entitled to return to their homes and properties. However, in accordance with the general principle that the benefits of the 1951 Refugee Convention are granted to persons who have crossed an international border, 1948 internally displaced Palestinians do not fall under the scope of Article 1D.271 The 2013 UNHCR Note refers to the second group as: Palestinians […] who are “displaced persons” within the sense of UN General Assembly Resolution 2252 (ES-V) of 4 July 1967 and subsequent UN General Assembly Resolutions, and who […] have been displaced from the Palestinian territory occupied by Israel since 1967.272 This second group of Palestinians falling within the scope of Article 1D includes persons who fled from the West Bank (including East Jerusalem) and the Gaza Strip as a result of the 1967 war. Descendants of beneficiaries also fall under the scope of Article 1D. Thus, for example, a Palestinian boy born in Gaza in 2014 to a mother whose parents fled Asqalan (today Ashkelon) in 1948 and took up residence in the Gaza Strip, still belongs to the group of 1948 Palestine refugees along with his mother and his grandfather. This interpretation draws, by analogy, on the position of family members in international refugee law, who are normally granted refugee status if the head of a family meets the criteria for the definition of a refugee, according to the principle of family unity.273 UNRWA has adopted a similar approach when providing assistance to descendants of Palestine refugees.274 The applicability of UNRWA’s mandate – entitlement to or actual registration with UNRWA – defines the scope of Article 1D to Palestinian refugees. Most 1948 Palestine refugees are registered with UNRWA. Some, however, decided not to register with the Agency, although they are eligible for registration. The 2013 UNHCR Note specifically criticizes the understanding of the CJEU, featured in its Bolbol decision, that only Palestinians who had “actually availed” themselves of the protection or assistance of UNRWA would be considered to fall under Article 1D. In the Note, UNHCR takes a different position, “based on the dual purposes of Article 1D to avoid overlapping competencies and to ensure the continuity of protection and assistance to Palestinian refugees.” By supporting the understanding that Article 1D applies both to Palestinians who were eligible as well as those 271 52 Note, however, that the borders of the state of Israel vis-à-vis the Palestinian West Bank and Gaza Strip remain undefined. 272 UNHCR, “2013 Note,” 3, item 2(b). 273 UNHCR, “Handbook on Procedures and Criteria for Determining Refugee Status under the 1951 Convention and the 1967 Protocol Relating to the Status of Refugees,” January 1992, para. 184, http://www.unhcr.org.hk/files/useful_resources/Important_documents/Handbook_on_ Procedures_and_Criteria_for_RSD.pdf. 274 Only descendants of males are considered Palestine Refugees, and are therefore counted as registered refugees under UNRWA’s mandate. Descendants of refugee females (even if their husbands are not refugees) are, however, eligible to receive UNRWA services and assistance (UNRWA, “Consolidated Eligibility and Registration Instructions (CERI),” 2009, 5). Handbook on Protection of Palestinian Refugees