By Sonia Boulos
On 21 September 2025, the United Kingdom, Canada, Australia, and Portugal formally recognized the State of Palestine in a coordinated diplomatic initiative unprecedented among Western allies of Israel.1 Additional recognitions by other European and Western states were expected to follow in the days ahead, reinforcing the sense of a concerted policy shift. This wave of recognition was deliberately timed to coincide with the opening of the United Nations General Assembly on 22 September 2025, which included a high-level summit devoted to reviving the two-state solution – a gathering of world leaders intended to reassert international commitment to a negotiated peace.2 By aligning their decisions with this summit, these governments not only signaled a collective departure from past caution but also sought to shape the debate within the UN framework, injecting renewed momentum into diplomatic efforts toward Palestinian statehood.
Two main justifications were advanced for this shift. First, the deteriorating humanitarian situation in Gaza, described in terms such as “man-made humanitarian crisis”3 or the “Israeli government’s contribution to the humanitarian disaster in Gaza,”4 though the term genocide was carefully avoided. Second, recognition was framed as essential to preserving the two-state solution after the widely acknowledged demise of the Oslo process, in parallel with the unprecedented expansion of settler-colonial policies in the West Bank.
There is no doubt that the recognition of a Palestinian state constitutes an important reaffirmation of the inalienable right of the Palestinian people to self-determination. Recognition becomes even more important in the face of a violent settler-colonial project, now in its genocidal phase most visibly in Gaza, that openly denies the very existence of a Palestinian people. This denial was elevated to a constitutional principle with the enactment of the 2018 Basic Law: Israel as the Nation-State of the Jewish People, which explicitly affirms that the right to self-determination belongs exclusively to the Jewish people, excluding Palestinians. Efforts to deny Palestinian rights to self-determination are also reinforced by the Israeli government’s announced plans for the annexation of large parts of the West Bank, and by resettlement schemes in Gaza that seek nothing less than the erasure of Palestinian presence there, together with its categorical insistence that a Palestinian state will never come into being.5 Against this backdrop, recognition is viewed by many as a historical moment of reaffirming international commitment to Palestinian sovereignty in the face of systematic efforts to foreclose it.
Despite its symbolic weight, recent moves toward recognition have been met with skepticism – ranging from faint optimism to outright cynicism.6 To many, they appear as hollow gestures aimed at deflecting public outrage over Western inaction in the face of Israel’s ongoing crimes. More critically, such declarations obscure the extent to which some of these very states have directly or indirectly enabled the genocidal violence in Gaza. Calls for recognition also serve to neutralize the decolonial framework that has taken shape in response to the genocide in Gaza – one that challenges both Israel’s practices and the colonial legacies underpinning them. The goal of this paper is not to dismiss the potential transformative power of recognition per se, but rather to contend that, in its current form, recognition undermines the very objectives of decolonization and emancipation for the Palestinian people.
Evading the duty to prevent genocide by performative politics
Indicating a series of provisional measures in the Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip, the International Court of Justice (ICJ) determined that the risk of genocide in Gaza was “plausible” and that there existed a “real and imminent risk” of irreparable harm to the rights of Palestinians protected under the Convention.7 Prevention lies at the core of the Genocide Convention, as its full title suggests. As the Court held in the Bosnian Genocide case, the duty to prevent requires States Parties to employ all means reasonably available to them to avert genocide, even where the actors in question are not under their direct control.8 This duty arises the moment a state knows, or should have known, of a serious risk that genocide will be committed.
In these cases, responsibility is incurred if the state manifestly fails to take all measures within its power to prevent genocide when such measures might have contributed to preventing it. In assessing whether a state has discharged this duty, the ICJ emphasized that a crucial factor is the state’s capacity to influence the actors likely to commit, or already committing, genocide. Importantly, the Court clarified that such capacity must be assessed against legal criteria, since states may only act within the limits permitted by international law.9
The Court also distinguishes between the obligation to prevent genocide under Article 1 of the Convention and complicity in genocide under Article 3(e). Complicity “requires that some positive action has been taken to furnish aid or assistance to the perpetrators of the genocide,”10 whereas the violation of the obligation to prevent “results from mere failure to adopt and implement suitable measures to prevent genocide from being committed.”11
By affirming the plausibility of genocide in Gaza, the ICJ has placed all States Parties on notice. Consequently, the continued supply of arms to Israel is not only a breach of the obligation to prevent genocide under Article 1, but may well amount to complicity in genocide under Article 3(e).
This conclusion is inescapable as it is further reinforced by a series of authoritative reports that have unequivocally accused Israel of committing genocide in Gaza. Foremost among these are the reports of UN Special Rapporteur Francesca Albanese, who has consistently advanced the legal case for genocide. Her March 2024 report, “Anatomy of a Genocide,” explicitly concluded that Israel’s conduct in Gaza meets the threshold of genocide.12 This conclusion was subsequently developed in analyses that locate Gaza within a longer settler-colonial trajectory (Genocide as Colonial Erasure)13 and, most recently, trace the “economy” and corporate infrastructures enabling mass violence (From Economy of Occupation to Economy of Genocide).14 In its March 13, 2025 report, the UN Independent International Commission of Inquiry on the Occupied Palestinian Territory and Israel (International Commission of Inquiry) issued detailed findings that tighten the evidentiary picture. It documented the systematic use of sexual, reproductive, and other gender-based violence by Israeli security forces since October 7, 2023, including the targeting and destruction of reproductive-health infrastructure (for example, Gaza’s main IVF facility). The Commission reached the conclusion that Isarel has destroyed “in part the reproductive capacity of the Palestinians in Gaza as a group, including by imposing measures intended to prevent births, one of the categories of genocidal acts in the Rome Statute and the Genocide Convention,”15 and that such actions amount to “deliberately inflicting conditions of life calculated to bring about the physical destruction of Palestinians as a group.”16 In its latest finding of 16 September 2025, the International Commission of Inquiry on Gaza concluded that there are reasonable grounds to believe that Israel has committed acts defined in the Genocide Convention. Specifically, the Commission found that Israeli authorities and security forces have carried out four of the five genocidal acts: (1) killing members of the Palestinian group; (2) causing serious bodily or mental harm; (3) deliberately inflicting living conditions calculated to bring about the physical destruction of the group, in whole or in part; and (4) imposing measures intended to prevent births within the group. More importantly, it found evidence of genocidal intent – the mens rea required under international law – on the part of senior Israeli officials, including explicit statements by leaders such as Prime Minister Benjamin Netanyahu and others, and that from the totality of conduct (military operations, blockades, displacement, humanitarian deprivation) the only reasonable inference is that those acts were committed with the specific intent to destroy Palestinians in Gaza, in whole or in part.17
Alongside these UN findings, leading international human rights organizations have spoken with unusual clarity. In its December 2024 report “‘You Feel Like You Are Subhuman’: Israel’s Genocide Against Palestinians in Gaza,” Amnesty International explicitly accused Israel of genocide, concluding that its military offensive consists of killing, causing serious bodily or mental harm, and deliberately inflicting on Palestinians in Gaza conditions of life calculated to bring about their physical destruction in whole or in part. Amnesty emphasized that these acts were carried out with the specific intent to destroy Palestinians in Gaza.18 Human Rights Watch, in its December 2024 investigation “Extermination and Acts of Genocide,” likewise concluded that Israel’s deliberate deprivation of water, electricity, and other essentials amounts to the imposition of conditions of life designed to make survival impossible for Palestinians in Gaza. HRW stressed that such measures not only constitute the crime against humanity of extermination but also fall within the legal definition of genocide.19
Palestinian human rights organizations, notably the Palestinian Centre for Human Rights (PCHR), continue to provide meticulous first-hand documentation – most recently the comprehensive 2025 synthesis “Voices of the Genocide,” which situates Israel’s campaign squarely within the legal framework of genocide.20 Even Israeli human rights organizations, including B’Tselem21 and Physicians for Human Rights–Israel (PHRI),22 have likewise concluded that Israel is committing genocide in Gaza.
The same Western States that have expressed readiness to recognize Palestinian statehood are simultaneously parties to the Arms Trade Treaty (ATT) of 2013.23 Article 6(3) of the ATT prohibits authorizing arms transfers where the exporting State knows that the weapons will be used to commit genocide, crimes against humanity, grave breaches of the Geneva Conventions, attacks against civilians, or other war crimes.
This obligation is salient not only in relation to the ongoing genocide in Gaza but also to Israel’s broader domination of Palestinians in the Occupied Palestinian Territory (OPT). In its June 2024 Advisory Opinion, the ICJ declared Israel’s continued presence in the OPT unlawful, finding violations of the Palestinian right to self-determination, the prohibition of territorial acquisition by force, and multiple obligations under international humanitarian and human rights law. Because these norms are jus cogens, they generate obligations erga omnes; as the Court emphasized, all States bear legal interest in their enforcement and are specifically obliged not to aid or assist in maintaining such unlawful situations.24
The UN General Assembly subsequently translated these findings into concrete prescriptions, adopting a resolution requiring third States to cease the “provision or transfer of arms, munitions and related equipment to Israel […] in all cases where there are reasonable grounds to suspect that they may be used in the Occupied Palestinian Territory.”25 The International Commission of Inquiry further underscored the convergence between the ICJ’s provisional measures in the genocide case and the Advisory Opinion, putting all States on notice that Israel “may be or is committing internationally wrongful acts” in both Gaza and the West Bank; continued assistance thus risks rendering them complicit in such acts.26
Yet despite these legal obligations, the very States that proclaim support for Palestinian statehood continue to supply Israel with weapons and military equipment, thereby entrenching its apartheid regime and sustaining the genocide in Gaza. The United Kingdom offers a telling example. In May 2025, the Palestinian Youth Movement, Workers for a Free Palestine, and Progressive International issued a joint report titled Exposing UK Arms Exports to Israel. The report demonstrates that, notwithstanding the UK government’s September 2024 announcement of a partial suspension of around 30 arms export licences to Israel, the UK has continued to transfer substantial quantities of arms, munitions, and aircraft parts during the war on Gaza. Drawing on import data from the Israel Tax Authority, the report documents shipments between October 2023 and March 2025 exceeding 160,000 military items, including 150,000 bullets, rocket launchers, grenades, missiles, and tank parts. Significantly, although the government claimed to suspend direct exports of F-35 components to Israel in September 2024, the data suggests that such shipments were still ongoing as of March 2025.27
Canada presents a similar case. A report published in July 2025 by Arms Embargo Now, The Palestinian Youth Movement, and World Beyond War reveals that, contrary to repeated assurances from Canadian leaders about restricting arms exports to Israel, Canada has continued extensive military-related transfers since October 2023. Evidence includes 47 shipments from Canadian manufacturers to Israeli weapons firms, over 421,000 bullets exported – including a single April 2025 shipment of 175,000 rounds – and three cartridge deliveries from a Quebec facility despite official pledges to block them. Overall, 391 shipments of bullets, weapons parts, aircraft components, and communications equipment were recorded by the Israeli Tax Authority up to June 2025, primarily destined for Elbit Systems and other Israeli defense companies. Nearly 100 international flights – many on commercial passenger planes – carried this military cargo to Israel, where it was loaded beneath civilian travelers on routes through Frankfurt, Paris, New York, Abu Dhabi, and New Delhi.28
Such declarations of support for Palestinian statehood operate as a smokescreen, concealing the systematic complicity of these States in grave breaches of international law and international crimes, including the ongoing genocide in Gaza.
From statehood to self-determination
The ongoing genocide in Gaza has profoundly reshaped global discussions about Palestine, framing it as a colonial question – more precisely, a settler colonial question.29 The Palestinian scholar Fayez Sayegh argued as early as the 1960s that the Zionist settler-colonial project was eliminatory from its inception, as its realization required both the political erasure of the Palestinians and the erasure of their physical presence on the land.30 The genocidal logic now unfolding in Gaza compels a return to the Nakba, which marks the institutionalization of this project through the establishment of the State of Israel. In this sense, the genocidal colonial violence in Gaza has decolonized Palestinian consciousness and, more broadly, that of the world. It is in this vein that South Africa situated the current genocide in Gaza “in the broader context of Israel’s conduct towards Palestinians during its 75-year-long apartheid, its 56-year-long belligerent occupation of Palestinian territory, and its 16-year-long blockade of Gaza.”31
The genocide in Gaza has sidestepped the language of “peace,” which long framed the Palestinian predicament as a conflict between two symmetrical and equal national movements, thereby distorting the colonial reality on the ground and obscuring the dynamics of racial domination between the colonizer and the colonized. In this sense, the current calls to recognize a Palestinian state – devoid of substantive content such as implementing the measures indicated by the ICJ to end Israel’s illegal presence in the OPT – purport to reverse this decolonizing shift by returning the conversation to October 7. Such gestures function as a strategy of colonial containment, aimed at insulating Israel and its settler-colonial structures from the imperatives of decolonization; they are efforts to shield Israel from the consequences of its genocidal course, rather than to advance the rights of the Palestinian people.
The ICJ’s 2024 advisory opinion places the right to self-determination – not statehood – at its core, characterizing Israel’s continued presence in the OPT as unlawful because it violates several peremptory norms of international law, most crucially, the Palestinian people’s collective right to determine their political status and freely pursue their development. Foregrounding self-determination demands a decolonization of the very framework of the “two-state solution,” since the 1947 Partition Plan was conceived in breach of the Palestinians’ right to self-determination, a principle already enshrined in the 1945 UN Charter. At that time, Palestine – still under British colonial rule – was categorized as a Class A Mandate, whose peoples were provisionally recognized as nations on the path to independence.32 As Ardi Imseis highlights, the UN partition plan “introduced a rupture in the purportedly new international legal order and challenged the primacy of the international rule of law as affirmed in its own Charter.”33 By Balfour’s own admission “the weak point of our position of course is that in the case of Palestine we deliberately and rightly decline to accept the principle of self-determination (…) we do not propose even to go through the form of consulting the wishes of the present inhabitants of the country... the 700,000 Arabs who now inhabit that ancient land.”34 This critique does not require rejecting recognition of Palestinian statehood within 1967 borders; rather, it underscores that statehood is meaningful only insofar as it serves and enables self-determination. Applied to Palestine, any version of “two states” that is disconnected from the right of self-determination would merely reproduce and entrench the existing colonial reality instead of transforming it.
Recognition can advance Palestinian freedom only if it is explicitly subordinated to the right of self-determination. A first principle here is that self-determination is a broader juridical category than statehood. This follows from the language of UNGA Resolution 69/23 (2014), which stresses “the realization of the inalienable rights of the Palestinian people, primarily the right to self-determination and the right to their independent State.”35 Likewise, the ICJ has underscored that territorial integrity is a corollary of the right to self-determination, not the reverse.36 Recognizing a Palestinian State within the 1967 borders should not be constructed as limiting self-determination of Palestinians to the OPT. Confining self-determination to the 1967 borders excludes roughly two-thirds of the Palestinian people – including approximately 5.9 million registered refugees and around two million Palestinian citizens of Israel – thereby reproducing the very colonial fragmentation the norm is meant to overcome.37 Recognition is therefore meaningless if it entrenches structures that deny the majority of Palestinians the inalienable exercise of self-determination. At the heart of this right is the right of return, not as a negotiable concession but as a fundamental expression of collective self-determination.38
Self-determination also encompasses Palestinian citizens of Israel, whose collective rights as a native people were constitutionally denied by the 2018 Nation-State Basic Law, which reserves the right of self-determination exclusively for Jews. This law represents a decisive inflection in Israel’s settler-colonial project: it de facto if not de jure downgrades the legal status of Palestinians of 1948 from nominal holders of (colonial) citizenship to permanent residents in their own homeland.39 In doing so, it entrenches a regime of Apartheid inside Israel itself, as documented by Amnesty International and Human Rights Watch.40 Both self-determination and the prohibition of systematic racial discrimination and Apartheid are peremptory norms (jus cogens) of international law, giving rise to erga omnes obligations: states must refuse recognition of the unlawful situation, refrain from assisting in its maintenance, and cooperate to bring it to an end.41
Therefore, recognizing a Palestinian state devoid of sovereignty, while ignoring the structures of colonial domination on both sides of the Green Line and beyond, risks providing a seal of approval to Apartheid and to the ongoing political elimination and dispossession of nearly two-thirds of the Palestinian people. Israel’s existence – irrevocable under international law – and the legal right of Israeli Jews to collective self-determination within it cannot be construed as affirming or legitimizing a colonial or racist order.
Second, recognition must reckon with impunity as a core privilege of Israel’s settler-colonial regime. Decolonization requires piercing the veil of impunity – not only as a moral imperative but as a legal obligation flowing from the ICJ’s articulation of erga omnes duties: non-recognition of the unlawful situation, non-assistance in its maintenance, and cooperation to bring it to an end. In concrete terms, recognition that serves self-determination should be tied to measures that implement the Court’s roadmap: to distinguish in all dealings between the sovereign territory of Israel and the OPT; to refrain from entering into economic or commercial relations with Israel connected to the OPT or parts thereof that may consolidate its illegal presence in the territory; and to adopt measures to prevent commercial or investment relations that contribute to maintaining the unlawful situation created by Israel in the OPT.42 Only by aligning it with these obligations can recognition become a transformative lever for Palestinian self-determination rather than a device that cements colonial relations.
Yet in practice, recognition announcements – even by seemingly sympathetic governments – reinforce the pre-October 7 status quo. On August 28, 2025, Jewish Insider reported that France is backing away from earlier support for including the right of return in an international declaration it co-drafted with Saudi Arabia – endorsed by the EU, the Arab League, and dozens of states – with President Emmanuel Macron’s advisor Ofer Bronchtein stating that the text would be “corrected” to frame refugees’ claims as a matter for negotiations rather than a guaranteed right.43 This declaration, advanced at a UN gathering and presented as the basis for a forthcoming General Assembly text on a two-state solution, underscores how recognition, absent rights, risks validating the very architecture of domination it purports to end. Moreover, none of these states has shown the political will to meet their obligations under international law to adopt concrete measures promoting accountability for Israel’s unlawful presence in the OPT, as outlined by the ICJ and subsequently articulated by the General Assembly – duties of non-recognition, non-assistance, and cooperation that should translate into targeted restrictions on trade, investment, and arms transfers sustaining illegality.
The absence of political will to adopt measures that promote accountability and end Israel’s impunity for its continual violations of peremptory norms is striking, especially given the Israeli government’s unprecedented candor in pursuing annexation of the OPT. Recognition, under these conditions, is not a vehicle for Palestinian justice and freedom; its aim is to contain the decolonial politics that have emerged in response to Israel’s genocidal violence in Gaza.
A final word
Recognizing a Palestinian state is not a concession or a favor to the Palestinians. It is a long-overdue step that represents the bare minimum of the international community’s duty to guarantee the Palestinian people’s right to self-determination and their right to exist as a political community with equal rights and dignity. This duty is all the more urgent at a time when the very physical existence of Palestinians in Gaza is being crushed.
Yet, in practice, recognition often functions less as a vehicle for Palestinian justice than as an instrument to contain the decolonial politics that have emerged in response to Israel’s genocidal war on Gaza. This is especially the case if recognizing states – and the international community as a whole – fail to fulfill their obligations to defend the inalienable rights of the Palestinian people and their right to be free from genocide, apartheid, and colonial domination.
In debating Palestinian statehood, states participating in the General Assembly should recall that they voted overwhelmingly last year to adopt a resolution giving Israel twelve months to comply with the ICJ’s Advisory Opinion. That resolution also outlined a package of collective enforcement measures to be enacted in the event of non-compliance. Israel has not complied. If recognition is truly about emancipating Palestinians and upholding international law, then the path forward is clear: the Assembly must now implement the measures it has already endorsed.
Footnotes:
1: “Canada, Australia, Portugal Join UK in Recognising Palestinian Statehood,” Al Jazeera, September 21, 2025, https://www.aljazeera.com/news/2025/9/21/canada-australia-join-uk-in-recognising-palestinian-statehood
2: United Nations, “What to Know Ahead of the UN Summit on the Question of Palestine,” UN News, September 21, 2025, https://news.un.org/en/story/2025/09/1165900
3: PM Statement on the Recognition of Palestine, 21 September 2025,” GOV.UK, 21 September 2025, https://www.gov.uk/government/speeches/pm-statement-on-the-recognition-of-palestine-21-september-2025
4: Prime Minister of Canada, “Statement by Prime Minister Carney on Canada’s Recognition of the State of Palestine,” Prime Minister of Canada, September 21, 2025, Ottawa, https://www.pm.gc.ca/en/news/statements/2025/09/21/statement-prime-minister-carney-on-canada-recognition-state-palestine
5: Reuters. “Netanyahu Signs West Bank Settlement Expansion Plan, Rules Out Palestinian State.” Reuters, September 11, 2025. https://www.reuters.com/world/middle-east/netanyahu-signs-west-bank-settlement-expansion-plan-rules-out-palestinian-state-2025-09-11
6: See for example Noura Erakat and Shahd Hammouri, “The Statehood Trap,” Jadaliyya, August 6, 2025. https://www.jadaliyya.com/Details/46838
7: Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), Request for the Indication of Provisional Measures: Order of 26 January 2024. https://www.icj-cij.org/sites/default/files/case-related/192/192-20240126-ord-01-00-en.pdf
8: Bosnian Genocide (Bosnia and Herzegovina v. Serbia and Montenegro), [2007] ICJ Rep 595, para. 166.
9: Id, para. 430. https://www.icj-cij.org/sites/default/files/case-related/91/091-20070226-JUD-01-00-EN.pdf
10: Id, para. 432.
11: Ibid.
12: Albanese, Francesca. Anatomy of a Genocide. UN HRC, 55th session, A/HRC/55/73 (March 2024). https://docs.un.org/en/A/HRC/55/73
13: Albanese, Francesca. Genocide as Colonial Erasure. UN GA, 79th session, A/79/384 (October 1, 2024). https://docs.un.org/en/A/79/384
14: Albanese, Francesca. From Economy of Occupation to Economy of Genocide. UN HRC, 59th session, A/HRC/59/23 (June 16, 2025). https://docs.un.org/en/A/HRC/59/23
15: Independent International Commission of Inquiry on the Occupied Palestinian Territory, including East Jerusalem, and Israel. “More than a Human Can Bear”: Israel’s Systematic Use of Sexual, Reproductive and Other Forms of Gender-Based Violence since 7 October 2023. A/HRC/58/CRP.6 (March 13, 2025). https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/sessions-regular/session58/a-hrc-58-crp-6.pdf
16: Ibid.
17: United Nations Human Rights Council. Report of the Independent International Commission of Inquiry on the Occupied Palestinian Territory, Including East Jerusalem, and Israel. A/HRC/60/CRP.3. September 2025. https://www.un.org/unispal/wp-content/uploads/2025/09/a-hrc-60-crp-3.pdf
18: Amnesty International. “You Feel Like You Are Subhuman”: Israel’s Genocide Against Palestinians in Gaza. London, December 5, 2024. https://www.amnesty.org/en/documents/mde15/8668/2024/en/
19: Human Rights Watch. Extermination and Acts of Genocide: Israel Deliberately Depriving Palestinians in Gaza of Water. New York, December 19, 2024. https://www.hrw.org/news/2024/12/19/israels-crime-extermination-acts-genocide-gaza
20: Palestinian Centre for Human Rights (PCHR), Voices of the Genocide (Gaza: PCHR, August 28, 2025). https://pchrgaza.org/wp-content/uploads/2025/08/Voices-of-the-Genocide-EN-1.pdf
21: B’Tselem, Our Genocide (Jerusalem: B’Tselem, July 2025). https://www.btselem.org/publications/202507_our_genocide
22: Physicians for Human Rights–Israel, Genocide in Gaza (Tel Aviv: PHRI, July 28, 2025). https://www.phr.org.il/en/genocide-in-gaza-eng/?pr=20812
23: United Nations, Arms Trade Treaty, opened for signature April 2, 2013, entered into force December 24, 2014, 3013 U.N.T.S. 269. https://treaties.un.org/doc/Treaties/2013/04/20130410%2012-01%20PM/Ch_XXVI_08.pdf
24: International Court of Justice. Legal Consequences Arising from the Policies and Practices of Israel in the Occupied Palestinian Territory, Including East Jerusalem (Advisory Opinion), ICJ Case No. 186, ICJ Reports, July 19, 2024. https://www.icj-cij.org/sites/default/files/case-related/186/186-20240719-adv-01-00-en.pdf
25: United Nations General Assembly. Advisory Opinion of the International Court of Justice on the Legal Consequences Arising from Israel’s Policies and Practices in the Occupied Palestinian Territory, Including East Jerusalem, and from the Illegality of Israel’s Continued Presence in the Occupied Palestinian Territory. A/ES-10/L.31/Rev.1. September 18, 2024. https://docs.un.org/en/A/RES/ES-10/24
26: United Nations Independent International Commission of Inquiry on the Occupied Palestinian Territory, Including East Jerusalem, and Israel. Legal Analysis and Recommendations on Implementation of the International Court of Justice Advisory Opinion, Legal Consequences Arising from the Policies and Practices of Israel in the Occupied Palestinian Territory, Including East Jerusalem. October 18, 2024, para. 23. https://www.ohchr.org/sites/default/files/documents/hrbodies/hrcouncil/coiopt/2024-10-18-COI-position-paper_co-israel.pdf
27: Palestinian Youth Movement, Workers for a Free Palestine, and Progressive International. Exposing UK Arms Exports to Israel. May 2025. https://labourhub.org.uk/wp-content/uploads/2025/05/159cf-report-exposingukarmsexportstoisrael-05072025.pdf?utm_source=chatgpt.com
28: Arms Embargo Now, Palestinian Youth Movement and World Beyond War. Exposing Canadian Military Exports to Israel. July 29, 2025. https://armsembargonow.ca/wp-content/uploads/2025/07/Exposing-Canadian-Military-Exports-to-Israel_07292025_compressed-.pdf
29: Boulos, Sonia. 2025. “The ‘G Word,’ Liberal Israeli Elites, and the Prospect of Decolonization.” Journal of Genocide Research, September, 1–21. https://www.tandfonline.com/doi/full/10.1080/14623528.2025.2556564?src=exp-la
30: Fayez Sayegh, Zionist Colonialism in Palestine (Beirut: Research Center, Palestine Liberation Organization. 1965). https://www.freedomarchives.org/Documents/Finder/DOC12_scans/12.zionist.colonialism.palestine.1965.pdf
31: International Court of Justice, Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), Order on Provisional Measures, 26 January 2024, https://www.icj-cij.org/case/192/orders.
32: League of Nations. The Mandate for Palestine. Official Journal, League of Nations, August 1922, 1007–1012. https://www.un.org/unispal/document/auto-insert-201057/
33: Ardi Imseis, The United Nations and the Question of Palestine: Rule by Law and the Structure of International Legal Subalternity (Cambridge: Cambridge University Press, 2023), 59. https://www.cambridge.org/core/books/united-nations-and-the-question-of-palestine/E8241B33B6C07028765E5E6785AF5CDE
34: Quoted in Yousef Munayyer, “It's Time to Admit That Arthur Balfour Was a White Supremacist — and an Anti‑Semite, Too,” Palestine Studies, November 1, 2017. https://www.palestine-studies.org/en/node/232119
35: United Nations General Assembly, Resolution 69/23, “Question of Palestine,” November 25, 2014.
36: International Court of Justice, Legal Consequences of the Construction of a Wall in the Occupied Palestinian Territory (Advisory Opinion), 2004, ICJ Reports. https://www.icj-cij.org/sites/default/files/case-related/131/131-20040709-ADV-01-00-EN.pdf
37: Boulos, Sonia, “New Legal Avenues for a Decolonising Agenda: The International Court of Justice and the Israeli Occupation of Palestinian Territories,” Journal of Holy Land and Palestine Studies 24.2 (2025) (forthcoming).
38: Ibid.
39: Sonia Boulos, “Can There be Citizenship Without a Right to Self-determination? The Case of Palestinians in Israel,” Revista de Estudios Internacionales Mediterráneos (REIM), no. 38 (2025): 1–30. https://revistas-new.uam.es/reim/article/view/reim2025_38_01/reim2025_38_011
40: Ibid.
41: Ibid.
42: International Court of Justice, supra-note 24.
43: Lahav Harkov, “France walks back call for Palestinian ‘right of return,’ but not recognition push,” Jewish Insider, August 28, 2025. https://jewishinsider.com/2025/08/france-palestinian-authority-statehood-right-of-return/
