It would also be beneficial if future decisions elucidate the concept of dignity, and what it means to be able to live in an UNRWA area in safe and dignified conditions for as long as necessary, as per Serin Alheto and XT. Palestinians often have no right of permanent residence — only “tolerated stay” or temporary residence permits based on employment — in UNRWA’s area of operation and throughout the Middle East and North Africa. They face significant discrimination, long-term forced poverty, restrictions on their activities, movement, and access to official procedures. In general, they lack the ability to naturalise or access other durable solutions that are at least theoretically available to non-Palestinian refugees in these areas. In such situations, their status remains temporary and precarious, and they should not be considered to be living in safety and dignity for as long as is necessary.131 A key question arising in CJEU and other jurisprudence is whether UNRWA is able to provide services commensurate with its mission. UNRWA’s mission is “to help Palestine refugees achieve their full potential in human development under the difficult circumstances in which they live, consistent with internationally agreed goals and standards.”132 UNRWA services include health, education, welfare relief and social services, as well as other assistance.133 At a very basic minimum, UNRWA should be expected to be able to ensure that Palestine refugees have sufficient food to meet dietary minimums; adequate clean water for drinking, cooking, personal hygiene, and other household use; adequate sanitation facilities; access to adequate healthcare; a decent education; and safe housing. Given its funding crisis and conditions in its area of operation, whether UNRWA is able to meet these objectives to an adequate standard is debatable. Given that UNRWA does not provide a protective legal status and many Palestinians in UNRWA’s area of operation have only a temporary and precarious legal status and face a lack of safety and dignity, it should be acknowledged that many Palestinians who could (at least in theory) return to an UNRWA field of operation cannot access effective protection there; thus, they should be granted refugee status under the inclusion clause of Article 1D. 5.3. Article 1D’s Application in Domestic Jurisdictions The application of Article 1D has varied considerably at the domestic level but has often been based on misunderstandings of international law and/or relevant facts. In some countries, recent jurisprudence has generally followed the El Kott approach, but with varying results. In addition to jurisprudence, there is also variation in government policies. This report is not a mapping study and does not purport to cover all relevant cases, but rather provides some examples showing varying interpretations of Article 1D. Additional summaries of Palestinian cases are available in the European Network on Statelessness’ (ENS) Statelessness Case Law Database.134 Belgium Belgium’s Council for Aliens Law Litigation (CALL – an asylum appeals body) has made several decisions relating to Article 1D in recent years. In several judgments in early 2021, the CALL concluded that because of the financial difficulties faced by UNRWA, the agency, in general, was no longer able to provide adequate assistance to Palestinians in Gaza and Lebanon, and it considered that UNRWA assistance had therefore ceased for the purposes of Article 1D. Consequently, Palestinian refugees from Gaza and Lebanon who are registered with UNRWA should be automatically recognised as refugees 131 See section above, ‘Conditions for Palestinians in UNRWA’s Area of Operation and Neighboring States’. 132 UNRWA, ‘About UNRWA’, https://www.unrwa.org/sites/default/files/about_unrwa.pdf (accessed 30 Jan 2022), 4. 133 Ibid, UNRWA, 14. 134 https://caselaw.statelessness.eu. 24