civilians. Often Palestinian individuals and communities are threatened with death or injury in order to deter future demonstrations. Not only is the use of excessive force illegal, but the threats to carry out an act deemed illegal by international law is in itself illegal as well.79 When suppressing these demonstrations, Israel is carrying out a law enforcement operation as part of its policing obligations as an occupying power. Since the applicable paradigm is that of law enforcement, protesters cannot be treated as combatants and the regulations regarding the use of force are those established by IHRL.80 While there is not a recognized ‘right to protest’ per se under IHRL, when participating in protests and demonstrations, Palestinians are exercising their right to freedom of peaceful assembly and association, as well as their right to freedom of opinion and expression, as enshrined in Articles 19 and 20 of the UDHR, which guarantees the right to protest. The only restrictions that may be placed on these rights are “those imposed in conformity with the law and which are necessary in a democratic society in the interests of national security or public safety, public order, the protection of public health or morals or the protection of the rights and freedoms of others.”81 Protests do not necessarily or always impose a threat to national security, they often constitute positive support for a more democratic and just order. The Israeli military order that regulates demonstrations in the West Bank is the “Order Regarding Prohibition of Incitement and Hostile Propaganda Actions" also known as Order No. 101, from 1967.82 According to this order, any assembly, demonstration or vigil of ten or more people requires a permit from the Israeli occupying forces, if the gathering could be interpreted as having a ‘political’ purpose. This applies to any gathering, in public spaces or in private homes, and the order also allows the military commander to close any space where a gathering is happening.83 This Military Order, therefore, severely restricts the aforementioned rights of association and expression that Palestinians hold. Moreover, further disregard for these rights is illustrated by the 2010 military orders issued by the Officer Commanding (OC) Central Command, imposing a sweeping prohibition on demonstrations 79 Geneva Convention IV, Article 27 80 Al-Haq, A Demonstration of Power: Israel’s Excessive Use of Force resulting in the Killing of Non-Violent Palestinian Protestors and Demonstrators during 2014 and 2015, May 2016. Available at: http://www. alhaq.org/publications/papers/Excessive.Use.of.Force.pdf 81 ICCPR, Article 21 82 Israel Defense Forces, Order Regarding Prohibition of Incitement and Hostile Propaganda Actions, Order No. 101. Available at: http://www.btselem.org/download/19670827_order_regarding_ prohibition_of_incitement_and_hostile_propaganda.pdf 83 B’Tselem, Military Law, last update: 2 January 2013. Available at: http://www.btselem.org/ demonstrations/military_law 27