Statement of Indictment

The State of Israel is directly and indirectly criminally responsible for committing specific acts of genocide, ethnic cleansing, including uprooting Palestinians by military attacks, arbitrary arrests and illegal imprisonment, administrative detention, attacks on women, children and the elderly, systematic and wanton destruction of property and homes, systematic expropriation and dispossession, violence to life and person, in particular murder of all kinds, including assassinations, confiscation of lands and property, creation of separate reserves and Bantustans, disrupting public life and terrorizing a whole population, including through acts of collective punishment and reprisals, racial discrimination, stealing, looting and plundering, infliction of serious bodily or mental harm, including torture, ill-treatment, cruel, inhuman and degrading treatment and punishment, mutilation, causing death and serious injury, deliberate imposition of living conditions calculated to cause physical destruction in whole or in part, approving and implementing legislative measures calculated to prevent Palestinians from participation in the political, social, economic and cultural life and the deliberate creation of conditions preventing the full development of Palestinians, exploitation of labor, persecution of organizations and members, depriving persons of fundamental rights and freedoms because they oppose military occupation, colonialism, or apartheid, and other criminal acts.

Violated Laws, Treaties, and Conventions

The State of Israel is criminally responsible for crimes, which are stated to be the most serious crimes of concern to the international community as a whole. These include:

The crime of genocide, crimes against humanity, war crimes and the crime of aggression as defined and specified in the Rome Statute of the International Criminal Court, as corrected by the procés-verbaux of 10 November 1998 and 12 July 1999.

-- Violations of 85 United Nations Security Council Resolutions
-- Violations of the following:
-- Charter of the United Nations;
-- Convention on the Prevention and Punishment of the Crime of Genocide;
-- Convention on the Non-Applicability of Statutory Limitations to War Crimes and Crimes against Humanity;
-- Geneva Convention Relative to the Treatment of Prisoners of War;
-- Geneva Convention relative to the Protection of Civilian Persons in Time of War;
-- Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of International Armed Conflicts;
-- Protocol Additional to the Geneva Conventions of 12 August 1949, and Relating to the Protection of Victims of Non-International Armed Conflicts;
-- International Covenant on Economic, Social and Cultural Rights;
-- International Covenant on Civil and Political Rights;
-- Declaration on the Right and Responsibility of Individuals, Groups and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms;
-- Declaration on the Granting of Independence to Colonial Countries and Peoples;
-- International Convention on the Elimination of All Forms of Racial Discrimination;
-- International Convention on the Suppression and Punishment of the Crime of Apartheid;
-- Convention against Discrimination in Education;
-- Convention on the Elimination of All Forms of Discrimination against Women;
-- Convention on the Political Rights of Women;
-- Convention on the Rights of the Child;
-- Standard Minimum Rules for the Treatment of Prisoners;
-- Basic Principles for the Treatment of Prisoners;
-- Body of Principles for the Protection of All Persons under Any Form of Detention or Imprisonment;
-- United Nations Rules for the Protection of Juveniles Deprived of Liberty;
-- Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment;
-- Principles on the Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment;
-- Principles of Medical Ethics Relevant to the Role of Health Personnel, particularly Physicians, in the Protection of Prisoners and Detainees against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment;
-- Code of Conduct for Law Enforcement Officials;
-- Basic Principles on the Use of Force and Firearms by Law Enforcement Officials;
-- Basic Principles on the Role of Lawyers;
-- United Nations Standard Minimum Rules for the Administration of Juvenile Justice;
-- Basic Principles on the Independence of the Judiciary;
-- Principles on the Effective Prevention and Investigation of Extra-legal, Arbitrary and Summary Executions.

Specific charges against the State of Israel

I. War crimes and crimes against humanity

1. The State of Israel and its predecessor agents have committed various acts of genocide, killing thousands of Palestinian civilians, causing serious bodily and mental harm to thousands of Palestinians, and deliberately inflicting conditions of life calculated to bring physical destruction, including but not limited to the following cases:
Baldat al-Shaikh (January 30-31, 1947), Yehida (December 13, 1947), Khisas (December 18, 1947), Qazaza (December 19, 1947), Katamon (July 5, 1948), Deir Yassin (April 9/10, 1948), Naser al-Din (April 13, 14, 1948), Tantura (May 15, 1948), Beit Daras (May 21, 1948), Lydda (July 11, 1948), Dawayma (October 29, 1948), Houla (October, 26, 1948), Sharafat (February 7, 1951), Kibya (October 14, 1953), Kafr Kassim (October 29, 1956), Gaza City (April 5, 1956), Khan Younis (November 3, 1956), Rafah (November 12, 1956), Al-Sammou' (November 13, 1966), Kawnin (October 15, 1975), Bint Jbeil (October 21, 1976), Abbasieh (March 17, 1978), Adloun (March 17, 1978), Saida (April 4, 1981), Fakhani (July 17, 1981), Beirut (July 17, 1981), Sabra and Shatila (September 16-18, 1982), Jibsheet (March 27, 1984), Sohmor (September 19, 1984), Seer al-Gharbiah (March 23, 1985), Maaraka (March 5, 1985), Zrariah (March 11, 1985), Homeen al-Tahta (March 21, 1985), Jibaa (March 30, 1985), Yohmor (April 13, 1985), Tiri (August 17, 1986), Al-Naher al-Bared (December 11, 1986), Ain al-Hilwe (September 5, 1987), Nablus (December 16, 1988), Nahhalin (April 13, 1989), Oyon Qara (May 20, 1990), Siddiqine (July 25, 1990), Jerusalem (October 8, 1990), Hebron (February 25, 1994), Jalabia (March 28, 1994), Aramta (April 15, 1994), Erez (July 17, 1994), Deir al-Zahrani (August 5, 1994), Nabatiyeh (March 21, 1994), Sohmor (April 2, 1996), Mansuriah (April 13, 1996), Nabatiya (April 18, 1996), Qana (April 18, 1996), West Bank/Gaza (September 25-28, 1996), Tarqumia (March 10, 1998), Janta (December 22, 1998), Beirut (June 24, 1999), Western Baq'a (December 29, 1999), Jerusalem (September 29, 2000), Idna (July 19, 2001), Nablus (July 31, 2001), Beit Rima (October 24, 2001), Jenin (April 3-21, 2002), Nablus (April 3-21, 2002).

2. Between 1948 and 1949, the State of Israel killed at least 13,000 Palestinians. During the June 1967 war, the State of Israel killed, although official figures have never been released, at least 15,000 Palestinians, Egyptians, Jordanians and Syrians.

3. In Lebanon, the State of Israel killed over 29,500 Palestinians and Lebanese civilians, 40% were children. During various invasions, the State of Israel forcibly evicted more than 100,000 Palestinian and Lebanese civilians.

4. Between December 1987 and September 1993, the State of Israel killed over 1,300 Palestinian civilians, including over a quarter under the age of 16, wounded more than 100,000, and demolished 2,089 homes. Between 1993 until the end of 1999, the State of Israel has killed 492 Palestinian civilians. Between 1993 and the end of 1999, the State of Israel has demolished approximately 1,000 Palestinian homes, leaving more than 5,000 Palestinians homeless.

5. Since the end of September 2000, the State of Israel and its army and citizens have killed 1,639 Palestinians, including 336 children.

6. Since the end of September 2000, the State of Israel has killed at least 103 Palestinians, of which half were simply bystanders, including women and children, in state-sponsored assassinations.

7. Since the end of September 2000, the State of Israel has killed more than 550 Palestinians through shelling and bombardments of civilian and public infrastructure, homes, schools and other places. The State of Israel has caused death and injury to more Palestinians at checkpoints and due to prevention of medical access or restrictions of movement.

8. Since the end of September 2000, the State of Israel has severely injured, maimed and wounded at least 20,000 Palestinians, leaving more than 2,000 Palestinians permanently disabled. In that same period, the State of Israel demolished more than 985 Palestinian homes.

9. Since the end of September 2000, the State of Israel has launched military attacks on Palestinian civilians. These attacks include shootings, shelling and bombings in their homes, schools, universities, hospitals, field clinics, and workplaces. The State of Israel targeted clearly marked ambulances and paramedics, journalists, and human rights defenders. The State of Israel has used heavy weaponry and ammunition against Palestinians, including bombs, mortar shells, tank shells, air-to-ground and ground-to-ground missiles fired from attack helicopters and F-16 warplanes, naval warships, tanks and armored personnel carriers. The State of Israel is also responsible for the death of Palestinians, who have been shot and killed by Israeli snipers, shooting high-velocity live ammunitions at civilians in civilian areas. In this period, the State of Israel has killed and injured a disproportionate number of women and children, clearly-marked medical personnel, human rights defenders and journalists.

10. Since 1967, the State of Israel has caused casualties by exploding objects and flares, including objects thrown from military jeeps and helicopters, mines and explosives, and flammable objects. These objects have either exploded, causing shrapnel wounds, or caught fire, causing severe burns. For example, on February 13, 1989, Iktimal Dim (6) was killed, and her brother, 'Isam Dim (10), injured by shrapnel from an exploding device thrown from an Israeli helicopter hovering above the village of Tayasir. Since 1967, a great number of Palestinians have been wounded or killed after stepping on mines or other explosives planted by the Israeli army.

11. Since 1948, the State of Israel ordered and encouraged its military's brutal use of physical force against unarmed, mostly young Palestinians. This includes the systematic beating of Palestinian civilians by Israeli soldiers and police, which gained particular notoriety in 1988, after the late Yitzhak Rabin, then Defense Minister, announced a policy of 'force, might, and beatings' on January 18, 1988. Palestinians have been beaten randomly, without any apparent connection to protests, they were often taken from their homes or off the streets and brutally assaulted. Beatings were also typically carried out by groups of Israeli soldiers acting in concert rather than individually. Beating incidents have taken place in situations where the victim offered no resistance. For example, on 19 and 21 January 1988, in the village of Huwarra, Israeli soldiers rounded up twenty residents, drove them to a remote area, bound and gagged them, and then deliberately broke their arms and legs. The lack of proper investigations into cases where Palestinians have been severely injured or killed as a result of beatings further confirms the fact that beatings are a policy of the State of Israel.

12. Between 1949 and 1956, the State of Israel killed at least 5,000 Palestinian refugees, mostly farmers trying to return home, either to live, see relatives or to harvest their crops.

13. The State of Israel has imposed severe restrictions on Palestinian movement, including through closures, besiegement, curfews and the use of trenches, fences, iron gates and walls. The State of Israel controlled, restricted, closed and altogether denied Palestinian access to key facilities, goods and services, including humanitarian aid and assistance, including hospitals and field clinics, basic supplies such as medicines, food and water, education, denial of Palestinian access to schools and universities, denial of Palestinian access to workplaces, businesses, agricultural areas, industries, family and community life.

14. The State of Israel has assaulted Palestinian women in various ways, including illegal and indiscriminate use of lethal force by Israeli military authorities, resulting in deaths or injuries, the deliberate abuse of tear gas by Israeli military, resulting in suffocation, health problems, and miscarriages among Palestinian women, soldiers' brutality, sexual harassment and intimidation by Israeli soldiers, the use of obscene language, exposure, urinating on women, molestation and attempted rape, arrest, interrogation and torture inside Israeli prisons, hostage taking, expulsion, obstruction and harassment of women's committees and charitable organizations, raids on women's centers, kindergartens and cooperatives.

15. The State of Israel has deliberately induced humanitarian crisis, with impoverishment of Palestinian civilians and starvation policies. The State of Israel has restricted movement, denied and hindered access to humanitarian aid and assistance, food and water, medical supplies and aid, hospitals, work and education.

II. Denial of Health Care

16. The State of Israel has allowed its military to beat and detain wounded Palestinians, obstruct attempts by medical personnel and others to aid critically injured Palestinians, delay ambulances transporting injured Palestinians, physically mistreat doctors and other health care professionals, mistreat wounded Palestinians, raid medical facilities, shoot at ambulances, and adopt measures which have reduced the quality and availability of health services. These abuses illustrate a disregard for the most fundamental humanitarian norms on the part of the State of Israel.

III. Expulsions

17. The State of Israel has systematically dispossessed, uprooted and expelled Palestinian communities, in whole or in part, forcing remaining Palestinian communities to live in separate, inferior, less fertile, fragmented and non-contiguous enclaves within its own boundaries and the occupied Palestinian territories. To reduce the number of Palestinians within the historic boundaries of Palestine from 70% to 50%, the State of Israel has used various methods, including forcible expulsions, acts of genocide and ethnic cleansing.

18. The State of Israel has forcibly expelled more than 780,000 Palestinians, which amounted to 60% of the total Palestinian population, and depopulated and completely destroyed 531 Palestinian villages and localities. In 1948, the State of Israel internally displaced approximately 37,500 Palestinians. Even after the armistice agreements of 1949, the State of Israel continued to expel thousands of Palestinians, notably from the 'Little Triangle', and in the south from Majdal, to Faluja and Bir Saba, the Hebron region, and from the east and north of the Sea of Galilee.

19. The State of Israel also carried out round-ups in Palestinian villages, and expelled those Palestinians it decided were 'illegals'. In the Negev desert, for example, between 1949 and 1953, the State of Israel expelled close to 17,000 Bedouin. In 1953 alone, the State of Israel forcibly expelled 7,000 Bedouin. Such expulsions were often conducted with brutality. That same year, on October 14, 1953, an Israeli commando unit, under command of the current Prime Minister of the State of Israel, killed 69 Palestinian civilians, mostly women and children, and blew up 45 Palestinian homes in the West Bank village of Qibiya. On October 29, 1956, the State of Israel killed forty-nine Palestinian villagers, including fifteen women and eleven children in Kafr Kassim, a Palestinian village in the little Triangle. The villagers were lined up and shot for breaking a curfew (for which they had not been informed). One day later, on October 30, 1956, the State of Israel forcibly expelled approximately 5,000 Palestinians from Krad al Baqqara and Krad al Ghannama into Syria.

20. In 1967, the State of Israel forcibly expelled 388,500 Palestinian civilians, including 188,500 for the second time.

21. Between 1967 and 2002, the State of Israel deported 1,531 Palestinians, including mayors, writers, students and university lecturers, as a punitive measure. In August 1971 alone, the State of Israel deported 600 Palestinian refugees living in the Gaza Strip. Between 1987 and 1999, in East Jerusalem alone, the State of Israel, revoked residency rights of 3,327 Palestinians.

22. To date, the State of Israel has prevented the return of approximately 6 million Palestinian refugees, who have either been expelled or displaced. On October 26, 1948, the first Israeli Prime Minister David Ben Gurion established the 'Transfer Committee' and adopted its recommendations preventing the return of Palestinian refugees. To date, approximately 250,000 internally displaced Palestinians are prevented from return to their homes and villages. Since 1948, the State of Israel has uprooted approximately three-quarter of the Palestinian people from their land, making this the largest and one of the longest standing unresolved refugee cases in the world today. The majority of Palestinian refugees, living inside the occupied Palestinian territories, and internally displaced Palestinians living within the boundaries of the State of Israel, live within 100 miles of their places of origin but are denied their right to return to their homes and lands.

IV. Home demolitions and destruction of property

23. Since 1967, the State of Israel has demolished at least 9,000 Palestinian homes, leaving 50,000 Palestinians homeless. In August 1971 alone, the State of Israel and the Israeli army, led by Israel's current Prime Minister, demolished 2,000 Palestinian homes in the Gaza Strip, uprooting 12,000 Palestinian refugees for the second time in their lives.

24. In 1948 and after, the State of Israel plundered and looted Palestinian property spread over hundreds of Palestinian towns and villages, including homes, household effects, cash, heavy equipment, trucks and whole flocks of cattle. The total quantity of Palestinian property confiscated by the State of Israel amounted to over 4 million acres of land, the looting and confiscation of tens of thousands of homes, apartments, shops, factories and other facilities.

V. Land Confiscation and Colonization

25. The State of Israel confiscated 800,000 acres of cultivated Palestinian farmland, including crops, olives, tobacco, and fruit. Additionally, the State of Israel confiscated livestock-goats, sheep, and hens.

26. The State of Israel confiscated assets of the Muslim waqf, endowments of land and property, accounting for one-tenth of all land in Palestine before 1948, and 70 per cent of all ships in some Palestinian towns, besides urban estate, houses and businesses. It is estimated that the State of Israel has confiscated, destructed and plundered US$1.8 billion of Palestinian refugee moveable property and lands. Today this is valued at US$ 209 billion.

27. Since 1948, the State of Israel has confiscated 96% of the land owned by Palestinians for use by Israeli Jews only. Since 1967, the State of Israel has confiscated 58% of the occupied West Bank and Gaza Strip, for use by Israeli Jews only.

28. Since 1967, the State of Israel has been responsible for establishing, financing and protecting illegal Jewish colonies (settlements) in the West Bank and Gaza. The State of Israel has confiscated 40,000 acres of land to build a vast road system in the occupied Palestinian territories, which are only allowed to be used by its army and settlers. Most of this land was under cultivation by Palestinian farmers.

29. Since 1967, the State of Israel has transferred 400,000 settlers into the occupied Palestinian territories, including East Jerusalem.

30. Since 1967 to September 2001, the State of Israel has built 123 illegal settlements on confiscated and expropriated Palestinian land in the West Bank, excluding East Jerusalem, hosting 198,000 settlers. Between 1993 and September 2001, the population of settlers increased from 100,000 to 198,000, and thus approximately doubled. In occupied East Jerusalem, between 1997 and September 2001, the State of Israel increased the number of settlers to 167,000. Between 1993 and August 2001, the State of Israel confiscated over 70,000 acres of Palestinian land. In 1999 alone, the State of Israel confiscated approximately 10,000 acres of Palestinian land. Since February 2001 alone, the State of Israel has built at least 34 new settlements, excluding expansion of existing illegal settlements.

31. Since 1967, the State of Israel have neither prevented assaults by Israeli settlers on Palestinian individuals and communities, nor effectively intervened to stop such assaults. For example, on June 2, 1980, as a result of car bombs placed by Israeli settlers, backed by the Israeli army, the mayors of Nablus and Ramallah, Bassam Shaka'a and Karim Khalaf, were severely maimed. On February 24, 1994, an Israeli settler, Baruch Goldstein, entered the Ibrahimi mosque in Hebron and opened fire on worshippers, marking the end of Ramadan. Twenty-nine Palestinians were killed. The State of Israel failed to intervene, except to kill another six Palestinians. The State of Israel has ordered its soldiers to cooperate with settlers engaging in wanton violence against Palestinian residents. Furthermore, the State of Israel has failed to hold Israeli settlers responsible for their actions. Israeli settlers have killed and wounded Palestinians, and destroyed, vandalized, or stolen large amounts of Palestinian property.

32. To this date, the State of Israel has continued this policy of land expropriation, land destruction, agricultural property destruction and home demolitions both inside Israel and the occupied Palestinian Territories. Inside Israel, the State of Israel has maintained a policy of continually establishing new settlements for Jews only that also serve to isolate and cut off Palestinian communities. In addition, the State of Israel has imposed massive restrictions on Palestinian construction.

33. Inside Israel, the State of Israel has confined Palestinians into restricted, deliberately under-developed enclaves with reduced access to necessary resources, services and facilities. The State of Israel has no laws to prevent discrimination in issues of land ownership, leasing, and residency issues. The State of Israel uses quasi-governmental agencies and zoning or planning laws to confine Palestinians and particular areas and prevent natural growth. In occupied East Jerusalem, the State of Israel prevents Palestinians access to 66% because of Israeli zoning, planning and building restrictions. In other parts of the occupied Palestinian territories, the State of Israel has confined Palestinians to Bantustan-style enclaves, again with reduced access to necessary resources, including water supplies, services and facilities.

VI. Water Confiscation

34. Since 1967, the State of Israel has confiscated more than 80% of Palestinian groundwater. Shortly after the June 1967 war, the State of Israel destroyed 140 Palestinian water pumps in the Jordan Valley, used to irrigate Palestinian farms in the area. Since 1967, all water management in the West Bank and Gaza Strip has been placed under Israeli military rule.

35. The State of Israel has strategically established illegal colonies to tap Palestinian groundwater and springs, enabling discriminatory allocation of water resources. Per capita basis, Israelis consume more than five times as much water as Palestinians, even though their population is only twice that of Palestinians, despite widespread dry periods where Palestinian municipal water supplies literally dry up for months during the summer.

36. In April and May of 2002 alone, the State of Israel has caused destruction to the Palestinian water sector worth of US$ 7 million. In that period, the State of Israel destructed water networks, denying Palestinians access to running water for up to two weeks at a time.

37. The State of Israel has systematically dug trenches across main roads, disrupting water and sewer mains and telecommunication lines to Palestinians homes, caused intentional damage to pumping facilities, intentional destruction of water transmission lines from wells located outside city limits, obstruction of municipal crews from carrying out emergency repair work, killing a municipality engineer in Nablus. A well operator from Jenin was taken hostage twice.

VII. Due Process Violations and Torture

38. Since 1967 to date, the State of Israel has arbitrarily detained over 620,000 Palestinians. In 1989 alone, the State of Israel detained 50,000 Palestinians, representing 16% of the entire male population of the West Bank and Gaza Strip between the ages of 14 and 55. By way of comparison, that same year, out of a total African population of 24 million in South Africa, no more than 5,000 or 0.2% were detained for security offenses against the apartheid regime.

39. Since 1948, the State of Israel has detained thousands of Palestinians without charge or trial.

40. Over 200 Palestinian prisoners have died while in Israeli custody, due to torture, ill-treatment, deprivation of medical treatment, and neglect.

41. The State of Israel has systematically tortured and ill-treated approximately 80% of all Palestinian detainees. Methods of torture used by the State of Israel include both psychological and physical torture, including beatings of sensitive organs, choking, pulling of hair off the body, prolonged solitary confinement, subjecting Palestinian detainees to noise, screams, and threats against their families. Other forms of torture and ill-treatment applied by the State of Israel against Palestinian detainees include forcing a person to stand, hooded and handcuffed, for long periods of time, while depriving him of food or sleep, starvation, the use of electric shocks, burnings, beatings with hands, fists, truncheons, and boots, deprivation of food, sleep, and basic hygiene, resulting in lice and general discomfort, and forcing detainees to stand for protracted periods of time.

42. In the occupied Palestinian territories, the State of Israel has established military courts that do not comply with fair trial standards.

43. The State of Israel provides virtual impunity for those Israeli soldiers and settlers, who commit crimes against Palestinians. The State of Israel has failed to investigate or properly and impartially investigate or prosecute those Israeli soldiers and settlers, who have committed crimes against Palestinians. The State of Israel has denied any remedy for Palestinian victims, including denies compensation.

VIII. Destruction of Means of Livelihood

44. Since 1967, the State of Israel has uprooted hundreds of thousands of trees. In 1984, the State of Israel issued a military order which made it illegal for Palestinians to plant a new or replacement fruit tree without a permit. During the summer of 1988, the state of Israel burnt 8,000 olive and fruit trees and thousands of dunums of wheat. Between 1993 and August 2001, the State of Israel has uprooted 280,000 fruit and olive trees belonging to Palestinians in the West Bank alone. In 2001 alone, the State of Israel uprooted 23,551 fruit and olive trees.

45. The State of Israel has deliberately strangulated the Palestinian economy with forced dependency through border controls of imports and exports, exploitation of natural resources, de-development of Palestinian industries and businesses, violation of the full range of employment and workers' rights, including through closures and curfews.

46. The State of Israel has deliberately imposed a range of measures and acts that have diminished the living conditions of Palestinians to an extent that can only result in their physical destruction. Methods include the confiscation and expropriation of Palestinian land and other natural resources, particularly, water, which has seriously affected the health and viability of Palestinian communities and their way of life. The State of Israel has damaged Palestinian property and environment through the use of heavy weaponry and has permitted dumping toxic and hazardous products. The State of Israel has imposed restrictions on movement on Palestinians in and out of Palestinian localities, affecting population centers and their associated agricultural and economic communities, including restrictions on movement, depriving them of access to their land and property.

IX. Discrimination and Apartheid

47. The State of Israel imposed a tax system on Palestinians, while, in per capita terms, Israeli Jews received fifty times more grants than Palestinians. Of aid spent in the occupied Palestinian territories, 96.5% was spent on Israeli settlers, and 3.5% on the 90% Palestinian population. In 1992, discounting East Jerusalem, Israeli settlers constituted barely 6% of the West Bank and Gaza populations. Although since 1970, the State of Israel required Palestinian workers to pay dues for the Histadrut, Palestinian workers cannot be members of this trade union federation. Between 1970 and 1994, the Histadrut confiscated NIS 700 million from Palestinian workers without these workers being represented.

48. Since 1948, the State of Israel has increasingly imposed segregation and apartheid, including by cutting off Palestinians from access to wider Arab communities in neighboring Arab states, cutting Palestinians from their families and communities in the West Bank, including East Jerusalem, and the Gaza Strip.

49. Since 1967, the State of Israel has separated and isolated Palestinians in East Jerusalem from their families in other parts of the West Bank and Gaza Strip. Since 1987, the State of Israel has separated and isolated Palestinian communities through barbed wired fences and iron gates, for example Dheishe refugee camp, near Bethlehem. Since 1989, the State of Israel has segregated, isolated and separated the Gaza Strip from the West Bank, including East Jerusalem and to outside neighboring countries.

50. Since 1993, the State of Israel has denied Palestinians in the West Bank access to the Gaza Strip and Israel. Since this period, the State of Israel has used curfews, partial and total closures on an ad hoc basis. Since 1993, the State of Israel further separated Palestinian communities inside the West Bank and the Gaza Strip, separating villages from cities and villages from villages, through checkpoints, bypass roads, settlements and closures.

51. Since March 2001, the State of Israel dug trenches into main roads, cutting of all movement for Palestinian villagers to any other area, including urban centers upon which they rely for work, education, humanitarian aid and assistance, including medicines, field clinics and hospital, and crucial supplies, including food and water. Since June 2001, the State of Israel dug more trenches and erected iron gates in some areas, closing off villages and cities. Since June 2002, the State of Israel has segregated, separated and isolated more than 11,000 Palestinians living between the 1967-demarcation line and a currently built wall or so-called 'security fence' in the north of the West Bank.

X. Denial of Freedom of the Press

52. The State of Israel has barred journalists access to areas, subjected journalists to physical violence and harassment, arrested and detained journalists, restricted access to Palestinian sources of information, for example, the closure of press agencies, impersonation of journalists and confiscation of materials, including footage, cameras, and films.

XI. Denial of Education

53. The State of Israel has repressed Palestinian education by closures, raids and destruction. The State of Israel has killed, injured, detained and harassed Palestinian professors, lecturers, teachers and students. The State of Israel has regularly closed schools and universities in the West Bank and Gaza for prolonged periods, disrupting Palestinian education, and has banned alternative education. Furthermore, the State of Israel has occupied many schools and destructed school property. The State of Israel has raided schools and universities and used tear gas inside school buildings.

XII. Denial of Freedom of Religion

54. The State of Israel has obstructed and harassed worship. The State of Israel has raided mosques and harassed worshippers. The State of Israel has allowed its soldiers to shoot tear gas inside places of worships, have assaulted mosques and churches, has disrupted the burial rites of Palestinians.