Handbook of Refugee and Forced Migration Studies UNRWA and Palestinian Refugees entire group or category, making these two definitions inconsistent in their application to Palestinians. Adding to the complexity of Palestinian refugee status is the wide divergence in interpretations under state domestic policies and jurisprudence. Badil’s Handbook on Protection of Palestinian Refugees (BADIL 2005, 2011) is the most comprehensive study available, and reports that in 20 of the 23 states researched, ‘Article 1D is either not incorporated or applied at all, or interpreted in a way that precludes recognition of Palestinian refugees as refugees under this provision’ (ibid, 337). The Handbook concludes that ‘due to the particular interpretation of Article 1D by national authorities and courts in these countries, Palestinian asylum-seekers have not derived any rights and benefits from Article 1D beyond the “right” to not be excluded from applying for refugee status under Article 1A(2) of the 1951 Refugee Convention’ (ibid, 337-338)vii Recent European cases illustrate the inconsistent application of Article 1D. In El-Ali v. The Secretary of State for the Home Department (26 July 2002) EWCA Civ. 1103. 1WLR 95, an immigration court in the United Kingdom interpreted Article 1D’s phrase ‘at present receiving’ as relating only to the date on which the Refugee Convention was signed. Thus, Article 1D applies only to those Palestinians who were born on or before 28 July 1951, and were in 13