2. Interpretations of Article 1D of the 1951 Refugee Convention 2.1. UNHCR’s Interpretation of Article 1D of the 1951 Refugee Convention UNHCR is responsible for providing international protection to refugees and is the guardian of the 1951 Refugee Convention.257. One type of protection that falls under the competence of UNHCR is supervising the application of international conventions providing for the protection of refugees by, for example, issuing guidelines on the application of certain provisions of the 1951 Refugee Convention.258 UNHCR has issued three Notes that provide guidelines for the interpretation of Article 1D.259 In October 2002, the Agency issued its “Note on Article 1D of the 1951 Convention” (hereinafter 2002 UNHCR Note),260 which, in October 2009, was replaced by “Revised Note on Article 1D of the 1951 Convention” (hereinafter 2009 UNHCR Revised Note).261 Most recently, in May 2013, UNHCR issued its “Note on UNHCR's Interpretation of Article 1D of the 1951 Convention relating to the Status of Refugees and Article 12(1)(a) of the EU Qualification Directive262 in the context of Palestinian refugees seeking international protection” (hereinafter 2013 UNHCR Note).263 Guidelines concerning Article 1D can also be found in UNHCR’s Statements – most notably, the “Revised Statement on Article 1D of the 1951 Convention” of October 2009 (hereinafter 2009 UNHCR Statement)264 – and interventions before courts – most notably, “UNHCR’s Oral Intervention at the Court of Justice of the European Union” of 2012 (hereinafter 2012 UNHCR Intervention),265 regarding the El Kott case (see below, section 2.2.6). Because the 2013 UNHCR Note constitutes the most recent guidelines concerning the interpretation of Article 1D, it is the main source of the analysis presented in this section; references to older position documents by UNHCR will be made either comparatively or complementarily. 257 UN General Assembly, “Convention Relating to the Status of Refugees,” Article 35. UN General Assembly, “Statute of the UNHCR,” Article 8(a). 259 UNHCR’s Notes are reproduced as Appendices. For a critique of the critique of the interpretation of Article 1D adopted by the UNHCR in its 1979 Handbook on Procedures and Criteria for Determining Refugee Status, see Takkenberg, The Status of Palestinian Refugees in International Law, 92–93. 260 UNHCR, “Note on the Applicability of Article 1D of the 1951 Convention Relating to the Status of Refugees to Palestinian Refugees,” October 2002, http://www.refworld.org/docid/3da192be4. html. 261 UNHCR, “2009 Revised Note.” 262 I.e., “Directive 2011/95/EU of the European Parliament and of the Council of 13 December 2011 on standards for the qualification of third-country nationals or stateless persons as beneficiaries of international protection, for a uniform status for refugees or for persons eligible for subsidiary protection, and for the content of the protection granted (Recast).” 263 UNHCR, “2013 Note.” 264 UNHCR, “Revised Statement on Article 1D of the 1951 Convention in Relation to Bolbol v. Bevándorlási És Állampolgársági Hivatal Pending before the Court of Justice of the European Union,” October 2009, http://www.refworld.org/docid/4add79a82.html. 265 UNHCR, “UNHCR’s Oral Intervention at the Court of Justice of the European Union, Hearing of the Case of El Kott and Others v. Hungary (C-364/11),” May 15, 2012, http://www.refworld.org/ docid/4fbd1e112.html. 258 50 Handbook on Protection of Palestinian Refugees