Handbook of Refugee and Forced Migration Studies UNRWA and Palestinian Refugees UNRWA areas on that date. The phrase ‘protection or assistance has ceased for any reason’ refers only to when UNRWA ceases to operate, and not to actual termination of services for any particular individual. In Bolbol v. Bevandorlasi es Allampolgarsagi Hivatal (BAH) (June 2010) C-31/09, the European Court of Justice (ECJ) held the opposite, finding that the ‘protection or assistance has ceased’ language applied to individuals who have actually availed themselves of UNRWA’s assistance, but which is no longer available. In 2012, the ECJ expanded this interpretation of 1D in El Kott v. BAH (13 September 2012) C-364/11, finding that the phrase ‘protection or assistance has ceased’ refers to the protection or assistance to which individuals had actually availed themselves, and which is no longer provided to them for any reason beyond their control. The ECJ further found that the ipso facto clause of 1D means that if the prior conditions are satisfied, the individual Palestinian would be automatically entitled to refugee status in a member state. Under either the El-Ali or the Bolbol decision, the vast majority of Palestinians who would be considered ‘Palestine refugees’ under the Res. 194(III) definition would not be considered ‘Palestinian refugees’ under Article 1D. Nor would they be recognised as refugees under the narrow definition of Article 1A(2). Following the El-Ali case, in the October 2012 decision of Said v. Sec’y of State for the Home Dept. (26 October 2012) UKUT 00413 (IAC), the UK court 14