Middle Eastern Christians: Battered, Violated, and Abused, Do They Have Any Chance of Survival?

, May 22, 2014

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Throughout the Middle East, the birthplace of Christianity, Christians are facing pervasive and systematic persecution that is steadily increasing in its intensity and scope. A century ago, Christians represented some 20 percent of the population of the Middle East; today, that figure is estimated at 4 percent.1  One leading academic authority in London has estimated that between one-half and two-thirds of Middle Eastern Christians have either been killed or left the area over the last century.2  Reviewing a report on this trend, the Daily Telegraph led with the title: “Christianity ‘close to extinction’ in the Middle East.”3

Pope Francis is expected to arrive in the Middle East this May,4 a region, he said, where Christians are “unjustly accused and are subjected to every type of violence.”5 Prince Charles recently expressed similar sentiments, saying, “It seems to me that we cannot ignore the fact that Christians in the Middle East are increasingly being deliberately targeted by fundamentalist Islamist militants.”6

In Muslim states throughout the Middle East the effects of this persecution are demonstrated by the drastically declining Christian population. While such censuses are by nature inexact, the rough picture they provide is extremely valuable in understanding the true magnitude of this phenomenon.

A century ago Christians represented some 20 percent of the population of the Middle East, today that figure is estimated at 4 percent.

To gain perspective on all this demographic data, it is useful to recall that even after the Arab conquests of the Middle East in the 7th century, the majority of the population in most cases was still Christian.7 Yet the number of Christians steadily declined over the centuries that followed.

In 1927, Egypt’s Christian population was 8.3 percent of the general population; by 2011, it was down to 5.3 percent.8 Similarly, Syria’s Christian population was found to be 9.7 percent of the population in 1970;9  today, contesting reports find it to be somewhere between 4.4 to 10.2 percent.10 A similar trend is seen in Iraq, too, where the Christian population has dropped from 3.7 percent in 197011  to varying reports of 0.9 to 2.5 percent today.12  According to another calculation, there were between 1.2 and 1.4 million Christians in Iraq in 1990. Today there are fewer than 200,000.13  Iranian Christians have also suffered from this trend with the population declining from 0.9 percent in 197014  to 0.35 percent today.15

As Pope Francis recently stated, the injustice of this persecution is compounded by the fact that it is occurring in states where “on paper, freedom and human rights are protected.”16  This author has spoken at length regarding the great peril Christian life in the Middle East finds itself in. To that end, he has visited with top Congressmen, including then-Senators Santorum and Brownback; he has testified at congressional hearings attended by a wide range of public officials; met with Vice President Cheney’s national security staff in the West Wing of the White House; consulted and lectured at the State Department; and spoken at think tanks such as the Hudson Institute.

If these warnings are not heeded, and these states continue to violate the basic human rights obligations incumbent upon them, Christian life may cease to exist in the very place of its birth. This danger was recently voiced by British cabinet minister and Muslim, Baroness Sayeeda Warsi, who stated:

Across the world, people are being singled out and hounded out simply for the faith they hold….[Middle Eastern Christians] are rooted in their societies, adopting and even shaping local customs. Yet…[a] mass exodus is taking place, on a Biblical scale. In some places, there is a real danger that Christianity will become extinct.17

If these warnings are not heeded, and these states continue to violate the basic human rights obligations incumbent upon them, Christian life may cease to exist in the very place of its birth.



  • In October 2013, four Coptic Christians, including young girls of 8 years-old and 12 years-old, were killed, and 24 were injured when gunmen fired on a wedding party in front of the Church of the Virgin Mary near Cairo.18 Among those killed was eight year-old Mariam Ashraf.19 Ashraf’s three year-old brother and mother were also shot.20 Her father stated, “Nobody comes out to tell you honestly: ‘We have arrested the culprit and they are being subjected to the law.’ There is nothing like that.”21 Eyewitnesses of the attack stated that despite numerous calls for help, ambulances and police only arrived two hours following the shooting.22
Egyptian Copts carry four coffins down the aisle of the Virgin Mary Coptic church, on October 21, 2013, as thousands attend the funeral of the victims, gunned down as they attended a wedding the previous evening at the same church.


  • In March 2010, an Egyptian court acquitted four Muslims in the killing and beheading of 61 year-old Farouk Attallah.23 Attallah was killed after the assailants shot him 31 times before beheading him in a busy market place.24 The court based its verdict on the testimony of false witnesses, exculpating the killers while refusing to accept the testimony of key witnesses of the attack.25 Peter Sarwat, the victim’s attorney, described the verdict, stating, “It sends a clear message that Coptic blood is extremely cheap…. This acquittal will make permanent the present culture of impunity enjoyed by Muslim aggressors against Copts.”26 He continued, “It is not safe for Copts now, as any Muslims who wants to get rid of a Copt, would kill him, knowing well that in the end he will be acquitted.”27 Sarwat further described how police often purposely prepare inadequate police reports in order to facilitate the acquittal of Muslims.28
  • Christians in the Minya Governorate in Upper Egypt have been the subject of countless kidnappings. An official in the Egyptian Ministry of the Interior stated that there had been 17 kidnappings in August and September.29 Ezat Ibrahim, director of the Minya branch of the Al-Kalema Human Rights Organization,30  reported that in November 2013 alone there were 9 cases of kidnappings.31 One report found that since the start of the revolution in 2011, there had been close to 100 kidnapping cases.32 In each of the cases, the Christian families were forced to pay 100,000 to 250,000 Egyptian pounds ($14,500 to $36,300 USD) in ransom.33
  • In one case of kidnapping, in June 2013, a six year-old Copt, Cyril Yusuf Sa’ad, was abducted and held for ransom. Despite his family paying the ransom,34 the Muslim kidnapper, Ahmed Abdel Moneim Abdel-Salam, killed the boy and threw his body in the sewer.35
  • A Human Rights group has reported that in 2013 alone, 207 churches have been attacked and 43 churches completely destroyed.36


Christian farmer Ishaq Aziz cradles a picture of his 17 year-old daughter Nirmeen, a school girl, who went missing in February 2013, in the Minya town of Matai, Egypt.


  • 15,000 Christians in the village of Dalga have been forced to pay the jizya, an additional tax or tribute imposed on conquered non-Muslims.37 Those unable to pay are often beaten or killed.38 In one such case, Emad Damian, 50, and Medhat Damian, 37, were murdered after refusing to pay 10,000 Egyptian Pounds demanded by the leader of a Muslim gang.39  The two Copts had reported the incident to the local police; however, nothing was done.40 Ahmed Fawzi, secretary of the Egyptian Social Democratic Party, described the case, stating, “the gang surprised the two Copts by going to their home in the morning and showering them with bullets, leaving both dead.…[T]he police know who the killers are but are doing nothing to arrest them.”41
  • Arguably the most telling aspect of this persecution is that this past August, for the first time in 1,600 years, prayers were not held in the Virgin Mary and Priest Ibram Monastery, which was destroyed by supporters of deposed President Morsi.42 That same month, Coptic Bishop Anba stated in the UK that “over the past weeks we have witnessed an increasing trend in anti-Christian rhetoric calling for the ‘attack upon and eradication of Christians and churches’ in Egypt.” The Coptic Pope Tawadros II also accused the Muslim Brotherhood of fomenting the anti-Christian violence.43

In 2013 alone, 207 churches have been attacked and 43 churches completely destroyed. An official in the Egyptian Ministry of the Interior stated that there had been 17 kidnappings in August and September.


  • As of December 2013, since the beginning of the Syrian civil war in March 2011, 450,000 Syrian Christians have fled their homes44 and 1,200 murders of Christians have been documented.45
  • In October 2013 in the town of Saddad, 45 Christians were killed and the town’s 14 churches were destroyed.46  Selwanos Boutros Alnemeh, Syrian Orthodox Metropolitan of Homs and Hama,47 described these events as “the greatest massacre of Christians in Syria.”48
  • On January 8, 2014, Fadi Matanius Mattah was beheaded by Islamic militants while travelling from Homs to the Christian village of Marmarita.49 The militants intercepted and fired on the car he was traveling in along with another Christian, Firas Nader.50 Mattah was beheaded after the militants noticed the cross he was wearing.51 Nader, who was wounded in the attack, succeeded in escaping after the militants believed he had been killed.52
  • The Antiochian Orthodox church of Sts. Sergius and Bacchus in al-Thawra was destroyed by rebel forces in August 2013. One refugee stated:

The ‘Free Syrian Army’ demolished the [Sts. Sergius and Bacchus] church.…[T]hey tore up the sanctuary curtains, Bibles and other holy books, and broke all the crosses, chairs and icons of Jesus and the saints. They stole electrical appliances like fans, chandeliers and lights. They took whatever was in the church, and sold it all. There is nothing there now.53

  • In December 2013, 12 nuns from the village of Maaloula were abducted and taken to a rebel-held town.54
  • In January 2014, it was reported that an Armenian Christian was killed by the al-Qaeda linked Islamic State in Iraq and the Levant after refusing to convert to Islam. The man and his father were reportedly held for 115 days in a prison maintained by the group in Aleppo.55
  • In June 2013, Mariam, a 15 year-old Christian, was kidnapped, repeatedly gang raped, and then killed.56  Mariam was abducted by a commander in the Jabhat al Nusra, who married, raped her, and then passed her on to another man who did the same. This took place over the course of 15 days, during which Mariam was raped by 15 different men.57

As of December 2013, since the beginning of the Syrian civil war in March 2011, 450,000 Syrian Christians have fled their homes and 1,200 murders of Christians have been documented.

  • In January 2014, it was reported that a group of rebel forces from the Islamic State of Iraq and the Levant (ISIS) imposed strict Sharia law in the northern province of Raqqa.58 Among others, the directives include that women must wear the niqab full face veil and all men must attend Friday prayers at a mosque.59  A directive also stated that Christians must not make renovations to churches or display crosses or any religious symbols outside of churches.60


Fighters from the al-Qaida linked Islamic State of Iraq and the Levant (ISIL) marching in Raqqa, Syria. Once a vibrant, mixed city, Raqqa is now a shell of its former life, transformed by al-Qaida militants into the nucleus of the terror group’s version of an Islamic caliphate they hope one day to establish in Syria and Iraq.


  •  After rebels attacked the town of Maalula on September 4, 2013, Adnan Narallah, 62, described the scene. “I saw people wearing Al-Nusra headbands who started shooting at crosses.…[O]ne of the shooters put a pistol to the head of my neighbor and forced him to convert to Islam by obliging him to repeat ‘there is no God but God’….Afterwards they joked, he’s one of ours now.”61
  • Another Maalula resident, Rasha, described how rebel forces murdered her fiancé. “I rang his mobile phone and one of them answered,” she said. She described how the man who answered told her that her fiancé was asked to convert to Islam but refused.62 The rebel added, “Jesus didn’t come to save him.”63
  • In al-Thawrah, three residents were stopped by rebel forces. The two who were Muslim were released; the third, who was a Christian, was bludgeoned to death.64
  • In September 2013, the al-Qaeda linked group the Islamic State of Iraq and the Levant, broke the crosses of the Church of the Annunciation and the Church of Martyrs in the city of Raqqah before setting fire to the contents of both churches.65
  • This troubling situation in Syria was recently summed up by Rima Tuzun of the European Syriac Union. While speaking to Nina Shea, Director of the Center for Religious Freedom, Tuzun stated, “[K]idnapping, killings, ransom, rape…2013 is a tragedy for Christians in Syria. All Syrians have endured great suffering and distress. The Christians, however, often had to pay with their lives for their faith.”66


  • On Christmas Day 2013, 37 people were murdered in attacks on Christians.67
  • In March 2013, it was reported that over the course of only one decade, the number of churches in Iraq has dropped from over 300 to only 57 today.68
  • According to one Iraqi pastor, Christians have ceased observing basic Christian traditions such as putting up a Christmas tree, due to fear of persecution.69


In this mobile phone camera image obtained by the Associated Press, the interior of the Our Lady of Salvation church is seen after gunmen took the congregation hostage on Sunday, Oct. 31, 2010.


  • In October 2010, 51 worshipers and 7 Iraqi troops were killed after gunmen from an al-Qaeda affiliated group attacked and laid siege to Our Lady of Salvation church in Baghdad.70 Among the 51 worshipers killed were five children and eight women.71 After these events, one church member commented, “We are the minority. We cannot defend ourselves. We cannot stay in this country anymore.”72
  • Iraqi Christians, too, have not been immune from the imposition of the jizya tax. Mofed, the owner of a photo shop in Baghdad, was threatened by Muslims who came into his shop and presented him with three options: convert to Islam, pay a $70,000 tax, or be killed.73 Mofed and his family have fled to Jordan.74
  • In a similar case, Androus, a Christian from the town of Mosul, described a similar threat he received by phone. He described being told “Because you are infidels, you have to pay jizya.…[E]ither you pay jizya, or we will kill you or your son.”75
  • On May 30, 2011, Arkan Juhad Yacob, a 63 year-old Christian, was shot dead in cold blood.76 Yacob previously escaped from two unsuccessful ransom abductions.77
  • On June 25, 2013, gunmen attacked St. Marry’s Assyrian Chruch in Baghdad, wounding two Christian guards.78
  • Also on June 25, 2013, two Christian owned businesses were bombed, killing one of the Christian shop owners.79
  • On August 2, 2011, 23 people were wounded when a car bomb exploded outside of the Holy Family Church in Kirkuk.80

Over the course of only one decade, the number of churches in Iraq has dropped from over 300 to only 57 today.


  • 78 people were killed and over 100 were injured in the bombing of the All Saints Church in Peshewar in September 2013.81


Pakistani Rukhsana Saleem, 38, who survived the bombing of the All Saints Church, prays at the church where the attack took place, in Peshawar, Pakistan, Monday, Sept. 23, 2013.


  • Following the attack, four blasphemy cases were filed against Christians in less than one month.82 In all four cases, no direct evidence against the accused was available.83 Pakistan’s blasphemy laws disproportionately protect Islam over other religions and have historically been used to persecute Christians and other non-Muslims.84 The laws prescribe a punishment of life imprisonment or death in certain instances.85
  • In October 2013, an illiterate vendor was beaten by a group of Muslims after it was discovered that fireworks he was selling were wrapped in pages that had verses of the Quran written on them.86 A blasphemy case has been filed against him.87 Khurram Shazhad, who filed the case, stated, “The police have also told us that they have put his name on the exit control list at all airports, and he will not be able to leave Pakistan….[H]is punishment will be an example to all those who dare insult Islam and our holy book.”88
  • In March 2013, a mob set fire to over 100 homes in a Christian neighborhood in Lahore,89 displacing over 150 families.90 The attack took place after Sawan Masih was accused of blasphemy following an altercation with a Muslim barber who refused to serve him.91 One resident stated, “They threw acid and stoned our houses, then set them on fire. The authorities intervened only when everything was destroyed.” The local imam said Sawan will be killed when found.92 Other Christian residents described how prior to the attack, police instructed them “to vacate the area for their ‘security’ and not to worry about their properties.”93 Three months after the attack, hundreds of those detained during the violence have been released. Naeem Shakir, a Christian lawyer stated, “Most of the people who were stopped after the attack were declared innocent by the police and immediately released, for corruption or political pressure.”94

Pakistan’s blasphemy laws disproportionately protect Islam over other religions and have historically been used to persecute Christians and other non-Muslims

  • In a similar case, a violent mob attacked the Christian village of Francis Abad in the city of Gujranwala.95  The attack ensued following a violent altercation between the Christian and Muslim communities that resulted from a conflict between Christian youth and Muslim clerics who accused the Christians of playing loud music outside of a mosque.96


  • On October 16, 2013, four Christians were sentenced to 80 lashes for drinking communion wine after being charged with consuming alcohol in violation of Iran’s anti-alcohol law.97
  • After being arrested in February 2012 in a raid on their house-church, four Christians, Mojtaba Seyyed-Alaedin Hossein, Mohammad-Reza Partoei, Vahid Hakkani, and Homayoun Shokouhi, were sentenced to 44 months in prison for “attending a house church, spreading Christianity, having contact with foreign ministries, propaganda against the regime, and disrupting national security.”98 Homayoun Shokouhi’s wife, Fariba Nazemina, and son, Nima Shokouh, also received two-year suspended prison sentences.99


It should be noted that Egypt, Syria, Iraq, Iran, and Pakistan are all parties to the International Covenant on Civil and Political Rights (ICCPR).100 Article 18 of the Covenant provides that, “Everyone shall have the right to freedom of thought, conscience and religion.”101 This also encompasses the right to manifest one’s “religion or belief in worship, observance, practice and teaching” in public or in private.102 The respect of freedom of religion is of such utmost importance, according to the Covenant, that it may not be derogated from under any circumstances, even in times of emergency as is allowed for other protected rights.103

Moreover, parties to the Covenant must ensure that anyone whose rights or freedoms are violated shall have an effective remedy.104 Additionally, Article 26 provides that the law must “guarantee to all persons equal and effective protection against discrimination on any ground such as…religion.”105 Furthermore, in regard to Pakistan and its blasphemy laws, Article 6 prescribes that in states that have not yet abolished the death penalty, “sentence of death may be imposed only for the most serious crimes.”106

Lastly, in addition to individual rights and freedoms, as a minority Christians are entitled to protections on the communal level as well. Article 27 says, “In those States in which ethnic, religious or linguistic minorities exist, persons belonging to such minorities shall not be denied the right, in community with the other members of their group, to enjoy their own culture, to profess and practise their own religion, or to use their own language.”107

Consequently, Egypt, Syria, Iran, Iraq and Pakistan are all obligated to prevent such acts as described above.  With regard to Syria, it should be noted that although most of the acts above were committed by rebel forces, Syria may still be held liable for these actions in a number of circumstances.108

In addition to the obligations of these states to themselves prevent and protect their citizens from persecution, the United States is also empowered and committed to help combat such persecution abroad. The International Religious Freedom Act of 1998 commits the United States “[t]o condemn violations of religious freedom, and to promote, and to assist other governments in the promotion of, the fundamental right to freedom of religion.”109 To that end, the statute provides that the President may impose various sanctions on States in response to violations of religious freedoms.110

Two levels of violations may trigger the use of sanctions. The first, “particularly severe violations of religious freedom,” includes “torture or cruel, inhuman, or degrading treatment or punishment [or] prolonged detention without charges…or other flagrant denial of the right to life, liberty, or the security of persons.”111  The second, “violations of religious freedom,” refers to “violations of the internationally recognized right to freedom of religion and religious belief and practice” as recognized in such instruments as the International Covenant on Civil and Political Rights.112 It includes actions such as “arbitrary prohibitions on, restrictions of, or punishment for assembling for peaceful religious activities such as worship, preaching and prayer; speaking freely about one’s religious beliefs; and changing one’s religious beliefs and affiliation.”113

The sanctions include, inter alia, public condemnation; “directing the Export-Import Bank of the United States, the Overseas Private Investment Corporation, or the Trade and Development Agency not to approve the issuance of any…guarantees, insurance, extensions of credit, or participations in the extension of credit with respect to the specific government, agency, instrumentality, or official” responsible for violations; and the cancellation of working, official, or state visits.114

In order to emphasize the seriousness of the acts of persecution described above, it should be noted that the Rome Statute of the ICC provides that when committed as part of a widespread or systematic attack, persecution against an identifiable group on religious grounds in connection to acts such as murder and imprisonment constitutes a crime against humanity.115


Palestinian Deception and Lip Service to Human Rights

With regard to Christians living in the West Bank and Gaza Strip, the leaders of the Palestinian Authority (PA), Hamas and the Christian community would have you believe that they are immune from this disturbing trend of persecution. At a Christmas tree-lighting ceremony in December 2013 in Bethlehem’s Manger Square, PA Prime Minister Rami Hamdallah stated, “Palestine has preserved the values of peace and tolerance by celebrating Christmas for centuries.”116

Similarly, Vera Baboun, a Christian and the first female mayor of Bethlehem, commented in a letter in honor of the holiday season that “this is the Bethlehem we also share with the world. A Bethlehem that is a model of natural coexistence between Christians and Muslims, an example for the rest of the region.”117 However, the utopian society described by the mayor does not even hold up to inspection of the mayor’s own experiences. Baboun has been the subject of a smear campaign claiming that she had discriminated against Muslims.118  Additionally, threats have been made against her and her family.119 Following these events, Baboun filed a complaint with the PA that was subsequently withdrawn following the intimidation of Fatah’s armed wing, the Aqsa Martyrs Brigades.120

PA President Mahmoud Abbas recently stated:

Christians are not a minority here: they are an integral part of the Palestinian people. Orthodox, Catholics, Armenians, Assyrians, Lutherans, Anglicans, Copts, Melkites, Protestants and others are all part of the rich mosaic of this free, sovereign, democratic and pluralistic Palestine we aspire to have and as established in our declaration of independence and draft constitution.121

Abbas’ invocation of the Palestinian Draft Constitution in support of the Palestinians purported commitment to human rights is rather peculiar considering that Article 7 of the Constitution provides that “The principles of the Islamic shari`a are a main source for legislation.”122

Yasser Arafat also made similar statements. In 1996, he claimed his people “have decided to celebrate with the Christian brothers, all Arabs and all friends in the world the 2,000th anniversary of the birth of Jesus Christ in a world religious celebration.”123 It should be remembered that this is the same Arafat who promptly after the PA gained control of Bethlehem converted the Greek Monastery next to the Church of the Nativity into his official residence and drastically altered the municipal boundaries of Bethlehem in order to marginalize the city’s Christian residents.124


Palestinian President Mahmoud Abbas, center, is welcomed by the Latin Patriarch of Jerusalem, Fouad Twal, at the Church of Nativity on Christmas Eve, Wednesday, Dec. 25, 2013.


Religious leaders echoed similar sentiments. The Bishop Alexius of the Roman Orthodox Church in Gaza praised the Hamas government, stating, “Hamas and its government are keen to maintain the security of the Church and the Gaza Strip [where]…our people experience a general sense of safety, even better than before.…The Palestinian government in Gaza has confirmed that it does not discriminate against Christians in the Gaza Strip on a religious basis.”125 Hamas media adviser, Taher Al-Nunu, similarly noted, “The Christians in Gaza are living in safety just like their Muslims brothers.”126

When one compares these statements to the reality of the everyday life of Palestinian Christians, the persistence of the long-established pervasive persecution of Palestinian Christians quickly becomes apparent.

The Reality of Christian Life under the PA and Hamas Leadership

When one compares these statements to the reality of the everyday life of Palestinian Christians, the  persistent and pervasive persecution of Palestinian Christians quickly becomes apparent. While rarely attracting media attention, this persecution has been documented since the early day of Palestinian self-administration in the 1990s. Sadly, numerous recent examples of such persecution can be seen.

  • In July 2013, it was reported that the St. Lazarus Monastery in Bethany (al-Eizariya) had been the subject of attacks including theft and stone throwing.127 The attacks stemmed from a dispute with a local Muslim family that asserted ownership of Monastery land.128 The monastery’s Mother Superior has appealed directly to PA President Abbas,129 clearly demonstrating that the chance of obtaining legal recompense were next to nothing.
  • In December 2013, Christian residents of Bethlehem spoke of the hostile environment they are forced to live in. One Christian told of how her friend was forced to flee Bethlehem after being accused of selling her land to Jews.130 The Palestinian Land Law prescribes the death penalty for the crime of selling land to Jews.131 This prohibition is regarded as applying to the selling of land to Christians as well and is applied and enforced in that manner. Ramzi, a Christian, described how he was threatened with death if he sold his land to Christians.132  Pastor Isa Bajalia, an evangelical pastor, described a similar case where two men, one a member of the Tanzin militia group, attempted to extort him in exchange for his land. He stated, “It’s like the mafia.…He says if I pay him $30,000 and assign the land over to him, he’ll get off my back.”133 Pastor Bajalia has been forced to flee to the United States.134  As will be described below, this incident is in clear violation of the Palestinian Authority’s legal obligations. Article 17 of the Universal Declaration on Human Rights protects “everyone’s right to own property.”135 Additionally, as with similar Pakistani laws, this PA law violates Article 6 of the International Covenant on Civil and Political Rights, which limits the use of the death penalty to the most “serious crimes.”136
  • In April 2013, arsonists set fire to the Christian Holy Family School in Gaza.137 A couple months later in June, in a further case of the imposition of extremist Islamic ideology, five Christian schools in Gaza were faced with closure following a government order forbidding mixed gender institutions.138 While the order applies to all schools, the five Christian schools are the only coed schools in Gaza.139
  • In July 2012, a Jericho court sentenced a man to a month of imprisonment for eating in public during Ramadan.140 Five other people were also arrested for the same conduct.141 On a related note, Sheikh Yusuf Ida’is, Chairman of the PA Supreme Court for Shari’ah Law, stated “[W]e have to monitor the streets and severely punish anyone who [eats] in public during Ramadan, and this is the responsibility of the security forces.…I call upon others [non-Muslims] to be considerate of Muslims’ feelings.”142 One should take note of the Sheik’s use of the word “considerate.” One would think that as Christians represent a miniscule minority in an overwhelmingly Muslim environment, that Muslims should be the ones being “considerate” to the vulnerable minority among them.
  • In June 2012, a young girl reciting a poem on a children’s program broadcasted on official Palestinian Authority TV,  stated, “They [Christians and Jews] are inferior and smaller, more cowardly and despised.”143
  • In 2006, Hamas and Islamic Jihad gunmen set fire to the YMCA headquarters in the Hamas-controlled city of Qalqiliya.144 One source in the city commented: “The identity of the attackers is well known to Hamas. We don’t expect the Hamas-controlled police, the Hamas city council or the Hamas Interior Ministry to do anything about this attack.”145
  • In February 2008, gunmen attacked the YMCA library in the Gaza Strip.146 The gunmen first kidnapped two of the library’s guards and then proceeded to detonate a number of explosives.147 The attack, which destroyed the library, was reportedly in response to the publication of Danish cartoons “ridiculing” the Prophet Mohammed.148


Palestinians examine the damage to the library of the YMCA in Gaza City, Friday, Feb. 15, 2008.


dead man

In this July 16, 2012, photo, a Palestinian Christian holds a poster of Ramez
Al-Amash, 25, during a rally at a Greek Orthodox church in Gaza City.


  • In May 2013, Steve Khoury, Pastor of the First Baptist Church of Bethlehem, told of the continuous harassment Christians have faced and the subsequent fear that has lead Christians to refrain from wearing crosses in public and carrying Bibles.149 Khoury further described the general sense of intimidation felt by Christians in Palestinian society, stating, “People are always telling them, ‘Convert to Islam. Convert to Islam. It’s the true and right religion.’”150 The First Baptist Church of Bethlehem has been firebombed 14 times.151
  • In October 2007, Rami Ayad, a Christian and owner of a Gaza book-store, was abducted and murdered, after having been publicly accused of missionary activities.152
  • In July 2012 according to the Greek Orthodox Church in Gaza, five Christians were kidnapped and forcibly converted to Islam.153 One of those Christians, Ramez Al-Amash, was allegedly kidnapped from his home and prevented from contacting family.154 An Islamic group released a video of Al-Amash declaring that he had converted voluntarily.155 After Al-Amash’s mother had fallen ill, his family succeeded in contacting the kidnappers and arranging a meeting at the hospital.156 Al-Amash was accompanied by gunmen to the meeting and was then taken to an unknown location.157 Al-Amash’s parents lodged a complaint with the Hamas police to no avail.158 In a press release, the Greek Orthodox Church claimed that the police refused to intervene due to the involvement of an Islamic religious leader and Hamas representative of the Palestinian parliament, Salam Salameh, in the events.159 Local Christians have accused the organization that Salameh chairs, the Hamas affiliated Palestine Scholars Association, as being responsible for the conversions.160 Following these events, Josef Elias, a Christian from Gaza City, stated, “We aren’t safe anymore.…This is a conspiracy against our existence in the Holy Land.”161
  • Samir Qumsieh, a Christian community leader from Beit Sahour near Bethlehem, spoke in December 2013 of the discrimination the Christian community faces. He provided a subtle example that is reflective of the extensive persecution of Christians. Qumsieh presented several souvenirs sold around Manger Square in Bethlehem, such as a FC Barcelona soccer ball and a t-shirt showing the Church of Nativity. The crosses that normally appear on both items were removed.162 This is not a new phenomenon, as Qumsieh spoke of the removal of the cross from souvenirs already in 2010.163
  • In a 2007 interview, Qumsieh described how Christians often “have their land stolen by the [Muslim] mafia.”164 He described how Muslim gangs forge documents attesting to their ownership of Christian owned land. When Christian owners resist, they are often beaten. Qumsieh’s own home was firebombed after publicly speaking about the Christian community’s suffering.165
  • In December 2013, the owner of a religious novelty store described the regular defacement of Christian property. He stated, “We are harassed, but you wouldn’t know the truth. No one says anything publicly about the Muslims. This is why Christians are running away.”166

It should be noted that while the examples above may not be as alarming as the experiences of Christians in Iraq, Syria, Iran, Pakistan, and Egypt, they are reflective of the greater prevailing atmosphere of persecution experienced by Palestinian Christians at the hands of their own leadership.

Christian Denial and Self-Blame

Perhaps the most saddening aspect of this persecution is the denial of it by Christian leaders and their disconnect from the members of their community. Qumsieh referred to Palestinian leaders as cowards more interested in the Palestinian cause against Israel than their community’s own issues.167 He stated, “If somebody claims that there is no discrimination, he is a liar.” He added, “[The mayor of Bethlehem] said everything is okay. Of course. In her position she can’t say anything else.”168 On another occasion, Qumsieh stated, “The future of Christianity here is gloomy and anyone claiming otherwise is wrong….Extremism is expanding and we, the Christians, are the weakest link in the chain.”169 A Palestinian journalist, Abd Al-Nasser Al-Najjar, similarly noted “Let us be honest with ourselves and courageously say out loud that Palestinian Christians are taking many severe blows, yet are suffering in silence so as not to attract attention.”170  He added, “Despite all the injustices [against the Christians], no one has seen or heard of any constructive action to curb it and to [defend] the Christians’ rights – whether by the elites, by any of the three branches (executive, legislative, and judiciary), by non-government organizations, or even by the political factions themselves.”171

In addition to denying and ignoring the plight of their own people, many Christian leaders go one step further in placing the blame for Christian persecution onto Israel. While speaking during his annual “Christmas message,” the Latin Patriarch of Jerusalem, Foud Twal, used the opportunity to point the finger at Israel for Christian suffering. The Patriarch stated, “The scenarios in Syria and Iraq can be repeated elsewhere, as seen in Egypt and Libya. The instability affects everyone, but especially our faithful who are tempted to emigrate.”172 The Patriarch continued, stating, “the Israeli-Palestinian talks resumed in late July, after three years of interruption. But the efforts are hampered by the continuous building of Israeli settlements. As long as this problem is not resolved, the people of our region will suffer.”173

Similar sentiments were expressed in literature published in honor of Christmas by the UK-based Amos Trust, which stated:

If Jesus was born today in Bethlehem, the Wise Men would spend several hours queuing to enter the town.…The shepherds, despite being residents of Bethlehem, would struggle to graze their sheep because their land would be annexed by the building of the separation wall [Israeli security fence], and a lack of freedom to travel and restrictions on trade would make it very difficult for them to make a living.174

The Palestinian Authority’s Human Rights Obligations

Article 18 of the PA Draft Constitution provides that “The state of Palestine shall abide by the Universal Declaration of Human Rights and shall seek to join other international covenants and charters that safeguard human rights.”175 Article 2 of the Declaration states, “Everyone is entitled to all the rights and freedoms set forth in this Declaration, without distinction of any kind, such as…religion.”176 Furthermore, Article 7 states, “All are equal before the law and are entitled without any discrimination to equal protection of the law…and against any incitement to such discrimination.”177 In addition to prohibiting incitement, this Article serves to extend the protection of the Declaration to discrimination of any kind, even that regarding rights and freedoms that are absent from the Declaration.178 Article 17 states that “everyone has the right to own property.”179

Article 18 of the Universal Declaration of Human Rights says that “everyone has the right to freedom of thought, conscience and religion; this right includes freedom to change his religion or belief, and freedom, either alone or in community with others and in public or private, to manifest his religion or belief in teaching, practice, worship and observance.”180  The PA is also obligated to protect fundamental human rights under the 2003 Palestinian Basic Law, which serves as the PA’s interim constitutional document.181 Article 10 of the Basic Law provides that “Basic human rights and liberties shall be protected and respected” and that “The Palestinian National Authority shall work without delay to become a party to regional and international declarations and covenants that protect human rights.”182 More explicitly, Article 8 of the previous 1995 Basic Law, states that the PA “recognizes and respects the fundamental human rights and freedoms prescribed in the Universal Declaration of Human Rights [and] the International Covenant on Civil and Political Rights.”183

Article 18 of the PA Draft Constitution provides that “The state of Palestine shall abide by the Universal Declaration of Human Rights and shall seek to join other international covenants and charters that safeguard human rights.”

An additional source of the PA’s Human Rights obligations is found in the Barcelona Declaration, to which the PA is a party. The Declaration provides that members undertake to act in accordance with the Universal Declaration of Human Rights and “respect human rights and fundamental freedoms and guarantee the effective legitimate exercise of such rights and freedoms.”184 Further sources can also be found in various declarations and agreements that the PA has signed with Israel.185

While the PA is not a sovereign state and consequently a party to the above treaties, it would be highly indisposed to on the one hand assume the responsibilities of governance while on the other hand look for a way out of complying with the law, which it purportedly adopted. If territorial non-state actors,186 such as the PA, are to “claim a right to become states by virtue of the right to self-determination, they cannot in good faith reject the applicability of norms that attach to statehood.”187 Moreover, international tribunals have recognized that unilateral declarations “may have the effect of creating legal obligations.”188  However, as it may be questioned whether non-state actors are capable of binding themselves under international human rights law, at the least, such unilateral undertakings may serve to stop the PA from denying its human rights obligations in certain circumstances.189

The PA’s human rights obligations have also been recognized by the UN Human Rights Council, which has stated that the PA has “declared their commitment to respect international human rights law” and is “bound to respect international human rights standards.”190 Moreover, the Human Rights Council has stated in regard to the PA that “it is clear that non-State actors that exercise government-like functions over a territory have a duty to respect human rights.”191 It should be noted that some have argued that such a rule has not yet attained the status of customary international law.192

The PA’s human rights obligations have also been recognized by the UN Human Rights Council, which has stated that the PA has “declared their commitment to respect international human rights law” and is “bound to respect international human rights.

Hamas’ Human Rights Obligations

Hamas has also bound itself to abide by international human rights standards. In July 2009, Hamas formally stated to the UN Fact-Finding Mission on the Gaza Conflict (Goldstone Report) that “they accepted the obligation to respect human rights and fundamental freedoms, including those enshrined in the Universal Declaration of Human Rights and Palestinian Basic Law.”193 Similarly, in the text of its 2007 National Unity Government program, Hamas committed to “respect…public liberties; to strengthen the establishment of democracy; to protect human rights…insofar as they conform with our character, customs and original traditions.”194 Lastly, in a speech given in 2006, Hamas Prime Minister Ismail Haniya stated that Hamas is determined “to promote…the respect for human rights, the equality among citizens; to fight all forms of discrimination; to protect public liberties, including the freedom of the press and opinion.”195

Additionally, the UN Human Rights Council has also recognized that “the Gaza authorities have an obligation to respect and enforce the protection of the human rights of the people of Gaza, in as much as they exercise effective control over the territory, including law enforcement and the administration of justice.”196 However, one should take note that the Human Rights Council made this determination on the basis of the language of a previous Human Rights Council Report197 that appears to have been intended as matter of lex ferenda that does not seem to reflect customary law.198

Hamas has also bound itself to abide by international human rights standards. In July 2009, Hamas formally stated to the UN Fact-Finding Mission on the Gaza Conflict (Goldstone Report) that “they accepted the obligation to respect human rights and fundamental freedoms, including those enshrined in the Universal Declaration of Human Rights and Palestinian Basic Law.”


Muslim states such as Egypt, Syria, Iran, Iraq, and Pakistan are obligated to protect the basic rights and freedoms of their Christians citizens. They have clearly failed to live up to the liberal values they have assumed upon themselves.

To contrast the treatment of the freedom of religion in those States described above, it should be noted that Israel, as a democracy with an independent and competent judiciary, has from its inception protected the fundamental rights and freedoms of all its citizens.Thus, while not explicitly enumerated in the 1992 Basic Law: Human Dignity and Liberty, a document of constitutional status, Israeli courts have recognized the freedom of religion as an inalienable and fundamental right of all citizens.199 The true realization of these values is demonstrated by the fact that a Christian Arab, Justice Salim Joubran, serves on the Israeli Supreme Court.200

Muslim states such as Egypt, Syria, Iran, Iraq, and Pakistan are obligated to protect the basic rights and freedoms of their Christians citizens. They have clearly failed to live up to the liberal values they have assumed upon themselves.

The Christians of the Middle East are suffering from debilitating persecution. The Muslim states described above have neglected and abused the most fundamental rights and freedoms of their most vulnerable citizens. In doing so, they have not only violated the very legal obligations they have assumed but also have violated the very values cherished by democracies the world over. The recalcitrance of these states to enforce international human rights standards has made them perpetrators and accomplices to a multitude of human rights abuses.

The behavior of these states is an affront to the international community. The definition of the crime of genocide includes deliberately inflicting on a religious group “conditions of life calculated to bring about its physical destruction in whole or in part.”201 Christians are being systematically persecuted across the Middle East, the result being the termination of communal Christian life in the Middle East. As one Palestinian Christian stated, “We aren’t safe anymore.…[T]his is a conspiracy against our existence in the Holy Land.”202  While the situation of Christians today does not amount to genocide, it is nonetheless alarming and disturbing. Left unchecked, this persecution is liable to lead to another mass exodus of a minority from the Middle East. It is evident that after Jews were driven from the Muslim states of the Middle East in the 20th century, that Christians are the next minority on the chopping block in the 21st century.

Christians are being systematically persecuted across the Middle East, the result being the termination of communal Christian life in the Middle East.

This eradication of minorities is of even more significance in light of the present turbulent times of the post-Arab Spring Middle East. Many states throughout the Muslim world are experiencing periods of governmental upheaval and change.

Our modern concepts of freedom and liberty have deep roots in Jewish scripture and the writings of early Christians.203 Medieval scholastics and Protestant reformers were essential in developing our modern concept of universal human dignity and freedom.204 The early Christian thinker Tertullian was the first to coin the phrase “religious liberty” and argued that religious liberty is a universal right of all people without any distinction such as race and creed.205 As a visible minority group in the Middle East, Christians bring a measure of diversity and pluralism to overwhelmingly Muslim societies.

The case of Palestinian Christians presents a unique opportunity to deal with such human rights abuses before they become fully entrenched with the backing of a state.

Thus, Christians have an essential role in stimulating the growth and development of pluralism and democratic values in the region. Consequently, it is essential that the treatment and rights of Christians be part of the current public discourse on the character and makeup of these states. True democratization will never be attained if the human rights abuses against Christians are swept under the rug.

The case of Palestinian Christians presents a unique opportunity to deal with such human rights abuses before they become fully entrenched with the backing of a state. The PA and Hamas (in Gaza) are obligated to protect the fundamental freedoms of their Christian citizens. The PA professes to the world its yearning and right to statehood, but as described, it has not lived up to the liberal values expressed in the foundational documents of the would-be Palestinian state.

However, while the seeds have been planted, there is still time to take action before they fully take root. Therefore, the question we must ask ourselves is, will Palestinian efforts for statehood lead to another state where minorities are brutally persecuted until they slowly cease to exist, or to a liberal state such as Israel where such minorities are accorded the rights and freedoms to which they are entitled?

Pope Francis is set to arrive in the Middle East this May. If this persecution persists, the next time a Pope visits the region, he may have no flock left to tend.


* * *


*The author wishes to express his appreciation to Gilad Lindenfeld and Ilia Binjamin for their contributions to this project.

1.    Peter Bergin and Jennifer Rowland, A post-Christian Middle East?, CNN (Aug. 22, 2013, 9:57 PM), http://edition.cnn.com/2013/08/22/opinion/bergen-post-christian-middle-east/; Regional Distribution of Christians, PEW RESEARCH CENTER, (Dec. 19, 2011), http://www.pewforum.org/2011/12/19/global-christianity-regions/.

2.     RUPERT SHORTT, CHRISTIANOPHOBIA, viii (2012), available at http://www.civitas.org.uk/pdf/Shortt_Christianophobia.pdf.

3.     Edward Malnick, Christianity ‘Close to Extinction’ in Middle East, TELEGRAPH, Dec. 23, 2012, http://www.telegraph.co.uk/news/religion/9762745/Christianity-close-to-extinction-in-Middle-East.html; See also Daniel Pipes, Disappearing Christians in the Middle East, 8.1 MIDDLE EAST QUARTERLY (2001), available at http://www.danielpipes.org/1050/disappearing-christians-in-the-middle-east.

4.     Eric J. Lyman, Pope Francis Announces Plans to visit Middle East in May, JERUSALEM POST, Jan. 5, 2014, http://www.jpost.com/Diplomacy-and-Politics/Pope-Francis-announced-plans-to-visit-Middle-East-in-May-337123.

5.     Pope Denounces Discrimination, Violence Against Christians, REUTERS (Dec. 26, 2013, 1:14 PM), http://uk.reuters.com/article/2013/12/26/uk-pope-christians-idUKBRE9BP08U20131226.

6.     Kevin Rawlinson, Prince Charles ‘deeply troubled’ by plight of Christians in Middle East, GUARDIAN, Dec. 18, 2013, http://www.theguardian.com/world/2013/dec/18/prince-charles-christians-middle-east-crisis.


8.     Regional Distribution of Christians, supra note 1. It should be noted that most sources tend to provide figures around 10 percent, however it has been found that such accounts were based on flawed methodology. While not perfect, the finding of 5.3 percent appears to be most correct. (M.K. Tozman, A short overview of the status quo of Christian Minorities in Egypt, Iraq, Turkey, Syria and Lebanon, WORLD WATCH MONITOR 3, http://www.worldwatchmonitor.org/research/ChristianMinorities (last visited Apr. 3, 2014).)

9.     Christianity in its Global Context, 1970 -2020: Society, Religion and Mission, CENTER FOR STUDY OF GLOBAL CHRISTIANITY 42 (June 2013), http://wwwgordonconwell.com/netcommunity/CSGCResources/ChristianityinitsGlobalContext.pdf.

10.  Guide to Christians in the Middle East, BBC (Oct. 11, 2011), http://www.bbc.co.uk/news/world-middle-east-15239529; International Religious Freedom Report for 2011: Syria, BUREAU OF DEMOCRACY, HUMAN RIGHTS AND LABOR, http://www.state.gov/j/drl/rls/irf/2011religiousfreedom/index.htm?dlid=192697#wrapper (last visited Apr. 3, 2014); Regional Distribution of Christians, supra note 1.

11.  Christianity in its Global Context, supra note 9; Guide to Christians in the Middle East, supra note 10.

12.  Regional Distribution of Christians, supra note 1.

13.  Shortt, supra note 2, at 9.

14.  Christianity in its Global Context, supra note 9.

15.  Guide to Christians in the Middle East, supra note 10.

16.  Pope Denounces Discrimination, Violence Against Christians, supra note 5.

17.  Kenn Starr, No tolerance without Christians, USA TODAY, Dec. 16, 2011, http://www.usatoday.com/story/opinion/2013/12/13/christianity-middle-east-persecution-column/4010181/.

18.  Raymond Ibrahim, More Slaughter in Muslim Lands; Media, Governments Silent, GATESTONE INSTITUTE (Dec. 17, 2013, 4:00 AM), http://www.gatestoneinstitute.org/4093/slaughter-in-muslim-lands; Laura King, Egypt’s Coptic Christians Feel Vulnerable Amid Nation’s Upheaval, L.A. TIMES, Dec. 25, 2013, http://www.latimes.com/world/la-fg-egypt-copts-20131225,0,2433836.story#axzz2oVmB2zWc.

19.  Lives of Fear for Egypt’s Christians, BBC (Dec. 23, 2013, 3:54 PM), http://www.bbc.co.uk/news/world-middle-east-25489001.

20.  Id.

21.  Id.

22.  Cairo, Police Fled Before the Attack on the Church of Virgin Mary, ASIA NEWS (Oct. 23, 2013 12:40 PM), http://www.asianews.it/news-en/Cairo,-police-fled-before-the-attack-on-the-church-of-the-Virgin-Mary-29353.html.

23.  Mary Abdelmassih, Egyptian Court Acquits Muslim Who Beheaded a Christian, AINA (March 4, 2010, 3:56 AM),  http://www.aina.org/news/20100303215642.pdf.

24.  Id.

25.  Id.

26.  Id.

27.  Id.

28.  Id.

29.  Kristen Chick, Egypt’s Christians Close Ranks as Kidnappings Spike, CHRISTIAN SCIENCE MONITOR (Nov. 12, 2013), http://www.csmonitor.com/World/Middle-East/2013/1112/Egypt-s-Christians-close-ranks-as-kidnappings-spike.

30.  The Al-Kalimah Center for Human Rights is an Egyptian human rights organization that advocates and provides legal assistance in regard to religious freedoms, journalists’ rights, the rights of women and the poor. The Center’s work focuses on the Egyptian Coptic community. (Jonas Rye Nielson & Sandy Neubert, Human Rights Organizations in Egypt, ARAB-WEST REP. 25 (May 2009), http://www1.umn.edu/humanrts/research/Egypt/Human%20Rights%20Organizations.pdf.)

31.  After Retaking of Delga, Christians Terrorized in Other Towns in Egypt, CHRISTIAN TODAY (Nov. 27, 2013, 7:12 AM), http://au.christiantoday.com/article/after-retaking-of-delga-christians-terrorized-in-other-towns-in-egypt/16535.htm.

32.  Egypt’s Christians Close Ranks as Kidnappings Spike, supra note 29.

33.  After Retaking of Delga, Christians Terrorized in Other Towns in Egypt, supra note 31.

34.  Raymond Ibrahim, Jihad on Egypt’s Christian Children, GATESTONE INSTITUTE (June 3, 2013, 3:30 AM), http://www.gatestoneinstitute.org/3744/egypt-christian-children.

35.  Id.

36.  Persecution of Christians: No Room at the Inn, GUARDIAN, Dec. 23, 2013, http://www.theguardian.com/commentisfree/2013/dec/23/persecution-christians-religion-editorial.

37.  Raymond Ibrahim, Brotherhood Imposes Jizya Tribute on Egypts Christians, RAYMOND IBRAHIM (Sept. 8, 2013), http://www.raymondibrahim.com/muslim-persecution-of-christians/brotherhood-imposes-jizya-tribute-on-egypts-christians/.

38.  Raymond Ibrahim, A Month of Horror for Christians Under Islam: Sept. 2013, GATESTONE INSTITUTE (Dec. 2, 2013) http://www.gatestoneinstitute.org/4065/september-horror-christians-islam.

39.  Mary Abdelmassih, Two Christians Murdered in Egypt for refusing to Pay Jizya to Muslims, AINA (Sept. 13, 2013, 7:37 PM), http://www.aina.org/news/20130913143703.htm.

40.  Id.

41.  Id.

42.  Michal Shmulovich, Egypt: Coptic Church Cancels Sunday Mass for First Time in 1,600 Years, TIMES ISRAEL (Aug. 20, 2013, 1:27 AM), http://www.timesofisrael.com/?p=641792.

43.  Mary Abdelmassih, Coptic Pope Blasts Muslim Brotherhood, US, EU, AINA (Aug. 18, 2013, 5:54 PM), http://www.aina.org/news/20130818125428.htm.

44.  Douglas Alexander, Christians Left by the World to Suffer, TELEGRAPH, Dec. 21, 2013, http://www.telegraph.co.uk/news/religion/10531964/Christians-left-by-the-world-to-suffer.html.

45.  Alex Newman, World Turns Away as Rebel Massacres of Syrian Christians Intensify, NEW AM. (Dec. 20, 2013, 6:00 PM), http://www.thenewamerican.com/world-news/asia/item/17229-world-turns-away-as-rebel-massacres-of-syrian-christians-intensify.

46.  Id.

47.  A Metropolitan (also referred as Archbishop) is a high level official in the clergy of the Syrian Orthodox Church who is third in line in the Church’s hierarchy. (Constitution of the Syriac Orthodox Church of Antioch, SYRIAC ORTHODOX CHURCH ANTIOCH, http://www.soc-wus.org/ourchurch/constitutioneng.html (last visited April 6, 2014).)

48.  Devastating Images & Report from the Christian Town of Sadad in Syria – Exclusive, ORTHODOX CHURCH (Oct. 31, 2013), http://theorthodoxchurch.info/blog/news/2013/10/devastating-images-report-from-the-christian-town-of-sadad-in-syria-exclusive/.

49.  Stephen J. Bos, News Alert: Syria’s Anxious Christians Urge Prayers for Troubled Peace Talks, BOS NEWS LIFE (Jan. 20, 2014, 2:50 PM), http://www.bosnewslife.com/31729-news-alert-syrias-anxious-christians-urge-prayers-for-troubled-peace-talks.

50.  Id.

51.  Id.

52.  Id.

53.  Syrian Rebels Destroy Church in Al-Thawrah, AINA (August 9, 2013, 6:12 PM), http://www.aina.org/news/2013089111228.htm.

54.  Syrian Opposition Fighters Seize Nuns, GUARDIAN, Dec. 3, 2013, http://www.theguardian.com/world/2013/dec/03/syrian-opposition-fighters-seize-nuns.

55.  Raymond Ibrahim, Syria: Armenian Christians Forced to Convert to Islam or Die, CHRISTIAN POST (Jan. 17, 2014, (9:37 AM), http://www.christianpost.com/news/syria-armenian-christians-forced-to-convert-to-islam-or-die-112841/.

56.  Raymond Ibrahim, The Degradation of Christian Women Under Islam, GATESTONE INSTITUTE (Sept. 11, 2013, 5:00 AM), http://www.gatestoneinstitute.org/3967/christian-women-degradation-islam.

57.  Id.

58.  Islamic Law Takes Hold in Northern Syria: Singing, Smoking and Pictures Banned, JERUSALEM POST, Jan. 20, 2014, http://www.jpost.com/Middle-East/Islamic-law-takes-hold-in-northern-Syria-Singing-smoking-and-pictures-banned-338771.

59.  Id.

60.  Syria Crisis: ISIS imposes rules on Christians in Raqqa, BBC (Feb. 27, 2014), http://www.bbc.com/news/world-middle-east-26366197.

61.  http://www.christianpost.com/news/syrian-jihadist-slits-throat-of-christian-man-refusing-to-deny-christ-then-taunts-fiancee-jesus-didnt-come-to-save-him-104498/

62.  Id.

63.  Id.

64.  A Month of Horror for Christians Under Islam: Sept. 2013, supra note 38.

65.  Raymond Ibrahim, Two Churches Attacked in Syria: Crosses Broken and Al-Qaeda Flag Raised, RAYMOND IBRAHIM (Sept. 27, 2013), http://www.raymondibrahim.com/from-the-arab-world/two-churches-attacked-syria-crosses-broken-and-al-qaeda-flags-raised/.

66.  Nina Shea, Persecution at Christmastime, NAT’L REV. (December 24, 2013, 4:00 AM), http://www.nationalreview.com/article/366956/persecution-christmastime-nina-shea.

67.  Paul Richter, U.S. Condemns Christmas Attacks that Kill 37 Christians in Iraq, L.A. TIMES, Dec. 25, 2013, http://www.latimes.com/world/worldnow/la-fg-wn-us-christmas-attacks-christians-iraq-20131225,0,7194958.story?track=rss#axzz2oVmB2zWc.

68.  Perry Chiamonte, Christians, Churches Dwindling in Iraq Since Start of War 10 Years Ago, FOX NEWS (Mar. 21, 2013), http://www.foxnews.com/world/2013/03/21/catholic-churches-dwindle-in-iraq-since-start-war-10-years-ago/#ixzz2ULvjxNuv.

69.  Cristina Corbin, Christmas a Day of Terror for Christians in Iraq, Says Human Rights Groups, FOX NEWS (Dec. 23, 2013), http://www.foxnews.com/world/2013/12/23/christmas-day-terror-for-christians-in-iraq-say-human-rights-groups/.

70.  Ernesto Londoño and Aziz Alwan, 51 Iraqi Worshippers, 7 Troops Killed in Church Siege, WASH. POST, Nov. 1, 2010, http://www.washingtonpost.com/wpdyn/content/article/2010/10/31/AR2010103101395.html.

71.  Id.

72.  Id.

73.  Christa Case Bryant, As Syria’s War Rages, Region’s Christians Hold Their Breath, CHRISTIAN SCIENCE MONITOR (Sept. 8, 2013), http://www.csmonitor.com/World/Middle-East/2013/0908/As-Syria-s-war-rages-region-s-Christians-hold-their-breath.

74.  Id.

75.  Id.

76.  Paul marshall, Lela Gilbert And Nina Shea, Persecuted: The Global Assault On Christians, 233-234 (2013).

77.  Id.

78.  Two Christians Wounded in Church Attack, Another Killed in Store Bombing, MORNING STAR NEWS (Jue 28, 2013), http://morningstarnews.org/2013/06/two-christians-wounded-in-church-attack-in-iraq-another-killed-in-store-bombing/.

79.  Id.

80.  Persecuted, supra note 77, at 230.

81.  78 Killed, Over 100 Injured in Peshewar Church Attack, EXPRESS TRIBUNE (Sep. 22, 2013), http://tribune.com.pk/story/607734/fifteen-dead-in-suicide-attack-outside-peshawar-church/.

82.  Rash of Blasphemy Accusations After Pakistan Church Bombings, CHRISTIAN POST (Nov. 29, 2013), http://crossmap.christianpost.com/news/rash-of-blasphemy-accusations-after-pakistan-church-bombings-7002.

83.  Id.

84.  See Pakistan Blasphemy Laws: A Fact Sheet, EUROPEAN EXTERNAL POLICY ADVISORS 2, http://www.eepa.be/wcm/dmdocuments/EP_Hearing_Pakistan/Blasphemy_law_fact_sheet.pdf.

85.  Id.  at 1.

86.  Blasphemy Laws Terrorize Pakistani Christians, PERSECUTION: INT’L CHRISTIAN CONCERN (Nov. 24, 2013), http://www.persecution.org/2013/11/24/blasphemy-laws-terrorize-pakistani-christians/.

87.  Id.

88.  Id.

89.  Lahore, More than 100 Christian Homes Burned Over Blasphemy Charge, ASIA NEWS (Sept. 3, 2013, 2:36 PM), http://www.asianews.it/news-en/Lahore,-more-than-100-Christian-homes-burned-over-blasphemy-charge-27347.html.

90.  Infran Ahmed, Christians Feel the Heat of Religious Intolerance, INTER PRESS SERVICE (Apr. 28, 2013), http://www.ipsnews.net/2013/04/christians-feel-the-heat-of-religious-intolerance-2/.

91.  Lahore, More than 100 Christian Homes Burned Over Blasphemy Charge, supra note 89.

92.  Id.

93.  Christians Feel the Heat of Religious Intolerance, supra note 90.

94.  http://www.catholicculture.org/news/headlines/index.cfm?storyid=18092.

95.  Christians Feel the Heat of Religious Intolerance, supra note 90.

96.  Id.

97.  Benjamin Weinthal, Iran Gives Christians 80 Lashes for Communion Wine as UN Blasts Human Rights Record, FOX NEWS (Oct. 27, 2013), http://www.foxnews.com/world/2013/10/27/iran-gives-christians-80-lashes-for-communion-wine-as-un-blasts-human-rights/.

98.  Christians Sentenced to Prison as Moderate Comes to Power, MORNING STAR NEWS (June 19, 2013), http://morningstarnews.org/2013/06/christians-sentenced-to-prison-as-moderate-comes-to-power-in-iran/.

99.  Id.

100.   Chapter IV 4, Multilateral Treaties Deposited with the Secretary-General, UNITED NATIONS TREATY COLLECTION, https://treaties.un.org/Pages/ViewDetails.aspx?mtdsg_no=IV-4&chapter=4&lang=en (last visited Apr. 7, 2014).

101.   International Covenant on Civil and Political Rights art. 18, Dec. 16, 1966, 993 U.N.T.S. 171. [Hereinafter ICCPR].

102.   Id.

103.   Id. §4.

104.   Id. §2(3).

105.   Id. §26.

106.   Id. §6.

107.   Id. §27.

108.   See Draft Articles on Responsibility of States for Internationally Wrongful Acts, §9 & §10, Rep. of the Int’l Law Comm’n, 53rd Session, UN Doc. A/56/10; UN GAOR, 56th Sess., Supp. No. 10 (2001).

109.   22 U.S.C. §6401(b) (1998).

110.   See Id. §6441 and §6442.

111.   See Id. §6402(11).

112.   See Id. §6402(13).

113.   See Id.

114.   See Id. §6445.

115.   Rome Statute of the International Criminal Court art. 7, 2187 U.N.T.S. 90. [Hereinafter Rome Statute].

116.   Thousands Attend Christmas Tree Lighting Ceremony, MA’AN NEWS Agency (Jan. 12, 2003, 10:19 AM), http://www.maannews.net/eng/ViewDetails.aspx?ID=653119.

117.   Id.

118.   Khaled Abu Toameh, bethlehem’s Female Mayor Faces Smears, Threats, GATESTONE INSTITUTE (May 30, 2013, 3:00 AM), http://www.gatestoneinstitute.org/3738/bethlehem-mayor-vera-baboun.

119.   Id.

120.   Id.

121.   Abbas: Christmas is a Message of Hope for Our People’s Daily Struggle, PALESTINE NEWS NETWORK (Dec. 23, 2013, 9:23 AM), http://english.pnn.ps/index.php/national/6445-abbas-christmas-is-a-message-of-hope-for-our-people-s-daily-struggle.

122.   2003 Permanent Constitution Draft, PALESTINIANBASICLAW.ORG, http://www.palestinianbasiclaw.org/basic-law/2003-permanent-constitution-draft (last visited Apr. 7, 2014). [Hereinafter Palestinian Draft Constitution].

123.   Charles W. Holmes, Religious Disneyland, ATLANTA JOURNAL CONSTITUTION, March 30, 1996.

124.   Justus Weiner, Palestinian Crimes against Christian Arabs and their Manipulation against Israel, JCPA (Sept. 19, 2008), http://jcpa.org/article/palestinian-crimes-against-christian-arabs-and-their-manipulation-against-israel/.

125.   Orthodox Bishop: Christians are Safe and Secure in Gaza, PRAVOSLAVIE.RU (Oct. 30, 2013), http://www.pravoslavie.ru/english/65457.htm.

126.   Id.

127.   Attacks on Orthodox Monastery in Holy Land, CATHOLICCULTURE.ORG (July 17, 2013), http://www.catholicculture.org/news/headlines/index.cfm?storyid=18477.

128.   Id.

129.   Id.

130.   Aaron Klein, Media Distort, Fabricate Bethlehem Christmas, WND (Dec. 23, 2013, 9:18 PM), http://www.wnd.com/2013/12/media-distort-fabricate-bethlehem-christmas/.

131.   Justus Reid Weiner, Palestinian Christians: Equal Citizens or Oppressed Minority In a Future Palestinian State?, 7 OR. REV. INT’L L. 26, 95 (2005).

132.   Id.  at 95-96.

133.   Mark Ellis, Palestinian Pastor Vows to Continue Despite Ongoing Threats, IDENTITY NETWORK, http://www.identitynetwork.org/apps/articles/default.asp?blogid=0&view=post&articleid=39749&fldKeywords=&fldAuthor=&fldTopic=0 (last visited Apr. 7, 2014).

134.   Pastor Threatened with Violence Flees to the U.S., WORLD WATCH MONITOR (Nov. 21, 2007),  http://www.worldwatchmonitor.org/2007/11-November/newsarticle_5122.html/.

135.   Universal Declaration of Human Rights art. 17, G.A. Res. 217A (III), U.N. Doc. A/810 at 71 (1948).  [Hereinafter UDHR].

136.   ICCPR, supra note 82, §6.

137.   Christian School Gates Torched in Gaza City, MA’AN NEWS AGENCY (Apr. 14, 2014), http://www.maannews.net/eng/ViewDetails.aspx?ID=585224.

138.   Judith Sudilovsky, Five Church Schools in Gaza Face Closure After Hamas Order, CATHOLIC HERALD, June 4, 2013, http://www.catholicherald.co.uk/news/2013/06/04/five-church-schools-in-gaza-face-closure-after-hamas-order/.

139.   Id.

140.   http://palwatch.org/main.aspx?fi=157&doc_id=7196.

141.   http://palwatch.org/main.aspx?fi=157&doc_id=7196.

142.   http://palwatch.org/main.aspx?fi=157&doc_id=7196.

143.   Itamar Marcus and Barbara Cook, Six Palestinians Arrested, One Given a Month in Prison, for Eating in Public During Ramadan, PALESTINIAN MEDIA WATCH, http://www.palwatch.org/main.aspx?fi=763&fld_id=763&doc_id=6898.

144.   Aaron Klein, Palestinians Torch Qalqiliya YMCA, YNET NEWS (Nov. 11, 2006, 3:44 AM), http://www.ynetnews.com/articles/0,7340,L-3302162,00.html.

145.   Id.

146.   Khaled Abu Toameh, Gunmen Destroy Gaza Strip’s YMCA Library, Kidnap Guards, JERUSALEM POST, Feb. 17, 2008, http://www.jpost.com/Middle-East/Gunmen-destroy-Gaza-Strips-YMCA-library-kidnap-guards.

147.   Id.

148.   Id.

149.   Gary Lane, Pal. Authority: Bethlehem First Baptist Church Illegitimate, CBN News (May 14, 2012, 10:05 AM), http://blogs.cbn.com/globallane/archive/2012/05/14/pa-bethlehem-first-baptist-church-illegitimate.aspx.

150.   Dexter Van Zile, Exclusive: Baptist Church in Bethlehem Declared Illegitimate by Palestinian Authority, ALGEMEINER (Mar. 3, 2012, 1:44 PM), http://www.algemeiner.com/2012/03/13/exclusive-baptist-church-in-bethlehem-declared-illegitimate-by-palestinian-authority/.

151.   Judy Stahl, Why are Christians Really Leaving Bethlehem?, CBN News (May 8, 2008), http://www.cbn.com/cbnnews/insideisrael/2012/may/why-are-christians-really-leaving-bethlehem/.

152.   Persecuted, supra note 77, at 151.

153.   Khaled Abu Toameh, Who Will Save the Christians of the Gaza Strip?, GATESTONE INSTITUTE (July 12, 2012, 5:00 AM), http://www.gatestoneinstitute.org/3181/gaza-christians.

154.   John Black, Persecution in Gaza: Christians Face Forced Conversion in Gaza, ICEJ (Aug. 21, 2012), http://int.icej.org/news/special-reports/persecution-gaza.

155.   Id.

156.   Gaza Christians Protest ‘Kidnapping’ of Young Man, MA’AN NEWS AGENCY (July 18, 2012), http://www.maannews.net/eng/ViewDetails.aspx?ID=505148.

157.   Id.

158.   Id.

159.   Itamar Marcus & Nan Jacques Zilberdik, Controversy in Gaza Over Five Christians’ Conversion to Islam, PALESTINIAN MEDIA WATCH (July 25, 2012),http://palwatch.org/main.aspx?doc_id=7161&fi=157.

160.   Nidal Al-Mughrabi, Gaza Christians Say the Feel Pressure to Convert to Islam, NAT’L POST, July 26, 2012, http://news.nationalpost.com/2012/07/26/gaza-christians-say-they-feel-pressure-to-convert-to-islam/.

161.   Ibrahim Barzak and Diaa Hadid, Gaza Christians Fear for Future of Tiny Community, HUFFINGTON POST (July 25, 2012), http://www.huffingtonpost.com/2012/07/25/gaza-christians-fear-for-_n_1702911.html.

162.   Debra Kamin, Are Bethlehem’s Christians Losing Grip on their City, TIMES ISRAEL (Dec. 22, 2013, 3:50 AM), http://www.timesofisrael.com/are-bethlehems-christians-losing-grip-on-their-city/.

163.   Christmas in Bethlehem: The Cross Banished From Souvenirs, ASIA NEWS (Dec. 22, 2010), http://www.asianews.it/news-en/Christmas-in-Bethlehem:-the-cross-banished-from-souvenirs-20318.html.

164.   Media Distort, Fabricate Bethlehem Christmas, supra note 130.

165.   Id.

166.   Id.

167.   Are Bethlehem’s Christians Losing Grip on their City, supra note 162.

168.   Id.

169.   Elhanan Miller, Bethelehem’s Christians Put a Patriotic Spin on Christmas, TIMES Of ISRAEL (Dec. 11, 2013, 6:34 AM), http://www.timesofisrael.com/bethlehems-christians-put-a-patriotic-spin-on-a-traumatic-siege/.

170.   Palestinian Columnist: Muslims Are Harming Christian Culture, MEMRI (Nov. 12, 2008), http://www.memri.org/report/en/0/0/0/0/0/0/2950.htm.

171.   Id.

172.   http://www.israelhayom.com/site/newsletter_opinion.php?id=6725.

173.   Id.

174.   Herb Keinon, With Christmas Upon Us, ‘tis the Season to Bash Israel, JERUSALEM POST, Dec. 24, 2013, http://www.jpost.com/Diplomacy-and-Politics/With-Christmas-upon-us-tis-the-season-to-bash-Israel-335948.

175.   Palestinian Draft Constitution, supra note 123, §18.

176.   UDHR, supra note 109, at §2.

177.   Id.  §7.


179.   UDHR, supra note 109, at §17.

180.   Id.  §18.

181.   Nate Brown, The Third Draft Constitution for a Palestinian State: Translation and Commentary, PALESTINIAN CENTER FOR POL’Y AND SURVEY RESEARCH 2 (October 2003), http://www.pcpsr.org/domestic/2003/nbrowne.pdf.

182.   2003 Amended Basic Law, PALESTINIANBASICLAW.ORG, http://www.palestinianbasiclaw.org/basic-law/2003-amended-basic-law (last visited Apr. 7, 2014).

183.   1995 Basic Law – Draft by PLO, PALESTINIANBASICLAW.ORG, http://www.palestinianbasiclaw.org/basic-law/1995-plo-basic-law-draft (last visited Apr. 7, 2014).

184.   Barcelona Declaration, Euro-Meditteranian Conference, Nov. 27-28, 1995, http://www.eeas.europa.eu/euromed/docs/bd_en.pdf (last visited Apr. 7, 2014).

185.   Human Rights Council, Human Rights Situation in Gaza and Other Occupied Arab Territories, 8th Sess., ¶8, A/HRC/8/17 (June 6, 2008).

186.   Territorial non-state actors are those non-actors that “exercise effective control to the exclusion of a government.” (Dr. Yael Ronen, Human Rights Obligations of Territorial Non-State Actors, 46 CORNELL INT’L L.J. 21, 22 (2013))

187.   Dr. Yael Ronen, Human Rights Obligations of Territorial Non-State Actors, 46 CORNELL INT’L L.J. 21, 22 (2013).

188.   Nuclear Tests Case (New Zealand v. France) 1974 I.C.J. 457, ¶46 (Dec. 20).

189.   Human Rights Obligations of Territorial Non-State Actors, supra note 181, at 37.

190.   Human Rights Council, Human Rights Situation in Gaza and Other Occupied Arab Territories, 8th Sess., supra note 182, ¶8; Human Rights Council, Human Rights Situation in Palestine and Other Occupied Arab Territories, 10th Sess., ¶ 21, U.N. Doc. A/ HRC/10/22 (May 29, 2009); see also Human Rights Council, Human Rights in Palestine and Other Occupied Arab Territories, 12th Sess., ¶306, U.N. Doc. A/HRC/12/48 (Sept. 25, 2009).

191.   Human Rights Council, Human Rights in Palestine and Other Occupied Arab Territories, 12th Sess., supra note 187, ¶305.

192.   Human Rights Obligations of Territorial Non-State Actors, supra note 181, at 47-48.

193.   Human Rights Council, Human Rights in Palestine and Other Occupied Arab Territories, 12th Sess., supra note 187, ¶1370.

194.   Human Rights Council, Human Rights Situation in Gaza and Other Occupied Arab Territories, 8th Sess., supra note 187,9.

195.   Id.

196.   Human Rights Council, Human Rights in Palestine and Other Occupied Arab Territories, 12th Sess., supra note 187, ¶1369; see also Human Rights Council, Human Rights Situation in Gaza and Other Occupied Arab Territories, 8th Sess., supra note 187, ¶9 & Human Rights Council, Human Rights Situation in Palestine and Other Occupied Arab Territories, 10th Sess., ¶22.

197.   Special Rapporteur on Extrajudicial, Summary or Arbitrary Executions, Special Rapporteur on the Right of Everyone to the Enjoyment of the Highest Attainable Standard of Physical and Mental Health, Representative of the Secretary-General on Human Rights of Internally Displaced Persons, and Special Rapporteur on Adequate Housing as a Component of the Right to an Adequate Standard of Living, Mission to Lebanon and Israel, Human Rights Council, ¶ 19, U.N. Doc. A/HRC/2/7 (Oct. 2, 2006).

198.   Human Rights Obligations of Territorial Non-State Actors, supra note 181, at 46-47.

199.   HCJ 1514/01 Gur Arieh vs. The Second Authority for Television and Radio. 55(4) PD 267, 277 [1994].

200.   Justice Salim Joubran, JUDICIAL AUTHORITY, http://elyon1.court.gov.il/eng/judges/doc/CvJoubran.pdf (last visited Apr. 7, 2014).

201.   Rome Statute, supra note 89, §6.

202.   Gaza Christians Fear for Future of Tiny Community, supra note 158.

203.   No tolerance without Christians, supra note 17.

204.   Id.

205.   Id.

Justus Reid Weiner

Justus Reid Weiner received his Juris Doctor degree from the University of California at Berkeley (Boalt Hall) School of Law and his BA from Colgate University. He is a Scholar-in-Residence at the Jerusalem Center for Public Affairs. His professional publications have appeared in leading law journals and intellectual magazines. In the U.S Weiner practiced law as an associate in the litigation department of the international law firm White & Case. Weiner also served as a senior attorney at the Israel Ministry of Justice specializing in human rights and other facets of public international law.