Tuesday, December 8, 2015

The Question of the Applicability of the Fourth Geneva Convention on Liberation Occupation to Judea, Samaria and Gaza, Howard Grief - Draiman



The Question of the Applicability of the Fourth Geneva Convention on Liberation Occupation to Judea, Samaria and Gaza

Howard Grief, Attorney

The legal question of the applicability of the Fourth Geneva Convention of 1949 to Judea, Samaria and Gaza has been the source of great argument ever since the Israel Defense Forces restored them to the possession of the Jewish People and the State of Israel in the Six-Day War. Some analysts who have approached this question have relied only on Article 2 of the Convention to determine if it applies to these territories, when the actual answer is to be found by combining Article 2 with Article 6 of the Convention.

The relevant paragraphs of Article 2 read as follows:

In addition to the provisions which shall be implemented in peacetime, the present Convention shall apply to all cases of declared war or of any other armed conflict which may arise between two or more of the High Contracting Parties, even if the state of war is not recognized by one of them.
The Convention shall also apply to all cases of partial or total occupation of the territory of a High Contracting Party, even if the said occupation meets with no armed resistance (emphasis added).
The relevant paragraphs of Article 6 state:

The present Convention shall apply from the outset of any conflict or occupation mentioned in Article 2.
In the territory of Parties to the conflict, the application of the present Convention shall cease on the general close of military operations. In the case of occupied territory, the application of the present Convention shall cease one year after the general close of military operations; however, the Occupying Power shall be bound, for the duration of the occupation, to the extent that such Power exercises the functions of government in such territory, by the provisions of the following Articles of the present Convention: 1-12, 27, 29 to 34, 47, 49, 51, 52, 53, 59, 61 to 77, 143. (emphasis added).

In light of the fact that Article 2(1) of the Convention applies to all cases of declared war or armed conflict between two or more of the High Contracting Parties and that the states engaged in the Six-Day War were and remain parties to the Convention, there can be no doubt that at the outset of the war on June 5, 1967 until its conclusion on June 10, 1967, all the provisions of the Convention applied to each of the combatant states of Israel, Egypt, Jordan and Syria and to the territories that Israel brought under its military control as a result of the war, regardless of their legal status or sovereignty at the time and regardless of whether or not they were to be considered “occupied territories” under international law. During the war, the 2 Convention also applied regardless of the formalistic question of whether it represented treaty law that required incorporation into the domestic law or customary law that did not require such incorporation. The discussion here will be limited to the applicability of the Fourth Geneva Convention to Judea, Samaria and Gaza after June 10, 1967 when the state of active war or hostilities between Israel and the combatant Arab states terminated, even without a peace treaty.

To begin with, it is important to note that the “military operations” referred to in Article 6 of the Convention ceased altogether on June 10, 1967, in accordance with three UN Security Council resolutions passed during the Six-Day War demanding an immediate cease-fire.1 This call for a cease-fire was accepted by Israel and Syria between whom active fighting was still raging on the Golan Heights. The state of war may have technically continued to exist between Israel and Syria (as well as Egypt and Jordan), but there were definitely no further military operations between them, within the meaning of Article 6 of the Convention.

Article 6 distinguishes between two kinds of territory: 1) the territory of the parties to the conflict, and 2) occupied territory. In the case of the former, the application of the Fourth Geneva Convention ceases “on the general close of military operations”. But in the case of the latter - “occupied territory” – the Convention continues to apply until one year after the close of military operations and even beyond that date if the Occupying Power exercises the functions of government in such territory.

Inasmuch as the Six-Day War was not fought, neither within the existing borders of the State of Israel, nor within the borders of Jordan on the east bank of the Jordan River – the only recognized borders of the country under international law, the Convention was no longer applicable to those specific areas after the cease-fire or cessation of hostilities, except for those provisions of the Convention “which shall be implemented in peacetime”. The question of the further applicability of the Convention then turns on the question of whether Judea, Samaria and Gaza were “occupied territories” belonging to the Kingdom of Jordan and/or Egypt within the meaning of both Article 6 of the Convention and Article 42 of the Hague Regulations of 1907. These regulations constitute an annex to the Fourth Hague Convention Respecting the Laws and Customs of War on Land.

Article 42 of the Hague Regulations defines territory as being occupied when the territory of the Hostile State is actually placed under the authority of a Hostile Army. It is to be noted that the text of Article 42 refers only to “territory” in a general sense, but the heading2 of Section III under which Article 42 appears – “Military Authority over Territory of the Hostile State” – makes it clear that the word “territory” can only be a reference to the “territory of the hostile state”, as is also

1 The three Security Council resolutions calling for a cessation of all military activities, all of which were adopted unanimously, were: 1) Resolution No. 233 of June 6, 1967; 2) Resolution No. 234 of June 7, 1967; 3) Resolution No. 235 of June 9, 1967.
2 In interpreting the text of a treaty or of an annex to it such as the Hague Regulations, recourse may be had according to Article 31 of the Vienna Convention on the Law of Treaties to the context to be given to the terms of the treaty and also to the treaty’s object and purpose. Based on this general rule of interpretation, the term “territory” as used in Article 42 of the Hague Regulations can only refer to the “territory of the hostile state” over which the army of the other state (i.e., the Occupying state) has assumed military authority. 3

evident from Article 55 of that Section, which specifically mentions various immovable properties belonging to the “hostile state”. Article 42 furthers lays down that “the occupation extends only to the territory [of the Hostile State] where such authority has been established and can be exercised.” At the conclusion of the Six-Day War, the territories of Judea, Samaria and Gaza were indeed placed under the authority of a “Hostile Army”, i.e., the Israel Defense Forces. However, these territories are not to be considered legally “under occupation”, unless they actually belong to either Jordan or Egypt. It is a well-known fact that though Jordan annexed Judea and Samaria on April 24, 1950, thus rendering this region a de facto part of the Kingdom of Jordan (i.e., the so-called “West Bank”), this unilateral annexation was never recognized as valid under the prevailing norms of international law, inasmuch as Jordan was an aggressor state in the Israel-Arab War of 1948.3 Thus Jordan never enjoyed sovereignty over Judea and Samaria, while Egypt never even claimed it over Gaza. Since neither Jordan nor Egypt (nor the fictitious “Palestinian People”) were recognized sovereigns of these territories, they cannot be legally classified as “occupied”. The only recognized sovereign over those territories under international law prior to the Six-Day War was the Jewish People as determined by several acts of international law. The first such act was the Smuts Resolution of January 30, 1919 (the precursor of Article 22 of the League Covenant), which in referring to the term “Palestine” must be interpreted in conjunction with the Balfour Declaration of November 2, 1917, the Lloyd George-Clemenceau Agreement of December 1, 1918, and the Weizmann-Feisal Agreement of January 3, 1919. It is thus evident that “Palestine” is a reference to the Jewish People and not to the local Arab inhabitants of the country. The other acts of international law that confirm the Jewish legal title to Palestine are the San Remo Resolution of April 25, 1920, the Mandate for Palestine of July 24, 1922, the Franco-British Boundary Convention of December 3, 1920 and the Anglo-American Convention Respecting the Mandate for Palestine of December 3, 1924. Since Israel, therefore, did not occupy the territory of a previous foreign sovereign, but only re-possessed the territory that the Principal Allied Powers of World War I had resolved was to be part and parcel of the Jewish National Home, as subsequently confirmed by the League of Nations, the Fourth Geneva Convention was not applicable to Israel’s rule over Judea, Samaria and Gaza. Accordingly, it is absolutely false to assert that Judea, Samaria and Gaza are “occupied Palestinian territory”, “occupied Arab territory” or simply “occupied territory” as claimed in many UN General Assembly and Security Council resolutions as well as by the Palestine Liberation Organization, the Palestinian Authority, the Arab League states, other governments and self-servingly, by the International Committee of the Red Cross.4 Furthermore, when the Six-Day War broke out on June 5, 1967, there was no

 3 The principle of international law that applied to the situation was jus ex injuria non oritur [a right does not arise from a wrong]. Even the Council of the Arab League refused to recognize the Jordanian annexation of Judea and Samaria, and four states – Egypt, Saudi Arabia, Syria and Lebanon – voted to expel Jordan for violating the League’s anti-annexation resolution of April 13, 1950.
4 The International Committee of the Red Cross (ICRC) principally formulated the four 1949 Geneva Conventions that were approved at a Diplomatic Conference for the Establishment of International Conventions for the Protection of the Victims of War, held in Geneva from April 21 to August 12, 1949. The ICRC has a special position in the implementation of these Conventions, charged with providing relief and affording protection for members of armed forces who are wounded, sick or shipwrecked; prisoners of war; and civilian persons in time of war (see, for example, Articles 3(2), 63 and 142 of Geneva Convention IV). Under the erroneous assumption of the ICRC that Judea, Samaria and Gaza are indeed “occupied territories”, the Government of Israel permits it to operate freely in these parts of the Land of Israel and the Jewish National Home. It is not without irony that the man who founded the 4

state in existence called “Palestine” whose territory could be considered “occupied” under international law, nor is there any such state even today, though if the Government of Israel continues to pursue the “two-state vision” of U.S. President George W. Bush, this state may yet emerge.

Despite the fact that Israel never occupied the sovereign territory of another Arab state or people, within the meaning of the Fourth Geneva Convention and the Hague Regulations, it has been falsely branded as an occupier of “Arab land”. This accusation has no basis in law but has persisted because of the false belief that has been nurtured since 1969 by the United Nations and the Arab States as well as the PLO, that Israel has conquered the national homeland of another people, the “Palestinians” who inhabit the non-existent state of “Palestine”. To dispel these falsehoods, it need only be remembered that Mandated Palestine was created in April, 1920 at the San Remo Peace Conference for the express purpose of the future independent state of the Jewish People, not for an imaginary people called “Palestinians”, whose existence as a separate nation was unknown during the whole period of the Mandate, especially to the Arabs themselves. Since Palestine was intended to be the Jewish National Home, the State of Israel, which inherited the national rights of the Jewish People to the country, can never be seen as the occupier of land that was specifically reserved for Jews and rightfully belongs, as a result, to Israel. It is only by ignoring these indisputable facts that the cry is incessantly raised that the “occupation” must end. Sadly, Israel itself was in large measure responsible for allowing this false conception to take root, when during the Six-Day War it made the fateful decision to apply the laws of war to the liberated Jewish territories rather than the corpus of its own law, thus failing to incorporate those territories into the Jewish State. This convinced world public opinion, especially that of American and European leaders, that Israel is indeed an occupier of foreign lands. To rectify this terrible mistake, which also violated existing Israeli constitutional law, Israel should not only strongly contest the allegation of “occupation” as baseless, but also pass legislation affirming Israel’s national rights to all areas of the Land of Israel and making it a criminal offense to describe its presence and status in any part of the land as “occupation”.5 This will then prevent Israel’s Supreme Court and most academic jurists in Israel’s institutions of higher learning from further spreading this insidious libel, as they have incredibly done up to now, to the acclaim of those who favor the re-partition of the Land of Israel.

Finally, it should be noted that the legal term “occupation”, as defined in international law, refers only to the occupation by a hostile army of territory belonging to a state. It does not refer to the people living in “occupied territory”, who as non-nationals of the Occupying Power enjoy the status of “protected persons” under the Fourth Geneva Convention. In reconquering areas of the Land of Israel in June 1967, what the Israeli Defense Forces really did was “repossessing” lands

International Red Cross, Jean Henri Dunant, a Swiss Protestant philanthropist, waged an unsuccessful campaign for the settlement of Jews in Palestine during the 1860s, even going so far as to establish an association for that very purpose. Herzl recognized Dunant’s unique efforts to promote Jewish settlement by referring to him as a Christian Zionist in his closing speech at the First Zionist Congress in 1897 in the Swiss city of Basle.
5 The Knesset on July 15, 2003 took an initial step in this direction when it passed, by a margin of 26 to 8, a resolution submitted by Gideon Sa’ar that read as follows: “…the Knesset affirms that the territories of Judea and Samaria are not occupied territories, either historically or from the standpoint of international law, and not according to the diplomatic accords signed by Israel…”. 5


internationally recognized ever since 1920 as belonging to the Jewish People, as originally reflected by the Hebrew phrase for those lands: shtahim muhzakim (“held” areas). This stressed that it was land, rather than people, that was repossessed. It is therefore a gross misuse of the term “occupation” to refer to Israel’s “occupation of the Palestinian People”, even without considering the question of whether Israel is a true occupier of what is now mistakenly termed “Palestinian land”, i.e., Judea, Samaria and Gaza. To give a parallel example, the United States may be said to be a military occupier of Iraq, ever since it overthrew the cruel regime of Saddam Hussein, but it cannot be said to “occupy the Iraqi people”. Those who accuse Israel of “occupying Palestinians” are using false and illogical terminology that has no basis in any instrument of international law. This terminology represents an unwarranted and unauthorized change of meaning of the term “occupation”, in that it wrongly conflates two non-synonymous categories. In actual fact, Israel neither occupies the land of Judea, Samaria and Gaza, the alleged homeland of the so-called “Palestinians”, nor does Israel “occupy” any nation of that name. Israel has a flawless legal right to govern all of the Land of Israel as well as all of its inhabitants, as the legitimate sovereign.

Israel and a Palestinian State:
Zero Sum Game?

Arieh Stav (ed.)
Zmora-Bitan Publishers and ACPR Publishers, 2001

This collection of articles, appendices and documents deals with different aspects of the establishment of a Palestinian state in the Western Land of Israel, thus reducing Israel to the borders of June 4, 1967. This initiative, known as "the peace process", involves a paradox where a minuscule democracy is being forced to provide to its totalitarian enemies - scores of times its size - the only thing that it lacks: territory. In exchange, these dictatorial regimes promise to provide the one and only thing that they lack: peace.
The essence of the current process is the establishment of an Arab-Palestinian state in addition to the on that already exists in Jordan, this time in Eretz Israel, beginning with Judea, Samaria and Jerusalem, the cradle of the Hebrew nation and the raison d'etre of Judaism and Zionism.
For the complete text of the book, click here. For individual chapters and documents, see below.

Contents


A Disaster Foretold
Rhetoric of Hatred
US and Europe
A Palestinian State and American Interests (Reprinted from: A Palestinian State: Implications for Security and American Policy, Jewish Institute for National Security Affairs, 1999) - Rudy Boschwitz

Demoraliztion

Other Perspectives
Appendices:

Documents (Chronological order)

6 comments:

  1. In Memoriam - Howard Grief (1940-2013)
    William Mehlman
    Howard Grief did not suffer fools gladly, most notably those, including jurists, who in the face of documented historical evidence of Israel’s sovereignty over Judea, Samaria and the Golan, as agent and assignee of the Jewish People, persist in referring to those areas as “disputed,” “unallocated” and,
    most offensively, “occupied” territories. Irrespective of the direction of the prevailing political winds, Howard might have believed that the legal questions had been put to rest with the publication in 2008 of his The Legal Foundation and Borders of Israel under International Law, the 660-page product of more than two decades of ground-breaking research that should have shattered every myth, every lie, every distortion and misrepresentation of fact employed over the 65 years of Israel’s reestablishment to
    negate the sovereign right of the Jewish People to their National Home.
    Alas, five years after the book’s publication and two months since Grief’s tragic, untimely passing, the myths, the lies, the distortions show no sign of loosening their grip on global consciousness.
    If he oversold himself on the compelling power of truth in an age in which “narratives” have all but supplanted historical fact, Grief could not have envisioned the solid wall of indifference with which The Legal Foundation was greeted by the media. Arguably the most important book published in Israel since the l967 war garnered not one review from a Leftist-dominated Israeli press. A review of the book by this writer did appear in Outpost and with the efforts of Americans For A Safe Israel, in several American-Jewish weeklies.

    ReplyDelete
  2. Howard Grief did not cast himself as the instrument for setting Israel’s legal and historical record straight when he gave up a successful 23-year law practice in Montreal to make aliya in 1989. As he points out in the introduction to his book, it was thrust upon him with the amazing discovery that 41 years after the state was declared, he could find “no single book that contained an organized and systematic presentation of Israel’s rights to the Land of Israel – not just the area included in the State of
    Israel, but to all of the land east and west of the Jordan…” Did any such “rights” exist? He was determined to find out. Two events triggered his decision to go public with what he was discovering: A
    93-page position paper on the key elements of Israel’s founding that he put together in 1991 for presentation to the Carnegie Foundation in New York by Yuval Ne’eman, prelude to a speech to be
    given by Ne’eman, then Minister of Energy and Infrastructure in the Yitzhak Shamir government.

    Grief served as legal advisor to the ministry from 1991-93. The second event was Ne’eman’s decision to do an article for the prestigious Global Affairs magazine citing Grief’s research as the authority for his conclusions.
    As a legal historian Grief at that point had already gone where no man had gone before.
    Beneath the accumulated debris of 70 years of history, he had unearthed the forgotten key, the rosetta stone that spelled out the Jewish People’s sovereign right to the Land of Israel in all its historic dimensions.
    It was the April, 1920 San Remo Resolution of the five victorious World War I Allied powers – America, Britain, France, Italy and Japan. British Foreign Minister Lord George Curzon, no defender of
    Jewish aspirations in Palestine, grudgingly called it the “Jewish Magna Carta. “ Supreme Court Justice Louis Brandeis, America’s most passionate Zionist, remarked that the boundaries of the future Jewish state had been set and that there was no need for additional discussion.
    Indeed, in transforming the 1917 Balfour Declaration into a binding legal document, making it the basis of Article 22 of the Covenant
    of the League of Nations and further incorporating it into the Mandate for Palestine, obligating Britain to aid and encourage Jewish immigration and settlement to the National Jewish Home, the San Remo Resolution was the ticket to Jewish sovereignty, albeit one that a Palestinian Jewish population of 60,000 at the time was not yet in a position to exercise.
    3
    “Once international law in the form of the San Remo Resolution recognized that de jure sovereignty over all regions of historical Palestine and the Land of Israel had been vested in the Jewish
    People,” Grief observed, “neither the Supreme Council of the Allied Powers nor the Council of the League of Nations, nor its successor, the United Nations, could thereafter revoke or alter Jewish
    sovereignty by a new decision…If either of these bodies really had such a right in regard to Palestine and the Land of Israel, the sovereignty of every state in the world over its own territory would be put in jeopardy.”

    ReplyDelete
  3. In ratifying the 1924 “Anglo-American Convention on Palestine,” Grief submits, the United States “became a contracting party” to the League of Nations Mandate for Palestine assigned to Britain
    for administration, “a document not only devoid of any provision for an Arab state within Palestine, but one that specifically prohibited the partition of the land for any purpose other than the creation of a National Jewish home.” In fact, then President Calvin Coolidge was not plowing new American legal ground with his signature to that document. He was simply reinforcing a unanimous resolution of the 67th Congress three years earlier, signed by his predecessor, President Warren G. Harding, recognizing a future Jewish state in “the whole of Palestine.” President Barak Obama’s obsession with the creation of a bogus, irredentist “Palestinian Arab State” in Judea and Samaria is nothing less than a repudiation of the signatures of two American presidents and the unanimously expressed will of the U.S. Congress.
    While Howard did not live to see the wide-scale embrace of his seminal contribution to Israeli history and international law or mercifully the post-mortem assault – thus far unavailing -- by an unforgiving Israeli Far-Left on his Wikipedia biography, he did live long enough to see The Legal Foundation and Borders of Israel under International Law beginning to gain traction. Wherever Israel’s history and legal rights to the Land of Israel are discussed and debated these days, this is the book most often cited.
    Howard was too ill to accept the speaking engagements beginning to pour in from activist groups in the U.S., Canada, Scandinavia and Israel, but he went to his final rest knowing he had not labored in vain.
    William Mehlman represents AFSI in Israel.

    ReplyDelete
  4. In ratifying the 1924 “Anglo-American Convention on Palestine,” Grief submits, the United States “became a contracting party” to the League of Nations Mandate for Palestine assigned to Britain
    for administration, “a document not only devoid of any provision for an Arab state within Palestine, but one that specifically prohibited the partition of the land for any purpose other than the creation of a National Jewish home.” In fact, then President Calvin Coolidge was not plowing new American legal ground with his signature to that document. He was simply reinforcing a unanimous resolution of the 67th Congress three years earlier, signed by his predecessor, President Warren G. Harding, recognizing a future Jewish state in “the whole of Palestine.” President Barak Obama’s obsession with the creation of a bogus, irredentist “Palestinian Arab State” in Judea and Samaria is nothing less than a repudiation of the signatures of two American presidents and the unanimously expressed will of the U.S. Congress.
    While Howard did not live to see the wide-scale embrace of his seminal contribution to Israeli history and international law or mercifully the post-mortem assault – thus far unavailing -- by an unforgiving Israeli Far-Left on his Wikipedia biography, he did live long enough to see The Legal Foundation and Borders of Israel under International Law beginning to gain traction. Wherever Israel’s history and legal rights to the Land of Israel are discussed and debated these days, this is the book most often cited.
    Howard was too ill to accept the speaking engagements beginning to pour in from activist groups in the U.S., Canada, Scandinavia and Israel, but he went to his final rest knowing he had not labored in vain.
    William Mehlman represents AFSI in Israel.

    ReplyDelete
  5. Howard Grief did not cast himself as the instrument for setting Israel’s legal and historical record straight when he gave up a successful 23-year law practice in Montreal to make aliya in 1989. As he points out in the introduction to his book, it was thrust upon him with the amazing discovery that 41 years after the state was declared, he could find “no single book that contained an organized and systematic presentation of Israel’s rights to the Land of Israel – not just the area included in the State of
    Israel, but to all of the land east and west of the Jordan…” Did any such “rights” exist? He was determined to find out. Two events triggered his decision to go public with what he was discovering: A
    93-page position paper on the key elements of Israel’s founding that he put together in 1991 for presentation to the Carnegie Foundation in New York by Yuval Ne’eman, prelude to a speech to be
    given by Ne’eman, then Minister of Energy and Infrastructure in the Yitzhak Shamir government.

    Grief served as legal advisor to the ministry from 1991-93. The second event was Ne’eman’s decision to do an article for the prestigious Global Affairs magazine citing Grief’s research as the authority for his conclusions.
    As a legal historian Grief at that point had already gone where no man had gone before.
    Beneath the accumulated debris of 70 years of history, he had unearthed the forgotten key, the rosetta stone that spelled out the Jewish People’s sovereign right to the Land of Israel in all its historic dimensions.
    It was the April, 1920 San Remo Resolution of the five victorious World War I Allied powers – America, Britain, France, Italy and Japan. British Foreign Minister Lord George Curzon, no defender of
    Jewish aspirations in Palestine, grudgingly called it the “Jewish Magna Carta. “ Supreme Court Justice Louis Brandeis, America’s most passionate Zionist, remarked that the boundaries of the future Jewish state had been set and that there was no need for additional discussion.
    Indeed, in transforming the 1917 Balfour Declaration into a binding legal document, making it the basis of Article 22 of the Covenant
    of the League of Nations and further incorporating it into the Mandate for Palestine, obligating Britain to aid and encourage Jewish immigration and settlement to the National Jewish Home, the San Remo Resolution was the ticket to Jewish sovereignty, albeit one that a Palestinian Jewish population of 60,000 at the time was not yet in a position to exercise.
    3
    “Once international law in the form of the San Remo Resolution recognized that de jure sovereignty over all regions of historical Palestine and the Land of Israel had been vested in the Jewish
    People,” Grief observed, “neither the Supreme Council of the Allied Powers nor the Council of the League of Nations, nor its successor, the United Nations, could thereafter revoke or alter Jewish
    sovereignty by a new decision…If either of these bodies really had such a right in regard to Palestine and the Land of Israel, the sovereignty of every state in the world over its own territory would be put in jeopardy.”

    ReplyDelete
  6. In Memoriam - Howard Grief (1940-2013)
    William Mehlman
    Howard Grief did not suffer fools gladly, most notably those, including jurists, who in the face of documented historical evidence of Israel’s sovereignty over Judea, Samaria and the Golan, as agent and assignee of the Jewish People, persist in referring to those areas as “disputed,” “unallocated” and,
    most offensively, “occupied” territories. Irrespective of the direction of the prevailing political winds, Howard might have believed that the legal questions had been put to rest with the publication in 2008 of his The Legal Foundation and Borders of Israel under International Law, the 660-page product of more than two decades of ground-breaking research that should have shattered every myth, every lie, every distortion and misrepresentation of fact employed over the 65 years of Israel’s reestablishment to
    negate the sovereign right of the Jewish People to their National Home.
    Alas, five years after the book’s publication and two months since Grief’s tragic, untimely passing, the myths, the lies, the distortions show no sign of loosening their grip on global consciousness.
    If he oversold himself on the compelling power of truth in an age in which “narratives” have all but supplanted historical fact, Grief could not have envisioned the solid wall of indifference with which The Legal Foundation was greeted by the media. Arguably the most important book published in Israel since the l967 war garnered not one review from a Leftist-dominated Israeli press. A review of the book by this writer did appear in Outpost and with the efforts of Americans For A Safe Israel, in several American-Jewish weeklies.

    ReplyDelete