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by Ido Rosenzweig and Yuval Shany

Introduction

Last month, the Divisional Court of the High Court of Justice of England and Wales rejected Al-Haq's application for permission to seek judicial review of the UK's government failure to respond to alleged breaches of international law by Israel in the occupied Palestinian territories during "Operation Cast Lead." The Court rejected the claim on the grounds of both justiciability and standing.

As part of our coverage of terrorism and democracy issues that are related to actions taken by Israel, we present a summary and a short discussion of the decision.

Background

On 3 February 2009, as a result of Israel's actions during "Operation Cast Lead",[1]  Al-Haq, an independent, Palestinian, human rights NGO,[2] submitted a pre-action protocol letter requesting judicial review.[3] Al-Haq called upon the relevant UK Secretaries of State to explicitly present the evidence that the UK Government has of the actions it took to comply with its legal obligations, both before and after “Operation Cast Lead”.

The UK Government responded to the letter on 20 February 2009,[4] claiming that the UK is not obligated to provide a detailed description of its compliance with its obligations under international law and, moreover, that Al-Haq does not have the standing to make such demands. It went on to explain that the issue raised in the letter relates to UK foreign policy, which is unsuitable for resolution in legal proceedings before UK courts.

Consequently, on 24 February 2009, the Al –Haq organization filed a claim for judicial review in the Administrative Court of the High Court of Justice of England and Wales against the Secretary of State for Foreign and Commonwealth Affairs, the Secretary of State for Defence, and the Secretary of State for Business, Enterprise, and Regulatory Reform.[5]

According to the claimant, Israel violated its obligation under international law, and especially under humanitarian law (IHL), during "Operation Cast Lead." These violations include the bombardment of civilians; the destruction of civilian buildings, including UNRWA and UN facilities, mosques, and health centers;  the intensive use of white phosphorus (which runs contrary to the 1980 Convention on Certain Conventional Weapons ); wanton destruction of civilian, cultural, and governmental infrastructure; and denial of the Palestinian people's right to self-determination.

Al-Haq requested that the UK Government publicly denounce Israel's actions in "Operation Cast Lead"; suspend all SIEL[6] approval to Israel; suspend all direct financial or ministerial assistance to UK companies that export military technological goods to Israel; request that the EU suspend the EU-Israel Association Agreement; seek out and suspend any other financial or military assistance given by the UK Government to Israel; and summon a Conference of the Parties to the Geneva Conventions to address Israel's grave breaches thereof.

Other steps suggested by the claimant include the exercise of universal jurisdiction to prosecute or extradite any Israelis involved in serious breaches of the Geneva Convention; the application of significant diplomatic pressure on Israel; the introduction of measures before the UN Security Council under Chapter VII of the UN Charter; and other lawful sanctions.

The Decision

In their decision,[7] Lord Justice Pill and Justice Cranston rejected the claim on the grounds of both standing and justiciability.

With regard to the question of justiciability, it was held that the decision of whether or not a claim is justiciable is based on the subject matter and suitability of the particular claim. According to Lord Justice Pill, at the heart of the subject matter of the case at hand is Israel’s conduct and whether Israel breached its international obligations. However, the UK Courts are not qualified to make this decision.  Unlike other cases in which the breach of international law was plain and widely acknowledged,[8] in this case, there is no legal precedent on the legality of “Operation Cast Lead”.

Moreover, like other cases dismissed by the courts,[9] the case deals with  policy areas that are unsuitable for judicial decision making – decisions affecting foreign policy. The object of the claim is to compel a change in government foreign policy, and the court is not allowed to dictate or direct the actions the government should take in response to the alleged breaches of international law by Israel.

Lord Justice Pill further stated that under UK constitutional law, the conduct of foreign affairs is exclusively within the sphere of the executive branch. While there may be situations in which the court will intervene in foreign policy issues, this case is not one of them. The nature of the underlying claim (the condemnation of Israel), and the nature of the claim against the UK government (directing or dictating its foreign policy) are issues that the court is not prepared to handle.

Justice Cranston added that this claim trespasses the issue of high policy, which is under the authority of the qualified executive chamber and not the excessively slow judicial system. High policy matters that are reviewed by the courts have some kind of domestic foothold, such as legislative authorization, which ensures fair trial for cases of the most blatant breach of international norms.

In order to proceed with this claim, it would be necessary to define Israel's obligations, and identify and prove its breaches of these obligations, while examining and exploring any justification that Israel might have for its actions, such as proportionality. This would confront the court with what seems to be the most complicated issues of law and fact, which are probably the most controversial disputes in international affairs today.

With regard to the question of standing, Lord Justice Pill said that standing should not be treated as a preliminary issue; in previous cases, the court has linked the granting of standing to the issue of exercise of jurisdiction[10] and, therefore, the claim to standing must be considered in the legal and factual context in which the claim arises. In this particular case, no right can arguably be claimed, and the claimants should not be granted standing to allow it to make the claim.

Justice Cranston also added that in this regard, Al-Haq is an internationally recognized human rights NGO and, therefore, according to the court's liberal standing test, as long as there are wrongs to be righted, standing will be allowed. However, the issue of standing has to be approached on the premises that there is a justiciable issue. Since the matter was found to be non-justiciable, the claimant could not be granted the standing required to take action.

Conclusions

This case presents another possible obstacle to Israel's counter-terrorism efforts:  judicial scrutiny over timid foreign responses to excessive measures allegedly taken by Israel. The move by Al-Haq to try to compel the UK Government to take action with regard to Israel's conduct represents an interesting development of the principle of universality, and underscores the erga omnes nature of counter-terrorism law.

Still, UK Courts are apparently not yet prepared to move in the direction proposed by Al-Haq. Such reluctance is related both to the Court's unwillingness to disrupt the constitutional equilibrium between the branches of government in the United Kingdom and the Court's apprehension to analyze a complicated situation over which UK Courts cannot properly exercise jurisdiction.

However, it seems that the court does not close the door completely on the possibility of bringing such claims in the future, and suggests that standing may be granted in cases with less controversial facts that clearly reveal egregious breaches of international law by third parties. In such cases, the court will have to deal with the claims on its merits, and address the issue of the constitutional equilibrium between the UK branches of government.

Notes

[1] “Operation Case Lead” is the name given by Israel to the armed conflict between the Israeli Defense Forces and Hamas, which took place between 27 December 2008 and 17 January 2009.

[2] See Al-Haq's website: www.alhaq.org

[3] www.alhaq.org/pdfs/pre-action%20protocol%20letter%20to%20david%20miliband,%203%20february%202009.pdf

[4] www.alhaq.org/pdfs/response%20from%20secretaries%20of%20state%2020%20february%202009.pdf

[5] www.alhaq.org/pdfs/claim%2024%20feb%202009%20-%20al-haq%20v%20uk%20grounds%20for%20judicial%20review.pdf

[6] Standard Individual Export Licenses

[7] www.alhaq.org/pdfs/Al-Haq%20v%20UK%20Judgment.pdf

[8] Kuwait Airways Corp. v Iraqi Airways Co. (nos. 4 and 5) [2002] UKHL 19 [2002] 2 AC 883; R (Abbasi) v Secretary of State for Foreign and Commonwealth Affairs [2003] 3 LRC 297

[9] R (Abbasi) v Secretary of State for Foreign and Commonwealth Affairs [2003] 3 LRC 297

[10] R (CND) v. Prime Minister [2002] EWHC 2777 (Admin) 2003 3 LRC 335.