According to Plan D: “[..] operations can be carried out in the following manner: either by destroying villages (avenue fire to them, by blowing them up, and by planting mines in their rubble), and especially those population centers that are difficult to control permanently; or by mounting combing and control operations according to the following guidelines: encirclement of the villages, conducting a search inside them. In case of resistance, the armed forces must be wiped out and the population expelled outside the borders of the state.”33 Plan D also called for the ‘transfer’34 of the Palestinian population out of their country, with Joseph Weitz, the head of the Jewish Agency’s Colonization Department at the time, stating that: “Between ourselves it must be clear that there is no room for both peoples together in this country [...] We shall not achieve our goal of being an independent people with the Arabs in this small country. [...] There is no other way but to transfer the Arabs from here to the neighboring countries; to transfer all of them; not one village, not one tribe should be left.”35 The resulting atmosphere of terror and panic led to the greatest outflow of refugees in April and early May 1948, before the start of the Arab-Israeli War.36 A massacre of more than 100 men, women, and children committed by Zionist forces in the Palestinian village of Deir Yassin on 9 April 1948 is widely acknowledged to have contributed to the fear and panic that led to the mass displacement. The unilateral declaration of the establishment of Israel in Tel Aviv on 14 May 1948 coincided with the withdrawal of British forces 33 For a full English translation of Plan D, see Walid Khalidi, ‘Plan Dalet: Master Plan for the Conquest of Palestine’ (1988) 18(1) Journal of Palestine Studies, 4-20 <https://doi.org/10.2307/2537591> accessed 3 October 2022. 34 War and genocide sociologist, Martin Shaw, pointed out that the Hebrew word used by the Zionist colonizers for ‘transfer’ is tihur, which actually is “closer in meaning to ‘purification’ or ‘cleansing’ of the land, and thus puts this strand of Zionist thinking close to […] ‘ethnic cleansing’ and ‘racial purification’ ideologies”, see Martin Shaw, ‘Palestine in an International Historical Perspective on Genocide’ (2010) 9(1) Holy Land Studies, 12 <https://doi. org/10.3366/hls.2010.0001> accessed 3 October 2022. 35 Cited in Haifa Rashed and Damian Short, ‘Genocide and settler colonialism: can a Lemkin-inspired genocide perspective aid our understanding of the Palestinian situation?’ (2012) 16(8) The International Journal of Human Rights, 1152 <https://doi.org/10.1080/13642987.2012.735494> accessed 3 October 2022. 36 Benny Morris, The Birth of the Palestinian Refugee Problem, 1947–1949 (Cambridge University Press 1987), 136 [hereinafter Morris, The Birth of the Palestinian Refugee Problem]. 7 Chapter Plan Dalet (also known as Plan D) was a military operational plan launched in March 1948 by the Haganah, the main Zionist militia led by David Ben Gurion, who two months later became the first Prime Minister of Israel. This plan resulted in the greatest outflow of refugees in April and early May 1948, before the start of the 1948 Arab-Israeli war. According to Plan D, Zionist forces deliberately employed tactics of violence aimed at forcibly removing Palestinians from their homes and encouraging flight. 1 Plan Dalet