transit, or to re-enter and reside, or where the authorities in the receiving country refuse his or her re-admission or the renewal of his or her travel documents. - Safety barriers would include dangers en route such as mine fields, factional fighting, shifting war fronts, banditry or the threat of other forms of harassment, violence or exploitation.292 The Note highlights, however, that the meaning of “ceased for any reason” should not be construed restrictively, and that the “objective reasons” that might impede an individual from (re-)availing himself or herself of UNRWA’s services are not limited to the examples above.293 2.1.4. UNHCR’2 2013 Note and the El Kott decision The most recent regional jurisprudence regarding Article 1D is provided by the Court of Justice of the European Union, in its decision regarding the El Kott case (see section 2.2.6 below). UNHCR provided legal advice on the issues arising in the case through its 2012 Intervention,294 and the 2013 UNHCR Note, largely based on that intervention, generally endorses the El Kott decision. Both the 2013 UNHCR Note and the El Kott decision present similar interpretations, that the term “ceased for any reason” is not restricted to “the abolition of that agency or an event which makes it generally impossible for it to carry out its mission.”295 A third possibility involves what UNHCR refers to as “any objective reason outside the control of the person concerned such that the person is unable to (re)avail themselves of the protection or assistance of UNRWA,”296 and which is also covered by El Kott decision as reasons “beyond his [or her] control and independent of his [or her] volition.”297 Notwithstanding, in contrast to the guidelines in the 2013 UNHCR Note, the El Kott decision establishes that: […] the cessation of protection or assistance from organs or agencies of the United Nations other than the HCR ‘for any reason’ includes the situation in which a person who, after actually availing himself of such protection or assistance, ceases to receive it for a reason beyond his control and independent of his volition [emphasis added].298 292 Ibid., 5. Ibid., 4. 294 UNHCR, “UNHCR’s Oral Intervention at the Court of Justice of the European Union, Hearing of the Case of El Kott and Others v. Hungary (C-364/11).” 295 Court of Justice of the European Union, “El Kott,” para. 58. In the 2013 UNHCR Note, those possibilities are described as “(i) the termination of UNRWA as an agency” and “(ii) the discontinuation of UNRWA’s activities” (UNHCR, “2013 Note,” 4). 296 UNHCR, “2013 Note,” 4. 297 Court of Justice of the European Union, “El Kott,” 65, also mentioned in para. 61, 64, 74 and 82(1). 298 Ibid., para. 65. 293 The 1951 Refugee Convention and Article 1D 57