90 QIL 60 (2019) 69-97 ZOOM IN that generally speaking aliens are subject to the jurisdiction of the receiving State as long as they do not merit special treatment as diplomats, as Heads of State, or as military personnel of foreign States.105 Thus, in the words of the South African Constitutional Court ‘the exercise of jurisdiction beyond a State’s territorial limits would … constitute an interference with the exclusive territorial jurisdiction of another state’.106 Nonetheless, the territorial jurisdiction of the receiving State is somewhat tempered by the minimum standard of rights for aliens required under international law. The standard,107 enlarged by human rights law, consists of certain fundamental rights, such as ‘the recognition of juridical personality and legal capacity, standards of humane treatment, law-abiding procedures in cases of detention, the right of unobstructed access to courts, the protection of life and liberty against criminal actions, and the prohibition of confiscation etc…’108 Violations of such standard give raise to the State of nationality’s right to exercise diplomatic protection, which, as discussed above, to some extent still represents an expression of the State’s personal sovereignty over its citizens. With respect to the Iraqi context, diplomatic protection − in both its meanings − appears to be the main tool to react to violations of the international minimum treatment standard,109 whereas the relevance of the extraterritorial obligations owed by the States of nationality to their citizens held in Iraqi prisons and subject to Iraq’s jurisdiction is, in this author’s view, considerably limited. In relation to the situation of FTFs and their family members in Syria − since the camps are under the authority of the SDF and the Syrian 105 K Hailbronner, J Gogolin, ‘Aliens’ in R Wolfrum (ed) Max Planck Encyclopedia of Public International Law (OUP 2013); I Brownlie, Principles of Public International Law (7th edn OUP 2008) 521-555. 106 Constitutional Court of South Africa, Kaunda v. President of the Republic of South Africa (n 91) 19. 107 The United States of America on Behalf of L.F.H. Neer and Pauline E. Neer (claimants) v The United Mexican States, decision of 15 October 1926, United StatesMexican Claims Commission, IV UNRIAA/RSA (1952), 61-62. 108 Hailbronner, J Gogolin (n 105) paras 26-27. 109 Notably, States like France and Germany are intervening on behalf of their citizens condemned to death in order to commute the sentences. ‘France Opposes Death Penalty for French ISIS Fighters in Iraq’, The Guardian (27 May 2019) <www.theguardian.com/world/2019/may/27/france-opposes-iraq-death-penalty-againstthree-french-isis-members>.