Sabar Lal Melma was a citizen of Afghanistan who was held in extrajudicial detention in the United States Guantanamo Bay detainment camps, in Cuba. Sabar Lal Melma's Guantanamo Internment Serial Number was 801. American intelligence analysts estimate that Sabar Lal Melma was born in 1962, Darya-e-Pech, Afghanistan. According to Ray Riviera of the New York Times, Sabar's killing angered officials on the Afghanistan High Peace Council, a body appointed by Afghanistan President Hamid Karzai to address Taliban fighters. The Peace Council believed they had secured assurances that coalition forces would stop bothering Sabar Lal Melma, and they believed his killing would frighten other Taliban fighters from defecting. A spokesman for the NATO-led military coalition said that security forces had never "detained him or had him in custody" until the operation that resulted in his death. Combatant Status Review Tribunal Initially the Bush administration asserted that they could withhold all the protections of the Geneva Conventions to captives from the war on terror. This policy was challenged before the Judicial branch. Critics argued that the USA could not evade its obligation to conduct a competent tribunal to determine whether captives are, or are not, entitled to the protections of prisoner of war status. Subsequently the Department of Defense instituted the Combatant Status Review Tribunals. The Tribunals, however, were not authorized to determine whether the captives were lawful combatants—rather they were merely empowered to make a recommendation as to whether the captive had previously been correctly determined to match the Bush administration's definition of an enemy combatant. Sabar Lal Melma chose to participate in his Combatant Status Review Tribunal. Allegations The allegations Sabar Lal Melma faced during his Tribunal were: Administrative Review Board hearing Detainees who were determined to have been properly classified as "enemy combatants" were scheduled to have their dossier reviewed at annual Administrative Review Board hearings. The Administrative Review Boards weren't authorized to review whether a detainee qualified for POW status, and they weren't authorized to review whether a detainee should have been classified as an "enemy combatant". They were authorized to consider whether a detainee should continue to be detained by the United States, because they continued to pose a threat—or whether they could safely be repatriated to the custody of their home country, or whether they could be set free. Sabar Lal Melma chose to participate in his Administrative Review Board hearing. Factors for continued detention The