Meir’s strategy, who declared that ‘[t]he frontier is where Jews live, not where there is a line on the map.’72 Since the Elon Moreh case before the Israeli Supreme Court in 1979, land seized to establish a colony is not to be justified under military necessity73 and therefore is to be found unlawfully acquired.74 Nevertheless, the practice did not cease entirely. In 2014 for instance, 4,000 dunums of Palestinian land was given by the Israeli Civil Administration (ICA) to Gvaot colony, located in the Etzion Colonial bloc, based on the military necessity exception, making it the largest designation of “state land” in the area since the 1980s.75 While Israeli authorities have allocated 70 percent of the land in Area C to settlements, only 0.5 percent of Area C is allowed for Palestinian building, and most of which is already built up.76 C. Restrictions on Use and Access Despite being home to 65,000 Palestinians living in over 50 communities, 90 percent of the Jordan Valley and Dead Sea area are off-limits for Palestinian use. The numerous confiscation policies explained above, supplemented by the construction of the Annexation Wall (1), the seam zones (2) and the network of bypass roads (3) have entrenched full Israeli control over the land and have effectively cut Palestinian towns and communities off from each other and from the rest of the Jordan Valley. 72 Prime Minister Golda Meir, Sept. 1972, quoted in Aronson, “Creating Facts: Israel, Palestinians and the West Bank” (Washington, D.C.: Institute for Palestine Studies), 1987, 14. 73 Customary Rule 51 of IHL allows the occupying power to seize or destroy private property only if required by military necessity. See ICRC: https://ihl-databases.icrc. org/customary-ihl/eng/docindex/v1_rul_rule51 74 HCJ, 390/79, Izzat Muhammad Mustafa Duweikat et al v Government of Israel et al, (1980) 34, P.D. 1 (1) [Hereinafter: Elon Moreh Case, 1979, HCJ Israel]. 75 Stuart Winer, “State seizes 1,000 acres in West Bank”, The Times of Israel, 31 August 2014, Accessed 15 February 2022, Available at: https://www.timesofisrael.com/ state-seizes-1000-acres-in-west-bank/ 76 Amnesty International Report, Israel’s Apartheid against Palestinians, 25. 18