2.5. Current Opinion among Scholars Based on the above interpretation of the drafting history of Article 1D, scholars generally agree that Palestinian refugees who meet the requirements for inclusion under Article 1D(2) do not need to undergo additional determination of refugee status in order to qualify for protection under the 1951 Refugee Convention (i.e, they do not need to demonstrate that they have a well-founded fear of persecution for a Convention reason).372 Alternative Interpretation of Article 1D Susan Akram developed an alternative to the UNHCR interpretation of Article 1D.373 Her legal interpretation agrees with UNHCR that the inclusion clause (second paragraph) in Article 1D entitles Palestinian refugees to status and benefits under the 1951 Refugee Convention without having to fulfil the individualized criteria set out in Article 1A(2). Akram’s interpretation, however, reaches a different conclusion regarding the event that triggers the applicability of the inclusion clause. They argue that the end of effective protection, through the cessation of UNCCP’s protection activities in 1952, is the single crucial event that triggers the inclusion clause for Palestinian refugees. In contrast, UNHCR considers cessation of UNRWA assistance as the event that triggers the inclusion clause. Akram and Rempel ask: Is the inclusion provision triggered by the cessation of assistance, the cessation of protection, the cessation of either one, or of both? The prevalent interpretation of this provision is that Palestinians must not be receiving any benefits from a UN organ or agency before they will be eligible for Refugee Convention coverage. In other words, according to this interpretation, Palestinians must be receiving neither protection nor assistance before they can be included under the Convention regime. As a preliminary matter, that interpretation appears contrary to the plain language. In order to make sense, the “when such protection or assistance has ceased” language must be read to give meaning to the entire sentence. The plain meaning of the word “or” in this phrase means that those refugees who are not receiving either protection or assistance are to be covered by the alternate protection scheme of the 1951 Refugee Convention. This interpretation is confirmed by the drafting history, and the purpose this provision was intended to fulfil[.]374 See Takkenberg, The Status of Palestinian Refugees in International Law, 123; Goodwin-Gill and McAdam, The Refugee in International Law, 92; Grahl-Madsen, The Status of Refugees in International Law, 141; Akram and Rempel, “Temporary Protection as an Instrument for Implementing the Right of Return for Palestinian Refugees,” 81. An exception can be found in Hathaway, The Law of Refugee Status, 208:“More specifically, this exclusion clause applies to all Palestinians eligible to receive UNRWA assistance in their home region. It does not exclude only those who remain in Palestine, but equally those who seek asylum abroad.” 373 Akram and Rempel, “Recommendations for Durable Solutions for Palestinians Refugees: A Challenge to the Oslo Framework.” 374 Ibid., 30. 372 The 1951 Refugee Convention and Article 1D 71