these lands by the JNF has been forestation, mostly to hide Palestinian villages that were destroyed by Israel. Indeed, one staff member even admitted that the JNF’s forest planted on lands “that were Arab villages” [emphasis added], aimed at such cover up.34 Out of the 93 percent of Israel-controlled land, the JNF currently holds title to about 13 percent, which cannot ever be sold as the JNF holds them “on behalf of the Jewish People in perpetuity.”35 However, the land it controls can be leased, but only to Israeli-Jews.36 In the territory of Palestine 1948, the use of force (A) as well as discriminatory legislations (B) and restrictions (C), has enabled Israel to deny Palestinian access to their lands, leading to both de jure or de facto confiscation of Palestinian lands. 34 Eitan Bronstein Aparicio, “Most JNF - KKL forests and sites are located on the ruins of Palestinian villages,” Zochrot, April 2014, Accessed 15 February 2022, Available at: https://www.zochrot.org/en/article/55963 35 Palestine Land Society, “Jewish National Fund’s Violation of International and Domestic Law”, Palestine Remembered, 2005, Accessed 15 February 2022, Available at: https://www.palestineremembered.com/Articles/JNF/Story1513.html 36 Ibid. 10