision Libre des Mille Collines (RTLM), which played a fundamental role in inciting the violence that ultimately led to the genocide. However, this is an extreme and exceptionally narrow scenario. Propagandistic content alone does not meet this standard.
Conclusion
Thus, the protection afforded to journalists and media broadcasters under IHL is robust, and any exceptions to this protection must be interpreted strictly. Against this backdrop, the Israeli Defence Minister’s justification does not stand up to legal scrutiny. Compared to RTLM during the Rwandan genocide, which explicitly incited mass violence and genocide, the Iranian broadcaster’s output, however antisemitic and hostile it may be, does not meet the legal threshold for loss of protection from this perspective.
Unless Israel can demonstrate that the broadcaster was also used for military purposes the strike must be considered incompatible with IHL. Simply labelling a media outlet as a propagandist arm of the state does not render it a lawful military target.
