Frontiers, Ruwad Association is a Lebanese non- profit independent organization providing professional,

Reg. # 231/‫أد‬ sustainable assistance to marginalized people to assist them to understand and access their rights.

UPDATE
POSITION PAPER ON
THE LACK OF RECOGNITION
OF UNDOCUMENTED PALESTINIAN REFUGEES IN LEBANON

October 2010

This paper is an update to Frontiers Ruwad Association's position paper issued in 2009 on
the lack of recognition of undocumented Palestinian refugees in Lebanon. It highlights the
major legal and policy development at the international and national level that took place up
to date.

- In October 2009, UNHCR revised its interpretation of Article 1-D to exclude from
its protection all Palestinians who are inside UNRWA areas of operations regardless
of their registration status or eligibility for registration.1 Subsequently, a Palestinian
who is not eligible for registration with UNRWA but resides in a country where
UNRWA operates will not be eligible for registration with UNHCR, simply due to
his physical presence in the area where UNRWA operates. Instead of filling the legal
gaps, the 2009 UNHCR revision has further widened the scope of Palestinians
denied any international protection.

- Following negotiations between the Lebanese authorities and the PLO and the
Lebanese-Palestinian Dialogue Committee (LPDC) that started in 2007, the
Lebanese authorities decided in August 2008 to issue a “Special Identification Card
for Undocumented Palestinians” residing in Lebanon. The Lebanese General
Security was assigned as the responsible body to implement that decision. The
process for application and issuing these identity cards started in August 2008.

Two months later (by October 2008) this process was put on a halt. The Minister of
Interior stated publicly that the decision was motivated by technical reasons and
should be resumed in a month time.2

Despite this promise, the process was only resumed in February 2010. Those who
have been issued IDs in 2008 which is valid for one year only, had to submit their
application anew. There are no official statistics but the number of individuals who
have submitted by the end of July 2010 an application is estimated to be slightly over
1700.

1 UN High Commissioner for Refugees, Revised Note on the Applicability of Article 1D of the 1951 Convention relating
to the Status of Refugees to Palestinian Refugees, October 2009, available at:
http://www.unhcr.org/refworld/docid/4add77d42.html [accessed 25 January 2010]
2 “Baroud to Al-Akhbar: documentation papers by the end of the month”, Al-Akhbar, 24/8/2009, available at:

http://www.al-akhbar.com/ar/node/153138

P. O. Box 13 6299 Beirut Lebanon Tel/Fax: +961 1 383 556 Mobile: +961 3 457 324 Email: info@frontiersruwad.org
 Frontiers continues to be concerned that the special identity card for the
undocumented Palestinian refugees does not give them security in terms of it does
not recognize the holders of these identity cards as “refugees” but as
“undocumented persons” residing on Lebanese soil, thereby providing them an
insecure legal status. It does not provide them the basic and fundamental rights such
as the right to work, to education, and access to basic health care. Further, the
decision is administrative and can be overturned at any time in the absence of
legislative guarantees. It does however give them recognition of their personality and
allow them to enjoy freedom of movement inside Lebanon

Moreover, the terms and conditions to obtain the card are not public making it
difficult to know who is eligible to obtain the document. In fact, some applicants
were rejected but the number of rejections remains unknown to this date. Rejections
appear to be motivated by suspicions of the applicant’s past military activity or proof
that the applicant holds an expired or valid travel document from other countries,
mainly Jordan, Egypt or the Palestinian Authority. The rejection of holders of travel
documents does not appear to take into consideration the fact that these documents
cannot be renewed or that their holders have no right to enter the territory of the
issuing authority. As such, it is expected that a large number of Non-IDs will not be
issued SIC by the Lebanese authorities and will remain undocumented in Lebanon in
the lack of any other solution.

RECOMMENDATIONS

Recommendation to the Lebanese authorities:

We call on the Lebanese authorities to:

- Make public eligibility criteria for obtaining the identity card for the undocumented
Palestinians in Lebanon, the mechanism and procedures to apply and obtain them.,
and to issue regularly related statistics ;
- Engage in dialogue with the authorities of the first host countries in order to find a
common sustainable solution for the phenomenon of lack of legal recognition of
undocumented Palestinians;
- Consider the review of the current legal and policy situation in light with the
developments that affected the Palestinian refugees since 1948 with the aim to adopt
a comprehensive legal framework and policy in this regard.

Recommendation to the UN agencies and the international community

- UNRWA should revise its gender discriminatory policy that denied women the right
to transfer refugee status to its descendants
- UNRWA should engage in direct interventions with the host governmental
authorities and the international community to ensure that Undocumented

2
 Palestinians are provided with protection through a secure legal status recognizing
them as refugees.

- UNHCR should recognize its responsibility to provide protection for Palestinian

refugees in the region that do not fall under UNRWA current working definition of a
Palestine Refugee.
- UNHCR offices should open their doors for the registration and adjudication of the
claim of Palestinian refugees in the region that do not fall under UNRWA current
working definition of a Palestine Refugee.

Recommendation to the League of Arab State

- The League of Arab State should include the phenomenon of undocumented

Palestinian refugees on its agenda and attempt to find a regional realistic and feasible
solution.