based and individualised threats would qualify as circumstances beyond the applicant’s control. Examples of group‑based threats would include armed conflict or other situations of violence, such as civil unrest, widespread insecurity or events seriously disturbing public order.46 Threats of a more individualised nature, which could also compel a Palestinian to leave an UNRWA area for reasons beyond his or her control, would include sexual or gender‑based violence, torture, inhuman or degrading treatment or punishment, human trafficking and exploitation, forced recruitment, severe discrimination,47 or arbitrary arrest or detention. f. Where any of these above-mentioned threats emanate from the authorities, protection under Article 1D would be required. Similarly, where the authorities are unable or unwilling to provide protection against threats emanating from non-State actors, protection under Article 1D(2) would also apply. A case-by-case assessment is necessary to determine the application of Article 1D in these cases.48 (iv) Practical, legal and/or safety barriers preventing an applicant from (re)availing him/herself of the protection or assistance of UNRWA g. Practical barriers include obstacles which prevent access the UNRWA area of operation, for example, because of border closures. h. Legal barriers would include absence of documentation allowing the individual to travel to, or transit through, or (re)enter and reside in the relevant UNRWA area of operation. Where the authorities refuse (re)admission or the renewal of travel or other requisite documents, the second paragraph of Article 1D would be satisfied. An applicant would not, however, benefit from protection under the 1951 Convention pursuant to Article 1D(2) if he or she were to seek to frustrate his or her (re)admission and stay by refusing to co-operate, for example, in acquiring documents.49 i. Barriers relating to safety or personal security which prevent (re)availment could include dangers en route such as minefields, factional fighting, shifting 46 See, UNHCR, Guidelines on International Protection No. 12: Claims for refugee status related to situations of armed conflict and violence under Article 1A(2) of the 1951 Convention and/or 1967 Protocol relating to the Status of Refugees and the regional refugee definitions, 2 December 2016, HCR/GIP/16/12, http://www.refworld.org/docid/583595ff4.html. 47 This would often but not always include systematic or a pattern of consistent discrimination. See UNHCR, Interpreting Article 1 of the 1951 Convention Relating to the Status of Refugees, April 2001, http://www.refworld.org/docid/3b20a3914.html, at para. 17. It also includes measures of discrimination which “lead to consequences of a substantially prejudicial nature [… for example,] serious restrictions on the right to earn a livelihood, the right to practise religion, or access to normally available educational facilities.” UNHCR, Handbook and Guidelines on Procedures and Criteria for Determining Refugee Status under the 1951 Convention and the 1967 Protocol Relating to the Status of Refugees, December 2011, HCR/1P/4/ENG/REV. 3, http://www.refworld.org/docid/4f33c8d92.html, (“UNHCR Handbook”) para. 54. 48 The provision of services by UNRWA is not relevant for this assessment. Non-state actors, including international organisations, do not have the attributes of a State, and are not in a position to provide protection and enforce the rule of law in the same fashion as a State. 49 Article 2 of the 1951 Convention notes that every refugee has duties to the country in which he or she finds himself or herself, which require in particular that he or she conform to its laws and regulations as well as to measures taken for the maintenance of public order. 11