For this struggle or resistance to be lawful, it must be exercised according to the principles and norms of International Humanitarian Law (IHL) and International Human Rights Law (IHRL). The right to resist of people under foreign and colonial domination, including armed struggle, and the applicability of these provisions to the Palestinian people has been reaffirmed by many other UNGA resolutions.7 Although UNGA resolutions have no enforcement power per se, however, according to international law, they do reflect the common legal opinion of the international community. Some resolutions in some cases such as those dealing with peoples' right to self-determination are binding as they are a reproduction of international customary law. Illegality of Israeli Suppression of Resistance In the case of the Gaza Strip and the West Bank, including East Jerusalem, the status of that territory as occupied and the position of Israel as the occupying power has been clearly established as a matter of fact and law.8 The legality of Palestinian resistance has been strongly disputed by Israel since 1967, when it occupied the Gaza Strip and the West Bank, and illegally annexed East Jerusalem. Although East Jerusalem was unilaterally annexed by Israel, Article 47 of the Fourth Geneva Convention states that “Protected persons who are in occupied territory shall not be deprived, in any case or in any manner whatsoever, of the benefits of the present Convention […]by any agreement concluded between the authorities of the occupied territories and the Occupying Power, nor by any annexation by the latter of the whole or part of the occupied territory,”9 and hence, the same legal framework applies in East Jerusalem as in the rest of the oPt. Not only does Israel refuse to recognize the lawfulness of Palestinian resistance, instead it penalizes all forms of resistance. Israel’s suppression of the Palestinian struggle for liberation (resistance) is most prominently justified by self-defense and counterterrorism. With regard to the latter, utilizing a few separate, occasional, and disorganized actions 12 7 Some of them are: UNGA Resolution A/RES/3246 (XXIX; 29 November 1974), UNGA Resolution A/RES/33/24 (29 November 1978), UNGA Resolution A/RES/34/44 (23 November 1979), UNGA Resolution A/RES/35/35 (14 November 1980), and UNGA Resolution A/RES/36/9 (28 October 1981) 8 United Nations Security Council (UNSC) Resolution S/RES/242 (22 November 1967); UNSC Resolution S/RES/338 (22 October 1973); International Court of Justice (ICJ), Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory, Advisory Opinion, 9 July 2004 (hereafter ‘The Advisory Opinion on the Wall’), para. 136. See also: UN Human Rights Committee, General Comment 31: Nature of the General Legal Obligation on States Parties to the Covenant, CCPR/C/21/ Rev.1/Add.13, 2004, page 11; and International Court of Justice, Armed activities on the territory of the Congo (D.R.C. v. Uganda), 19 December 2005 9 Convention (IV) relative to the Protection of Civilian Persons in Time of War, Geneva (Geneva Convention IV), 12 August 1949, Article 47