2021 Statelessness & Citizenship Review 3(1) CONSIDERATIONS RELATING TO CURRENT EVENTS The inability to travel to some destinations, due to COVID-19 or border closures for security or political reasons, may be a material consideration in establishing that an applicant cannot return to an UNRWA area for reasons beyond their control. Another important factor that may affect the future of art 1D jurisprudence is UNRWA’s ability to continue functioning, and in which circumstances. For years, despite significant successes, UNRWA has been unable to adequately meet some needs of the people it serves, due to resource constraints. The US discontinuation of UNRWA funding in 2018 had a severe impact, but it is likely that President Joe Biden will resume major US contributions to UNRWA.40 CONCLUSION Following XT, if a Palestinian refugee could live in safety and dignity in any part of UNRWA’s area of operation, they will be excluded from the benefits of the Refugee Convention under art 1D. This will make it more evidentially challenging for some Palestinian refugees to prove that they merit protection under art 1D and will likely result in exclusion of some Palestinian refugees who merit protection. Prior voluntary travel from one field of UNRWA operation to another may also lead to exclusion in some cases. This seems unnecessary and likely to result in problematic situations; for example, where a Palestinian has voluntarily travelled from Jordan to Syria but cannot return, either to a life of dignity or at all, to any part of UNRWA’s area of operations, for reasons beyond their control. It is hoped that domestic courts and future CJEU jurisprudence will clarify that the inability to return to an UNRWA area and live in safety and dignity are the material factors in this consideration, rather than prior voluntary travel from one UNRWA field to another. 40 ‘Countries Raise $130 million for UNRWA and Commit Long-Term Support to Palestine Refugees’ United Nations Relief and Works Agency for Palestine Refugees in the Near East (Press Release, 23 June 2020) <https://www.unrwa.org/newsroom/press-releases/countriesraise-130-million-unrwa-and-commit-long-term-support-palestine>. Specific details of amounts were not publicly available at time of writing, however. See Mayaan Lubell and Rami Ayyub, ‘Analysis: What will survive of U.S.-Middle East policy under Biden?’ Thomson Reuters (News Article, 20 Jan 2021) <https://www.reuters.com/article/us-usatrump-legacy-mideast-analysis-idUSKBN29P1RB>; ‘Biden Administration to Restore Aid to Palestinians’ BBC News (News Article, 27 January 2021) <https://www.bbc.com/news/world-middle-east-55824227>. 112