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apply, while as between the States and non-State armed groups, the rules of non-internationalarmed conflicts would apply. 283.3.2 Unrecognized Governments. Even if a State does not recognize an opponent as thelegitimate government of a State, under certain circumstances, rules of international armedconflict may apply to a conflict between a State and a government that it does not recognize. Forexample, members of the regular armed forces who profess allegiance to a government orauthority not recognized by the Detaining Power nonetheless would be entitled to POW status ifthey fall into the power of the enemy during international armed conflict. 293.3.3 State Recognition of Armed Groups as Belligerents. In certain cases, States haverecognized armed groups as belligerents for certain legal purposes.For the purpose of applying humanitarian rules, recognition of the armed group as havingbelligerent rights is neither a prerequisite for nor a result of applying humanitarian rules. 303.3.3.1 Recognition by Outside States of a Rebel Faction as a Belligerent in aCivil War. In the past, in cases of a major civil war in a State, other States have recognized therebel faction as a belligerent with the effect of treating the rebels as though they were a Statewith belligerent rights under the law of neutrality. 3128 See, e.g., Military and Paramilitary Activities in and Against Nicaragua (Nicaragua v. United States), Merits,Judgment, 1986 I.C.J. 14, 114 (219) (“The conflict between the contras’ forces and those of the Government ofNicaragua is an armed conflict which is ‘not of an international character’. The acts of the contras towards theNicaraguan Government are therefore governed by the law applicable to conflicts of that character; whereas theactions of the United States in and against Nicaragua fall under the legal rules relating to international conflicts.Because the minimum rules applicable to international and to non-international conflicts are identical, there is noneed to address the question whether those actions must be looked at in the context of the rules which operate for theone or for the other category of conflict.”); Prosecutor v. Thomas Lubanga Dyilo, ICC Trial Chamber I, ICC-01/04-01/06, Judgment 258 (563) (Mar. 14, 2012) (“Similarly, although there is evidence of direct intervention on thepart of Uganda, this intervention would only have internationalised the conflict between the two states concerned(viz. the DRC and Uganda). Since the conflict to which the UPC/FPLC [Lubanga’s militia] was a party was not ‘adifference arising between two states’ but rather protracted violence carried out by multiple non-state armed groups,it remained a non-international conflict notwithstanding any concurrent international armed conflict betweenUganda and the DRC.”).29 Refer to § 4.5.3 (Regular Armed Forces Who Profess Allegiance to a Government or an Authority NotRecognized by the Detaining Power).30 Refer to § 17.2.3 (Application of Humanitarian Rules and the Legal Status of the Parties to the Conflict).31 For example, STEFAN TALMON, RECOGNITION OF GOVERNMENTS IN INTERNATIONAL LAW 309 (1998) (“Prior toits installation in Nicaraguan territory the PJNR [Provisional Junta of National Reconstruction] was recognized asthe Government of Nicaragua by the following States: Panama (22 June 1979), Grenada (23 June 1979), Costa Rica(18 July 1969). In a rare case of recognition of belligerency in modern history, the members of the Andean Group(Bolivia, Colombia, Ecuador, Peru, and Venezuela) declared on 17 June 1979 that they had recognized both sides inthe Nicaraguan conflict as ‘belligerents’.”); B.F. Butler, Attorney General, Piracy Upon the High Seas, May 17,1836, 3 OPINIONS OF THE ATTORNEY GENERAL 120, 122 (1852) (“The existence of a civil war between the people ofTexas and the authorities and people of the other Mexican States, was recognised by the President of the UnitedStates at an early day in the month of November last. Official notice of this fact, and of the President’s intention topreserve the neutrality of the United States, was soon after given to the Mexican government.”); The SantissimaTrinidad, 20 U.S. 283, 337 (1822) (“The government of the United States has recognized the existence of a civil warbetween Spain and her colonies, and has avowed a determination to remain neutral between the parties, and to allow75