In June 2025, a dramatic and highly controversial military escalation occurred in the Middle East. On the night of June 12, Israel launched a coordinated set of airstrikes against Iran, targeting nuclear infrastructure at Natanz, Fordow, and Isfahan. These attacks, reportedly carried out under the codename "Operation Rising Lion," were swiftly followed by American strikes that destroyed similar installations and military facilities, marking an effective alignment between the two powers.[^1]
Within days, multiple Iranian officials, including high-ranking members of the Islamic Revolutionary Guard Corps (IRGC) and nuclear scientists, were assassinated. As of date of this publication, among those reported killed were:
(1) Major General Mohammad Bagheri, Chief of Staff of the Iranian Armed Forces;
(2) Major General Gholam Ali Rashid, a senior commander at the Khatam-al-Anbiya Central Headquarters;
(3) Brigadier General Gholamreza Mehrabi, Deputy Head of Intelligence; and
(4) Nuclear Physicist Ahmadreza Zolfaghari Daryani.
On June 21, Israel assassinated
(5) Brigadier General Saeed Izadi, the Quds Force’s senior commander for Palestinian operations, in Qom.[^2]
What made these attacks particularly alarming from a legal perspective was the absence of any preceding Iranian military action against either Israel or the United States. Iran had not launched an armed attack, nor had it made an overt declaration of war. There were no new developments in Iran's nuclear program indicating weaponization or any imminent deployment of a nuclear device. Thus, the strikes appeared not as a response to aggression, but as pre-emptive or preventive attacks lacking lawful justification.
This article undertakes a comprehensive legal critique of the June 2025 strikes by Israel and the United States under international law. It examines the applicability and violations of the jus ad bellum framework under the UN Charter, the law of armed conflict (jus in bello), and international human rights law. It also considers the obligations imposed by customary international law and relevant case law, such as Nicaragua v. United States and Oil Platforms, and evaluates whether these acts amount to the international crime of aggression.
II. THE LEGAL FRAMEWORK GOVERNING USE OF FORCE AND TARGETED KILLING
To determine the legality of Israel’s and the United States’ military actions against Iran in June 2025, we must first establish the governing legal standards. International law recognizes three principal legal regimes relevant to this context:
(1) jus ad bellum, or the law governing the resort to force;
(2) jus in bello, or international humanitarian law (IHL), applicable in armed conflicts; and
(3) international human rights law (IHRL), which continues to apply in both peace and war.
A. Jus ad Bellum and the United Nations Charter
The cornerstone of the international legal regime on the use of force is the United Nations Charter. Article 2(4) of the Charter provides that “all Members shall refrain in their international relations from the threat or use of force against the territorial integrity or political independence of any state.”[^3]
There are only two exceptions to this prohibition:
(1) when force is authorized by the United Nations Security Council under Chapter VII of the Charter, and
(2) when it is exercised in self-defense under Article 51, which states that “nothing in the present Charter shall impair the inherent right of individual or collective self-defense if an armed attack occurs.”[^4]
To claim lawful self-defense, a state must demonstrate that it has suffered an armed attack or is under an imminent threat of such an attack. The International Court of Justice (ICJ) in the Nicaragua v. United States case (1986) reaffirmed that mere threats or provision of arms does not constitute an armed attack.[^5] The ICJ also noted that self-defense must be both necessary and proportionate.
B. Jus in Bello (International Humanitarian Law)
IHL governs the conduct of hostilities during armed conflict and is primarily codified in the four Geneva Conventions of 1949 and their Additional Protocols. Fundamental principles include:
✓distinction (between combatants and civilians);
✓proportionality (prohibiting attacks that cause excessive civilian harm relative to anticipated military advantage); and
✓military necessity.
IHL only applies when a situation qualifies as an armed conflict under international law.[^6]
C. International Human Rights Law (IHRL)
In situations where there is no armed conflict, IHRL applies. The International Covenant on Civil and Political Rights (ICCPR), to which the United States and Iran are parties (though Israel has signed but not ratified it), recognizes in Article 6 the right to life and prohibits arbitrary deprivation of life.[^7] The United Nations Human Rights Committee has consistently stated that targeted killings outside armed conflict are presumed unlawful under the ICCPR unless they meet strict criteria of necessity and proportionality, and unless the individual poses an imminent threat.[^8]
D. The Crime of Aggression under the Rome Statute
Although Israel and the United States are not parties to the Rome Statute of the International Criminal Court (ICC), the Rome Statute’s definition of the crime of aggression is instructive. Article 8 defines aggression as “the planning, preparation, initiation or execution, by a person in a position effectively to exercise control over or to direct the political or military action of a State, of an act of aggression which, by its character, gravity and scale, constitutes a manifest violation of the Charter of the United Nations.”[^9] This definition reflects customary international law and reinforces the illegality of the unauthorized use of force against another sovereign state.
III. LEGAL ANALYSIS OF THE JUNE 2025 STRIKES
A. Violation of Article 2(4) of the UN Charter
Israel’s initial strikes on Iran in June 2025 were not conducted in response to any identifiable armed attack. Iran had not launched missiles at Israeli or American assets, nor had it threatened imminent hostilities. At most, Israeli and American intelligence agencies claimed that Iran’s nuclear facilities had resumed uranium enrichment at levels close to weapons-grade - something Iran denied, and which was not corroborated by the International Atomic Energy Agency (IAEA) as of May 2025.[^10]
Without a clear act of aggression by Iran, the Israeli and U.S. actions constituted a violation of Article 2(4) of the UN Charter. These were not defensive acts but offensive operations aimed at degrading Iran’s military capacity. In Oil Platforms (Iran v. United States), the ICJ held that military force used without direct evidence of an armed attack cannot be justified under Article 51.[^11] That precedent is clearly applicable here.
B. No Justification for Preemptive or Preventive Self-Defense
Some states, including Israel and the United States, have advocated for an expanded doctrine of anticipatory self-defense. This includes the right to use force preemptively to avert an imminent attack. However, even this controversial doctrine, rooted in the 19th-century Caroline case, requires that the threat be “instant, overwhelming, and leaving no choice of means, and no moment for deliberation.”[^12] There is no public evidence that Iran posed such an imminent threat.
Even more tenuous is the doctrine of preventive self-defense, which seeks to justify the use of force based on speculative future threats, such as the possibility of Iran developing a nuclear weapon in the coming years. This doctrine has no basis in the UN Charter and has been repeatedly rejected by the majority of the international legal community.[^13] The June 2025 strikes appear to fall squarely into this discredited category.
C. Assassinations of Iranian Officials as Extrajudicial Killings
The targeted killings of high-ranking Iranian officials, such as Major General Bagheri and Brigadier General Izadi, occurred outside any lawful armed conflict. These individuals were located within sovereign Iranian territory, were not engaged in combat, and were not shown to pose an imminent threat. Under IHRL, and specifically Article 6 of the ICCPR, their killings constitute extrajudicial executions.[^14]
According to the 2010 Report of the UN Special Rapporteur on Extrajudicial Killings, “in cases outside armed conflict, where international human rights law continues to apply, targeted killings are only legal if they meet the standards of necessity, proportionality, and imminent threat.”[^15]
None of these criteria were satisfied in the June 2025 assassinations. The operation lacked transparency, independent oversight, or post-strike review mechanisms. Furthermore, these officials could have been subject to arrest or non-lethal containment if they were truly perceived as threats.
D. Illegality of Strikes on Nuclear Infrastructure
The Israeli and U.S. attacks on Iran’s nuclear facilities - Natanz, Fordow, and Isfahan - pose significant challenges under both IHL and customary international law. While dual-use infrastructure may be lawful targets during armed conflict, the key criterion is that such sites must make an “effective contribution to military action” and that their destruction must offer “a definite military advantage.”[^16]
In the absence of an ongoing armed conflict and given that Iran’s nuclear program was under IAEA supervision, these conditions were not met. The strikes undermined international non-proliferation frameworks and set a dangerous precedent for unilateral military action against civilian infrastructure.
The ICJ, in its Advisory Opinion on the Legality of the Threat or Use of Nuclear Weapons (1996), noted that attacks on nuclear installations must be approached with extreme caution due to the humanitarian and environmental consequences.[^17]
E. Customary Law and the Crime of Aggression
The cumulative nature, scale, and intent of the June 2025 operations - launched without Security Council authorization and absent any armed attack - meet the threshold of the crime of aggression as articulated in Article 8 bis of the Rome Statute.
While jurisdictional barriers may prevent formal prosecution at the ICC, the acts remain illegal under customary international law. Furthermore, these actions undermine global norms on the non-use of force and risk creating precedents for lawless, discretionary violence among states.
IV. IMPLICATIONS AND RECOMMENDATIONS
The June 2025 strikes by Israel and the United States represent one of the most serious contemporary breaches of the international legal order governing war and peace.
These acts of aggression, masked under the rhetoric of self-defense, have undermined the fundamental principle that force must be used only as a last resort and in strict compliance with international law.
Consequently, there are several urgent steps that the international community must consider.
(a). The United Nations General Assembly should convene an emergency session under the “Uniting for Peace” resolution to debate the legality of the strikes and adopt a resolution condemning the use of force against Iran.
(b). Iran or a third-party state could request an advisory opinion from the ICJ regarding the legality of the June 2025 actions.
(c). States parties to the Rome Statute could initiate a referral to the ICC Prosecutor to open a preliminary examination, especially if Iranian territory suffered grave violations that amount to crimes under international law.
(d). The international community should reaffirm the narrow and well-established criteria for self-defense, and resist the normalization of preventive war doctrines. International legal mechanisms - such as the Security Council, the ICJ, and human rights treaty bodies - must be strengthened to hold violators accountable and prevent the erosion of the Charter system.
V. CONCLUSION
The June 2025 attacks by Israel and the United States against Iran lack any credible legal justification under the UN Charter, international humanitarian law, or international human rights law. They were neither acts of self-defense nor proportionate responses to armed aggression. Instead, they were preventive strikes rooted in geopolitical strategy and speculation, not in law.
The targeted assassinations of Iranian officials and destruction of nuclear infrastructure amount to grave violations of sovereignty, extrajudicial executions, and possibly the crime of aggression under customary law.
Only a robust legal and institutional response can prevent these violations from becoming a dangerous new norm in international relations.
References
[^1]: The Guardian, “A Week of War That Left Iran Stunned and Bloodied,” June 20, 2025.
[^2]: AP News, “U.S. Strikes Iranian Nuclear Sites, Joins Israeli Offensive,” June 22, 2025.
[^3]: United Nations Charter, Article 2(4).
[^4]: United Nations Charter, Article 51. [^5]: International Court of Justice, Military and Paramilitary Activities in and against Nicaragua (Nicaragua v. United States), Judgment, ICJ Reports 1986.
[^6]: Geneva Conventions of 1949 and Additional Protocols I and II.
[^7]: International Covenant on Civil and Political Rights (ICCPR), Article 6.
[^8]: UN Human Rights Committee, General Comment No. 36, 2018.
[^9]: Rome Statute of the International Criminal Court, Article 8 bis.
[^10]: The Times, “Does Iran Have Nuclear Weapons? Why the U.S. Is Attacking Now,” June 2025.
[^11]: ICJ, Oil Platforms (Iran v. United States), Judgment, ICJ Reports 2003.
[^12]: Correspondence between Webster and Ashburton, Caroline Incident (1837).
[^13]: UNGA, Resolution 3314 (XXIX), 1974, Definition of Aggression.
[^14]: ICCPR, Article 6(1); General Comment No. 36.
[^15]: UN Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Report A/HRC/14/24/Add.6 (2010).
[^16]: Additional Protocol I, Article 52(2).
[^17]: ICJ, Legality of the Threat or Use of Nuclear Weapons, Advisory Opinion, ICJ Reports 1996.
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