The International Court of Justice (?) and Israel’s Security Barrier

Rabbi George's Reflections, December 2004

The International Court of Justice’s (ICOJ) decision rubber-stamping a Palestinian-sponsored UN General Assembly resolution holding Israel’s construction of the security fence “illegal” offends two of my greatest passions: My attachment to Israel and my love for the law. The Court’s holding (see below) that Israel has no right to defend itself against Palestinian terrorists because Israel does not “claim” that Palestine is a state disrespects both Israel and the law. Since Israel was not a party to the proceeding it could not make any “claim.” But the Court’s churlish approach is hardly surprising. Israel, as I pointed out at Rosh HaShanah, has become an international pariah state.

From a legal standpoint, the case in which the Court ruled was highly peculiar. First the UN General Assembly decided the legal question, namely does the security barrier violate international law, and then it asked the ICOJ for a legal opinion agreeing that the General Assembly was right. Obviously, the General Assembly asked the Court’s opinion not because it was in doubt about the law but to enhance the resolution’s effect as propaganda. No self-respecting Court would engage in such a charade.

The ICOJ is hardly a body from which Israel could expect a fair decision. The President of the Court is the Chinese official who masterminded China’s response to the Tiennamen Square demonstration and one member of the Court is a Palestinian by birth. No Israeli jurist is eligible for appointment as a judge of the ICOJ.

Just reading the decision makes plain that the ICOJ did not set out to find the law or do justice. Three moves, fatal to any claim of propriety, illustrate the point. First, the Court adopted without comment the Palestinian/General Assembly denomination of the security barrier as a “wall”. As you know, more than 96% of the barrier consists of barbed wire and electronic sensors, backed by a roadway to allow quick response to any terrorist incursion. The Israelis call the barrier a “fence”; the Palestinians call it a “wall”. Eschewing both positions the Israeli High Court used the term “security barrier”. But the ICOJ, spurning its obligation to appear and to be impartial, chose the Palestinian’s obviously misleading term “wall”.

Second, at a critical point in its opinion the Court misquoted General Assembly Resolution 242, enacted after the 1967 War. That resolution, in which Israel acquiesced, calls for “establishment of a just and lasting peace” which “should include”... “withdrawal of Israeli armed forces from territories occupied in the recent conflict”. An earlier version of the quoted sentence had called for Israeli withdrawal “from the territories occupied in the recent conflict”. But at the insistence of Israel and others the word “the” was deleted and a sentence added as one of the principles upon which peace should be based: “Termination of all claims or states of belligerency and respect for and acknowledgment of the sovereignty, territorial integrity and political independence of every state in the area and their right to live in peace within secure and recognized boundaries free from threats or acts of force;” (Emphasis added). The legislative history of that addition —to say nothing of the body of the resolution— shows unmistakably that Israel’s eventual boundaries (and the scope of its obligatory withdrawal) were to be settled in subsequent negotiations, not by the resolution. Obviously, the full text of the resolution demonstrates that the 1949 Line was not to be the final border. By omitting the limitation at one point, and completely ignoring its force at another the Court read the 1967 resolution as if it confined Israel to the 1949 Armistice Line. That, in turn, enabled the Court mendaciously to conclude that international law forbade the construction of a security barrier beyond that line. 1

Third, the Court utterly ignored the decision of the Israeli High Court of Justice requiring modifications of the security barrier to protect local Palestinians who were injured by it. That decision significantly changed the facts before the ICOJ and rested upon interpretations of Israeli law and of treaties and conventions that the ICOJ also considered. No honest court would treat the decision of another tribunal, especially a tribunal empowered to act upon the same matter, as so much judicial waste paper.2 The ICOJ’s conduct in this respect was disgraceful.

Law aside, the ICOJ decision is profoundly unfair. The UN Charter limits the U.N.’s power by preserving the member states’ right of self defense.3 The Court disregarded that limitation (which binds the Court as well as other UN organs) by announcing for the first time that as far as the UN is concerned the right of self-defense is of no moment when the attacker is not a State. So the Court’s opinion pays not the slightest attention to the Palestinian murder campaign against Israeli men, women, and children. It neither holds the Palestinians responsible nor affords any weight to the protection the security barrier has given to the Israeli populace. The Court simply orders Israel to tear it down. On the other hand, the Assembly resolution before the Court was initiated by the Palestinians’ UN delegation and the Court found the wall illegal explicitly because allegedly it violates the Palestinians’ right to self-determination (that is, to be a nation) and implicitly because the security barrier route will prejudice the Palestinians in future negotiations over boundaries. That, after all, is the significance of the Court’s concern with Israel’s actions beyond the 1949 Armistice Line. The Court’s biased treatment of the parties’ interest is shameful, and its failure in any way to hold the Palestinians responsible for terrorism is bound to encourage its continuance.

As a religious Jew, I am deeply saddened by the ICOJ’s decision. It gathers in a seemingly endless parade all the General Assembly and Security Council resolutions condemning Israel, buttressing the feeling that Israel has become the “world’s Jew,” an international pariah, a feeling I discussed in my High Holiday talk. Beyond that, the disingenuousness of the ICOJ decision betrays once again the great hopes that I felt when the UN was created in New York City where I was then living. Corruption, bias, hypocrisy, and fecklessness in the face of genocidal murder campaigns around the globe have rightly tarnished the UN’s once bright image. Thus the ICOJ decision is for me emblematic of a deeper rot, a rot which in the long run is far more threatening to mankind than Israel’s security barrier, problematic though it is in some respects, could ever be. Sad indeed.

Rabbi George B. Driesen


1The Court treated Resolution 242 as a binding “law.” On its face, however, the resolution describes what “should” occur, language that is inconsistent with the enactment of law. The General Assembly has not usually been thought of as a law making body. Just how the resolution became “law” the Court did not bother to say, perhaps because it would have been too embarrassing to admit that the Court had simply accepted the General Assembly’s request in effect that the Court treat its Resolutions as “law”. Generally, courts jealously guard their power to say “what the law is”. Marbury v. Madison, 5 U.S. 137 (1803)(court decides whether a Congressional enactment violates the Constitution because courts must decide “what the law is).”

2Unlike the ICOJ decision, which binds no one, the Israeli decision has the force of law in Israel.

3“Nothing in the present Charter shall impair the inherent right of self-defence if an armed attack occurs against a Member of the United Nations....” UN Charter Article 51.

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