In other events, the Congress (of the United States) had not made a formal declaration of war, yet the President, as the commander-in-chief, has claimed authority to send in the armed forces when he deemed necessary, with or without the approval of Congress. The legal legitimacy of each of these actions was based upon declarations such as the Gulf of Tonkin Resolution and Iraq Resolution by Congress and various United Nations resolutions. Nonetheless, Congressional approval has been asserted by means of funding appropriations or other authorizations as well as the contested War Powers Resolution. The United Nations approved police action during the 2011 military intervention in Libya to protect civilians. Since the September 11 attacks, states have militarily pursued individuals they deem terrorists within the borders of other states in a form of police action that is not clearly defined in the international law. So called 'Indonesian security forces' uses police actions against uprisings of Papuans in the most Eastern province. The Indonesian police have been empowered to lead the counterinsurgency operation against the Free Papuan Movement (OPM). Nonetheless, the Indonesian police's deficiencies in battling OPM requires that the police maintain a strong partnership with the Indonesian military. Under international law Police actions are authorized specifically by the Security Council under Article 53 (for regional action) or Article 42 (for global action). In both cases, the term used in the Charter text (English) is 'enforcement action'; the term 'police action' is not used. Appropriate use of the term Use of the term does not appear to have gained currency outside of the limited arena of justification of military action: for example, the U.S. Navy refers to the Korean conflict as the Korean War, and when they refer to police action, they surround the term in quotation marks. Similarly, a plaque at the Vietnam Veterans Memorial refers to the Vietnam War as a war, not a police action, even though it was undeclared. Use of the term "police action" is intended to imply either a claim of formal sovereignty or of authority to intervene militarily at a nation's own discretion, typically unilaterally or with a small group of nations. This is often done through the United Nations or by asserting that the military operation is defensive or humanitarian in nature such as the United Nations Stabilisation Mission in Haiti or the Invasion of Grenada. See also War Powers Resolution Declaration of