Criteria and rules for denial of a permit are generally not published.11 The lack of transparency and the consequential lack of meaningful opportunities for appeals is not a new phenomenon, but one that has always been a defining characteristic of the permit regime. Indeed, the lack of transparency has been criticized since at least 1996.12 South African Pass Laws The Israeli permit regime shares many similarities with the former South African Pass Laws. Like the Israeli regime, the Pass Laws continued to grow in number and, ultimately, came to control most aspects of the lives of black African citizens in South Africa.13 For example, the Pass Laws made it an offence for these citizens to be in what were considered “white areas” if they could not show the correct documentation.14 In 1986, when the Pass Laws were finally repealed, they had led to more than 17 million arrests.15 In 2011, former UN Special Rapporteur on the situation of Human Rights in the Palestinian territories, John Dugard, himself from South Africa, wrote about the similarities between the Israeli permit regime and the South African Pass Laws. Dugard stated that, although the two regimes are very different, in practice there is little difference, as “[b]oth regimes were/ are characterized by discrimination, repression and territorial fragmentation”.16 To Dugard, the demolition of Palestinian homes, built without the necessary permits, reminded him of the situation in South Africa, where homes located in “black areas” were demolished if the area was set aside for white occupation. However, he continued, the humiliating check points, where Palestinians have to show that they have the necessary permits, are even worse than the way Pass Laws were implemented in South Africa.17 11 Yael Berda, “The Bureaucracy of the Occupation: An Introduction to the Permit Regime”, cccb. org, 2006, page 9. Available at: www.academia.edu/2123046/THE_BUREAUCRACY_OF_THE_ OCCUPATION_AN_INTRODUCTION_TO_THE_PERMIT_REGIME_2006 12 Human Rights Watch, “Israel’s Closure of the West Bank and Gaza Strip Vol. 8, No. 3”, July 1996. Available at: https://www.hrw.org/reports/1996/Israel1.htm 13 Overcoming Apartheid and Michigan State University, “Pass Laws”, located 4 December 2015, available at: http://overcomingapartheid.msu.edu/multimedia.php?id=65-259-3 14 John Dugard, “The Law and Practice of Apartheid in South Africa and Palestine”, al-Majdal, issue no. 47, autumn 2011, available at: http://www.badil.org/en/publication/periodicals/al-majdal/ item/1692-art4.html 15 Overcoming Apartheid and Michigan State University, “Pass Laws”, located 4 December 2015, available at: http://overcomingapartheid.msu.edu/multimedia.php?id=65-259-3 16 John Dugard, “The Law and Practice of Apartheid in South Africa and Palestine”, al-Majdal, issue no. 47, autumn 2011, available at: http://www.badil.org/en/publication/periodicals/al-majdal/ item/1692-art4.html 17 Ibid. 12