only to the narrow caveat of imperative military reasons or security of the population, and even then subject to strict criteria for the conditions under which such transfer may happen, and it must be temporary. Lack of compliance with the duty to protect Palestinians with Israeli citzenship Within its 1948 borders, Israel acts as a state and therefore its obligation to protect its citizens is the same that is applied to all other states. However, not only has Israel failed to abide by this obligation, it has continually and intentionally displaced Palestinians within and outside that territory. The 1947 UN Partition Plan recommending the partition of Palestine into two states, and the British mandate that preceded it, provided the necessary conditions for the Zionist movement to induce the widespread displacement of Palestinians in order to make way for a Jewish state. Plan Dalet (Plan D) was formulated in March 1948 by Haganah, the leading Zionist militia led by David Ben Gurion, who two months later became the first Prime Minister of Israel. This plan resulted in a great outflow of refugees in April and early May 1948, before the start of the 1948 War. According to Plan D, Zionist forces deliberately employed violent and coercive tactics aimed at forcibly removing Palestinians from their homes and causing their flight. By the end of the War, between 750,000 and 900,000 Palestinians had been forcibly displaced. Half of these were displaced before 15 May 1948, when the War officially began. Ultimately, 85 percent of the indigenous Palestinian population, who had been living in the territory that became Israel, were displaced.23 Since its establishment, Israel has employed a variety of policies to continue displacing large numbers of Palestinians from their homes. Following the 1948 War, Israel established a military government in the Galilee, the “Little Triangle” (an area ceded to Israel under the armistice agreement with Jordan), the Naqab (Negev), and the cities of al-Ramla, al-Lydd, Jaffa, and al-Majdal Asqalan to control the remaining Palestinian population inside Israel and to prevent the return of both Palestinian refugees and IDPs.24 During this period of Israeli military administration (1949-1966), even more Palestinians were expelled from their homes and lands, primarily during military operations aimed at optimizing Israel’s demographic and strategic 23 Tom Segev, 1949, The First Israelis (New York: Henry Holt, 1986) [hereinafter, Segev, The First Israelis]. 24 Jiryis Sabri, The Arabs in Israel (New York: Monthly Review Press, 1976). 17