"The very real danger in which conflict-journalists find themselves is well illustrated by the fact that during the recent conflict in Iraq proportionally more journalists were killed than members of the coalition forces (BalguyGallois March 2004 International Review of the Red Cross 37). The fact that journalists in conflict zones require protection is no new notion to humanitarian law, as is evidenced by the Geneva Convention of 1929-07-27 (relative to the treatment of prisoners of war). However, problems may arise where journalists start choosing sides. Should a journalist enter the arena of hostilities on either side, the situation will be that a person protected, at least to the same degree as a local civilian, will have a bearing on the hostilities. No better example exists than the Nahimana case (The Prosecutor v Ferdinand Nahimana, Jean-Bosco Barayagwiza, Hassan Ngeze case no ICTR-99-52-T (2003) (hereinafter "Nahimana")." (Abstract)