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WRITTEN STATEMENTOF THE REPUBLIC OF CUBATO
THE INTERNATIONAL COURT OF JUSTICE
REGARDING THE REQUEST OF A CONSULTATIVE
OPINION ON THE FOLLOWING QUESTION:
What are the legal consequences arising from the construction
of the wall being built by Israel, the occupying Power, in the
Occupied Palestinian Territory, including in and around East
Jerusalem, as described in the report of the Secretary-General,
considering the rules and principles of lnternational Law,
including the Fourth Geneva Convention of 1949, and relevant
Security Council and General Assembly resolutions?
INTRODUCTION
The GeneralAssembly of the United Nations, through resolution ES-
10114 of 8 December 2003, requested the emission of a
Consultative Opinion, in conformity with Articles 96 of the UN
Charter, and 65 of the Statuteof the Court.
The situation in the Occupied Palestinian Territories continues to be
cause for deep concern to the Republic of Cuba. For more than 50
years, Israel, the occupying Power, has been responsible of
continuous and flagrant violations of human rights, of lnternational
Humanitarian Law and of lnternational Law in said territories.
Since Israel, the occupying Power, initiated, on April 14, 2002, the
construction of a wall in the Occupied Palestinian Territory,including
in and around East Jerusalem, departing from the Armistice Line of
1949 (Green Line) and from the relevant provisions of lnternational
Law, numerous defenseless civilians have lost their lives or been
injured.
It is totally impossible to estimate the degree of mourning imposed
to Palestinian families, of pain to the mothers of the Palestinian
children who have died as a result of the violence exerted by the
occupying Power, and of the systematic humiliation to which the
Palestinian people is subjected. The Palestinian economy has
likewise suffered a devastating blow as a result of the construction
of the wall.The Government of the Republic of Cuba observes with serious
concern that, in spite of the multiple appeals by the international
community to Israel,the occupying Power,to put an end to violence,
and "stop and reverse the construction of the wall', that has brought
about the confiscation and destruction of Palestinian lands and
resources, the disruption of the lives of thousands of protected
civilians and the annexation of extensive tracts of land, lsrael
continues to follow an aggressive escalationthat increasingly makes
it more difficultto achieve a just and lasting peace in the region.
The occupying Power,with the construction of the wall, goes against
the provisions of the Fourth Geneva Convention of 12August 1949
relative to the Protection of Civilian Persons in Time of war,
principles of International Law enshrined in the United Nations
Charter and principles of International Humanitarian Law, as well as
a number of resolutions adopted by the General Assembly and the
Security Council.
The impunity with which Israel, the occupying Power, has acted
during al1these years is a consequence, inter alia, of the failure of
the Security Council, where the consideration of this situation has
been characterized by double standards and the lack of democracy
and transparency, particularly by one of its Permanent Members,
that has exercised the obsolete privilege of the veto on 27
occasions. This has led the occupying Power not to recognize any
limit whatsoever, either legal, ethical, or humanitarian regarding its
actions in the Occupied Palestinian Territories.
The Government of the Republic of Cuba condemns the acts of
annexation, the excessive use of force without establishing
distinctions between civilians and combatants, the creation of a
humanitarian crisis through the limitations imposed to the circulation
of goods and persons, the inhuman treatment of children, the
generalized destruction of goods and, more recently, the territorial
expansion implied by the construction of the wall.
At the same time, Cuba reaffirms its firm and unwavering solidarity
with the Palestinian people in its struggle for the establishment of a
'The U.N. General Assembly, on 21 October 203, adopted, in the continuation of its Tenth
Emergency Session, resolution0113,which in its paragraph 1 "Demandsthat Israel stop
aroundvEast Jerusalem, which is in departure of the Armistice Line ofis intory, including in and
contradiction to relevant provisions of internationalsovereign and independent State,with East Jerusalem as its capital,
and for the return of al1 the occupied Arab territories. We are
convinced that only determined and firm actions by the international
community will be able to Savethe negotiating process and facilitate
the achievement of a just and lasting peace in the Middle East.
This situation must cease. Israel, the occupying Power, has the
obligation of putting an end to the construction of the wall and
reverting its consequences. The international community should not
recognize the control by the occupying Power of the Palestinian
territory delimited bythe wall.
The lnternational Court of Justice should act in a decisive and
unanimous manner in favor of peace and justice. Every minute,
innocent persons die and are permanently humiliated. Each new
stone placed for the lifting of the wall of separation continues to
accentuate the illegal lsraeli occupation, and perpetuates the system
of "apartheid" established by lsrael in the Occupied Palestinian
Territories. Furthermore, with these actions, lsrael moves the
possibility of reaching a negotiated, just and lasting solution to the
Palestinian-lsraeli conflict further along intothe future.
1. Legal consequences of the construction of the wall from the
pointof view of the principles and norms of lnternational Law.
In the view of the Republic of Cuba, the analysis carried-out by the
distinguished Judges of the International Court of Justice on this
issue should take into consideration the following elements:
The construction of the wall bythe occupying Power in the Occupied
Palestinian Territories, including in and around East Jerusalem,
violates the following principles of lnternational Law enshrined in the
Charter of the United Nations:
A. The prohibition of the threat or useof force.
As described in the Report of the Secretary ~eneral~, presented in
compliance with resolution ES-10113of the General Assembly of the
United Nations, the layout predicted for the construction of the wall
in the Occupied Palestinian Territoriesdoes not follow the Armistice
2
GeneralAssemblyAIES-101248.ry General, preparedin compliancewith remlution Es-10113of theLine of 1949 (Green Line), generally accepted by the international
community as the border between Israel and Palestine and as the
demarcation between both territories3.The wall follows a layout that
incorporates to the occupying Power considerable portions of
Palestine. At present, the wall enters between 6 and 7 kms. in said
territory. If the layout foreseen by the authorities of the occupying
Power is applied, the wall would deviate from the Armistice Line of
1949 (Green Line) up to 22 kilometers in several places, annexating
important portions of the West Bank and of in and around East
Jerusalem.
The occupying Power, withthese actions, would de facto establisha
new border by means of the use of force.
The reality on the field does not corroborate the affirmation of Israel,
the occupying Power, that the wall is conceived exclusively for
security purposes without the intention of modifying the political
borders. In reality, it is conceived to cover half of the population of
settlers in the West Bank and East Jerusalem, thus proving that its
ultimate end is to further guarantee the position of the said settlers
and the illicitannexation of those territories.
The wall has al1the characteristics of a permanent structure. Its
construction (structure of concrete, wire, observation towers and
electronic monitoring means) will be extremely costly. According to
calculations presented by the media, approximately 1.5 billion US
dollars will be spent for that end4. This only confirms the permanent
nature of the wall, with the obvious purpose of creating de facto
situations that would eventually condition the solution of the conflict
according to the interests of the occupying Power. With this
measure the occupying Power would consolidate its policy of
territorial expansion and forced acquisition of territory that has
characterized its actions. The United Nations Charter and the
Geneva Conventions of 1949 prohibitannexations of this kind, which
in International Law are tantamount to "conquests". "Conquests", or
the "acquisition of territories by the use of force", were banned by
the prohibition of the use of force imposed by the Kellogg-Briand
3Security Council reso242, whileorderingthewithdrawalof Israeliarmedforces from the
territories occduringthe conflictof 1967, dejure recognizedthe Armistice Lineof 1949
(Armistice Lineof 1949 (ArmisticeLineof 1949 (Green Line)))as the demarcationof
betweenIsraelandPalestine.
4Accordingtoinformationprovidedbythe Spanish Televn2 November2003.Pact of 1928~and by paragraph 4, Article 2 of the Charter of the
United Nations.
The prohibition of the acquisition of territories by force applies
independentlyof the fact that the territory be acquired as a result of
an act of aggression or legitimate defense. The Declaration on
Principles of International Law concerning Friendly Relations and
Cooperation among States in accordance with the Charter of the
United Nations (resolution 2625 (XXV) of 24 October 1970),
establishes that "the territory of a State shall not be the object of
acquisition by another State resulting from the threat or use of
force. No territorial acquisition resulting from the threat or use
of force shall be recognized as legal". This prohibition is
confirmed in resolution 242 (1967) of the Security Council and in the
Oslo Agreements. Said agreements establish that "Neither side
shall initiate or take any step that will change the status of the
West Bank and the Gaza Stri pending the outcome of the
permanentstatus negotiations" r.
The construction of the wall in the Occupied Palestinian Territories
qualifies also as an illicit act of annexation in accordance with the
provisions of resolutions 478 (1980) and 497 (1981) of the Security
Council, which declare that the acts of lsrael geared at the
annexation of East Jerusalem and the Golan are nuIl and void, and
should not be recognized by States.
B. The equality of rights and the self-determination of
peoples.
The right to self-determination is closely linked with the concept of
territorial sovereignty. A people can only exercise the right to self-
determination within a territory. The amputation of the Palestinian
territory by means of the construction of a wall is a serious violation
of the right to self-determination of the Palestinian people, since it
considerably reduces the size of the self-determinationunit (already
small) within which such right should be exercised.
5During the holding of the Paris Pact (1928), 63 nations subscribed the Treaty for the
Renunciationof War, also knownasthe Briand-KellogPact,by which they renounced war as an
instrument of their respective national policies, and committed themselves to resolve
international conflicts by peacefulIt is considered a consuetudinary norm of
6ProvisionalAgreement betweenIsrael and Palestineon the EasternBank andthe GazaStrip,
28 September1995.II.- The construction of the wall violates the provisions of the
resolutions of the General Assembly and the Security Council.
The construction of the wall should be seen in the context of the
lsraeli settlements in the Occupied Palestinian Territories, which
have been the object of resolutionsadopted by the United ~ations.~
The Government of the occupying Power is determined to
consolidate those settlements. There is consensus in the
international community with regard to the lsraeli settlements in the
Palestinian territories, which have repeatedly been considered as a
violation of paragraph 6, Article 49 of the Fourth Geneva
Convention, prohibiting the occupying Power from transferring part
of its own civilian population to the territory it has occupied. It is
clear that the dismantling of the settlements is a fundamental issue
in the context of a politicalsolution of the Israeli-Palestinianconflict.
This has been evident from the resolutionsadopted in that regard by
the General Assembly and the Security Council, and from the
different negotiatingprocessesthat have been carried-out during the
last period.
III.- The construction of the wall violates principles and norms
of the lnternational Humanitarian Law.
- The occupying Power intends to justify the construction of a wall in
the Occupied Palestinian Territoriesas being a security measure by
virtue of the exercise by Statesof their rightto legitimatedefense. In
accordance with the Charter of the United Nations and lnternational
Law, States have the right to exercise said right individually or
collectively in the case of an armed attack for the protection of its
legitimate security interests, and in cases of strict military necessity.
Nevertheless, those actions should be compliant with international
human rights norms and lnternationalHumanitarian Law. The action
adopted by Israel, the occupying Power, of building a wall in the
Occupied Palestinian Territoriesis notjustified by militarynecessities
and goes against the principle of proportionality. It is a
disproportionate answer to its security interests, moves away from
measures of that character and acquires the nature of punishment,
humiliationand conquest.
'Resolution242 of 22 November 1967,resolution446 of 22 March 1979and resolution54/38
of the GeneralAssemblyshould detaken as references.- Though it is accepted that combatants participating in armed
conflict be faced by situations of mortal danger, International
Humanitarian Law tries to limit the damages to be suffered by
by requiring that al1 parties in the conflict respect the
civilians
principles of distinction and proportionality. The principle of
distinction, enunciated in Article 48 of Additional Protocol 1to the
Geneva Conventions of 12 of August of 1949, establishes that "the
Parties to the conflict shall at al1times distinguish between the
civilian population and combatants and between civilian
objects and military objectives and accordingly shall direct
their operations only against military objectives". The acts or
threats of violence whose main purpose is to terrify the civilian
population are forbidden (Article 51, paragraph 2). The principle of
proportionality, enunciated in Article 51, paragraph 5 b) prohibits
attacks against a military objective when it may be expected to
"cause incidental loss of civilian life, injury to civilians, damage
to civilian objects, or a combination thereof, which would be
excessive in relation to the concrete and direct military
advantage anticipated".
The construction of the wall in the Occupied Palestinian Territories,
included East Jerusalem, and the inclusion within its limits of the
illegal lsraeli settlements, with the intention of carrying-out territorial
expansion, de facto annexation or conquest, places seriously in
doubt that the occupying Power is acting in good faith by arguing
reasons of security for its actions.
IV.- Legal Consequences of the construction of the wall from
the point of view of the principles and norrns of International
Humanitarian Law.
A. Applicability of the Geneva Convention of August 12,
1949 regarding protection of civilian persons in times of
war (Fourth Geneva Convention) to the Occupied
Palestinian Territory, including in and around East
Jerusalem.
Though Israel, the occupying Power, has said that the Fourth
Geneva Convention is not applicable to the Occupied Palestinian
Territory as it is "not a territory of a High Contracting Party asrequired by the onv vent ion t",^applicability of this Instrument to
said territories enjoys extensive international recognition.
Inthe view of the Republic of Cuba, the analysis to be carried-out by
the distinguished Judges of the InternationalCourt of Justice on this
issue, should take into account the following elements:
- By its resolution 3210 (XXIX) of 14 October of 1974, the General
Assembly of the United Nations recognized the Palestine Liberation
Organization (PLO) as the representative of the Palestinian people.
Approximately one month later, by its resolution 3237 (XXIX), the
General Assembly granted to said organization the status of
Observer to the U.N.
- By its resolution 431177of 15 of December of 1988, the General
Assembly of the United Nations recognized the proclamation of the
State of Palestine carried-out by the National Palestinian Council on
15 November that same year. Since then, and by decision adopted
in resolution 431177 itself, the designation "Palestine" has been
used, instead of "Palestine Liberation Organization", to name the
entity that, with full recognition of the international community,
represented the interests of the Palestinian people in the framework
of the United Nations.
-Outside the U.N. context, a very large majority of the international
community recognized formally the PL0 as the representative of the
Palestinian people. This was materialized in the fact that a large
number of States established bilateral relations with said
organization, and even, in a number of cases, it has been granted
full diplomatic status. The Republic of Cuba recognizes the
Palestinian State and maintains diplomatic relations at the level of
Ambassadors.
- On June 21, 1989, the Federal Department of Foreign Affairs of
Switzerland, Depository of the Four Geneva Conventions of 1949
and its two Additional Protocols of 8 of June of 1977, received a
communication dated 14 June 1989 addressed to the Office of the
United Nations in Geneva by the Permanent Observer of Palestine,
regarding the participation of Palestine in the four Geneva
Annex1, paragraph3 of the Reportof the U.N. SecretaryGeneral,preparedin cornpliance
with resoluES-10113oftheGeneralAssernbly(AIES-101248)Conventions of 12 August 1949 and its two Additional Protocols of
1977.9
- The communication delivered by the Permanent Observer of
Palestine demonstrates the consent of Palestine in being obliged by
the four Geneva Conventions of 12 of August of 1949 and its two
Additional Protocols of 8 of June of 1977.
- The Fourth Geneva Convention does not define the term "High
Contracting Parties". Therefore, there is no argument in said legal
Instrument to exclude the possibility that the entity internationally
recognized as the representative of the Palestinian people acquire
the obligations and rights foreseen by the Convention.
- Likewise, it should be said that, according to a number of
resolutions adopted by the Security Council and the General
Assembly of the United ~ations", which summarize the point of
view of the international community,the Fourth Geneva Convention
is applicable to the Occupied Palestinian Territory, including East
Jerusalem.
- In accordance with this analysis, the argument that the Occupied
Palestinian Territory should not be considered as belonging to a
High Contracting Partywould not seem sustainable.
Keeping in mind the elements previously expressed, and basing
ourselves onArticles 1, 2 (second and first paragraphs) and 6 of the
Geneva Convention of 12 of August of 1949 relative to the
Protection of Civilian Persons in Time of War, the Republic of Cuba
considers that said legal instrument, ratified by the State of lsrael in
1951, is applicable to the Occupied Palestinian Territories, including
East Jerusalem. At the same time, as occupying Power, lsrael is
also legally obliged by other consuetudinary norms relating to
occupation, according to the stipulations of the Rules annexed to the
Hague Convention on laws and costumes of land wars of 18
October of 1907.
9Page 17 of the Report by the U.N. Secretary Generalregarding the situationof the Additional
Protocols to the Geneva Conventions ofon the protection of victims of armed conflict
OAl571164)
the U.N. General Assembly, al1 of which reaffirm the applicability of the Fourth Geneva
Conventionto the Occupied Palestinian Territories, including in and around Jerusalem.Not to accept the applicability of the Fourth Geneva Convention to
the Occupied Palestinian Territories, including East Jerusalem,
would be tantamount to placing the Palestinian population residing
in those territories in a situation of defenselessness against the
actions of Israel, the occupying Power. Therefore, those persons
should be considered as "protected persons", according to the
definition of this condition in article 4 of said Convention.
Ingeneral terms, the Fourth Geneva Convention protects the civilian
population in occupied territories against the abuses by the
occupying Power; it is particularly ruled that no discrimination be
exercised against that population, that it be protected against al1
forms of violence, and that, in spite of the occupation, it may carry-
out, in as much as possible, a normal life, according to its own laws,
culture and traditions.
B. Violations by Israel, the occupying Power, of the
Fourth Geneva Convention of 12 of August of 1949
relative to the Protectionof Civilians in Time of War.
Keeping in mind the informationsupplied in the Report of the u.N."
Secretary General, the construction by the occupying Power of the
wall in the Occupied Palestinian Territories has caused important
humanitarian and socioeconomic damages to the Palestinian
population residing in said territories.
In the view of the Republic of Cuba, as a result of the construction of
the wall and of the severe humanitarian and socioeconomic
conditions that this has had and will continue to have for the
population of the Occupied Palestinian Territories, the occupying
Power incurs in the following violations of the Fourth Geneva
Convention of 1949:
- By separating up to now 22 Palestinian locations from access to
sch~ols'~, and by impeding the free circulation of Palestinians in
both sides of the wall, the occupying Power is violating the
provisions of Article 50, paragraph 1, according to which "the
11Reportbythe U.N. SecretaryGeneralpreparedin compliancewith resolutionES-10113of the
General assembly(AIES-101248)
l2Data providedby the Central StatisticalOffice of Palestine, quoted in paragraph 23 of the
Report by the U.N. Secretary Generalpreparedin compliance with resolutionES-10113of the
General assembly(AIES-101248)occupying Power shall, (...) facilitate the proper working of al1
institutions devoted to the care and education of children".
- By separating up to now 30 locations from access to health
ser~ices'~and 8 from the primary sources of water provision'4, and
by impeding the free circulation of Palestinians on both sides of the
wall in order to accede to hospitals and other medical centers, the
occupying Power is violating the provisions of Article 56, according
to which, inter alia, "(...)the occupying Power has the duty of
ensuring and maintaining, (...) the medical and hospital
establishments and services, public health and hygiene in the
occupiedterritory ..."
- With the destruction of dwellings, stores, cultivated lands and other
goods belonging to the Palestinianpopulationfor the construction of
the wall, the occupying Power is violating Article 53, according to
which "any destruction by the occupying Power of real state or
personal property belonging individually or collectively to
private persons, or to the State, or to other public authorities,
or to social or cooperative organizations, is prohibited, except
where such destruction is rendered absolutely necessary by
military operations." In Cuba's view, the exception foreseen in this
Article is not applicable to this case.
-As a result of the construction of the wall and of the establishment
of arbitrary restrictions to the movement of persons and Palestinian
goods from one side of the wall to the other, access by the
Palestinian population to their lands, jobs, markets and other
sources of subsistence has been severely limited, with which the
Palestinian economy has been severely affected and its population
has been subjected to unsustainable conditions. In face of this
situation, the occupying Power has not fulfilled its obligation to
provide these persons with the opportunity to find paid employment,
according to provisionsincluded in paragraph 1,Article 39.
- Likewise, the occupying Power has not fulfilled the provisions of
paragraph 2 of saidArticle 39, according to which "where a Party to
the conflict applies to a protected person methods of control
which result in his being unable to support himself, and
especially if such a person is prevented for reasons of security
13
14Ibidem
Ibidemfrom finding paid employment on reasonable conditions, the
said Party shall ensure hissupport and that of his dependents".
- In this context, the occupying Power has not fulfilled the provisions
of paragraph 1, Article 55, according to which "( ..the occupying
Power has the duty of ensuring the food and medical supplies
of the population; it should, in particular, bring in the necessary
foodstuffs, medical stores and other articles if the resources of
the occupied territory are inadequate".
- Keeping in mind the previously mentioned violations of the rights of
the "protected population", in this case the Palestinian population
residing in the Occupied Palestinian Territories, the occupying
Power is violating article 47 of the Fourth Geneva Convention of
1949, according to which "protected persons who are in
occupied territory shall not be deprived, in any case or in any
manner whatsoever, of the benefits of the present Convention
(..)"
All the violations of the provisions of the Fourth Geneva Convention
of 1949 above described, have caused a worsening of the
humanitarian crisis in the Occupied Palestinian Territories.
Furthermore, they represent a humiliation to the Palestinian people
by virtue of Article 27 of said Instrument, according to which
"protected persons are entitled, in al1circumstances, to respect
for their persons, their honour, their family rights, their
religious convictions and practices, and their manners and
customs. They shall at al1times be humanely treated, and shall
be protected especially against al1acts of violence or threats
thereof (...)" In fact, the construction of the wall, with its concrete
structure, its wire, its towers of observation and its electronic
monitoring means, creates a population of prisoners.
International Humanitarian Law,while conferring certain rights to the
occupying Power, also imposes limits to the scope of its powers.
Considering that it is only a temporary administrator of the occupied
territory, the occupying Power should not interfere in its original
social and economic structures, organization, legal system or
demography. It should ensure the protection, the security and the
well being of the population that lives under occupation. This also
implies that, if the occupation were to be prolonged, the normal
development of the territory should be permitted.According to interpretations of the facts described in the Report of
the U.N. Secretary General, as well as from other public sources
consulted, nothing of what has been previously quoted has been
fulfilled by the Power occupying Palestinianterritories.
The extreme humanitarian crisis imposed by the occupying Powerto
the Palestinian population since the construction of the wall, as
described in the Report of the Secretary General and in other public
sources, may be classified as a crime of extermination, as it
constitutes the intentional infliction of conditions of life, calculated to
bring about the destruction of part of a population, in this case the
Palestinian population.
Therefore, Israel, as a State party to the Fourth Geneva Convention
and, at the same time, as occupying Power,should comply with the
obligation emanating from Article 1, common to the four Geneva
Conventions, according to which the High Contracting Parties
undertake to respect and to ensure respect of said Convention in al1
circumstances.
FINALCONSIDERATIONS
The Government of the Republic of Cuba considers it difficult to
accept that the following elements may be considered an answer
proportionate to the perception of security of the occupying Power:
the excessive use of force, the lack of distinction between civilians
and combatants, the creation of a humanitarian crisis as a
consequence of the limitations imposed to the circulation of goods
and persons, the death and the inhuman treatment of children, the
generalized destruction of goods and, ultimately, the territorial
expansion by means of the construction of the wall.
The construction of the wall in the Occupied Palestinian Territories,
including East Jerusalem, and the inclusion within its limits of the
illegal lsraeli settlements, the intention of which is non another than
territorial expansion, de facto annexation, or conquest, put seriously
in doubt the good faith of the occupying Power when addressing
security reasons.Israel, the occupying Power, persists in serious violations of the
provisions of the Fourth Geneva Conventionof 1949. It still refuses
to accept the de jure applicability and even the application of the
Convention to the Occupied Palestinian Territory, including
Jerusalem, thus showing its refusal to respect the will of the
international community, which for more than 30 years has
confirmed the applicability of the Fourth Geneva Convention to the
Occupied Palestinian Territories, including in and around East
Jerusalem.
The Government of the Republic of Cuba expects that the
lnternational Court of Justice, while emitting the Consultative
Opinion requested by U.N. General Assembly resolution ES-1011 4
of 8 December 2003, recognizes that the construction of the wall by
Israel, the occupying Power, in the Occupied Palestinian Territory,
including in and around East Jerusalem, is illegal and in violation of
the norms and principles of lnternational Law, including the Fourth
Geneva Convention of 1949 and the pertinent resolutions of the
Security Council and the GeneralAssembly.
The Government of the Republic of Cuba equally expects that the
lnternational Court of Justice recognize the international
responsibility derived for the occupying Power by the illicit acts
previously expressed. Likewise, the Government of the Republic of
Cuba considers that the stopping of the process of construction of
the wall in the Occupied Palestinian Territory cannot be postponed,
and requests that the Court demand Israel, the occupying Power,
that the wall be totally demolished and that it unrestrictedly fulfills
lnternationalLaw and lnternational Humanitarian Law.
Written Statement of the Republic of Cuba