Conclusion Discussion of the implementation of the right of return of Palestinian refugees raises all sorts of questions regarding the nature of the state of Israel and the legality of its actions vis-à-vis Palestinian refugees, including barring their right of return, subsequent mass denationalization and the illegal confiscation of their entire private property and land-holdings.[44] Consequently, it will come as no surprise to learn that supporters of the Zionist position (who hold that all these actions are perfectly legitimate) have labored long and hard – as noted at the beginning of this Brief - to challenge the legal validity of Resolution 194. Following are responses to some of the most prevalent arguments, which have been raised to challenge and argue against the binding nature of Resolution 194. First, the argument is raised that Resolution 194 is not binding because the word “should” is used instead of a stronger term, for example the word “shall.” A related argument is that since General Assembly resolutions are only recommendatory in nature anyway, Resolution 194 could not be binding. Both of these arguments fail to take into consideration that by 1948, the right of return had already gained customary status under international law. Therefore, implementation of the right of return in 1948 was in any case mandatory upon all states, regardless of the use of the word “should” or the fact that the resolution was issued by the General Assembly. Moreover, Resolution 194 has never been annulled, repealed, diluted or overturned in any way. On the contrary, Resolution 194 has been reaffirmed annually by the United Nations every year since it was initially passed in 1948. Second, the argument is raised that Israel is not expressly mentioned by name in Resolution 194 and therefore that the call to repatriate the Palestinian refugees is somehow not necessarily binding upon Israel. This argument fails to take into consideration the obvious point that Israel was the only country of origin whose policies (including refusal to readmit) generated the refugee situation in the first place. Therefore, the call to repatriate the refugees constituted a binding obligation, under international law, on the sole country of origin, which was and remains Israel. Third, the argument is raised that Resolution 194 describes the returning refugees as being those who “wish[] to … live at peace with their neighbors,” and that this somehow implies that Israel has the right to “screen out” returning refugees according to its own internally defined criteria. This argument fails to take into consideration the obvious point that Palestinian refugees realize full well that they are seeking to return to the state of Israel, and they realize that they will be fully subject to its laws and regulations, as is normal in all cases of naturalized citizens. Israel should not be permitted to use arbitrary or discriminatory filters to screen out potential returnees, especially filters that do not conform to normal due process guarantees or other requirements of international law, such as are practiced in other existing nation states.