In the International Court of Justice

Peace Palace, The Hague

Netherlands

Case concerning International Criminal Court Jurisdiction and International Criminal Law

Office of the Prosecutor, International Criminal Court

Applicant

v.

State of Israel and Hamas

Respondent

On Submission to the International Court of Justice

Memorial for the Respondent Hamas

1
 LIST OF ABBREVIATIONS

Art./ Arts. Article/s of the Rome Statute, unless stated

Chamber Pre-Trial Chamber

Hamas Harakat al-Muqawama al-Islamiya

ICC International Criminal Court

ICTJ International Center for Transitional Justice

No. Number

The Statute Rome Statute

UN United Nations

2
 I. Israel committed and continues to commit war crimes and genocide against Palestine

with Hamas resorting to means to resist and counter Israel’s attacks, all to defend and

preserve Palestine.

A. Historical precedents show that the ongoing war between Israel and Hamas is

founded on Israeli aggression.

Israel’s illegal occupation represents an unlawful use of force. Israel and its allies are using

moral obfuscation to justify the attacks of a colonial power that has evicted Palestinians from their

land. For as long as the illegal occupation persists, the occupied state and people have a continuous

right to self-preservation.

The origins of Israel’s attacks against Palestine began in 1947, when “the Partition Plan” of

the United Nations divided the British Mandate of Palestine into Arab and Jewish states.1 The

Palestinians, however, opposed this as it allotted 55% of Palestine to the Jewish state, comprising

most of the “fertile coastal region,” even if the Palestinians owned 94% of historic Palestine.2 In the

following year, Israel was formed, leading to the Arab-Israeli War.3 With the end of the war came

Israel’s victory, leaving 750,000 Palestinians displaced and the territory divided into the State of

Israel, the West Bank, and the Gaza Strip.4 Israel once again engaged in conflict with Egypt, Jordan,

and Syria in the succeeding years, seizing historic Palestine, including Gaza Strip and the West Bank.5

This thereby engendered the second forced displacement of Palestinians.6 Settlement construction

likewise commenced in the occupied West Bank and Gaza Strip, with an established “two-tier system”

where Jewish settlers were granted the rights and privileges of being Israeli citizens while Palestinians

were subject to military occupation, discrimination, and restricted political or civic expression.7

In 1987, the first Palestinian Intifada or uprising occurred, as Palestinians living in the West

Bank and Gaza Strip revolted against the Israeli government given the deaths of four Palestinians who
1
Center for Preventive Action, Israeli-Palestinian Conflict, available at
https://www.cfr.org/global-conflict-tracker/conflict/israeli-palestinian-conflict (last accessed, Nov. 25, 2023)
2
Aljazeera, What’s the Israel-Palestine conflict about? A simple guide, available at
https://www.aljazeera.com/news/2023/10/9/whats-the-israel-palestine-conflict-about-a-simple-guide?fbclid=Iw
AR3dAWUvUL3ZNirHOvj1ThNaeSpP9ckUHXnOuRYlTjfie41-h8aFn5EKEY4 (last accessed, Nov. 25, 2023)
3
Center for Preventive Action, supra note 1.
4
Id.
5
Id.
6
Aljazeera, supra note 2.
7
Id.

3
were killed after an Israeli truck collided with two vans filled with Palestinian workers.8 This sparked

the Hamas Movement, anchored in the resistance of Israeli occupation.9 The 1993 Oslo I Accords then

attempted to resolve the issue, with objectives of allowing Palestinians to govern themselves in the

West Bank and Gaza, and establishing the mutual recognition of the Palestinian Authority and Israel’s

government.10 In addition, the accords included provisions that provided for Israel’s complete

withdrawal “from 6 cities and 450 towns in the West Bank”.11

However, Palestinians began a second Intifada or uprising in 2000.12 This was on account of

their issues with Israel’s continuing control over the West Bank and the ineffective peace process, as

promises of “the first elected Palestinian government with an independent state in the West Bank and

Gaza Strip” were never met.13 Other clashes that sparked the uprising include the death of five

Palestinians and the visit of Likud opposition leader Ariel Sharon to the Al-Aqsa Mosque.14

Throughout the second Intifada, Israel initiated the reoccupation of areas belonging to the Palestinian

Authority and commenced the construction of a separation wall around the West Bank, even if the

International Court of Justice and the International Criminal Court opposed its construction.15 On top

of this, rampant settlement construction was also initiated, damaging Palestinian livelihoods and

communities.16

In 2008, 2012, 2014, and 2021, Israel continued to direct four military assaults on Gaza.17 The

aftermath resulted in the deaths of thousands of Palestinians, and the destruction of countless homes,

schools, and offices.18

B. The means that Israel and its allies have taken towards eliminating Hamas have

fuelled the ubiquity of Islamophobia

8
Id.
9
Id.
10
Center for Preventive Action, supra note 1; Aljazeera, supra note 2.
11
Id.
12
Aljazeera, supra note 2.
13
Center for Preventive Action, supra note 1; Aljazeera, supra note 2.
14
Aljazeera, supra note 2.
15
Center for Preventive Action, supra note 1.
16
Aljazeera, supra note 2.
17
Id.
18
Id.

4
 The ubiquity of Islamophobia has led to generalized stereotypes of Muslims and Palestines as

being prone to violence and terrorism. When these narratives are espoused by politicians, they falsely

equate the support of Palestinian people with support for terrorism— instilling fear and moral panic

about Muslim presence. Israel’s Prime Minister, Benjamin Netanyahu, is mostly responsible for

creating the conditions that Palestinians are resisting. His government has consistently undertaken

measures to alienate Muslims and depict them as a people who must be eliminated. This is especially

seen in his address at the U.N. General Assembly last 2014, where Netanyahu baselessly associated

Hamas and Iran with the terrorist group, ISIS or the Islamic State group.19 He then warned the

international community against signing a nuclear deal with Iran, stating that Iran’s nuclear program

will be used by Muslim militant groups.20 In the pursuit of eliminating militant groups, there is a clear

political agenda where there are “no holds barred”.21

La Viña, citing Justice Leonen, further states that successfully caricaturing a group leads to

their dehumanization, which are what Israel and its allies are fueling through their us versus them

rhetoric22. Governments, such as that of Israel, have especially employed “radical and repressive

measures” in the name of religion against those who do not “belong,” thereby transgressing the

bounds of decency and morality.23

In October, the United States, Israel’s closest ally, requested a $14.3-billion aid package from

its Congress to bolster Israel’s war against Hamas.24 Since 2016, the U.S. has already been allocating

$3.8 billion a year for Israel’s defense.25 The additional $14.3 billion, alongside President Biden’s

19
Rebecca Nelson and National Journal, Netanyahu Likens ISIS to Iran at U.N. General Assembly, Atlantic,
September 29, 2014, available at
https://www.theatlantic.com/politics/archive/2014/09/netanyahu-likens-isis-to-iran-at-un-general-assembly/4513
86/?utm_source=copy-link&utm_medium=social&utm_campaign=share (last accessed Nov. 24, 2023).
20
Id.
21
Antonio La Viña, Ateneo Law School, Human Rights and The Law in More’s Utopia and Duterte’s
Philippines, Address at the Ateneo de Manila University (September 15, 2016), available at
https://tonylavina.com/teaching-lectures/ (last accessed November 24, 2023).
22
Id.
23
Id.
24
Jonathan Guyer, Most of Israel’s weapons imports come from the US. Now Biden is rushing even more arms,
Vox, November 18, 2023, available at
https://www.vox.com/world-politics/2023/11/18/23966137/us-weapons-israel-biden-package-explained (last
accessed Nov. 24, 2023)
25
Id.

5
decision to deploy aircraft carrier strike groups, affirms where the country stands in this humanitarian

conflict, despite Israel facing condemnation for the mounting civilian death toll in Gaza.

History has taught us that repressive governments that commit the most horrendous and

barbaric acts of violence against their fellow human beings are founded on a warped and perverse

notion of a utopia that their leaders conjure, imagine and forcibly impose upon their people.26

Unfortunately, we see history play out once again at the present time.

i) Hamas employs means for self preservation because of Israel’s attacks

towards the State of Palestine and their beliefs

The Palestinian right to self-defense is recognized in international law. In 1982, the UN

General Assembly passed a resolution asserting “the legitimacy of the struggle of peoples for

independence, territorial integrity, national unity and liberation from colonial and foreign domination

and foreign occupation by all available means, including armed struggle.”27 The resolution explicitly

describes Palestinians as “under foreign and colonial domination.”28

Israel’s attacks, in the form of unlawful occupation, genocide, mass destruction, and

Islamophobia, have impeded on Palestine’s three basic human rights, namely the right to survive, to

develop as a people, and to self-determination.29 Diokno’s notion of these three basic rights further

shed light on the three’s interconnectedness and their necessity to humanity.30 He states that the right

to life, at its core, is essential.31 But it should be more than just the right to live and survive.32 It entails

living in a way that fulfills our human dignity and potential, encompassing the right to develop as a

people.33 In furtherance of these would be the right to self-determination, serving as “the root of

[Palestine’s] rights to sovereign equality in international affairs and international organizations, to

freedom from all forms of racial discrimination, to political independence, and freedom from

26
La Viña, supra note 21.
27
Importance of the universal realization of the right of peoples to self-determination and of the speedy granting
of independence to colonial countries and peoples for the effective guarantee and observance of human rights,
G.A. Res. 37/43, ¶ 2, U.N. Doc. A/RES/37/43 (December 3, 1982).
28
Id.
29
Jose W. Diokno, Human Rights Make Man Human, Source Book on Human Rights 4-5 (2006).
30
Id.
31
Id.
32
Id.
33
Id.

6
colonialism, neo-colonialism, alien domination and intervention in [their] national affairs”.34 With

this, given Israel’s attacks on Palestine’s fundamental human rights, Hamas is forced to resort to

actions for the self-preservation and defense of Palestine.

C. Theological underpinnings of Hamas

Much like any quest for justice, the Palestinian struggle is rooted not only in the rejection of

oppressive and colonialist projects, but on the aspirations of genuine national liberation. Article 7 of

the Hamas Covenant of 1988 states that the Islamic Resistance Movement is one of the links in the

chain of the struggle against the “Zionist invaders”.35 Such a distinction is important to detract from

the claims of the movement’s arbitrary and blanket violence and aggression. So while the religious

connotations of the armed struggle is part and parcel of the movement, it nonetheless ought to be

understood in the context of resisting external security threats and is very much a rational political

project and therefore within the bounds of international law, far removed from its reductive

description of being an extremist militant group. This is important to note because it paves the way

towards the legitimization of Hamas’ use of force and detracts from the religious and often

Islamophobic narratives of Palestine’s oppressors. Hamas’ conceptualization as a terrorist group

undermines what the organization actually does. It is a social movement with hundreds of thousands

of Palestinian supporters that engages in extensive political and social activities.36 It is likewise

problematic to classify terrorist groups and groups who periodically use acts of terror for tactical

political reasons into the same category as it overlooks the ideological nuances and material

conditions that radicalize such groups to resort to the use of force in the first place. Contemporary

academic literature on Hamas has been much more sensitive to these nuances and are able to present a

more comprehensive picture of Hamas and depict them as having similar features to many social

movements around the world, notwithstanding the violence.37 In the stride towards peace and justice,

34
Id.
35
The Islamists, Doctrine of Hamas, Wilson Center, October 20, 2023, available at
https://www.wilsoncenter.org/article/doctrine-hamas (last accessed Nov. 24, 2023)
36
Glenn E. Robinson, Hamas as Social Movement, in Islamic Activism: A Social Movement Theory Approach
112. (Quintan Wiktorowicz, eds., 2012)
37
Id. 113

7
there has to be a conscious movement of undoing the Othering that hegemonic Western belief systems

established.

Plato’s ‘ideal city’ in the Republic can serve as a guide towards the pursuit of a virtuous

political life.38 One of the social classes within the ‘ideal city’ is the guardian class; who are tasked to

defend the city. The Republic’s logic therefore necessitates the state’s capacity for self-defense against

those entities that threaten its sovereignty and its very existence. In this regard, the Resistance’s

anti-colonial violence, we argue, is necessary to unmake Palestine’s colonial condition.39 And as with

all social movements and resistance groups, Hamas does not exist in a vacuum— it is a reaction and a

rejection of Israel’s occupation of their land, it is inalienable in the path towards Palestine’s national

liberation.40

For Plato, war is an unavoidable consequence of the desire to have and own more, it is the

soul’s predisposition towards earning and gaining more.41 This is the very logic that underpins the

colonialist doctrine, including that of Israel’s expansionist policies. The Marxist approach of

understanding power likewise reveals the asymmetric power relations between the historically

subjugated Hamas and Palestinian people and the Zionist State that receives US backing. For Marx,

power is expressed through unequal political domination, that social relations are manifestations of

inherently unequal political structures that seek to preserve the unjust status quo rather than bringing

about radical change.42 Absent the ideological underpinnings of the Israel-Palestine conflict is a

struggle for liberation of a Palestinian people that were deprived of justice and dignity and are

victimized by the structural political realities that Israel has subjected them to. The transformation of

such unjust social relations goes beyond traditional avenues for reconciliation, because to do so would

subject the Palestinians to a status quo that was already unjust. Genuine social transformation, at least

according to Marx, necessitates the overthrow of the established social order.43 Perhaps the

asymmetric and unjust power relation between Palestine and its colonizers is best illustrated in the
38
Henrik Sye, Plato: The Necessity of War, the Quest for Peace, 1, Journal Of Military Ethics 36, 41 (2010)
39
Somdeep Sen, To Fight is to Exist, Interventions 1, 6 (2016).
40
Id
41
Sye, supra note 6, at 41.
42
Bob Jessop, Marxist Approaches to Power, in The Wiley-Blackwell Companion to Political Sociology, 4
(Edwin Amenta, et al. eds., 2012)
43
Samir Franjieh, How Revolutionary is the Palestinian Resistance? A Marxist Interpretation, 1 Journal of
Palestine Studies 52, 53 (1972).

8
logic that when Palestine’s enemies refrains from its actions the more likely result is a cessation of

genocide, but when the Palestinian refrain from their actions, the more likely and deadly outcome is a

cessation of their existence.

D. The demands of justice require the recognition of Palestinian rights and the

crimes of Israel.

Peace is not the absence of war but the achievement of justice. As earlier established, the

longstanding conflict between Palestine and Israel is grounded on the historical persistence of an

oppressive and violent colonialist project that has deprived Palestine and its people not only of the

right to its homeland and the freedom to exercise its right to self-determination, but even basic human

rights enshrined under international law.44 This deprivation is the essence of a denial of justice which

must be redressed in order for peace to be achieved in the region. Resulting therefore from the

deprivation of these rights is the natural desire of the Palestinian people to pursue genuine justice and

liberation from the existential threat posed by its oppressors. In its essence, Hamas emerged from a

convergence of factors arising out of the violence perpetrated by Israel, having gained legitimacy for

the political and social stability it provides Palestine along with the pursuit of liberating it from its

oppressors.45 The conceptualization of Western scholars of Hamas as a mere terrorist movement only

further Others the Palestinian people and invalidates their calls for justice. Although Plato considers

war as an unavoidable consequence for the desire to have more it can be said that Palestine’s use of

force is rooted in its desire to exist.46

The path towards justice amidst this violence can be found only in the genuine justice and

liberation of Palestine, and entails a recognition by one of the other’s right to exist and its existence,

along with its right to security and to development.47 This idea of justice as a mutual recognition of

rights is seen in Rawls’ conception of justice which recognizes an extensive set of liberties equally

inherent in all individuals as its basis.48 Roberts states that basic liberties in Rawlsian philosophy

44
Adam G. Yoffie, The Palestine Problem: The Search for Statehood and the Benefits of International Law, Vol.
36, YALE J. INT’L L. 497, 496-497 (2011).
45
Shawn David Adkins, Understanding Hamas Through Social Movement Theory: A Dynamic Approach, 36
(2008) (Thesis, Dalhousie University) (Library and Archives Canada)
46
Somdeep Sen, To Fight is to Exist, Interventions 1, 6 (2016).
47
Asem Khalil, Israel, Palestine and International Law, 2 MISKOLC J. INT'L L. 20 25-26 (2005).
48
John Rawls, Justice as Fairness, Vol. 67 No. 2 PHILOS. REV. 164, 166-168 (1958).

9
include the right to justified self-defense against unlawful attacks, while simultaneously denying such

right to externally aggressive outlaw states.49 Without such recognition by Israel of the inherent

human and sovereign rights of Palestine, Rawls argues that no community, and thus no true justice,

can be achieved.50 The recognition of such human rights also thus entail the acknowledgement and

prosecution of acts considered war crimes under the Arts. 6 and 7 of the Rome Statute (hereafter

referred to as “The Statute”) by Israel against the Palestinian people, including that of genocide,

deportation, and apartheid among others.51 Such acts in Sen’s philosophy have unjustly deprived the

Palestinian people of their freedom and their opportunities for living as their capabilities become

further restricted52 particularly by the continued denial of humanitarian assistance into Gaza by Israel

and its foreign allies.53

Though Sen focuses on the individual well-being and capability of individuals as a basis for

justice, the role of institutions in both the maintenance of the status quo and a pathway for justice are

similarly fundamental. Although international law presents opportunities for the pacific settlement of

disputes and the attainment of justice in a community of coequal sovereigns, it is undeniable that such

laws remain tools through which hegemonic states wield their power.54 Reisman speaks of such a

dichotomy in his Myth System and Operational Code, wherein despite the existence of a myth system

of international law such myths are distorted by the reality of elite rationalizations of an operational

code that see this myth system swayed in the favor of powerful states. Seen in the philosophies of

Marx, international law in itself may be perceived as a product of asymmetric power relations

between hegemonic states and their allies against historically subjugated and Othered states such as

49
Peri Roberts, War and Peace in The Law of Peoples: Rawls, Kant and the Use of Force, Vol. 23 No. 4 KANTIAN
REV. 661, 667-668 (2018).
50
RAWLS, supra note 5, at 179.
51
International Federation for Human Rights, Alarming increase of human rights violations against Palestinians
in the occupied territory and against Palestinian citizens of Israel (Statement), available at
https://www.fidh.org/en/region/north-africa-middle-east/israel-palestine/alarming-increase-of-human-rights-viol
ations-against-palestinians-in (last accessed November 24, 2023).
52
AMARTYA SEN, THE IDEA OF JUSTICE 232-233 (2009)
53
Patrick Wintour, US vetoes UN’s call for ‘humanitarian pause’ and corridors into Gaza (The Guardian News
Article) available at
https://www.theguardian.com/world/2023/oct/18/us-vetoes-un-call-for-humanitarian-pause-and-corridors-into-g
aza (last accessed November 14, 2023)
54
Nico Kirsch, International Law in Times of Hegemony: Unequal Power and the Shaping of the International
Legal Order, Vol. 16, EUR. J. INT’L L. 369, 370-371 (2005)

10
Palestine.55 Thus, to ensure the primacy of justice and the rule of law in the international community,

further steps must be taken in order to ensure that not only Israel but its respective members recognize

the rights of Palestine in paving the way for justice to prevail, bringing together the ideals of justice—

looking at what is actually enshrined in international law and what is the current operational code of

the international community that rejects genuine justice in favor of satisfying political alliances

among states.

II. ICC does not have jurisdiction over Hamas and its acts.

A. Pursuant to the principle of complementarity, the ICC is a court of last resort

when a state refuses or is unable to investigate and prosecute war crimes.

The International Criminal Court (hereafter referred to as “ICC”) was established under the

Statute pursuant to its mandate to be a permanent international institution empowered to investigate

and prosecute crimes of the most serious nature.56 It is further established by Art. 1 of the Statute that

its criminal jurisdiction is complementary to that of the state. The principle of complementarity is

based on the sovereign right of the state to investigate and prosecute international crimes, coupled

with considerations on efficiency, effectiveness, and redundancy.57 This principle highlights the

primacy of state sovereignty as well as the collective international pursuit of justice in ensuring that

crimes do not go unpunished. Should the state refuse to prosecute such crimes or acts in bad faith in

misleading others to think that there are ongoing investigations, the ICC may exercise its

jurisdiction.58 The establishment of the ICC was not meant to rid domestic courts of jurisdiction in

grave crimes that occur in their national soil, because doing so would effectively errode the state’s

sovereignty. Rather, the powers of the ICC are clearly defined to be complementary to a state.

In the present case, the conflict in Gaza has led to the paralyzation of essential infrastructure

in the state of Palestine. However, it cannot be said that the state of Palestine affords impunity to

either Hamas or Israel as it devotes its resources to extending aid to its citizens. This does not mean

55
Bob Jessop, Marxist Approaches to Power, in The Wiley-Blackwell Companion to Political Sociology, 6-8
(Edwin Amenta, et al. eds., 2012)
56
Rome Statute of the International Criminal Court art. 1, signed April 1, 2015, 2187 U.N.T.S. 38544 (entered
into force July 1, 2002).
57
Xabier Agirre, et al., The principle of complementarity in practice, ICC-OTP 2003, 3 (2003).
58
Oscar Solera, Complementary jurisdiction and international criminal justice, 84 RICR 145, 147 (2002).

11
that the state of Palestine is unable to investigate and prosecute on its own. The determination of

inability or unwillingness is provided by Art. XVII, and under paragraph 3 it states that “In order to

determine inability in a particular case, the Court shall consider whether, due to a total or substantial

collapse or unavailability of its national judicial system, the State is unable to obtain the accused or

the necessary evidence and testimony or otherwise unable to carry out its proceedings.”59 The

paralyzation of infrastructure in the state of Palestine, or more specifically Gaza, however, is not a

permanent inability that will foreclose efforts toward justice. The presence of the truce agreement60

and further negotiations to follow show prospects towards a resolution that will, eventually, uphold

the rule of law.

B. Under the definition of the Rome Statute, the acts of Hamas do not fall under

“Genocide” and “War Crimes.”

The jurisdiction of the ICC covers only the most serious crimes that concern the international

community as a whole, which includes Genocide and War Crimes. The Statute defines Genocide as

“acts committed with intent to destroy, in whole or in part, a national, ethnical, racial or religious

group”61. On the other hand, War Crime is defined by The Statute as “grave breaches of the Geneva

Conventions of 12 August 1949” and “other serious violations of the laws and customs applicable in

international armed conflict within the established framework of international law”62, as relevant.

Both definitions clearly pertain to acts disturbing the peace with a clear intent to harm.

As earlier established, in Hamas’ case, acts done were in response to the circumstances

between Palestine and Israel. In an effort to save itself from the aggression Palestinians have been

experiencing at the hands of Israel, Hamas had to employ means to prevent further dominion,

evidently without intent to disturb the peace or harm but acting out of necessity to preserve the future

of the Palestine people.

59
Rome Statute, supra note 55, art. 17, ¶ 3.
60
Aljazeera, Israel-Hamas truce deal, available at
https://www.aljazeera.com/news/2023/11/22/israel-hamas-truce-all-you-need-to-know#:~:text=What%20have%
20Israel%20and%20Hamas,and%20children%20from%20its%20prisons (last accessed Nov. 24, 2023).
61
Rome Statute, supra note 55, art. 6
62
Id. art. 8, ¶ 2 (a & b)

12
III. CONCLUSION

The issue before the Court is the jurisdiction of the Prosecutor over Hamas and its alleged

commission of war crimes and genocide. It is averred that Palestine, as a state party to the Rome

Statute, is under the jurisdiction of the ICC and that the gravity of the acts done by Hamas constitute

grave crimes warranting the jurisdiction of the ICC. However, we posit that the ICC does not have

jurisdiction over Hamas because of the principle of complementarity and because Hamas has not and

did not commit genocide and war crimes.

The ICC is a court of last resort that may exercise its jurisdiction upon a state’s refusal or

inability to carry out the investigation and prosecution of war crimes. Given that the Rome Statute

establishes that the ICC’s jurisdiction is complementary to that of a state, the principle of

complementarity is applied in providing for the sovereign right of a state to investigate and prosecute

international crimes. While the attacks against Gaza engendered the paralyzation of essential

infrastructure in Palestine, impeding Palestine’s ability to investigate and prosecute war crimes, the

truce agreement and negotiations show promise that it is not a permanent inability that will bar the

attainment of justice. Moreover, Hamas’ acts do not fall under the definition of “Genocide” and “War

Crimes” in the Rome Statute. These definitions apply to acts that disrupt peace with a clear intent to

harm. Acts done by Hamas, however, were only to prevent further aggression by Israel against the

Palestinians and preserve the future of the Palestine people, all without intent of disrupting the peace.

Through our discussions on the theological underpinnings of Hamas, philosophical works of Plato,

Marx, and Riessman, among others as well as the historical review of the exigency of the conflict, we

have established that Hamas’ acts are but a reaction to the perpetuation of war crimes and genocide by

Israel. Ultimately, Hamas’ purpose is anchored in the pursuit of self-defense and preservation, genuine

justice, and liberation from Israel’s oppression.

13