MM and FH (Stateless Palestinians, KK, IH, HE reaffirmed) Lebanon CG  UKAIT 00014
Date of hearing: 29 June 2007
Date Determination notified: 4 March 2008
|MM and FH
|Secretary of State for the Home Department||RESPONDENT|
i. The differential treatment of stateless Palestinians by the Lebanese authorities and the conditions in the camps does not reach the threshold to establish either persecution under the Geneva Convention, or serious harm under paragraph 339C of the Immigration Rules, or a breach of Articles 3 or 8 under the ECHR.
ii. The differential treatment of Palestinians by the Lebanese authorities is not by reason of race but arises from their statelessness.
The Adjudicator's Findings in Respect of the First Appellant
"50. A further strand to the appellant's claim is based upon whether the discrimination and ill-treatment of Palestinian refugees by the Lebanese authorities amounts to persecution.
51. In her submissions, Miss Sheikh has suggested that this persecution has been suffered by the appellant as part of a particular social group. It seems to me that if I were to find that the discrimination suffered by the Palestinian refuges amounted to persecution then accepting as I do that the appellant is a Palestinian refugee, his claim must succeed both under the Refugee Convention and Article 3 of the 1950 Convention.
52. However, on the facts before me I do not consider that the appellant has been discriminated against to an extent that amounts to persecution.
53. The appellant and his family have lived in the Palestinian refugee camp, certainly for the whole of the appellant's life. The appellant's family have two different houses in different refugee camps. The appellant himself was educated to a point where he was able to go to university. He chose not to pursue that because of his wish to join Fateh in one of the refugee camps. He had no problems with the authorities until 1998, which eventually I did not accept as being truthful. [A reference to the appellant's evidence that he had been stopped leaving Rashidieh camp in 1998]
54. I have been referred to the Court of Appeal decision in  EWCA Civ 649 Karyem.
55. I cannot find on the evidence before me, that the appellant has shown that he has suffered differential treatment in relation to economic, social and cultural benefit as between Lebanese nationals and/non nationals or stateless persons.
56. There is nothing in the appellant's evidence that supports any claim that he has been discriminated against other than very general assertions that Palestinian refuges had limited employment opportunities. The fact is that this appellant was employed, was paid for that work and supported within the refugee camp. At the same time he was able to travel backwards and forwards to his parent's house in another one of the refugee camps. He was educated and could have gone to Beirut University. His parents in fact had two houses in separate refugee camps.
57. None of this is predicated on the finding that the appellant had been discriminated against and therefore I would reject any claim on behalf of this appellant that he has been discriminated against to an extent that would amount to persecution as acknowledged by the 1951 Convention that would accord him refugee status. As I reject therefore the appellant's asylum claim for the reasons as set out above, so I would reject any claim under Article 3 of the 1950 Convention."
There was no evidential basis for this conclusion (see paragraph 43 of the determination)
The Adjudicator's Findings In Respect of the Second Appellant
Material Error of Law
The Appellants' Statements before This Tribunal on the General Living Conditions for Palestinian Refugees in Lebanon
The First Appellant
Statement of the Second Appellant
The Expert Evidence
Report of Abbas Shiblak dated 27 June 2007
"(c) Despite the fact that Palestinian refugees were living in the country for three generations since 1948, the Lebanese authorities deny Palestinians refugees residency rights and consider them foreign citizens who could have been in Lebanon for a few days. In many aspects, Palestinian refugees are in fact worse off. Foreigners for instance are allowed to own property in Lebanon but such a right is denied for the Palestinians. Lebanon also denies social security for Palestinian refugees under the pretext that these rights are offered to citizens of other states on a reciprocity basis. Lebanon has such reciprocal arrangements with at least two Arab states, Syria and Egypt that put the workers of these countries in a better position than the Palestinian refugees in terms of access to the job market, the number of issued work permits and social security benefits. Available statistics suggest that in 1991, the Ministry of Labour issued about 18,000 work permits to Egyptian workers, but only 350 permits to Palestinians. The majority of Palestinian workers are required to pay fees of US$830 to apply for such permits or renew, which in most cases the Lebanese authorities refuses to issue. In April 2007, I visited Beirut and met a group of Egyptian agricultural, construction and building maintenance workers at the airport. In the course of my conversation with them I was informed that they received health, medical and social benefits as part of a Memorandum of Understanding between Egypt and Lebanon."
"Those we have killed are sufficient".
Mr Shiblak had said that this summarised the attitude of the Lebanese establishment.
"One of the most damaging constraints on Palestinians in Lebanon is that which excludes refugees from the professions and a wide range of skilled and semi-skilled work, as well as public sector employment, making it almost impossible for them to work in the private sector either. Those who work in the private sector have to do so, in most cases, under black-market conditions. They have no pension or social benefits. The now resigned Labour Minister, Hamadeh Trad, issued a memorandum in June 2005 trying to legalise menial labour for Palestinians. His measures were [sic] not been implemented because of political and bureaucratic reasons and the lack of cooperation by the private sector which is characterised by anti-Palestinian racial attitudes. Since June 2005, there has been no successor to Mr Trad. However the government has not implemented any changes in favour of basic employment rights for Palestinians. This is based upon my regular research and close supervision of the Lebanese political scene."
Cross-examination by Miss Laing
"(h) The present Lebanese government of PM Fauad Siniora took some steps in the last few years to improve the Palestinians' conditions so as to steer them away from being used as a political card by the Syrian government. The Lebanese government issued a pardon to the Fateh representative, Sultan Abu-Al-Ayneen, who was sentenced to death during the Syrian era of domination. The Lebanese government agreed to reopen the PLO office in Beirut in early 2006. The government partially removed its long standing restriction of not permitting any construction work to improve the infrastructure within the camps, mainly in Ein El-Hilweh camp."
"The political reformulation that followed the Syrian army withdrawal"
She asked Mr Shiblak whether that caused him to reconsider his view that the political changes were not to do with the Syrian withdrawal. He replied that everything had a political agenda in Lebanon. However whether in reality the Syrian withdrawal had an impact was questionable, there was no real change.
"More than anything else" says Suheil El-Nator "Mohammed's Memorandum was a political move, designed to say 'We want to deal with Palestinians differently than we have up to now'. This inspired polemics on both sides of the Lebanese political divide [because] the memorandum implicitly recognised the misery of the Palestinians here and acknowledged the need to so something about it. This is important."
"Practically, a broad segment if [sic] Palestinian workers are employed in daily agricultural work, construction, travelling sales, mechanical work, repair and workshops, and as beauticians. Another segment works in a number of occupations, such as teachers in private schools, and in rare cases as secretaries and computer operators in companies and offices. Finally, a third segment of the Palestinian population mostly women is employed to provide services in private homes and associations."
Mr Shiblak said he could not see why this was not accurate.
"Nator acknowledges that the new permit regime which makes the paperwork more affordable and ties permits to the calendar year rather than to individual jobs is somewhat more reasonable than the previous one. The whole regime, however, places obstacles in the way of the Palestinians finding work, and provides opportunities for Lebanese employers to deny it to them."
"Lebanese commerce, as has been noted by many local political analysts, has many excellent laws but their enforcement ranges from selective to arbitrary. The same is true of inhumane laws like the ones that governed its refugee community."
"Since the 'KK' decision which I have considered, it is important to note that the condition faced by Palestinian refugees since the date of that decision has significantly declined because the discriminatory measures have not receded, the living conditions remain extremely poor and matters are exacerbated because of the declining security in the camps. UNRWA's services are declining in terms of resources and in terms service delivery."
Re-examination by Mr Blum
Submissions on Behalf of the Respondent
" the sustained or systemic failure of state protection in relation to one of the core entitlements which has been recognised by the international community. The types of harm to be protected against include the breach of any right within the first category, a discriminatory or non-emergency abrogation of a right within the second, or a failure to implement a right within the third category which is either discriminatory or not grounded in an absolute lack of resources."
"(a) The evidence demonstrates that the appellants have no well-founded reason to fear arbitrary arrest or detention, or that their freedom of moment will be restricted. Nor does the evidence demonstrate, save to a very limited degree, that they have been unable to access economic, social and cultural rights.
(b) Differential treatment between nationals and non-nationals in relation to access to economic, social and cultural rights cannot amount to discrimination in the sense necessary to establish persecution, and the same principle applies to the treatment of stateless persons: an individual cannot establish by such generalised evidence of differential treatment that he is persecuted in his country of habitual residence.
(c) In any event, curtailment of such rights or discriminatory denial of access to benefits can only amount to persecution if there is no justification, and the measures involved persistent and serious ill-treatment are of a substantially prejudicial nature and effect a significant parts of an individual's existence so that it would make his life intolerable if he were to return: the appellant must be able to point to something which has an exceptional impact on him personally.
(d) For these reasons, the Article 3 threshold is not crossed (and neither is there any entitlement to humanitarian protection)."
"The relevant countries, with due regard to human rights and their national economy, may determine to what extent they would guarantee the economic rights recognised in the present covenant to non-nationals."
"This Convention shall not apply to distinctions, exclusions, restrictions or preferences made by a state party to this Convention between citizens and non-citizens."
" bearing in mind the delicate political balance in Lebanon, the Lebanese authorities are entitled to take account of the political impact upon their society of one-tenth of the population suddenly being granted citizenship and thereby enfranchised."
"These claims may at first not seem contradictory. The refugees demand 'civic rights', that is the right to live and work in Lebanon, but do not seek citizenship (which, inter alia, includes the right to vote). This is because naturalisation would compromise the right of return and symbolically erase the Palestinian refugee community, as well as being construed as a victory for the Israeli authorities, who categorically reject the refugees 'right of return'. Upholding the right of return is therefore a highly charged symbolic issue, especially for the older generation, and bridges past wrong doings (forced exodus) the future redemption (returning to Palestine). Nonetheless, a large number of Palestinians have been naturalised in recent years. Since 1994 decrees by the Lebanese authorities have naturalised about 30,000 Palestinians, the majority of them from the former security zone to the south of the country (Peteet 1996: page P29)"
"Camp residents are generally free to leave whenever they please"
"The better off and the most wretched"
"A sympathetic Labour minister has set out to regulate and open up the job market for Palestinian labour".
"Almost all shelters in the camp are ventilated and supplied with water and electricity".
"Shelters are small and very close to each other. Some still have zinc sheet roofing."
"The UNRWA health programme aims to protect, preserve and promote the health status of Palestinian refugees and meet their basic health needs consistent with basic WHO principles and concepts and with the standards of public sector health services in the agencies area of operations."
"Palestinians refugees may organise their own unions; however, because of restrictions on their right to work, few Palestinians participated actively in trade unions."
Submissions On Behalf Of the Appellants
"which by virtue of their nature a refugee is incapable of fulfilling"
"The state parties to the present covenant recognise the right of everyone to an adequate standard of living for himself and his family, including adequate food, clothing and housing, and to continuous improvement of living conditions. The states parties will take appropriate steps to ensure the realisation of this right, recognising to this effect the essential importance of international cooperation based on free consent."
"Systematic discrimination against Palestinian refugees continued"
"Institutionalised legal discrimination of refugees."
"No real right of any kind may be acquired by any person that does not carry a citizenship issued by a recognised state, or by any person if such acquisition contradicts with the provisions of the Constitution relating to the Prohibition of Settlement (Tawteen)."
" substantial impairment of ability to earn a living coupled with other discriminatory factors could, depending on the circumstances, constitute persecution."
"To establish a well-founded fear of economic persecution, Borca must show that she faces a probability of deliberate imposition of substantial economic disadvantage on account of her political opinion."
Mr Blum accepted that this was a case involving different legislation. However the court had found there was no need for physical harm to establish economic persecution, and he submitted the same principle applied in the UK jurisdiction. The US court had found the need for a deliberate imposition of punishment and the analogy here was that there was a deliberate restriction on the employment for Palestinians in Lebanon, and the situation was therefore analogous.
"The refugee camps, where most Palestinians reside, are extremely crowded and are of poor condition. The average refugee household consists of 2.2 rooms and occupancy rate is 2.6 persons per room. Among recently displaced families, this figure rises to 3.4 persons per room. Most camps lack adequate water and electricity and only 57% of households are connected to the public sewage system. Nearly seven out of ten households are cold and difficult to heat during winter. Lebanese authorities prohibit Palestinians living in the camps from transporting building materials into the refugee camps, especially in southern Lebanon. Hence, the shelters are dilapidated. In some camps, restrictions are so extreme that authorities even confiscate wood planks and nails from refugee camps residents."
"Bourj Al-Shamali, the author's NPA informant says, has the distinction of being one of the poorest camps in Lebanon. Another informant referred to the camp as a symbol of Palestinian deprivation in Lebanon.
The camp's dominant architectural style is a single storey breeze block structure topped with sheets of tin for roofing. Like the other camps in south Lebanon, the residents of Bourj Al-Shamali were for years forbidden to bring building materials into the camp, so that when the ban was eased somewhat a couple of years ago, the camp infrastructure was in desperate condition.
Three UNRWA operated wells provide the camp's water supply. Camp toilets are connected to percolating pits and sewage and waste water run into open storm drains along roads and pathways.
A number of health conditions result from the camp's poor infrastructure. Skin diseases are particularly common, resulting from the consumption of contaminated water. For the last year or so, an NGO financed project has been attempting to repair the infrastructure of the village and camp of Bourj Al-Shamali. The project has ground to a halt due to lack of funds.
All the authorities the author consulted for this report agreed that health conditions in Bourj Al-Shamali are particularly grievous."
The Tribunal's Decision in KK
"82. UNRWA describes the situation of Palestinian refugees in Lebanon as involving them in facing specific problems. They do not have social and civil rights and have a very limited access to the government's public health or educational facilities, and no access to public or social services. The majority rely entirely on UNRWA as the sole provider of education, health in relief and social services. They are considered as foreigners and prohibited by law from working in some seventy-two trades and professions which has led to high levels of employment among the refugee population. It seems that popular committees in the camps representing the refugees regularly discuss these problems with the Lebanese government of the UNRWA officials. As we say, UNRWA provides services and administers its own installations and has a camp services office in each camp which residents can visit to update records or raise issues about services with the camp services officer who will refer petitions etc. to the UNRWA administration in relevant areas. It is said that socio-economic conditions in the camps are generally poor. There is a high population density and there are cramped living conditions and an inadequate basic infrastructure as regards matters such as roads and sewers. As we have noted above, some two-thirds of registered refugees live in and around cities and towns."
" Our view is that although there is evidence as we have described briefly above for example from the UNRWA at page 91 of Mr Southey's bundle concerning the serious problems in the camp, to regard the circumstances in the camps as life threatening is excessive and objectively unfounded, having regard to the information in the international reports provided to us."
"91. The UNRWA website states that all of the camps suffer from a lack of proper infrastructure and overcrowding, poverty and unemployment. Living conditions and specific aspects of the infrastructure such as roads and sewers are described as being inadequate. The Amnesty International team which visited four camps between 27 May and 14 June 2003 noted that the sewage systems in most of the camps appeared to be damaged and posed health risks to the community and that living conditions were aggravated by crowding in the camps."
"Based on the exercise of discretion by the Ministry of Labour, founded on requirements of 'public interest' and 'reciprocity of treatment'."
"It is however unclear from the evidence whether the Syrians and other non-Lebanese who work in significant numbers in Lebanon are able to fulfil this requirement, as we have not been told that there are reciprocal arrangements in place in Syria or the other countries available to Lebanese nationals. The same point can be made with regard to rights to social security. Again, Palestinians cannot qualify, given their inability to provide reciprocity of treatment, but again we are unclear as to the situation with regard to nationals of other states working in Lebanon. As regards the purchase of land, as we have noted above, it is clear that Palestinians do not have the right to do so in Lebanon or indeed to inherit land. It appears, however, that all nationals of recognised states can acquire or inherit property in Lebanon, according to paragraph 5 of the amnesty document, and there is clear discrimination in that regard. It is said in the State Department Report at page 86 of Mr Southey's bundle that the Lebanese parliament has justified this law on the grounds that it is protecting the rights of Palestinian refugees to return to the homes from which they have fled after the creation of the State of Israel in 1948. It is also said in this regard that other foreigners may own a limited size plot of land but only after obtaining the approval of five different district officers, and that the law applies to all foreigners but it is applied in a manner disadvantageous to the 25,000 Kurds in the country."
"that such detention and questioning of Palestinians as takes place at Lebanese checkpoints has a significant degree of justification to it in light of the understandable concerns that the authorities might have."
"a public emergency threatening the life of a nation whose existence has been officially proclaimed, which is the only basis upon which it is said that second category rights can be denied".
"As regards these points, as we have noted above, although there is an extent to which under Lebanese law other foreign nationals are not discriminated against to the same extent in Lebanon as the Palestinians are, there is a lack of evidence in regard to particular matters as to whether or not they are in fact in the same position, especially as regards employment and access to social services. Moreover, other foreign nationals in Lebanon will have been regularly admitted under Lebanese immigration laws which may well give status restricted either in point of time or of the rights which they may pursue whilst lawfully there. That is a situation which is not apparently comparable to that of Palestinian refugees and their descendants, whose needs are to be provided for primarily by an international agency, UNRWA. If Mr Southey is relying on what he considers to be the genuine justification rather than the purported justification, then we find ourselves in agreement with Miss Laing that, bearing in mind the delicate political balance in Lebanon, the Lebanese authorities are entitled to take account of the potential impact upon their society of one-tenth of the population suddenly being granted citizenship and thereby enfranchised. The purported justification is not in any event in our view a legitimate one. The period of time factor is also in our view, though not without relevance, in no sense determinative. All the indications are that the Palestinians would prefer on the whole to return to their homeland rather than continue the existence that they have in the camps in the various countries in which they find themselves, and in our view it is a factor that the Lebanese state is entitled to take into account. We remind ourselves that this arises in the context of Article 26 of the International Covenant on Civil and Political Rights upon which both Mr Southey and Mr Cantor relied, but we consider that it has some relevance to the other provisions concerning discrimination to which we turn."
"104. We are not sure to what extent a report of the UN Special Rapporteur [which had indicated that Article 2(3) must be narrowly construed, and could only be relied on by developing countries and only with respect to economic rights] can be said to qualify or give binding guidance on the meaning of a provision in an international agreement, and also we have not heard argument on whether Lebanon can be described as being a developing country, although we consider that it can probably properly be so described. If that is right, then even with the Special Rapporteur's restriction, the construction would cover economic rights if not social and cultural rights, and we do not consider that it can properly be said that the obligation to pay due regard to human rights in the context of Article 2(3) includes any discrimination which is outlawed by a Convention such as the Statelessness Convention. We note the point made by Miss Laing at paragraph 9 of her skeleton of the Statelessness Convention provides that contracting parties should accord a stateless person treatment as favourable as possible and in any event not less favourable than that accorded to aliens generally in the same circumstances, for example, in relation to wage earning, employment, self employment and housing, and that in relation to free movement, stateless persons are also subject to the regulations applicable to aliens generally. There is in our view force in the submission at paragraph 10 of her skeleton that the treatment of aliens or stateless persons different from and less favourable than that accorded by the state to its own citizens, does not of itself amount to persecution, and in this context we bear in mind the distinctions that have been pointed out to us between the treatment of Palestinians in Lebanon on the one hand and citizens of other states in Lebanon on the other hand.
105. We return to the point made by Miss Laing concerning the particular context in which these appeals arise. It is not a straightforward issue of a state carrying out a range of discriminatory measures against stateless persons and others within its jurisdiction. It is clear from the UNRWA mandate that there are specific matters which are within the remit of UNRWA and other matters which are within the remit of the State of Lebanon. UNRWA on its own account is under funded and it is clearly labouring to do the best it can under very unpromising conditions. That having been said, undoubtedly there are aspects of discrimination against Palestinians in Lebanon for which the Lebanese state can be said to be accountable. Various justifications are given for this including economic circumstances, fear of armed militias and reserving the right of the Palestinians without restriction ultimately to return to their own homelands.
106. Having considered these matters as a whole, as we have done in some detail above, we have concluded that to the extent there is a discriminatory denial of third category rights in Lebanon for Palestinians, this does not amount to persecution under the Refugee Convention or breach of protected human rights under Article 3 of the ECHR. We do not consider that it has been shown that the discrimination is of such a degree that it can properly be described as degrading as set out in Ireland v United Kingdom  2 EHRR 25. On this point we address particularly the matters set out at paragraphs 16.5 of Mr Southey's skeleton. The contentions that he makes there and made before us in submissions concerning the perceived hopelessness of the situation for those in the camps and bearing in mind the points made in the East African Asians case with regard to the nature of discrimination are not such that it can properly be said to breach Article 3."
"Moreover, the International Covenants to which we have referred contain, in contrast to the absolute nature of Article 3 of the ECHR, clear derogations and areas of appreciation. They are in many instances exhortatory and aspirant of an ideal, for that reason necessarily requiring modification in its application, as recognised by the covenants. Before any breach of such convents could properly be regarded as a breach of the provisions of the European Convention which bind the UK, there would require to be such flagrant denials as would result in the high threshold imposed by Article 3 being breached. In the circumstances, therefore, we consider that the Article 3 threshold would not be crossed in any of these cases on the basis of general attitudes in Lebanon towards Palestinians."
"Act of Persecution
5(1) In deciding whether a person is a refugee an act of persecution must be:
(a) sufficiently serious by its nature or repetition as to constitute a severe violation of a basic human right, in particular a right from which derogation cannot be made under Article 15 of the Convention for the Protection of Human Rights and Fundamental Freedoms; or
(b) an accumulation of various measures, including a violation of a human right which is sufficiently severe as to affect an individual in a similar manner as specified in (a)."
This definition accepts in our view that cumulative violation of human rights could create persecution, so in this regard it encompasses the Hathaway principles to which we were referred.
Our Findings and Conclusions
"Palestinian refugees were subject to arrest, detention and harassment by statue security forces and rival Palestinian factions."
is any more than a comment on the authorities' reaction to the security situation. This section of the US State Department Report refers the reader in turn to section 2D, which deals with freedom of movement within the country, and here it states:
"Security services use checkpoints to conduct warrantless searches for smuggled goods, weapons, narcotics and subversive literature."
"The law does not explicitly target Palestinian refugees, but bars those who are not bearers of nationality of a recognised state from owing property. Palestinians no longer may purchase property, and those who own property prior to 2001 are prohibited from passing it on to their children. The parliament justified these restrictions on the grounds that it was protecting the right of Palestinian refugees to return to the homes they fled after the creation of the State of Israel in 1948. Other foreigners may own a limited size plot of land but only after obtaining the approval of five different district officers. The law applies to all foreigners, but it was applied in a manner disadvantageous to the 25,000 Kurds in the country."
"The present Lebanese government of PM Fuad Siniora took some steps in the last few years to improve the Palestinians' conditions so as to steer them away from being used as a political card by the Syrian government. The Lebanese government issued a pardon to the Fateh representative, Sultan Abu-Al-Ayneen, who was sentenced to death during the Syrian era of domination. The Lebanese government agreed to reopen the PLO office Beirut in early 2006. The government partially removed its long standing restriction of not permitting any construction work to improve infrastructure within the camps, mainly in the Ein El-Hilweh camp."
The Impact of Differential Treatment; Justification and the Lebanese Authorities' Obligations in International Law
The Application for these Findings to the Appellants
The First Appellant
The Second Appellant
The appeal is dismissed on asylum grounds.
The appeal is dismissed on human rights grounds.
The appellant is not entitled to humanitarian protection.
The appeal is dismissed on asylum grounds.
The appeal is dismissed on human rights grounds.
The appellant is not entitled to humanitarian protection.
Senior Immigration Judge Nichols
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