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Internees shall also have the right to apply without restriction through the InterneeCommittee or, if they consider it necessary, directly to the representatives of the ProtectingPower, in order to indicate to them any points on which they may have complaints to make withregard to the conditions of internment. 32710.21.1.1 Making Requests and Complaints to the ICRC. Such complaints mayalso be made to the delegates of the ICRC, who enjoy the same prerogatives of access tointernees as the representatives of the Protecting Power. 328 In the past, the ICRC has been ableto take appropriate measures besides merely forwarding the complaint to the Power on which thePOWs depend, including measures on a confidential basis that help to improve the situation ofinternees. 32910.21.2 Communication of Petitions and Complaints. Such petitions and complaintsshall be transmitted forthwith and without alteration, and even if the latter are recognized to beunfounded, they may not occasion any punishment. 33010.21.2.1 Review and Censorship of Requests and Complaints by the DetainingPower. Although petitions and complaints shall be transmitted forthwith and without alteration,the Detaining Power has the right to examine and censor petitions and complaints for securityreasons. 331 Communications for transmittal may be examined to determine whether theylegitimately contain petitions or complaints. 332 Security review and censorship must beconducted in accordance with the general rules on censoring internee correspondence. 333the commandant of the place of internment to issue regulations concerning the exercise of this right, and particularlyto say whether petitions can be submitted orally or in writing and in what form.”).327 GC art. 101 (“They shall also have the right to apply without restriction through the Internee Committee or, ifthey consider it necessary, direct to the representatives of the Protecting Power, in order to indicate to them anypoints on which they may have complaints to make with regard to the conditions of internment.”).328 Refer to § 10.33.1.2 (ICRC Delegates Enjoying the Same Prerogatives of Access).329 Compare § 9.23.1.1 (Making Requests and Complaints to the ICRC).330 GC art. 101 (“Such petitions and complaints shall be transmitted forthwith and without alteration, and even if thelatter are recognized to be unfounded, they may not occasion any punishment.”).331 See 1956 FM 27-10 (Change No. 1 1976) 308b (“The Detaining Power has the right to examine and censor thecomplaints, petitions, and reports referred to above in the same manner as correspondence addressed to internees ordispatched by them. It may also examine such complaints and reports to the representatives of the Protecting Powerto verify that they are what they purport to be and to delete matter not constituting either a complaint or a reportwithin the meaning of the foregoing provision.”).332 GC COMMENTARY 435-36 (“The transmission ‘forthwith’ of complaints and petitions and the absence ofpunishment even when they are not well founded is in conformity with the procedure established with regard toprisoners of war during the two world wars. The Fourth Convention of 1949 has introduced a particularly importantidea by stating that the transmission shall take place ‘without alteration’. This wording was rejected by the authorsof the Third Geneva Convention in order to respect the Detaining Power’s right of censorship. The discussions atthe Diplomatic Conference concerning the Fourth Convention showed that there was a specific wish to avoid anysuggestion of censorship with regard to civilians. It was nevertheless said that some supervision by the DetainingPower must be allowed ‘for security reasons’.”).333 Refer to § 10.23.6 (Censorship and Security Review of Internee Correspondence and Shipments).691

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