IN TIMES OF CONFLICT, journalism can often be a deadly game. In a report on press freedom for the year 2002, the Committee to Protect Journalists (CPJ) recorded 20 work-related deaths among journalists worldwide. Already, five journalists have been killed in 2003.

Many of these deaths — especially those that occur in the heat of battle — are accidents. Yet over the last week, the specter of military forces specifically targeting media outlets has sown controversy once again. Attacks by US-led coalition forces on Iraqi leader Saddam Hussein’s media infrastructure began last week. These bombings raise serious questions about the rules of war. Can a TV outlet be targeted simply for telling the truth as it sees it? Can it be targeted for being selective with the truth — highlighting the enemy’s missteps and eliding its successes? If propaganda alone is the criterion for launching a missile at the media, what is protecting pan-Arab network Al-Jazeera or Fox News?

Journalism activists have come down strongly against these attacks, arguing that media outlets are civilian institutions protected by the Geneva Conventions. " I think there should be a clear international investigation into whether or not this bombing violates the Geneva Conventions, " Aidan White, general secretary of the International Federation of Journalists, told the Guardian. And Amnesty International has said that " [t]he bombing of a television station, simply because it is being used for the purposes of propaganda, cannot be condoned. It is a civilian object, and thus protected under international humanitarian law. "

The bombing of state-run media outlets is nothing new. In one sense, it is a simple but extreme case of killing the messenger. In the Gulf War of 1991-’92, for instance, Iraqi television was bombed on the very first night of the conflict. Yet the question of using lethal force on media can prove vexingly complicated as well, a point underscored by the juxtaposition of two cases: Rwanda, where an enemy media outlet left untouched was later exposed as an instrument of genocide; and Serbia, where targeting a media facility resulted in a war-crime investigation.

In Rwanda, taking steps against the media might have ameliorated, if not prevented, a tragic massacre. In her provocative book on America’s apathy toward preventing genocide, A Problem From Hell: America and the Age of Genocide (Basic Books, 2002), Carr Center for Human Rights Policy scholar Samantha Power argues that the United States could (and should) have destroyed the antennas or jammed the transmissions of the murderous Rwandan radio station Radio Milles Collines in 1994. That government-run radio station’s broadcasts were the prime media inciting the horrific genocide launched by the Hutu government against Rwanda’s ethnic Tutsis (whom the station dubbed " cockroaches " ) and its own political opponents (whom the broadcasts often named specifically).

One chilling anecdote from Power’s book sums up US inaction in Rwanda and offers a glib, flippant retort to the notion that the media influences armed conflict. Powers notes that when US Deputy Assistant Secretary of State Prudence Bushnell and others in the Clinton administration argued for at least jamming Radio Milles Collines, the State Department’s legal section advised against it by arguing that it would break international agreements on media and undermine free speech. " When Bushnell raised radio jamming yet again at a meeting, " Power writes, " one Pentagon official chided her for naïveté: ‘Pru, radios don’t kill people. People kill people.’ " The United States was not a party to the Rwanda conflict, but Power and others argue that international conventions on genocide place signatories — including the US — under obligation to take measures to stop it. (Indeed, argues Powers, the US studiously avoided using the word " genocide " in official pronouncements on Rwanda to avoid this responsibility.)

On the other hand, the April 1999 bombing of Radio Television Serbia’s headquarters in downtown Belgrade caused a controversy that included an investigation of that particular NATO attack by the International Criminal Tribunal for the Former Yugoslavia (ICTY). As noted above, opponents of striking media in wartime cite the prohibition in Protocol 1, Article 52 of the Geneva Conventions (Part IV), which states that " attacks shall be limited strictly to military objectives. "

Others, however, believe media outlets, as part of an opposing force’s " command and control, " are fair game during wartime. At a briefing last week, Assistant Secretary of Defense for Public Affairs Victoria Clarke repeated those three words twice when quizzed about why Iraqi TV had been targeted. (In fact, much of the recent speculation about attacking Iraqi TV has focused less on why it was attacked, and more on the question, " What took so long? " On Monday, New York Times columnist William Safire labeled " the inability to locate and obliterate all of Saddam’s TV propaganda facilities " as the " most inexplicable weakness of our intelligence and air power. " )

But the definitions of " military " and " command and control " are becoming more slippery. In his book Waging Modern War (Public Affairs, 2001), Retired General Wesley Clark, who served as supreme allied commander in Europe, offers a number of rationales for attacking enemy media outlets that are strikingly similar to those raised in the present conflict. They range beyond the simple " command and control " mantra into something more convincing militarily — and more questionable in relation to the codified laws of war.

Clark notes that it was " difficult to get political approval " from NATO countries for striking Serbian television, " in part because it seemed undemocratic and perhaps illegal. " Yet in the conclusion of the book, he offers a detailed description of the effect of Serbian propaganda on the NATO bombing campaign that could easily be substituted for present circumstances merely by substituting " Iraqis " for " Serbs " and " US-led coalition " for " NATO " :

The Serbs, reflecting the totalitarian methods at the heart of communist rule, were excellent in organizing press coverage and directing it toward NATO mistakes. From the outset we had seen that the Serbs would do all they could to portray the NATO strikes as targeting civilians, rather than the Serb military and police. For the first few weeks we avoided playing into their plan, but eventually, the accidents and misfortunes inevitable in any air campaign took over. The fact was, the Serbs were on the ground and we weren’t. They had an immediate advantage in knowing when the bombs struck and, when the result was embarrassing to NATO, they could assure world media coverage faster than we could investigate and explain it.

They had the advantage in time and space. They had access to the media representatives in Belgrade. And though they did their best to avoid coverage of NATO’s successes, we found that there was usually an element of truth when they shone the spotlight on NATO failures.

The public to-and-fro over alleged missile attacks directed at markets in Baghdad perfectly illustrates Clark’s point. Images of the civilian carnage at both marketplaces were gruesome and widely broadcast in both Iraq and the rest of the world. Yet analysis of the visual evidence has produced a credible argument that one — and perhaps both — of last week’s explosions were the result of stray Iraqi anti-aircraft ordnance, and not the bombs of US-led coalition forces.

Like the Serbs in Clark’s account, Iraqi media have time, space, and access advantages in covering such bombings. And the media scrum over responsibility for civilian casualties in Baghdad does recall similarly virulent battles over responsibility for massacres in Sarajevo markets during the Bosnian Serb siege of that city. As Slate blogger Mickey Kaus points out in a Sunday entry: " It’s true that, in the past, when the United States has been accused of killing innocent civilians with an errant missile, the charge has usually been proven accurate. But I’m still skeptical about the Iraqi claims that two U.S. missiles have now struck crowded marketplaces and killed dozens. Why do these errant missiles always fall in crowded marketplaces and kill dozens? Why don’t they ever fall in back alleys and kill one or two people? "

Yet the opposing views of such incidents bring us back to the main questions involved in targeting media outlets during war. Does the fact that the other side is broadcasting its version of events — or even propaganda — transform its media outlets into legitimate military targets? And if propaganda alone is reason to strike at the journalism practiced by the opposing side in war, is the pan-Arab channel Al-Jazeera — fiercely attacked by British prime minister Tony Blair’s press spokesman on Monday as broadcasting " fiction " — a legitimate target for bombs or cyber-warfare?