60 Israeli Land Grab and Forced Population Transfer of Palestinians Next to this protocol, the acting Israeli authority is bound by the “Proportionality test” that considers three questions: 1. Does the route pass the “appropriate means” test (or the “rational means” test)? The question is whether there is a rational connection between the route and the goal of the construction of the wall; 2. Does it pass the test of the “least injurious” means? The question is whether, among the various routes which would achieve the objective of the wall, is the chosen one the least injurious; 3. Does it pass the test of proportionality in the narrow sense? The question is whether the route, as set out by the Military Commander, injures the local inhabitants to the extent that there is no proper proportion between this injury and the security benefit of the wall. According to the “relative” examination of this test, the Wall will be found disproportionate if an alternate route for it is suggested that has a smaller security advantage than the route chosen by the respondent, but which will cause significantly less damage than the original route.210 The Court concedes the power to designate what is military necessity to the Military Commander and where to apply this. The Court retains the authority to deem whether or not these designations are proportional.211 Ghassan Al-Harami - Jayyus, Qalqilya 212 Jayyus is a village composed of around 3,200 Palestinian residents, around 95 percent of them own land parcels located on the Western side of the Annexation Wall which was built there in 2002. The main source of income in Jayyus comes from agriculture. In 2002 when Israel started to build the Annexation Wall, about 8,200 dunums (8.2 km2) of the total 12,500 dunums (12.5 km2) of the lands of Jayyus were kept on the Western side of the Wall. These lands constitute 80 percent of total arable land. Annually, those lands used to produce around 10,000 tons of vegetables and fruits. Access to land Since the building of the Annexation Wall, the farmers of Jayyus had several difficulties in accessing their lands. First of all, each farmer needs an entry 210 Beit Sourik Village Council V. The Government of Israel para 44. 211 Beit Sourik Village Council V. The Government of Israel para 48. 212 Ghassan Al-Harami, ‘The Village of Jayyous, District of Qalqilya’, interview by BADIL, March 2013.