The active role the PFLP leader played did not in any way justify his assassination. If Israel had evidence of his involvement in attacks, and in consideration of the ‘effective control’ Israel had of the oPt, it should have tried to apprehend him instead. However, this killing exemplifies Israel’s continued implementation of its fierce and consistent policy of ’targeted killings’ carried out against Palestinian people. In 2006 the Israeli Supreme Court developed the legal underpinnings of the targeted killings policy, but in doing so it adopted a mixed approach. It held that the hostilities paradigm was the applicable framework for targeted killings, but only permitted the targeting of civilians if they “directly participated in hostilities.”71 Israel has often justified the use of this paradigm on the existence of an armed conflict against alleged terrorists.72 This is an obvious argument as the hostilities paradigm has less restrictive regulations for killing someone than IHRL, and it usually provides immunity to the army. Although IHL also contains restrictions, such as the requirement that lethal force be necessary and proportional, it does serve to expand the executive power in terms of domestic law and it facilitates public support.73 This appeal has a significant potential for abuse by state powers. Israel, by unilaterally expanding the applicability of the laws of armed conflict to cases where the law enforcement paradigm as regulated by IHRL should be applicable, such as in the oPt, it obscures the necessary distinction between the different paradigms that are in place to restrict the powers of states to carry out arbitrary or targeted killing.74 However, the legality of a killing is governed by human rights standards, as established by international law and as mentioned in the legal framework. Taking into consideration the requirements of proportionality and necessity, an intentional, premeditated, and deliberate killing is a targeted killing, and as such, can never be legal as it is never permissible for the objective of a law enforcement operation to be killing. Israel has often justified this policy by claiming it was the only way to stop Palestinian ‘terror’ attacks, or that the killings were an act of self-defense. As previously explained, this argument disregards IHRL, which imposes a duty on states to respect and ensure the right to life and the obligation to exercise ‘due diligence’ to protect the lives of individuals from attacks. Therefore, according to IHRL, Israel should protect the lives of its citizens from attacks, 71 Israel High Court of Justice, The Public Committee Against Torture et al. v. The Government of Israel, et al., HCJ 769/02, Judgment of 14 Dec. 2006 (PCATI) 72 Ibid. 73 UN Special Rapporteur Philip Alston, op.cit. (A/HRC/10/24/Add.6), page 16 74 Ibid. 25