27. Although “ceased for any reason” does not generally include reasons of mere personal convenience for refusing to (re-)avail oneself of the protection or assistance of UNRWA, (as noted in paragraph 19 above),58 it is not relevant whether the applicant departed in the first place on a voluntary basis from an UNRWA area of operation (for example, for study or work purposes). They are still eligible to benefit from the 1951 Convention pursuant to Article 1D should they meet its criteria.59 A careful examination of the circumstances in each case would be required. 28. A person may become a refugee sur place in a country in which she or he claims asylum, as a result of his or her own actions, such as associating with refugees already recognized, or expressing political views in his or her country of residence.60 Politically active Palestinian refugees who may attract attention because of their beliefs or activities, and who may even do so at great personal risk to themselves or their families, cannot be required to cease such activities as a precondition for protection under Article 1D; that would undermine the object and purpose of the 1951 Convention overall.61 F. Automatic or “ipso facto” entitlement to the benefits of the 1951 Convention 29. When it is established that UNRWA’s protection or assistance has ceased for any of the reasons mentioned in paragraph 22, the Palestinian refugee is automatically or “ipso facto” entitled to the benefits of the 1951 Convention,62 provided Articles 1C, 1E or 1F of the 1951 Convention do not apply [see Parts G, H, and I below]. 63 The term “ipso facto” would be entirely redundant if the provision merely meant that a Palestinian refugee could apply for international protection in accordance with the general rules and in the same way as all asylum-seekers via Article 1A(2) of the 1951 Convention.64 58 This interpretation is closely aligned with State practice which has not generally accepted automatic entitlement to Article 1D by reason simply of being outside an UNRWA area of operation. 59 El Kott, note 9 above, para. 59. 60 UNHCR Handbook, note 47 above, para. 96. 61 By analogy with the general position that one cannot be required to conceal or be discreet about a protected characteristic, see X, Y, Z v Minister voor Immigratie en Asiel , C-199/12 - C-201/12, European Union: Court of Justice of the European Union, 7 November 2013, http://www.refworld.org/docid/527b94b14.html; UNHCR Observations in X, Y and Z, 28 September 2012, http://www.refworld.org/docid/5065c0bd2.html; Bundesrepublik Deutschland v Y and Z, Judgment of the Court (Grand Chamber) of 5 September 2012 http://www.refworld.org/pdfid/505ace862.pdf; RT (Zimbabwe) and others v Secretary of State for the Home Department, [2012] UKSC 38, United Kingdom: Supreme Court, 25 July 2012, http://www.refworld.org/docid/500fdacb2.html. 62 See UNHCR, Written Intervention before the Court of Justice of the European Union in the case of El Kott, 27 October 2011, para 4.3, C-364/11, http://www.refworld.org/docid/4eaa95d92.html and UNHCR, Oral intervention before the Court of Justice of the European Union in the case of El Kott and Others v. Hungary, 15 May 2012, C-364/11, http://www.refworld.org/docid/4fbd1e112.html, paras 10, 12-14. (“UNHCR Oral intervention in El Kott”). UNHCR’s views were accepted by the Court in El Kott, note 9 above, paras 80-81. 63 “There can be no doubt that the category of refugees considered in the present Paragraph is subject to the exclusion clauses contained in Article E and F, as well as to the cessation clauses enumerated in Article 1C of the Refugee Convention.” Grahl-Madsen, note 5 above, 142. 64 UNHCR Oral intervention in El Kott, note 63 above, para. 13. Although a common interpretation of this provision is that it only entitles the person to be considered under Article 1A(2) and that they must still meet the well-founded fear standard, “this is not the correct interpretation of Art. 1D as read in light of its history and protection purpose. The plain meaning of the term ‘ipso facto’ holds that no other criteria need to be used for assessing the situation – they are by the fact of that precondition alone de 14