UNDERSTANDING STATELESSNESS IN THE SYRIA REFUGEE CONTEXT  reported that in practice, the Turkish authorities sometimes do not accept Palestinian documents – such as Palestinian travel documents – which can result in irregular border crossing even for those with a valid Palestinian travel document.249 There have also been reports that the Turkish government refuses to issue Temporary Protection cards to some who hold a Syrian-issued Palestinian Travel Document.250 5.1.2.2 Children of PRS New-born PRS may fall through the gaps of registration and not be recorded anywhere, irrespective of whether the birth takes place within or outside UNRWA’s areas of operation. In order to add a child to their UNRWA records, a PRS must go through the office in Syria where the parents were initially recorded. This can be a complicated procedure and is often impossible when a family is displaced in a neighbouring country.251 However, as with all other Palestine Refugees, in exceptional circumstances UNRWA continues to record and provide services until the registration of the Refugee can be verified. The status of these children who have not been added to the family records may become increasingly vulnerable and they may remain unrecorded for many years,252 until they are able to return to Damascus. This lack of registration may mean it will be more difficult for them to obtain other documents in the future.253 5.1.2.3 Non-ID Palestinians A non-ID Palestinian is the term commonly used to refer to a Palestinian who is not registered with UNRWA, UNHCR or the authorities of the country in which they reside.254 Although there are no figures, there are known cases of non-ID Palestinians from Syria who have been displaced across the region. The operational definition of a Palestine Refugee that forms the basis for UNRWA registration is any person whose “normal place of residence was Palestine during the period 1 June 1946 to 15 May 1948 and who lost both home and means of livelihood as a result of the 1948 conflict”.255 While registration with UNRWA is a prerequisite for an entitlement to services, in exceptional cases, UNRWA has adopted a flexible approach to providing services until registration can be verified. The issue of non-registration with UNRWA is still a pertinent issue because Palestinians living in Syria previously enjoyed a wide range of rights and could often access basic services through UNRWA, regardless of their legal status or whether they were UNRWA-registered. Many had not therefore taken steps to register in the past. UNRWA accepts new registrations and for the duration of the conflict has also recorded individuals with neighbouring UNRWA fields of operation to ensure as far as possible that eligible persons receive services, even if not previously registered. Some refugees may nevertheless find it challenging to prove eligibility. At the same time, Palestine refugees who receive UNRWA assistance have been specifically excluded from the international refugee law regime of the 1951 Refugee Convention and its 1967 Protocol, which form important cornerstones for UNHCR’s refugee mandate.256 This 249 Amnesty International, Turkey: Struggling to Survive: Refugees from Syria in Turkey, 2014, available at: https://www.amnesty.org/en/documents/EUR44/017/2014/en, page 15. 250 See E. C. Dağlıoğlu, ‘Palestinian refugees from Syria face visa obstacle’, 3 June 2015, available at: http://www.agos.com.tr/en/article/10791/palestinian-refugees-from-syria-face-visa-obstacle and Action Group for Palestinians of Syria and Palestinian Return Centre, Palestinians of Syria. The Bleeding Wound, 2015, available at: http://actionpal.org.uk/en/reports/special/the_bleeding_wound_ semi_annual_report_2_2014.pdf, page 77. 251 Interview with UNRWA, Beirut Lebanon, May 2016. 252 UNHCR, The Situation of Palestinian Refugees in Lebanon, 2016, available at: http://www.refworld.org/ pdfid/56cc95484.pdf. 253 Emergency registration procedures allow for non-State endorsed documents to be accepted on an exceptional basis. There are, however, significant problems with physical access to registration points in Syria. 254 For more information on the definition and on the situation of non-ID Palestinians in Lebanon, see DRC, Survey Report on the Situation of Non-ID Palestinian Refugees - Lebanon, 2007, available at: http:// www.refworld.org/docid/47fdfad80.html. 255 UNRWA, Consolidated Eligibility and Registration Instructions (CERI), supra n241. 256 UNHCR, Revised Note on the Applicability of Article 1D of the 1951 Convention relating to the Status of Refugees to Palestinian Refugees, 2009, available at: http://www.refworld.org/docid/4add77d42.html. RESEARCH REPORT 47

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