“Displaced persons: Persons who are ‘displaced persons’ within the sense of UN General Assembly Resolution 2252 (ES-V) of 4 July 1967 and subsequent UN General Assembly resolutions, and who, as a result of the 1967 conflict, have been displaced from the Palestinian territory occupied by Israel since 1967 and have been unable to return there. It also includes those persons displaced by ‘subsequent hostilities’”.96 Other Palestinians may qualify as refugees under Article 1A of the Refugee Convention, based on a wellfounded fear of persecution for a Convention reason, or have a right to protection under other human rights law (e.g., complementary protection or protection of family or private life).97 And, as noted, some Palestinians are entitled to protection pursuant to the 1954 Convention relating to the Status of Stateless Persons. However, even in the relatively few countries that have adopted statelessness determination procedures, there are sometimes significant barriers to stateless Palestinians accessing adequate protection.98 5.1. CJEU Jurisprudence The Court of Justice of the European Union (CJEU) has considered Article 1D in several cases, which show a trajectory of offering some protection but also imposing some unwarranted restrictions on the rights of Palestinian refugees. Bolbol: The CJEU first considered Article 1D in 2010 in Bolbol v Hungary.99 The key holdings were that: 1) To establish whether a person is receiving protection from a UN agency other than UNHCR, the words “at present” in Article 1D mean the present day (date of consideration by a government authority or court), rather than the date the 1951 Refugee Convention was signed (see Paras 47-48). 2) “It follows from the clear wording of Article 1D of the Geneva Convention that only those persons who have actually availed themselves of the assistance provided by UNRWA come within the clause excluding refugee status set out therein, which must, as such, be construed narrowly and cannot therefore also cover persons who are or have been eligible to receive protection or assistance from that agency” (Para 51). 3) “While registration with UNRWA is sufficient proof of actually receiving assistance from it, … such assistance can be provided even in the absence of such registration...” (Para 52). 4) For the purposes of the first sentence of Article 12(1)(a) of Directive 2004/83,100 the parallel of Article 1D of the Refugee Convention, “a person receives protection or assistance from an agency of the United Nations other than UNHCR, when that person has actually availed himself of that protection or assistance” (Para 53). 5) “It should be added that persons who have not actually availed themselves of protection or assistance from UNRWA, prior to their application for refugee status, may, in any event, have that application examined pursuant to Article 2(c) of the Directive”, the parallel of Article 1A(2) of the Refugee Convention (Para 54).101 96 UNHCR, Guidelines on International Protection, No. 13, n 6, Para 8. 97 E.g., ‘a Palestinian [or their descendant] originally from the West Bank, who was never displaced.’ UNHCR, Guidelines on International Protection, No. 13, n 6, Para 10, fn 24. 98 For examples from the UK, see Bezzano and Carter, n 39. For other European examples, see generally the Statelessness Index of the European Network on Statelessness (https://index.statelessness.eu/). 99 Bolbol v Bevándorlási És Állampolgársági Hivatal (Court of Justice of the European Union, C-31-09, ECLI:EU:C:2010:351, 17 June 2010). https://caselaw.statelessness.eu/caselaw/cjeu-bolbol-case-c-3109 100 Council Directive 2004/83/EC of 29 April 2004 on Minimum Standards for the Qualification and Status of Third Country Nationals or Stateless Persons as Refugees or as Persons Who Otherwise Need International Protection and the Content of the Protection Granted [2004] OJ L 304/12 [the parallel of Article 1D of the Refugee Convention]. 101 Ibid, Article 2(c) of the 2004 Qualification Directive is the parallel of Article 1A(2) of the Refugee Convention. 17