Guerrilla History - UN, the Palestine Question, & International Law w/ Ardi Imseis (Crossover w/ The Majlis)

Episode Date: May 10, 2024

In this special episode of Guerrilla History, we bring you a crossover episode done in collaboration with The Majlis, a project by the Muslim Societies Global Perspectives project at Queens University, which is hosted by our own Adnan Husain (so be sure to subscribe on your podcast app!). Here, Adnan and Dr. Ardi Imseis, explore the complexities of international law, human rights and the urgent imperative of addressing the current situation of Palestine. Through meticulous research and unwavering dedication to justice, Imseis's scholarship offers invaluable insights into the legal frameworks that underpin the Palestinian struggle. As we unpack the historical narratives and contemporary realities shaping the question of Palestine, Imseis's work serves as a guiding beacon, challenging prevailing norms and advocating for a rights-based approach to peace and justice. Ardi Imseis joined the Queen’s University Faculty of Law in 2018, following a 12-year career as a UN official in the Middle East, first with the United Nations Relief and Works Agency for Palestine Refugees in the Near East (UNRWA), and then with the United Nations High Commissioner for Refugees (UNHCR). Dr. Imseis's Latest Book is The United Nations and the Question of Palestine: Rule by Law and the Structure of International Legal Subalternity.  You can  follow him on twitter @ArdiImseis Help support the show by signing up to our patreon, where you also will get bonus content: https://www.patreon.com/guerrillahistory 

You don't remember den, Ben, boo? The same thing happened in Algeria, in Africa. They didn't have anything but a ranker. The French had all these highly mechanized instruments of warfare, but they put some guerrilla action on. Welcome to Guerrilla History, the podcast that acts as a reconnaissance report of global history for the activist left and aims to use the lessons of history to analyze the present. I'm one of your co-host, Adnan, Hussein, and I'm on my own today, without my usual

co-host, Henry Hakamaki, but don't worry, he'll be back again for the very next episode. But before I introduced our guest and the topic of the episode today, I'd like to remind the listeners that they can help support the show and allow us to continue making episodes like this by joining us on patreon.com slash gorilla history, two R's, two L's, and you can keep up to date with the show by following us on Twitter at Gorilla underscore Pod. Again, G-U-E-R-R-I-L-A underscore pod. For today's special episode, we're doing a collaboration between guerrilla history and the Mudgellus podcast, and listeners of both podcasts know that in each of them we have dedicated a number of episodes to different aspects of the question of Palestine broadly

and, of course, on the current situation. And for this reason, I'm really pleased that our guest today can provide a unique perspective on a different component or aspect of analyzing the situation, that is, around international law. Dr. R.D. M. Sase, is a treasured colleague and assistant professor in the faculty of law here at Queen's University. Previously, he was legal counsel and senior policy advisor at the United Nations Relief and Works Agency for Palestine refugees in the Near East, and also has served as editor-in-chief of the Palestine Yearbook of International Law and a Human Rights Fellow at Columbia Law School. I think we're going to be interested maybe to hear a little bit about his experience, working for UNRWA and as a scholar of international law dedicated to the question of Palestine.

He has provided testimony before the UN Security Council, Human Rights Council, and Committee on Economic, Social and Cultural Rights, among other international fora, and his scholarship has appeared widely, including in the American Journal of International Law, European Journal of International Law, Harvard International Law Journal, and Oxford Journal. of legal studies. Artie, I'm delighted you could make time in your very busy life to join me for this discussion. Welcome. Thank you so very much for having me.

It really is an honor and a pleasure to be with you. Well, I've been looking forward to this conversation for a while, and of course, so much of your work relates to things that we would be concerned with on these shows, given the world's situation. but we're convening actually also because you are author of a major new book titled the United Nations and the question of Palestine, rule by law and the structure of international legal subalternity. And I think we're going to talk about some of those concepts, rule by law and international legal subalternity. But before, you know, getting into the substance of the discussion,

I noticed in the book many times you talk about the need to take Palestinians and Palestine seriously. And I wondered if you could maybe explain a little bit your background and your experience, including working with the United Nations, before you undertook this kind of academic research. And what it means for you, what is taking Palestinians and Palestine seriously? entail for you. Thanks very much. A great question, actually. It's always nice to know a little bit about the authors and what goes into a book when it is drafted and written up and so on, because there's a story behind a story all the

time. So my story behind the story is that I'm a Canadian born Palestinian, and I sort of grew up, I did my undergraduate degree at the University of Toronto, and at that time as a sort of young man. I was heavily influenced by the work of Edward Saeed, who many of your listeners will be familiar with one of the greatest public intellectuals of the 20th century. And Professor Saeed's sort of exhortations to all of us to speak to truth, to power. Those things sort of stayed with me throughout. But he was always somebody who demanded, and now I'm sort of paraphrasing or even quoting from some of the titles of some of his works.

that Palestinians have the permission to narrate their stories. Because in the West, in particular, we have, for decades, been represented, but represented for, that is to say, others have done the representations for us or about our predicament, or indeed our reality, such as they perceive it to be, these others, invariably not Palestinian, And as a result, the Palestinian story and experience has been reified, narrowed, condensed, misrepresented, and infused with all manner of things, including racist appropriation of history and so on. So in this context, Saeed always reminded us of the importance of Palestinians being able to narrate their own history and their own experience. instead of being, for instance, represented merely as bloodthirsty terrorists or womanizing Arabs or, you know, and so on. And so that's what I mean when I say in the book that Palestine and its people need to be taken seriously.

Because I, as an international legal scholar and as an international law practitioner, I could see the very same patterns replicated in how. Palestine and its story and its circumstances were represented by members of the legal community. To my knowledge, there is no book on the question of Palestine in the United Nations. That is to say, the United Nations, there's a great deal of work that has been written on the UN, obviously, and a great deal of work that has been written on Palestine and international law. but one would be surprised to find that there has yet to be written a book devoted to the UN's management of the question of Palestine, which is rather odd, because the question of Palestine is the longest running problem on the agenda at the United Nations. And I had served as a Canadian international lawyer. I had served with the United Nations, that is UNRWA, the United Nations Relief and Works Agency, for over 12 years in occupied Palestine, for which in Gaza City, seven of which in East Jerusalem, with duty, of course, elsewhere in the agency's

areas of operation, Syria, Lebanon, Jordan. And in that 12-year period, you know, I had observed a great deal and had come to, of course, the agency with prior study and to scholarship as well on Palestine. So this book is an attempt by me to provide a legal history. critical legal history of the UN's management of the question of Palestine, given my experience as a UN official on the ground, my knowledge of the situation through years of study and observation and my expertise as an international lawyer. And I do hope that I'm able to give a critical examination. And the idea, of course, is to help the UN do a better job, not only in Palestine, but ultimately elsewhere in the world in line with its claims to be the standard

bear of the rules-based international legal order. Yeah, you know, this is a very thoroughly researched book, and it covers a lot of ground, some major episodes in the history of the UN's involvement in the question of Palestine. And you go very carefully through a lot of the debates, discussions and interpret all of that. But, you know, even before we get into some of that material, I noticed that you're using a few conceptual frameworks and introduce a concept yourself as part of, it's even in the title, you know, rule by law, and you draw a distinction between international rule by law and international rule of law. Perhaps you can tell us a little bit more about what's at stake in the differences between these two conceptions.

Sure. Well, the rule of law will be well known, I'm sure, to most any person who's done any civics class in high school and indeed studied in the university. And the idea of rule of law is that once law is created, whether domestically or internationally, once law is created, it is held out as strictly normative and governs. relations between all actors on the legal system and does so universally, without fear or favor, regardless of the station or the position, political, economic, or otherwise of the actor in question, all are held to account under the rule of law. And through an examination of Palestine's predicament at the United Nations, and over time, from 1947 to the present, which is a rather long period of time, seven,

years, and through different paradigms of history, a late empire at the beginning decolonization in the middle, if you like, in the 60s, 70s, and 80s, all the way up to a period of neo-imperial sort of unipolar world under the United States hegemony, if you like, in the modern period, now moving into now a multipolar world. Throughout each of these paradigms, I found looking at the UN records management of the question of Palestine, rather looking at the UN's management of the question of Palestine through the UN record, I found that there was more of what I call a rule bylaw, by which I mean the use, abuse, selective application of international legal norms, typically by hegemonic actors within the UN system, or by the UN itself, with the

results that there is under a claim of liberal rights-based approaches of universalism of quite the opposite. There is an exacerbation of the difference between the hegemonic powers on the one hand and what I call the subaltern powers or what can be called the subaltern powers, or rather actors on the other subalternity being the diametric opposite to the hegemony. That is the weaker parties on the international plane. And so what I see at work is this abuse, selective application of international law. And the thing is, is that it's all done under this claim of universalism and rule of law, when in fact law is being used as a tool for other ends, not necessarily just ones,

but to sort of keep people down. And in this case, the Palestinians and the state of Palestine. Yeah. And so what I say is that based on an analysis of the record, through the rule of law, rule by law, forgive me, there has created a condition on the international order, international legal order, that I call international legal subalternity. And international legal subalternity effectively is designed according to the idea that those who are subjected to it are continually presented to the promise of a more just and equitable future through the application of international law bolstered by the unrivaled political legitimacy of the purveyor of that promise being the United Nations, but its realization is interminably withheld. So despite the lengths to which such groups go in reliance on this promise of justice through international law, through the

United Nations, this justice is perpetually kept out of reach. This justice is perpetually kept out of reach in one way or another. And paradoxically, usually through the actions of the very same purveyor of the promise being the United Nations. And so as a result of all of this, I argue that there is a condition on the international legal order called legal subalternity, and it attaches to people who are on the outside looking in. They could be the Palestinians. They embody this idea. But they also, you can see this condition across other areas. They could be refugees, non-self-governing peoples, internally displaced persons, indigenous people. You can see the same patterns that I've tried to flesh out through Palestine's experience at the UN attached to these other groups.

And in this way, almost in a magnanimous way, the Palestinian story has something to add, if you like to the rules-based international legal order and what it produces. Yeah, this is a very interesting. I'm excited to get into some of the specifics here, but I'm also curious about the question. I mean, the book focuses mostly on the period from the UN's creation forward. When supposedly, as you're pointing out, you know, there was supposed to be a new system of international law, of human rights, universally applied. And you are studying the gap between, you know, there was supposed to be a new system of international law, of human rights, universal, universally applied. And you are studying the gap between. you know, that kind of discourse in law and the actual reality of the way in which the UN has managed the situation to make the argument that you've just stated that they rule, you know, ruled by law rather than of law. And it has created this condition that you're characterizing as international legal subalternity. But, you know, what it suggests to me and something that you discuss in the first, in one of the first chapter, of the book is that there were a lot of continuities that affected the question of Palestine and these early decisions that the UN made with the previous regimes of the League of Nations mandate period where a lot of the presumptions of a kind of European imperial approach to

hierarchies of civilizations and so on as managing, you know, relations between peoples was very much at root of the mandate kind of system and that this carried over. Perhaps you could tell us a little bit more about that kind of prehistory and where the continuity seemed to be that that inform how and why the UN despite, you know, the post-World War II announcement of a kind of new approach to international relations and respect of, you know, universal human rights, you know, you get the Declaration, Universal Declaration of Human Rights and so on. How and why, from the very beginning, it seems that this wasn't applied in a universal way to the condition of Palestine. Why was Palestine so exceptional? And what does that have to do with?

with, you know, that pre-48 period when it was subject to, like, the League of Nations mandate under the British. Sure. I suppose a good place to begin is to appreciate how critical international law engages with the discipline. We are told that the onset of the international rules-based legal order post-World War II began a period that was new. There was a paradigm shift we were told that from here on in human rights would be given a special place. New laws were created to ensure against the ravages of what took place during World War II. World War II, the obliteration of civilian populations, the Holocaust, the appropriation of their property, and so on.

Whole bodies of law were created after World War II to govern such circumstances in the future, occupied territories, and so on, human rights law among them, and international humanitarian law as well, the Geneva aspects of that law, to be precise. And yet, we see from a critical international legal perspective a continuation of the old legal orders despite these claims of change, of liberal change. And we can see that they are either repackaged or somehow morphed into something that looks or claims to be liberal, but in fact operates in the same manner in which the old order did. So one needs to appreciate the starting point. And if you look at, say, 18th, 17th, 19th century conceptions of the international legal

order, as you'd mentioned Adnan, and as I do in the book, that order was rooted in, among other things, one firm sort of fixed feature, that is to say, the difference between civilized and uncivilized. And those persons who were deemed to be, or those nations who were deemed to be civilized were invariably European and Christian. Indeed, modern international law, through the writings of Hugo Grosius and Vital and many others, Westlake and others, asserts that that modern international law is based in a Eurocentricity and a Eurocentric worldview, right? And so in the 19th century rules, rather obligations and rights were divvied up, or

proportioned according to your level of civilization as determined by the European and if you aren't European and if you are a European Christian then you be damned you do not enjoy civilization and therefore you do not have any standing on the international legal order well there was a shift or so we were told with the onset of the post-World War I age with the emergence of the League of Nations where Wilsonian conceptions of self-determination now emerge, and President Woodrow Wilson presents himself as a liberal. Of course, we knew that not to be true. He was a card-carrying member of the KKK and a supporter of racial segregation at the very best in the United States. But at any

rate, Wilson comes up with this idea of self-determination and the idea that peoples who are subjected to European colonialism should have a say in how they are going. governed, right? So in comes this idea through Wilson of self-determination, and the League of Nations system is created. And the League of Nations creates these mandates, that is, a continuation, if you like, of imperial colonial rule by the European powers, in this case, Great Britain, France, Italy, and others. But under an idea that they hold a quote unquote sacred trust of civilization. And that is to say that they recognized through the League of Nations covenant under Article 22, to be precise, the provisional independence of territories that were formerly held by the Germans who are now destroyed in World War I and whose territories are now placed under mandate of the League of Nations in the hands of Great Britain, France, and others, they recognize their provisional independence, subject only to the discharge by, the mandatory powers who take over these territories of a sacred trust and that sacred trust is the

idea of almost like a white man's burden great britain is given the mandate over palestine transjordan france is given the mandate over portions of rather syria and what became lebanon and so on and under these sacred trust under this sacred trust of civilization the mandate is meant to give rise to the independence of the locals through consent of the government and one day they will be able to emerge from the yoke of colonialism, as it were. But a critical understanding of the mandate system demonstrates that this order was rooted in a rule by law, not a rule of law, so taking Palestine in particular. Palestinian self-determination that was provisionally recognized under the League was undermined

and by the League as well simultaneously, when the League incorporated into the terms of the mandate agreement for Great Britain over Palestine, the terms of the Balfour Declaration of 1917. Now, that's a key moment in this period, the Balfour Declaration, of course, in 1917, where the foreign minister, the then foreign minister of the United Kingdom, promises to the Zionist movement, the Jewish Zionist movement, Europe, that's, there will be established a Jewish national home in Palestine. And obviously that would run counter to the notion of any idea of self-determination, Wilsonian self-determination for the Palestinians that were there, the natives that were there. And so we are told that, you know, there's a clash between these two things. And indeed, during the mandate period, the British couldn't control the clash between these two things. And ultimately, by virtue of British malfeasance and inability to manage the relationship between the Palestinian community,

Arab community and the Jewish Zionist community in Palestine, the settler community, they hand the matter over to the UN in 1947. And they asked the UN, well, we would like you to advise on quote unquote future government to Palestine what should be done. And so when the UN gets a hold of the problem, this is 1947 immediately after World War II, where now principles of self-determination have been incorporated into the U.N. Charter, where we are told there's even been a greater paradigm shift.

Colonialism is out. The empire is done. Now, it's a rules-based order based on human rights and ensuring the end of the scourge of war, et cetera. So you see this all written up in the UN Charter. And so despite this promise that there will be a new order, the UN takes decisions that run completely consistent with the rule of, rather rule by law order that prevail during the League of Nations mandate period. And so I try and set that out, a very long chapter on article on the partition resolution of 1947, where I looked deeply into the record and I asked what was required of the General Assembly as a matter of international law when it considered the termination of the mandate

and how to deal with future government in Palestine and what, in fact, it did, which had nothing to do with what was required of it under international law. It portitioned or reported to partition Palestine with consequences that we continue to have negative consequences that Palestinians continue to face to this day. And the takeaway there is that despite this claim that the UN and its onset in 1945,

had to the onset of a new world order. In fact, the old world order of rule by law continued just under a different guise. Yes, and you alluded there to some of the consequences, and now we've gotten into some of the substantive moments that you really look at in depth. I mean, the GA General Assembly Resolution 181 that in 1947 announces the plan of partition, and you spend a lot of time examining and studying the assumptions there and the way the decisions were taken to substantiate this point that from the very outset, the way they dealt with the question of Palestine

was so much more related to colonial sorts and imperial sorts of views. But I was very interested in some of these other moments as well. You talk about the refugee question. You look at 1967 occupation. And the 2011 era effort to seek admission of Palestine to the UN as a member state, and you go through and talk about each of these in great substantial detail. I don't know if we'll have time to go into all of the details of each of these cases, but I did want to talk a little bit about the 1948 consequences of the war and ethnic cleansing of Palestine that led to massive displacement of people as refugees. Palestinians as refugees, I myself was very surprised to learn just a few months ago when I was reading something and looking into the question that the mission of UNRWA is so different from the standards of the UN High Commission for refugees. I mean, I just assumed that because UNRWA was formed a little bit earlier before the actual establishment of the UNHCR was just sort of a matter of, you know,

historical institution was founded and, you know, I guess I should have thought, why didn't they roll it into, you know, under the administration of the UNHCR? But I was quite surprised at that time to learn that the standards were quite different and the mission was very different. And this is something you go through very substantially in talking about what you and other scholars talk about as the protection gap between, you know, the universal basis of the UNHCR and what actually UNRWA and the other mechanisms to deal with the Palestinian refugees actually involved. Perhaps you could tell us about, you know, what this gap is, what it constitutes this gap, and how and why this has never come under, you know, any serious revision.

Why wasn't it, you know, incorporated, you know, why weren't Palestinians incorporated into the UNHCR? And what are the consequences of this over time, of the differentiation? between the specific historical experience of Palestinian refugees and the general principles of international law that guide, you know, the commission on refugees. Yeah. Great question. In fact, it's one of the most more detailed questions that emerge from the research. And I think in order to understand the rationale or the first place to begin is to understand the rationale behind why the United Nations General Assembly established. UNRWA in 1948, in 1949, forgive me.

And in order to do that, one needs better to understand what the generalist, the same General Assembly did in partitioning Palestine, because they're connected, right? So very briefly, under international law, when the United Nations was seized of the question of Palestine in 1947, and the options available to it under international law were two-fold. First, independence of all of Palestine, in line with the principle of the consent of the consent of the governed. And, of course, the vast majority of the population of Palestine being indigenous Al-Sinian Arab

did not want to partition their country, and they made it clear in the United Nations, right? Or two, second, trusteeship, UN trusteeship. And notwithstanding the requirements of interneutral law very briefly put, and which I set out in some detail in the chapter on the partition, the United Nations General Assembly recommended partition. And they did so in a very inequitable way. One third of the population of the territory, being the Jewish settler population, was granted, forgive me, 56% of the total of the country. Likewise, within this purported Jewish state, as envisioned by the United Nations, there would be a minority population of Jews and a majority population of Palestinian Arabs from the start. And, of course, under the same plan of partition,

the General Assembly required both the purported Arab state and the Jewish state that would be partitioned to have democratic constitutions and rule of law and equality before the law. And so it strikes one as why would the United Nations organization create a Jewish state that would be governed ostensibly in accordance to these democratic principles from the awe but would be governed by a minority population. It didn't make any sense. Of course, the Jewish community at the time also only owned 5.6% of the land of Palestine

and, of course, granted 56% of the territory. So it ran counter the basic principles. of consent by the governor and in the debates that i've examined on our on 1947 very carefully thousands of pages of debates right the states the western states in the general assembly who were keen on partition including canada were warned by the very few in number states from the global south right uh pakistan uh india and others, certainly the Arab states, Egypt, Syria, Iraq, and so on, were warned that partition really runs counter to all principles of self-determination and the UN Charter.

And it's absurd that you should do this for the reasons I've just set out. And yet the General Assembly persist. One of the issues that was raised in the debates by these states from what we'll call the global sound was the consequences of partition, that there would be, in Palestine, a great tumult and that the Palestinians themselves would be without any protection because the British had made it clear that they would quit Palestine, that they would leave Palestine, that is including their military and their police power, would remove itself from Palestine if the parties, the Jews and Arabs, were unable to agree on partition. So the writing was on the wall, the Western states were told. the British were going to lead with their police power

the Palestinians would be left undefended the Zionists who made it clear to the United Nations through various meetings that I looked at the records on in West Jerusalem between the Jewish agency then the head of the Jewish community

the Ashut headed up by David Ben-Gri-on who became the first Prime Minister of Israel and the United Nations Special Committee of Palestine the Uzaitists were armed and prepared to use force, and I'm paraphrasing Ben-Gurion when he was asked this, to use force to impose partition or some other situation on the Arabs if they disagreed with it, right? So in all of that context, all of that, rather, is put before the states who are now considering partition,

and yet they persist. Great. Three days after partition, a civil war breaks out, and that war lasts for six months, in which 300,000, during which 300,000 Palestinians are ethnically cleansed, as was foretold. And then on the 15th or 14th of, I think it's 15th of May, the Arab states enter into Palestine to save it. Israel portrays this in its historiography as being invaded by the Arab states, to save it. And during the course of the next eight or nine, ten months of the rest of what is called the 1948 war, a further 400,000 refugees or 450,000 Palestinian refugees are ethically cleansed. So at the end of the 1948

war, the Fletchling state of Israel is created. Its territory is now covering 78% of the whole of Mandate Palestine. And the same General Assembly now has to deal with between 750,000 to 900,000 Palestinian Arab refugees from the conflict. I say the same General Assembly because it's the same individuals. the same representatives of the same countries who argued against or for partition are now dealing with the fallout of what to do. The General Assembly argues that there is a right in the Palestinian, well, members of the General Assembly argue that there is a right in the Palestinian refugees

to return to their homes, but pending their right to return. And there's a general consensus on this, by the way, between the states. But pending the right to return, there should be some aid and relief provided to them. So UNRWA is created by the General Assembly. And people ask why this unique institutional and legal framework of UNR was created instead of folding it into the UNHCR. Well, the first answer, of course, is because of what has since been called the UN's permanent responsibility for the question of Palestine

until it is resolved in all of its aspects in accordance with international law. wherever does this permanent responsibility come from, clearly from the decision-making of the General Assembly in November 1947 to partition and its fallout. So in answer to your question, Adnan, initially, in answer to your question, one of the reasons why this unique regime for the Palestinian refugees was created was because of the permanent responsibility the UN has, the unique responsibility the UN has for the creation of the refugee problem. But that's not the end of it. And in my church, chapter, I explained this protection gap that exists between UNHCR, the High Commissioner for Refugees, which was also created by the United Nations General Assembly in 1950, to provide

protection and assistance for refugees. Initially in Europe, it wasn't actually a universal organization with universal coverage in 1950. That only happened in 1967 with the adoption of an additional protocol to the 1951 convention relating to the status of refugees. But UNHCR to deal with refugee problems emerging from World War II and the European continent and UNRWA to deal with the problem of the Palestine refugees. And it's interesting because initially the creation of these two refugee regimes is consistent with the international practice on refugees. That is to say, where there were problems that arose, dealing with displaced persons,

ad hoc bodies would be created by the international community. So UNHCR for European refugees, UNR for Palestinians. But as UNHCR over time becomes universal in its scope of application geographically, right, over all of the world. And covering all of the refugees, UNRWA remains very limited and focused on Palestinian refugees. And when I delve into the record, I find, and I learned this when I was an UNRWA official, In fact, the United Nations created UNRWA not to ensure their right to return, to provide them, on the one hand, with aid and assistance, handing their realization of their rights under Resolution 194 to return and to receive compensation and so on. But if you dig a bit deeper, you realize that the programming of the agency was designed, in fact, to resettle the Palestinian refugees where they were. were. That is, in the Arab states where they took refuge, or in the West Bank and Gaza Strip,

then under different administrations, Egypt controlled the Gaza Strip. Jordan controlled the West Bank. And we see this through the records of what was called the Economic Survey Mission, whose work created UNRWA effectively. This is why, and the idea was to put people to work. The refugees were we were pulled in this record, I'm now paraphrasing, they cannot remain idle. and if they remain idle, then they will be poor. And in fact, the ESM suggests something absurd. They create this. They invent this out of whole cloth.

They say the reason why these people find themselves in forced exile is for economic reasons, right? In fact, it's not. They're lying, and they know they're lying, and yet they do so. And the idea is that they want to put people to work so that they create roots where they are and effectively forget about their political rights, their homes, their properties from which they were ethnically cleansed only years prior. This is why UNRWA includes the term relief and works in its style, if you like, in its title. And of course, the Palestinian refugees from early on realized what this was about to resettle them and they resisted.

And so there's been this very odd dance between Palestinian refugees on the one hand over many decades, the agency on the other who's had to change is programming to accommodate the rights of the refugees, including to return for the human rights, right? Health, education, relief and social services, and so on, as well as the host states

who insist that they will never be allowed to resettle in their territories because they have rights to go back to Palestine. There's this odd dance that's taking place between these three stakeholders, if you like. And then, of course, the Western donors, as we now know, who have a great deal of power and control over UNR as well. And UNR has morphed and evolved over time. But it's created protection gaps where, and I'll end here on this question, where UNHCR has an off, has a legal

mandate to seek durable solutions for Palestinian refugees. That is solutions for their asylum in other countries or their repatriation to their original country and so on, Anra has no such authority, no such mandate given to it for durable solutions. And there was another body, UNCC, the UN Conciliation Commission for Palestine, that was given effectively a mandate for durable solutions, but they stopped working substantially, substantively, forgive me, in 1953 or thereabouts. So there is this protection gap, particularly on durable solutions embedded in the institutional legal and normative regime for Palestinian refugees. And I try and look at that in chapter four of the book.

Yeah, well, it just reminds me, as you pointed out, the name, Relief and Works. I mean, it sounds very much like one of these New Deal administrations, you know. In fact, if I might interject, you're spot on. It not only sounds like it, but the fellow who was brought in to be. the first head of UNRWA, was in fact the head of the New Deal in the United States and the Tennessee Valley River Authority. I think it is the Tennessee Valley Authority, the TVA. So they're thinking this. Yeah. Carry on. Yeah. And no, just that that's fascinating because it's that period of trying to solve these major problems through institutions and institutional development. But

the underlying assumption that they're essentially economic migrants and that they need to be economically reintegrated into the region, you know, is this kind of rule of logic that one's completely counter to the political questions. And what's interesting is that Palestinians are denied politics in all of these situations. They weren't consulted in the original partition plan. They're not being, you know, their grievances are not characterized here or their condition is not characterized as refugees as a political question. And instead, all the political kind of dimensions are, and I think you explain this very well, that, you know, in this UNCC kind of, you know, administration that then ceases to exist that's actually

tasked with finding a durable solution, it imagines the political kind of resolution as one of interstate relations between the Arab states and the new. state of Israel. And again, Palestinians are written out completely as political actors. I think that's what you mean when saying take Palestine and Palestinians seriously, is that they have to be considered political agents and not just economic refugees and, you know, actors that don't matter in, you know, a durable solution. It's just like the Abraham Accords, you know, it's like, well, we can create some kind of normalization of relations in the Middle East through bilaterally negotiated treaties for trade and commerce,

and we don't actually have to deal with the Palestinians and the Palestinian question. So it seems like that logic is, you know, very pervasive and what you mean when you talk about this taking Palestinian seriously. Quite right, quite right. You actually articulate it very, very elegant, a denial. of the politics and the agency of the Palestinian people, and it runs like a theme throughout. Yeah. Well, I mean, to look at it, you know, at another component, I think the other episode that I think I'd be really interested to talk more with you about your analysis of it in this continuing

structuring of legal, international legal subalternity of the Palestinians is the, you know, consequences of the 1967 war and Israel's occupation by conquest of territories, the Gaza, Gaza Strip, West Bank, East Jerusalem, Golan Heights. And I was very surprised, you know, I mean, I think of the occupation as manifestly by international law recognized as illegal and, you know, it's just a question of the fact that this is a purduring, you know, contradiction that nobody's willing to actually act as if it's illegal, even though, of course, everyone recognized. But I was very surprised in reading this, that although so many of the individual actions conducted within the occupation, like

transfer of populations and the creation of illegal, these illegal settlements, and, you know, various other individual things that are done by the occupying power have been taken up, been, you know, debated and determined whether they're legal or illegal, but that the occupation itself had never as a totality been characterized as such. I find that very interesting. I would like you to tell us what does that say about the situation and your overall thesis? And because I know this has come up as a case at the International Court of Justice about the legality of the occupation and that you are involved in providing some legal analysis on this that perhaps you can tell us about why it has taken almost 60 years

for this question to actually be posed and what do you think, you know, the possibilities of challenging the occupation on these grounds through this case are and their, you know, potential consequences. I know that these hearings have been taking place recently. Yes, absolutely. Thanks for that question. Yeah, for a lot of folks who don't do international law, they have the same reaction as you do. Many people naturally assume that occupation as such is illegal, but that isn't so under international law. So let me explain first what some of the

legal principles are, and then I'll talk to you about how they have been applied or misapplied, if you like, by the United Nations in its management of the occupied Palestinian territory. And then we'll talk about the case, if we might. So here, the focus of inquiry geographically is the occupied Palestinian territory, being the West Bank, East Jerusalem, and Gaza Strip. This is the remainder of what was intended to be the Arab state, as understood under the partition resolution, only half of the Arab state, in fact, 22% of the historical patrimony of the Palestinian people in Mandate Palestine. And since 1967, Israel has been in foreign military occupation of it, as you rightly said.

Occupation is when one state enters the territory of another or the territory under the effective control of another and quashes all armed resistance to it and establishes itself in place of the ousted sovereign as having effective control over the territory. Once effective control is established, then the occupying power has certain rights, obligations, a status as an occupying power. The occupation commences effective through this effective control. Occupation is meant to be temporary. It cannot last indefinitely. And as a result of the fact that it is meant to be temporary, an occupying power may never claim sovereignty in the territory, may never take actions to fundamentally alter the status of the territory, including through settling the territory with its own civilian nationals, or annexing the territory under law, or indeed in fact. So you see where I'm going with this. but occupation as such can be lawful it can equally be unlawful depending on how the occupation resulted how it emerged so i'll give you some examples and this goes into deep differences

in two areas of law but i won't get too too detailed with your with the discussion but if the initial use of force that gives rise to an occupation is unlawful, the occupation is unlawful. A good example, Russia's occupation of Ukraine. Russia entered Ukraine on the 25th of February, 2022, I think it was, or the 24th, and occupied portions of eastern Ukraine, and has since annexed portions of Ukraine. I think in Crimea as well, they took that in 2016, I feel it was, or maybe 2014. But at any rate, because their initial resort, to force was unlawful, violating Article 2, subsection 4 of the UN Charter, which imposes a prohibition on the use of force in international law. There are only two exceptions there where

forces used in self-defense. Russia was not acting in self-defense. Or where forces used authorized by the UN Security Council, there was no such Security Council resolution. So it was engaged in an aggression and the legal use of force, therefore the occupation is unlawful. illegal. Even an unlawful occupation, you still have IHL that applies. Humanitarian law, the law of belligerent occupation, but we won't get into that just yet. That's an illegal occupation. You might also have an occupation that results from a lawful use of force, say force is used in self-defense under Article 51 of the UN Charter. If the force used in self-defense results in the effective control of a territory by the defending state of foreign territory,

the occupation as such, not illegal. Again, this does not mean that IHL, humanitarian law, does not apply in this situation. It does. And it imposes obligations on the occupying power not to settle the territory and so on. So looking at Israel and Palestine, or Israel occupied Palestinian territory, Israel claims it entered the territory in 1967 defensively, using and exercising a right of self-defense. This is a highly disputed claim. The UN record does not establish that Israel used force in self-defense in 1967, and the Arab states argue very clearly and historically and consistently.

In fact, most of the global self does, that Israel used an aggressive action in 1967. It violated the general prohibition on the use of force. and therefore its occupation is illegal from the beginning ab initio. And yet, the UN record was not equally clear on whether or not Israel was an aggressor in 1967. See UN Security Council Resolution 242. It doesn't indicate whether Israel acted in aggression or in self-defense. So this is a debate, and the UN record is not clear.

And since 1967, the UN effectively has treated Israel's presence in the occupied territory as though it were merely a fact, as though it were lawful as well. And instead of declaring the illegality of Israel's presence in the territory, instead reams of documents, thousands and thousands and thousands of pages of investigation, reported to the General Assembly, reported to the Security Council, reported to the Human Rights Council, Well, basically, the UN has spent a great deal of time over many decades, now 57 years, documenting Israel's violations of the laws of war as an occupying power, IHL. So documenting the consequences of Israel's commission of great breaches of IHL,

the torture of Palestinian prisoners, the detention of Palestinians, the destruction of their wounds, the deportation of Palestinian protected persons, the settlement by Israel the occupied Palestinian territory the annexation of that territory and so on so it has thrown a great deal of law into how and recorded

how Israel has managed its occupation. This law has been human rights law. This law has been international humanitarian law. And so there's been a great deal of law thrown at it, but there's been a great omission and that omission has been the refusal or

the fact of the United Nations has yet to pronounce on the legality of Israel's very presence in the occupied Palestinian territory. So you give rise to these absurd questions where a lot of laws thrown at the occupied Palestinian territory, but this is what I call a managerial or humanitarian approach to the question. Why? Because let's look at the law of state responsibility.

If Israel corrects its ways under international humanitarian law and stops settling the territory and stops torturing Palestinians and stops all of its discrete violations of this international humanitarian law or this internationally human rights law, none of that means the occupation ends. It only means that the occupation will continue but just be managed in line with Israel's obligations under international humanitarian law as an occupying power. However, if the occupation is in and of itself unlawful, existentially, unlawful, then as an internationally wrongful act, it must be brought to an end immediately. Again, I'm applying the law on state responsibility here. I know I'm getting technical.

So there's a huge gap by omission, which I point out in chapter five of the book, I set out the reasons why the occupation is unlawful, and I build on the UN record. So the occupation is unlawful for three reasons. One, it's a manifestation or an expression of an attempt by Israel to annex the territory in whole or in part. And this violates a norm against territorial conquest in international law. Second, it violates the Palestinian people's right to self-determination. Third, it imposes on the Palestinian people, at least in the occupied Palestinian territory, a regime of racial discrimination that may also amount to the crime of apartheid. Now, the uniqueness of these

three violations, if you like, are that they are peremptory norms, derogation from which is not permitted. So peremptory norm under international law is a norm of law that is hierarchically superior to all other international legal norms. Hierarchically superior because these norms are respect for these principles, these norms, is so fundamental to the maintenance of international peace and security that they admit of no derogation under any circumstance, no exceptions to these, right? So, if Israel's very presence in the territory over 57 years, a situation that is meant to be temporary but has lasted over a half century, violates, and openly so, based on the UN record and Israel practice, Israeli practice, these three peremptory norms, derogation from which is not permitted, I ask a simple question, how can it be that the regime giving rise to the violation of these norms, the regime that is existentially reliant on the violation, of these norms. How can that regime itself be lawful? I say it's illegal and unlawful. As a result of this research, among some of the research of a few other scholars,

I've been advising the state of Palestine for some years to take a case to the International Court of Justice. And thankfully, in December of 2022, long before the current plausible genocide to use the term used by the ICJ and the South Africa case kicked off post-September October, post 7th of October, forgive me, the General Assembly passed a resolution in 30 December 2022, the resolution being 247 forward slash, sorry, 77 forward slash 247, in which the General Assembly asks the ICJ for an advisory opinion on, on, certain series of questions, the nub of which is whether or not Israel's occupation is lawful. And hearings took place in that case. We submitted our legal counseled in the state

of Palestine, so we submitted our written filings last year. And hearings took place in that case before the ICJ three weeks ago or thereabouts in mid-February, late February. And now we're waiting to hear what the court has to say. More than any other case before the International Court of Justice, this case has had engagement in, that is to say, 57 states, maybe about 60 states engaged or international organizations engaged in this case. This is the most highly participated in case in the history of the ICJ. And the vast majority of opinions offered before the court are supportive of the claim that Israel's continued presence in the occupied Palestinian territories unlawful. There are a few states who disagree with that, but don't really argue on the merits. They just simply say the court shouldn't seize jurisdiction.

At the United States, the United Kingdom, even Israel, they submitted in writing, but they didn't appear orally, the Israelis. So the other detractor states aren't really coming with a very strong case in dealing with the merits. And the vast majority of states, as I say, agree that Israel's occupation is unlawful. And if it is determined by the court that it is unlawful, then that has political consequences and legal consequences. But for the purposes of this book, right, taking it away from the practice, the law practice and its consequences, is that this is an attempt in my view of the global subaltern class as represented through Palestine to use international law counter-hegemonically to basically mitigate its negative position in the international legal order. And in real terms, if the court determines that the occupation is unlawful, what that means is that third states like Canada, the United States, and others will not be able to do anything to aid or assist in the amendments of Israel's continued presence in the occupied territory. Nor will they be able to insist that the only way to end the occupation is for Palestine to negotiate its end with the occupying power.

That makes sense because under the law of state responsibility, states when they engage in an internationally wrongful act, as I said earlier, have to end that act, forthwith and unconditionally. So you'll see the importance of removing what I call this negotiations condition off the table politically if the occupation is deemed to be unlawful. Well, this is very interesting. This is where I wanted to go in the conclusion of our discussion is to bring it to the consequences in the contemporary kind of struggle for the

liberation of Palestine and the implications of your analysis here. I mean, I've gotten the sense that extending, you know, and this is, you know, sort of the thesis of your book is that there's this huge gap between the actual universal application of international law and what ends up happening rule by law. But this deferral, this kind of promise that there will be, you know, a kind of resolution on the basis of these principles in law that, you know, end up being deferred and delayed and so on, is that, you know, the pressure to actually extend international law universally to apply to Palestine and Palestinians, you know, opens up this huge political gap that you've been talking about in your book, but that we're seeing today with, for example,

the South Africa case, you know, where Canada, you know, for example, just announced without any sense of the merits, just dismissed as that they don't agree with the presumptions, as if presumptions are the issue. I mean, what presumption is it that they don't, you know, recognize in the South African case about violations under the, you know, genocide conventions? Is it just that you can, cannot have, you know, Palestinians and or, you know, groups from the global South, you know, actually demanding. I mean, is that the presumption that they don't, you know, really seem to recognize that, you know, actors from the global South can, you know, put forward these cases? Because what it seems to do is it puts the whole regime in some ways of international law in jeopardy. I mean, it's such a contradiction right now, you know, for states that claim to be a,

upholding international law to be ignoring or trying to somehow dismiss the very clear, you know, provisional measures and judgments that were made by the International Court of Justice. So, and I see this happening in other realms and regimes where you see the actual attempt to apply, say, for even domestically political rights of protest. When it's for pro-Palestine, you know, protest, suddenly we have this problem, you know, emerging politically like here in the UK where I happen to be right now, you know, where new police measures are being, you know, developed. The prime minister announces that, well, you know, we've got to do something about the extremism of these and using coded Islamophobic kind of languages about violence and extremism to describe peaceful democratic protests of diverse populations, you know, most of. of whom are not, you know, Muslim or Palestinian or Arab, but, you know, the specter of challenging and actually demanding that these rights be applied to this case tends to undermine, you know, the integrity of the regime and undermine, you know, these rights. And that seems to me

a real question is whether and how, you know, the international law and these institutions can be used for hegemonic purposes to overturn the subalterity of, you know, Palestinians and others who are, you know, international legal subalterns in the way that you describe it. And so my question here is, you know, really about how do you respond going forward? Do you think it can be, you know, counter-hegemonic? I know that there are debates and discussions among international law scholars, some of whom, you know, you talk about.

the third world approaches to international law, this kind of school that sees it needing to be reformed, but that there can be counter-hegemonic use, but that the whole history that you're talking about also kind of demonstrates, you know, to your minds that, you know, that's been ruled, you know, by law rather than of law. And the question is, is whether the UN and whether, you know, these institutions and the ICJ can be converted, really, to a count. counter-hegemonic kind of purpose. So what kinds of conclusions do you have from your study and then from watching how it's being deployed in the case you're involved in in the South Africa case, you know, the prospects for

actually using it counter-hegemonically effectively? Great commentary and great questions. I take the first question, which is the impact, if you like, of the South African matter and where we are today, I think we're in an inflection point that is events since 7 October and the plausible genocide taking place in Gaza, again, to use the terms used by the ICJ, have pointed up a huge divide, pointed up the fact of a huge divide that exists between the global south and the global north, between those states that are settler colonial and And if you like, the remnants of or connected to the old European imperial powers and the rest of the world, the vast majority of the world in terms of population and numbers of countries and so on.

There's a huge divide because the South Africans have basically told us through their case against Israel, but they've told the, they've laid down a claim effectively to the international law. based legal order to the UN and to the ICJ, look, international law is only as good as your ability to apply it universally. Here's an opportunity for you to do so. The facts overwhelming. The case extremely strong. We're basing it all on the jurisprudence of the court elsewhere in its application of the genocide convention in the European context, right? All we request is that you apply the same principles to what is happening in occupied Palestine that you've applied in other context and come out with a reason to result. You see the responses of Western states, one of which you spoke in Canada's response

and disagreeing with the plot, what was it, what was the word that they used? The premise. The premises, yes. Premises, the premise of the case. what does that mean, as you say? And so it's put the Western states in a difficult situation. For instance, in a case concerning Myanmar, and Myanmar's alleged violation of the genocide convention vis-à-vis the Rohingya, Canada, Germany, the Netherlands, Denmark, France, and perhaps Belgium, I can't recall, they put in an opinion before the court in that case, arguing that the genocide convention needs to be given a very liberal interpretation, a very progressive interpretation to ensure that genocide does not take place against the Rohingya, and that Myanmar officials are held to account and so on.

A very broad, expansive one in line with their view of the propulsive nature of the genocide convention, which is to stop genocide, right? It's human rights based and all that sort of stuff. they submitted this document just weeks before the South Africans commenced hearings against Israel under the Genocide Convention using the same law. And now, oddly, the same states who submitted this very propulsive, liberal position in the genocide matter concerning the Rohingya are arguing completely opposite position. And of course it points up the double standard. So we are at, and this is just an example, we are at an inflection point.

This case has given rise to an inflection point. Perhaps even a paradigm shift, I'm not entirely sure it will result in one, but a point where those Western sponsors, we are told, of the rules-based international legal order post-World War II, have to seriously or take seriously the claims of the global south, and Palestine is at its center. And if they fail to do so, the consequences of that will go deep because it will demonstrate that we don't have a rules-based international legal order,

and it isn't based in the rule of law. Rather, it's based in the rule by law, that is, the use and abuse of law by hegemonic powers to further a political position that privileges them and their allies over everyone else. That's not law. That's something else. It's just not law, right? So the inflection point. On Twail, there is a debate within the Twale network of scholars. I was just having this debate two days ago at a book talk that I gave with a few other Twilers, who were kind enough to engage with me on my intellectual offerings in this book. And there's a disagreement.

Some of them think there's no such thing as rule of law. They argue, in fact, it's all rule by law. And that law is implicated in empire and violence. from the off, and that it is almost fault to engage with it in thinking that you can somehow end the predicament of the subaltern through the use of law, the countergemonic use of law. I take a slightly more nuance to be. Of course, I'm not giving them their due. I'm trying to be curt with how I summarize the position. But that position speaks to the point that you raised in your question, Adnan. Is there any use to this law, right?

I mean, why even engage in it, right? I take the view that, and this, I borrow here from Professor Marty Koskenyemi, not a tweler, but a critical legal scholar in Finland. He argues that international law has rooted within it two key things that are in tensioned with one another. The first thing is that law is an apology for power. It's created by states, powerful, and for purpose, in line with their interests, dictated by politics, and therefore the law will serve and will be an apology for the power that

creates it. On the other hand, once it's created, we're told that the law is strictly normative and binds all under its rubric, regardless, as I said earlier at the beginning of our conversation of the position or station of these actors on the system. And therefore, as a normative force, it pretends something else it holds out the prospect of a utopia a better society a society that does operate on the basis of rule of law and these things are in tension with one another law as apology for power law as a plea for a utopia i tend to take that as a fixed feature of the order so i do believe in the international principle of the international rule of law and we can see it manifest itself in various ways in a positive way, right? Sometimes it doesn't manifest itself.

Sometimes it does manifest itself. Take, for instance, staying with Palestine, the recognition of Palestinians as a juridical people. This was done in the 1970s by the General Assembly. Of course, it was based on previous positions, legal positions, going as far back as the League of Nations. And of course, it says nothing, that says nothing of the fact that Palestinians themselves have regarded themselves as people and with agency for a very long time, and long before even the League of Nations. But in the 1970s, when the General Assembly recognizes the Palestinian people as a juridical people, that implies, therefore, that they have a right to self-determination, and then that builds on. If they have a right to self-determination as acknowledged by the General

Assembly, then surely they have a place to do it in the occupied Palestinian territory. If the occupied Palestinian territory is occupied, surely the occupying power cannot, as a matter of law, be sovereign in that territory. That is indeed true. So you see these legal propositions over time, resulting in positive gains made by the Palestinians, and yet liberation is still on the horizon and possibly continually moving. I do believe that there is a rule of law. I believe that we can get to it through the counter-hagmonic use of law. I just believe that we can't expect the law to operate in our benefit without our human engagement with it. And that means finding the entry points, first of all, understanding law as political, as sometimes a tool that has been used to bludgeon, but also as a tool they can be used to push back, finding those creative entry points to push back, and making it happen.

And that's the counter-hegemonic potential of law. it will not liberate overnight but hopefully through the use of it over time there will be enough of a political move

and a legal move to push the sort of domino down such that there will be freedom for people one day and we see this in changes in history and moments the end of the Berlin Wall

the ostensible end of the apartheid regime in South Africa I know there are situations in South Africa is nowhere near as was initially envisioned today, but there is no longer anti-apartheid and official apartheid and so on.

The differences between slavery and the first 200 years of the American abuse of Africans, etc. And what took place after civil war and what took place after the Civil Rights Movement, it's still not perfect. But all of it is a drive towards

the rule of law and a situation of justice through the counter-hegemonic use of law against power. And you can see the trajectory is a slow move towards a better and just society. And that's where I situate myself within the Twale Pantheon. And that's how I see the move with South Africans and the Palestinian move in this advisory opinion as part of. None of these things are going to liberate Palestine.

But collectively, hopefully they'll make a change. Well, on that very positive note, and I very much like the idea since I agree, I don't think law by itself, you know, is going to liberate anyone, but that it does mark the vision of equality. You know, that's the promise of the law. And so that's something that certainly is a tool around which to organize our popular support for Palestine and what we envision, you know, is actually rule of law. So listeners, I really encourage you If you can, check out this book and follow Dr. R.D. M. Sase's work.

Perhaps you can tell our listeners how they can follow you and follow your work and find out more about your very important and relevant scholarship. Sure. Look, I'm not much of a social media fellow. I do have a Twitter handle. RDMsase is the handle, one word. but yeah you can get access to my work in most any library and you can go on the queen's website my web page at the queen's faculty of law will have access to all of my work the book itself can be purchased at the cambridge university press website there is a discount code you're welcome to use it for 20% off it's msace my last name i ms e i am s 21st 23 just after the name one construct. That'll get you 20% off the book. And yeah, happy to engage with any of your

listeners. If you have any questions, just email me. My email address is at Queens University website. And if you look me up, you'll find it there. Thank you so much. I feel like we could have continued. This is a fascinating and wonderful conversation. The book is so full of thorough research and amazing insights. And, you know, I even neglected dimensions. about, you know, just as a remark that, you know, your characterization, for example, of UNRWA, you would think now today, given the way, you know, the Israeli government has characterized UNRWA, which led to suspension of its funding by U.S., Britain, Canada, many other countries during the period when it was the only effective, you know, way to distribute aid for, you know, the population. in Gaza during this horrific medieval siege and blockade of them being denied, you know, the means of life, you know, you would think that UNRWA was, you know, founded to be this, you know, Palestinian advocacy movement and to actually see and understand, you know, that's legal subalternity

and the presumptions behind it. There's just so, the book is full of so many of these kinds of, you know, insights based on, you know, evident. and analysis in the history of the UN's involvement with the question of Palestine that I recommended to all listeners. I have learned so much from it and have enjoyed so much this conversation. You know, maybe someday we might have you on again, at least for the Mudgellis, and talk a little bit about things like, you know, why the two-state crystallization, what the consequences of that early, you know, resolution about partition, how it has, you know, patterned, and participated in this story.

We didn't get into, you know, the details of that versus a kind of more democratic one-state solution that seems like that would be more in accord with international law, or that would be my question. But that's for another conversation that I hope we'll get a chance to have someday, Ardy, but I just want to thank you so much for the work that you're doing, for taking the time from your busy schedule, because you're discussing these issues on many fronts, on many platforms to come and speak with me so that our listeners could have the opportunity to hear you discuss in some detail, you know, the theses of your book and what you found. So again,

thank you so much for joining us today. Thank you very much for having you, Adnan. All the best to you. Well, my co-host, Henry, wasn't able to join us today, but you can follow him on Twitter at Huck 1995. And you can follow me at Adnan A. Hussein on Twitter. Be sure to subscribe to Gorilla History and the Mudge List wherever you get your pods and you can help support Gorilla History by joining our patreon.com slash Gorilla History and follow the show on Twitter at Gorilla underscore Pod. Until next time, listeners, Solidarity and Masalam. I'm going to be able to be. Thank you.