Consequently, Article 1D was adopted in its entirety by sixteen votes to none, with three abstentions.237 Article 1D of the 1951 Refugee Convention references relevant United Nations General Assembly resolutions. Resolutions related to the hostilities of 1948 are relevant for determining the group of Palestinians qualifying as refugees vis-à-vis Israel (the refugee-generating state/persecuting state), and provides for their entitlement to protection under the Convention until their situation is resolved in accordance with these resolutions if the special UNCCP/UNRWA regime should fail them.238 It is thus the purpose of Article 1D to ensure continuity of protection for Palestinian refugees as long as no durable solutions are found for them. Based on Article 1D, Palestinian refugees and displaced persons who benefit from special status under international refugee law thus constitute a group distinct from other refugees. 1. Standards and Benefits of the 1951 Refugee Convention The 1951 Refugee Convention prescribes certain standards of treatment and benefits to be granted to refugees.239 Most of them require a legal stay in the host country. The minimum standard is that refugees should receive at least the treatment accorded to aliens in general. A higher standard is that of most-favored-nation treatment, for example, with respect to the right of association and the right to engage in wage-earning employment. The highest standard is treatment equal to nationals, prescribed with regard to: freedom of religion (Article 4); protection of artistic rights and industrial property (Article 14); access to courts, legal assistance, and exemption from the requirement to give security for costs in court proceedings (Article 16); rationing (Article 20); elementary education (Article 22(1)); public relief (Article 23); labor legislation and social security (Article 24(1)); and fiscal charges (Article 29).The 1951 Refugee Convention specifies benefits and standards of refugee protection in Articles 3-5, 7-8, 10-24, and 26-34. 1.1. Non-refoulement The principle of non-refoulement is a core principle of refugee law that prohibits states from returning refugees in any manner whatsoever to countries or territories 237 44 UN General Assembly, “Conference of Plenipotentiaries on the Status of Refugees and Stateless Persons, Summary Record of the Thirty-Fourth Meeting, 25 July 1951,” November 30, 1951, 12, UN Doc. A/CONF.2/SR.34. 238 While at the time of drafting the 1951 Refugee Convention, United Nations General Assembly Resolution 194(III) (1948) represented the major relevant United Nations resolution, the plural chosen in the language “relevant UN resolutions” clearly implies that the drafters intended to make reference also to other relevant United Nations resolutions (e.g., United Nations General Assembly Resolution 181(II)) and Armistice agreements. Also, it implies the drafter’s expectation of passing resolutions on Palestine refugees’ status and durable solutions in the future. Thus, the plural language used at the time established a wide space to include future relevant resolutions dealing with unexpected evolution of the unresolved problem of Palestine refugees, such as United Nations Security Council Resolution 237 (1967). 239 Note that states might have made reservations to these standards. Handbook on Protection of Palestinian Refugees