Power may undertake total or partial evacuation of a given area if the security of the population or imperative military reasons so demand.”60 Contravening this law constitutes a grave breach of GCIV under Article 147, as well as a war crime and, potentially, a crime against humanity under the Rome Statute of the ICC.61 The denial of use and access to land as well as illegal confiscation of Palestinian land often leads to the direct forcible transfer of Palestinians. Both de facto and de jure confiscations of land create a ripple effect in which a plethora of fundamental rights deteriorate to the point that the victims are left with no other option than to abandon the confiscated area. As such, indirect forcible transfer occurs through the creation of a coercive environment that transforms an area into an uninhabitable living space. Jurisprudence from the ICC and other international criminal tribunals is consistent in asserting that the forcible nature of the displacement must not be limited to forced physical removal. Forcible transfer also includes acts or omissions that amount to threats of force or coercion, creating fear of detention or violence, or taking advantage of a coercive environment. Here, the essential component is that displacement is involuntary, where the person(s) in question are deprived of agency in the decision to leave their homes and communities.62 Involuntary displacement due to a coercive environment, when taking place on grounds not permitted under international law according to the provisions outlined above nor for “imperative military reasons” constitutes forcible transfer. 60 Ibid. 61 Rome Statute, art. 7(d); art. 8(e)(viii), supra note 57. 62 ICTY, Prosecutor v. Popović et. al, Case No. IT-05-88 -T, Trial Judgment, 2010, BADIL, Coercive Environments, February 2017. 25