of occupying powers, has illegally annexed Palestinian territory, and that the situation in the occupied Palestinian territory constitutes apartheid.44 Gaza: Approximately 1.4 million Palestinians are registered with UNRWA in Gaza and live mainly in refugee camps.45 Hamas (the Islamic Resistance Movement) was elected to govern Gaza in 2006 and 2007.46 However, Hamas has very limited governing power. There has been sporadic armed conflict between Hamas and the Israeli military since Hamas’ inception in 1988. Israel controls Gaza’s borders and has implemented a blockade since 2007, which UN bodies have criticised as unlawful collective punishment.47 Active armed conflict continued between Israel and Hamas throughout 2021, with intermittent ceasefires. Humanitarian conditions are at crisis level, with high levels of poverty, unemployment, and food insecurity. Palestinians in Gaza have limited access to healthcare, electricity, and clean water. There are few educational or economic opportunities. The Covid-19 pandemic has compounded existing problems.48 UNHCR recommended in March 2022 that states should properly assess Palestinians’ need for international protection and should not force them to return to Gaza, in light of the circumstances there.49 Syria: Conditions for Palestinians in Syria remain harsh. Before 2011, there were approximately 522,000 Palestinians registered with UNRWA in Syria.50 Approximately 120,000 Palestinians have left Syria since 2011, and many of those who remain have been internally displaced multiple times trying to avoid armed conflict, abuses by the government or armed groups, and other harm. Many have been forced to leave certain areas by armed groups. Many have lost their homes and livelihoods, and they live in poverty and at constant risk of human rights abuses. Many fled Syria to Turkey in the early part of the civil war, but it is now generally not possible for Palestinians from Syria to enter Turkey lawfully, after restrictions imposed in 2012 and 2015, even for some who had appointments with embassies in Turkey for family reunification in other countries.51 Turkish authorities have at times detained and/or forcibly returned Palestinian refugees to Syria, in violation of international law.52 Lebanon: Conditions for the approximately 470,000 Palestinians registered with UNRWA in Lebanon are very difficult, including widespread discrimination, poverty and unemployment, inadequate housing, inadequate healthcare, restrictions on freedom of movement, and other human rights violations.53 44 UN Human Rights Council, ‘Report of the Special Rapporteur on the situation of Human Rights in the Palestinian territories occupied since 1967’ (21 Mar 2022) A/HRC/49/87, Paras 17, 55 (citing various sources, including former Israeli officials); UNGA ‘Situation of Human Rights in the Palestinian Territories Occupied Since 1967’ (22 Oct 2018) UN doc A/73/447; and see Akram, ‘UNRWA and Palestine Refugees’ (2021) n 7, 657. 45 Akram, ‘UNRWA and Palestine Refugees’ (2021) n 7, 657. 46 ‘Hamas: The Palestinian militant group that rules Gaza’ (BBC, 1 July 2021) https://www.bbc.co.uk/news/world-middleeast-13331522 [accessed 30 June 2022] (noting that Hamas (or its military wing) is designated as a terrorist group by some governments, including the US, UK, EU, and Israel). 47 The UN considers the blockade of Gaza to constitute unlawful collective punishment, which has harsh consequences for the lives of Palestinians in Gaza, impacting their standard of living, their right to freedom of movement, and economic, social and cultural rights. See UN Human Rights Council, Implementation of Human Rights Council Resolutions S-9/1 and S-12/1, A/ HRC/34/36 (25 Jan 2017); and UN General Assembly, Annual report of the United Nations High Commissioner for Human Rights and reports of the Office of the High Commissioner and the Secretary-General, Human rights situation in Palestine and other occupied Arab territories, 20 Jan 2020, A/HRC/43/70. 48 Akram, ‘UNRWA and Palestine Refugees’ (2021) n 7, 657-58; European Commission, ‘Palestine Factsheet’ (2021) n 43; UN Office for the Coordination of Humanitarian Affairs, ‘Response to the escalation in the oPt | Situation Report No. 9’ (August 2021) https://www.ochaopt.org/content/response-escalation-opt-situation-report-no-9-august-2021; Dan Bilefsky, ‘What Drove the Israel-Gaza Conflict? Here’s What You Need to Know’ (New York Times, 17 Nov 2021) https://www.nytimes.com/article/ israel-gaza-what-we-know.html [accessed 30 June 2022]. 49 UNHCR, UNHCR Position on Returns to Gaza (March 2022) https://www.refworld.org/docid/6239805f4.html. 50 Akram, ‘UNRWA and Palestine Refugees’ (2021), n 7, 656. 51 Rollins, n 38, S. 2. 52 Rollins, n 38, S. 4. 53 See Rollins, n 38, Ss. 1-3; and ‘MAP highlights plight of Palestinian refugees in Lebanon to UN Special Rapporteur on Extreme Poverty’ (Medical Aid for Palestinians’ [MAP], 12 Oct 2021) https://www.map.org.uk/news/archive/post/1301-as-lebanonaseconomic-crisis-deepens-map-highlights-plight-of-palestinian-refugees-to-un-special-rapporteur-on-extreme-poverty-. [accessed 30 June 2022]. See also UNHCR, The Situation of Palestinian Refugees in Lebanon (February 2016) http://www. refworld.org/docid/56cc95484.html. 9