Article 1A(2) of the Refugee Convention, rather than Article 1D. The Court decided that the applicant could not be granted refugee status in France, because he had not personally been exposed to a serious threat, and therefore could not demonstrate personal fear of persecution within the meaning of the Geneva Convention. Case 493412, A, of 14 May 2008628 On 14 May 2008, the Court granted refugee status to Mohammed Assfour, a Palestinian asylum seeker who was registered with UNRWA in Jordan. Mr. Assfour voluntarily left Jordan for France in 2003. In its decision, the Court declared that Article 1D applies only to asylum seekers actually receiving assistance from UNRWA or other UN agencies. According to the Court, once an asylum seeker leaves the UNRWA area of operations, this protection ceases and the asylum seeker is entitled to protection under the Refugee Convention. While the Court reserved the right to reject an application under Articles 1E and 1F, the Court applied Article 1D and did not require Article 1A(2) to apply for a Palestinian asylum seeker to be granted refugee status. Here, while the circumstances surrounding the Mr. Assfour’s departure from Jordan were not enumerated, the court declared that he was no longer under the protection of UNRWA as he was outside of Jordan, and automatically granted him refugee status. Case 318356, A, of 23 July 2010629 In this case, the Office for Refugees claimed that there was an error in the decision of 14 May 2008 regarding Mohammad Assfour’s case, and requested a re-evaluation of the decision. Upon evaluation, the Court declared that the previous decision was in error, as it failed to consider whether the asylum seeker left Jordan due to the circumstances detailed in Article 1A(2) of the Refugee Convention. In so doing, the Court clarified its position regarding Article 1D. While the exclusion clause in Article 1D does not apply to Palestinians who left the area of UNRWA’s mandate, the asylum seeker is only entitled to protection under the Refugee Convention if he or she left the UNRWA area due to a well-founded fear of persecution within the meaning of Article 1A(2) of the Refugee Convention. Here, the Judge did not determine whether Mr. Assfour left Jordan due to a fear of well-founded persecution, as described in Article 1A(2). Rather, the decision simply noted a mistake in the previous decision and, for that reason, nullified the decision of 14 May 2008. Commission des Recours des Réfugiés (CRR), Contentieux Des Réfugiés: Jurisprudence Du Conseil d’État et de La Commission Des Recours Des Réfugiés, Année 2008 (Cour Nationale du Droit d’Asile (CNDA), April 5, 2009), 76–77, http://www.cnda.fr/content/download/5122/15496/version/1/file/ recueil2008.pdf. 629 Commission des Recours des Réfugiés (CRR), Contentieux Des Réfugiés: Jurisprudence Du Conseil d’État et de La Commission Des Recours Des Réfugiés, Année 2010 (Cour Nationale du Droit d’Asile (CNDA), February 1, 2012), 131–132, http://www.cnda.fr/content/download/7969/24037/ version/1/file/recueil-2010.pdf. 628 128 Handbook on Protection of Palestinian Refugees

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