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By Ido Rosenzweig and Yuval Shany

Introduction

Israeli Supreme Court Publishes Reasons for Not Disqualifying Parties from 2009 Elections
On March 7, 2011, the Israeli Supreme Court published the reasoning behind its 2009 decision to accept the appeal of two Israeli-Arab political parties accused of condoning terrorism - Balad (The National Democratic Assembly) and Raam-Taal (The Arab Movement for Change) - and to reject the disqualification of these parties from participating in the 2009 general elections for Parliament. [1] The Court held 8-1 that the evidence presented before it was insufficient to prevent a party from running in elections. One dissenting judge, however, held that the appeal of the Balad party should have been rejected and should therefore have been disqualified from running in the 2009 elections.

Background

On January 12, 2009, the Central Elections Committee for the Eighteenth Knesset (hereinafter: "the Elections Committee") conducted a hearing on a motion to disqualify two Israeli Arab parties—Balad and Raam-Taal—from running in the 2009 Knesset elections.
The grounds for the disqualification of Balad were twofold and met two of the three conditions stipulated in Article 7A of the Basic Law: The Knesset (1985).  According to this law, parties can be disqualified from running for Knesset if their goals or actions (1) negate the existence of the State of Israel as a Jewish and democratic state and (2) support armed struggle by a hostile state or a terrorist organization against the State of Israel. [2]

The evidence that was presented to the Committee regarding the motion to disqualify Balad on because of its alleged support for armed struggle by a hostile state or a terrorist organization against the State of Israel—consisted of quotes from articles and websites made by the Balad leadership, the party leaders' attendance of events related to the Palestinian terror organization "Popular Front for the Liberation of Palestine" (PFLP), and alleged meetings with hostile elements (such as Syrian political leaders).

Regarding the Raam-Taal party, it was submitted that the head of the party, MK Ahmed Tibi, took a connecting flight through Lebanon (an enemy state) and met with Arab leaders (the Syrian President, the President of Lebanon, and the leader of Qatar). It was also alleged that another Raam-Taal leader, MK Talab El-Sana, gave a speech at a university in Jenin, in which he called for armed conflict.
Both Balad and Raam-Taal opposed the motion for disqualification that was brought before the Elections Committee. They claimed that their actions were legal and fell within the limits of freedom of speech in a democratic regime. The Attorney General supported the position of the two parties and took the position that the evidence presented against them did not merit disqualification from the elections according to past rulings of the Supreme Court. 

On January 12, 2009, the Elections Committee, a political body that is mostly composed of representatives of different political parties, disqualified both parties from running in the upcoming elections. This decision was challenged before the Supreme Court, which overturned the Committee's decision on January 21, 2009.   On March 7, 2011, the Supreme Court published the reasoning behind its 2009 decision.

The Decision

Justice Dorit Beinisch, the President of the Supreme Court, wrote the majority opinion for the Court. The decision opened with an overview of past Supreme Court rulings on the disqualification of political parties on the grounds of the principle of "Defensive Democracy," which allows democracies to place limits on the right of free speech and on the right to elect and be elected, in order to ensure the existence of the state and its democratic nature. [3] Justice Beinisch also referred to Article 7A of the Basic Law: The Knesset, which reflects this principle.

Justice Beinisch first outlined the normative framework for disqualification of parties and commented that the balance between the right to be elected and the security needs of the State struck in Article 7A of the Basic Law: The Knesset must be applied in accordance with the developments in Israel. In her opinion, the situation in Israel in 2009 was very different from the situation in 1965, when the "Defensive Democracy" principle was introduced by the Supreme Court, since at that point, Israel was still a young State fighting for its existence. [4] Justice Beinisch noted that  the  Supreme Court repeatedly held that "Defensive Democracy" is an extreme measure that should only be used under very narrow circumstances, and even then, on the basis of very strict  legal and factual grounds. In order to determine that a party's goals or activities are faulty to an extent that would justify barring it from running in Knesset elections, the Elections Committee and the Court must be convinced that a threat to democracy arises from dominant elements that serve as the party's foundations, rather than on esoteric features that have no effect on the party's main ideology. Secondly, these dominant disqualifying goals must be clearly deduced from the Party's statements and activities. Thirdly, the goals must be practical and the party must act in an attempt to implement them. In addition, such actions must not be sporadic but rather repetitive in nature. Lastly, the evidence presented in favor of the disqualification of the party must be persuasive, clear, and unambiguous.

The three conditions identified by Beinisch apply equally to cases involving alleged challenges to the Jewish and democratic identity of the states and to cases involving allegations of support for the armed struggle against the State of Israel.

With regard to the conduct of the hearings before the Elections Committee, Justice Beinisch held that despite the grave allegations leveled against the two parties, the Committee failed to conduct a serious and thorough discussion of the evidence presented and did not consider the relevant standards that had been stipulated by the Supreme Court. She further noted that the evidence submitted to the Committee was not clear and compelling.  (Beinish embraced the opinion of the Attorney General that the evidence presented to the Committee was even weaker than the evidence presented in a previous case in 2002, which the Court also deemed insufficient to warrant disqualification.) Nevertheless, Justice Beinisch noted that some of the evidence about Balad that had been submitted raised concerns and could serve as the basis of a claim that the party supports the armed struggle, were it to be supported by additional evidence. (The evidence demonstrated that Balad did have some connections to the Popular Front for the Liberation of Palestine and that some Balad members had participated in a memorial ceremony for the former PFLP leader George Habash.)

Thus, Justice Beinisch held that the concrete evidence that had been presented was not sufficient to cross the strict threshold needed to disqualify Balad and Raam-Taal.

Justice Edmond Eliyahu Levy, who wrote a dissenting opinion, held that although the right to be elected is one of the most important rights in the democratic regime, this right is not absolute and the democratic state is allowed to protect itself from those who wish to use the democratic process in order to destroy it. This delicate balance is expressed in Article 7A of the Basic Law: The Knesset. According to Justice Levy, the evidence presented with regard to Balad did not leave any room for doubt that this is a case in which exceptional circumstances of this nature come into play. In particular, he noted that there had been some significant changes since the Court had rejected a previous disqualification of Balad in 2002, especially the fact that allegations of active support of terrorism were raised against MK Azmi Bishara—the leader of Balad—who had fled Israel in the meantime.

Analysis and Conclusions

This case demonstrates one of the most important paradoxes in a democracy: Are undemocratic measures justified in order to curb a threat to the democratic regime? Arguably, the stronger a democracy is, the more tolerant the political system can and should be.  Furthermore, it is often alleged that a broad and diverse system of representation may serve as a disincentive to those seeking to change the regime.

While the Supreme Court has accepted the "Defensive Democracy" theory reflected in Article 7A of the Basic Law in principle, it has consistently set a high evidentiary threshold in cases of disqualification of political parties. This may come as a reaction to the abuse of the disqualification process by the Knesset Elections Committee, which sometimes uses it to settle political accounts. It may also reflect the Court's assessment that despite the legislature's inclination to create more grounds for disqualification, Israeli democracy has reached a level of maturity in which such measures are largely redundant, and perhaps counterproductive.  

Notes

  1. EA [Elections Appeal] 561/09 Balad and Raam-Taal v. Central Elections Committee for the Eighteenth Knesset <Hebrew>

  2. Basic Law: The Knesset (unofficial translation from the website of the Ministry of Foreign Affairs).

  3. EA 1/65 Yardor v. Chairman of the Central Elections Committee for the Sixth Knesset [1965].

  4. For more on this issue, see the "Disqualification of Lists" position paper by Prof. Mordechai Kremnitzer and the Venice Commission'sGuidelines on Prohibition and Dissolution of Political  Parties and Analogous Measures (2000) and Opinion On the Constitutional and Legal Provisions relevant to the Prohibition of Political Parties in Turkey (2009)