UNRWA. Nevertheless, in Bolbol (2010), the Court limited the class of Palestinians entitled to invoke the protection of the 1951 Convention under Article 1D to those who have actually availed themselves of UNRWA assistance, while those who were merely “eligible” fell outside. This ruling was mitigated somewhat by the Court also finding that evidence of registration for assistance was enough. In El Kott (2012), the Court was faced with the question of what it means for protection or assistance to have ceased “for any reason.” It rejected the argument that simple residence outside UNRWA’s area of operations was enough, or that UNRWA itself would have to come to an end. Instead, and in-between, the Court imposed the requirement that protection or assistance to an “eligible” Palestinian refugee would need to have ceased for a reason beyond the control and independently of the volition of the individual concerned, for example, when he or she was forced to leave UNRWA’s area of operations because their personal safety was at risk. The Court then emphasized – and here it reflected the European Union’s predisposition for procedures, rather than the non-specific terms of the 1951 Convention – that Palestinians did not enjoy an unconditional right to refugee status and the benefits of the Convention. Rather, they needed still to submit an application for refugee status, which the national authorities should consider with regard, not to whether the applicant had a well-founded fear of persecution, but to whether (a) he or she had actually sought assistance from UNRWA, (b) that assistance had ceased for reasons beyond the applicant’s control or volition, and (c) the applicant might otherwise be denied protection, for example, by reference to Articles 1C, 1E or 1F of the Convention. If the applicant were able to return to that area of UNRWA’s operations where he or she was formerly resident, then refugee status would cease. On the plus side, the Court underlined that the words of Article 1D entailed entitlement “as of right” to the benefits of the Convention (or, perhaps more accurately, the benefits of the European Union’s Qualification Directive, which is based on the Convention). If there is one clear phrase in Article 1D, it is that once the general conditions are met, then Palestinians are “ipso facto entitled” to the benefits of the Convention. In the compelling French version, they “bénéficieront de plein droit du régime de la Convention.” “Ipso facto” means “by that very fact,” “by virtue of the fact itself,” in this case the cessation of protection or assistance and the absence of definitive settlement, which are the facts expressly mentioned. The French text is equally or even more clear: “de plein droit” means, “par le seul effet de la loi, sans contestation possible; à qui de droit.” The intent of these words should have guided the application of Article 1D as a whole, and it is seriously to be hoped that, so long as Palestinian refugees continue to be in need of protection and assistance, an approach consistent with the object and purpose of the relevant international instruments will be adopted; the goal of continuity of protection should be especially recalled, and given life and meaning. Despite the welcome clarifications by the CJEU, the regime of protection for Palestinian refugees remains incomplete. Within its area of operations, UNRWA’s Preface xi