Stone platform overlooking the Be’er Sheba–Hebron–Gaza corridor, ancestral and current homeland of the Indigenous Canaanite tribes: the Tribe of Abimelech, Tribe of Brahmiyya, Tribe of Zamāʿirah, and related clans and families. These tribes are not Arab; they descend from "pre-Abrahamic" Canaanite lineages native to Palestine. The report documents how, unlike "immigrant minorities" protected by the State of Israel, these Indigenous populations face targeted incitement to genocide through weaponized biblical extermination rhetoric.
Tribe of Abimelech Report
Report on: Remember what Amalek did to you: Incitement to Genocide against Indigenous Palestinians in the Be’er Sheba, Gaza and Hebron Corridor (2023–2025)
Issued: 17th November 2025 by the Tribe of Abimelech Platform
Abstract
This report advances one clear legal thesis. Since October 2023, senior officials of the State of Israel publicly invoked the biblical term Amalek while directing military operations against Palestinians. Those utterances are direct and public incitement under Article III(c) of the Genocide Convention and probative of genocidal intent and persecution under the Rome Statute when considered with the ensuing conduct. The same term, Amalek (the Giants), is also part of our own indigenous memory in the southern corridor as ancestral Canaanite tribal confederation of which Palestinians, including the Tribe of Abimelech, are the living continuation. To label Palestinians Amalek is therefore to mark an indigenous people for elimination by name. The law does not recognize scripture as a defense. It examines what was said, by whom, to whom, and with what foreseeable effect, and it imposes duties to prevent, punish, and repair.
At the debut ICJ hearing, South Africa’s legal champion, Tembeka Ngcukaitobi, brought these statements into the spotlight, pointing out that they were again publicly stated in a 3 November pep letter to soldiers, something he argued was less "rally the troops" and more "incite the troops, to commit genocide" particularly against the indigenous people of the Holy Land.
1) Introduction and Purpose of the Report
Purpose.
The purpose of this legal report is to establish, using admissible evidence and binding international legal standards, that the public deployment of the term Amalek by State of Israel officials between October 2023 and November 2025 constitutes direct and public incitement to commit genocide against a real, identifiable, Indigenous civilian population. This population includes the Tribe of Abimelech of Be’er Sheba and Gaza, the Tribe of Brahmiyya of Tell es-Safi, the Tribe of Zamāʿirah of Ḥalḥūl, and additional Canaanite-descended Palestinian tribes whose continuous presence in southern Palestine is documented across genealogy, tribal memory, settlement continuity, Arabic historiography, and recognized archaeological geography.
This report is submitted from the legal and historical standing of an Indigenous Canaanite tribe, the Tribe of Abimelech, whose lineage, settlement patterns, and kin branches in the Be’er Sheba, Gaza and Hebron corridor represent an unbroken demographic continuity from ancient Canaanite populations recorded in Bronze-Age, Iron-Age, classical, and Ottoman sources. This standing matters for international law, as the targeted population is Indigenous, and the use of an exterminatory label against an Indigenous people activates heightened obligations under the Genocide Convention, UNDRIP, customary international law, and erga omnes partes duties owed by all states.
The purpose of this report is legal and evidentiary, not rhetorical, theological, or speculative. It demonstrates that:
State of Israel officials publicly invoked Amalek, a term universally associated with extermination in 1 Samuel 15, during an active military campaign.
The targeted population is not symbolic, but consists of the surviving Indigenous Canaanite-descended tribal communities of southern Palestine.
Massive civilian destruction, including the elimination of entire family lines, followed these statements, correlating rhetoric with action.
Under binding treaty law, once a state official identifies a protected group with an exterminatory command narrative and violence follows against that group, the threshold for direct and public incitement to commit genocide is satisfied. When that rhetoric is paired with sustained civilian destruction across municipalities and kin groups, liability extends to genocide, persecution, and extermination as crimes against humanity.
This report therefore provides a comprehensive legal argument that the invocation of Amalek constitutes:
A direct incitement offense under Article III(c) of the Genocide Convention.
Individual criminal responsibility under Article 25(3)(e) of the Rome Statute.
Persecution and extermination under Article 7 of the Rome Statute.
A violation of Indigenous rights to survival, land, and identity under UNDRIP Articles 7, 8, and 10, which prohibit forced removal, cultural destruction, and demographic elimination of Indigenous peoples.
The submission’s factual and legal conclusions are based not on religious interpretation, but on the plain meaning of public official statements, the observable results of military operations, the established identity of the target population, and recognized evidentiary standards applied by international courts.
Scope.
The scope of this report encompasses four interlocking domains:
The factual record.
The governing law.
The application of that law to the established facts.
The Indigenous standing that anchors the legal argument.
First, the factual record is constructed from publicly documented statements issued by State of Israel officials beginning on 28 October 2023, when:
The Prime Minister invoked the phrase "Remember what Amalek did to you" at the outset of intensified military operations, and again on 3 November 2023, when the same exterminatory language appeared in a written directive addressed to active combat units.
Additional statements made throughout 2024 and 2025, together with the Defense Minister’s description of Palestinians as "human animals" and the siege declaration ("no electricity, no fuel, no food"), create an evidentiary environment in which state rhetoric and military conduct are inseparable.
This record also includes verifiable documentation of how these phrases diffused downward into the ranks: soldier-filmed chants celebrating the destruction of the "seed of Amalek," unit-level recordings invoking the term during demolitions and raids, and videos circulated by troops themselves on public platforms. These materials establish that the rhetoric was not metaphorical, private, or obscure; it entered the operational culture of forces conducting large-scale civilian destruction and displacement in Gaza, Be’er Sheba/Naqab district Bedouin communities, and Hebron-region municipalities. The correlation between the statements and the resulting civilian targeting and large-scale demolitions and destruction are therefore within the scope of analysis.
Second, the scope includes a full review of the governing international law:
Convention on the Prevention and Punishment of the Crime of Genocide (1948)
Rome Statute of the International Criminal Court (1998)
ICJ provisional measures orders (January 2024; March 2024)
Customary principles of individual criminal responsibility
UN Declaration on the Rights of Indigenous Peoples (UNDRIP)
Jurisprudence from ICTR, ICTY, and ICJ on incitement, intent, and contextual analysis.
The report situates these instruments within their operative legal framework: Incitement as an independent crime; the definition of persecution, extermination, and genocide; Intent analysis; and the obligations of states parties to prevent, suppress, and punish incitement.
The UN Declaration on the Rights of Indigenous Peoples (UNDRIP) is also treated as part of the controlling interpretive environment, because it codifies the rights of Indigenous peoples to survive as peoples, to exist on their land, and to be protected against erasure and genocide, forced displacement, and demographic targeting.
Third, the scope extends to the application of these legal standards to the factual record:
This includes a detailed examination of directness, publicness, context, and intent, as defined in international criminal law. The analysis examines how the identification of Palestinians as Amalek satisfies the objective elements of incitement: a specific exhortation directed toward identifiable military units; public dissemination through official channels; contextual reinforcement through additional dehumanizing statements; and a foreseeability that such language would produce violent acts, which were in fact carried out on a massive scale. The legal consequences of explicitly identifying an Indigenous civilian group with a command narrative of extermination are therefore addressed in depth, including the nexus between speech and conduct.
Finally, the scope includes the Indigenous standing, identity, and continuity of the targeted population:
This dimension is central rather than peripheral. The report documents the Canaanite origin and millennia-long demographic presence of the Tribe of Abimelech, the Tribe of Brahmiyya, the Tribe of Zamāʿirah, and related families of the Be’er Sheba–Gaza–Hebron corridor. It also analyzes the Indigenous law of this corridor, including the historical oath traditions of Gerar and Be’er Sheba, and the implications of weaponizing ancient terms against a population whose continuity on the land is supported by archaeology, genetics, settlement geography, oral tradition, and historical scholarship. The use of an exterminatory biblical term against an Indigenous Canaanite-descended civilian population is therefore treated as a direct legal violation with significant consequences for state responsibility and individual criminal accountability.
The scope concludes by identifying the remedies and implementation measures required under international law. These include the obligation to suppress incitement, to prosecute individuals responsible for genocidal speech and actions, and to ensure the protection of Indigenous Palestinians from ongoing demographic and territorial harm. Each of these components is essential to the overall argument advanced in this report.
Authority.
The authority of this report derives from the evidentiary sources, treaty instruments, judicial precedents, Indigenous legal standing, and historical documentation upon which its conclusions rest. The factual foundation relies on official Israeli government publications, including recorded press conferences, written directives, letters issued by the Prime Minister’s Office, and additional statements delivered by senior officials in the course of military operations. These materials are authoritative not because they are rhetorically significant but because they constitute direct admissions by state actors whose public statements carry binding legal consequences under international criminal law.
Additional authority comes from records submitted to the International Court of Justice, including state-filed memorials, oral pleadings, and evidentiary annexes submitted by South Africa and other intervening states. These submissions provide independently corroborated documentation of the use of Amalek and related dehumanizing language, and they form part of the judicial record that triggered provisional measures orders in early 2024. The report also draws upon United Nations documents, including findings of the UN Commission of Inquiry, emergency special session resolutions, rapporteur reports, and official warnings issued by UN agencies regarding the scale of civilian destruction and the risk of genocide.
A further source of authority lies in the Arabic-language documentation that recorded the diffusion of incitement terminology into troop behavior. These sources are not anecdotal; they include verifiable soldier-posted recordings, media investigations, and field reporting by Palestinian and regional outlets that documented how the exterminatory label circulated from official state podiums into unit-level military conduct. Because these materials capture real-time behavior within operational units, they hold significant probative weight for intent and foreseeability analysis.
The historical and Indigenous dimensions of authority rest on peer-reviewed archaeology, anthropology, population genetics, and settlement-continuity research demonstrating the Canaanite origins and demographic persistence of Palestinians in the southern corridor. These materials include ancient-DNA publications, archaeological site reports, classical and Ottoman registries, and local Palestinian municipal records confirming lineage continuity. Critical authority also comes from Ottoman-era land deeds, family registries, and the tribal oral histories of the Tribe of Abimelech, the Brahmiyya, and the Zamāʿirah, which collectively document Indigenous presence and governance prior to and throughout the colonial disruptions of the twentieth century.
Treaty authority is grounded in the Arabic, English, and French texts of the Genocide Convention, the Rome Statute, and related instruments, all of which establish the governing standards for incitement, genocide, persecution, extermination, and individual criminal responsibility. These treaties are complemented by the judicial authority of the ICTR, ICTY, ICJ, and ICC, whose jurisprudence defines the operative thresholds for intent, context, foreseeability, and the relationship between speech and crimes against civilian populations.
Finally, this report asserts legal standing through the Tribe of Abimelech Platform, an Indigenous body whose right to exist, to identify itself, to preserve its ancestral lands, and to articulate legal claims on behalf of its members is protected under UNDRIP and customary Indigenous rights principles. As such, the report functions as a formal legal submission intended for courts, investigators, Indigenous rights bodies, and policymakers, synthesizing a complete evidentiary record for proceedings related to genocide, crimes against humanity, and violations of Indigenous rights. Its authority rests not only on the evidence it compiles but on the standing of the Indigenous population whose destruction the rhetoric sought to justify.
2) Chronology of Public Incitement, Diffusion, and Denials
The timeline of inciting statements is clear, documented, dated, and corroborated across multiple independent sources, including Arabic-language media, international press outlets, legal filings, and official government documents.
The following chain is speech, diffusion, and operations, documented in official records and open‑source material. It is legally sufficient to proceed on incitement and to treat rhetoric as probative of intent.
(a) Prime Minister’s 28 Oct 2023 statement.
The chronology begins on 28 October 2023, when the Prime Minister of the State of Israel publicly declared, "Remember what Amalek did to you," during an active military campaign. This was not an offhand remark; it was a direct invocation of a term referenced with extermination, delivered during a period of intensified operations. The statement was widely disseminated and reproduced across Arabic outlets because of its explicit and alarming content.
In an official address carried on the Government of Israel’s website, the Prime Minister declared: "Remember what Amalek did to you" (Deut 25:17), adding "we remember and we fight." The statement tied the invocation to active operations ("our brave soldiers who are now in Gaza"). This is a dated, public, government‑hosted record.
(b) 3 Nov 2023 letter to soldiers.
The same phrase "Remember what Amalek did to you" appeared in a written letter issued by the Prime Minister’s Office to "our soldiers and commanders," distributed through official channels and republished by multiple outlets. This placement matters legally: the audience is the armed forces engaged in an active theater.
On 3 November 2023, the Prime Minister’s Office issued an official letter to soldiers repeating the reference to Amalek. This document was later cited by South Africa at the ICJ as evidence of direct incitement. Arabic newsrooms published the full text and contextualized it as a wartime exhortation. Its official status, its intended audience (combatants), and its timing (during an active campaign) make it a key piece of probative evidence.
(c) Dehumanization by senior officials.
On 10 Oct 2023, the Defense Minister publicly described Palestinians in Gaza as "human animals" and announced a "complete siege" ("no electricity, no food, no fuel"). Dehumanization is a classic vector for mass violence and is legally relevant to context and intent when paired with other acts.
The Defense Minister’s "human animals" declaration contributed to a broader dehumanizing rhetorical environment. While this was not an Amalek reference, it forms part of the incitement matrix under international criminal law by stripping the target population of human status. Dehumanization is recognized in ICTR jurisprudence as a defining component of genocide preparation.
(d) Diffusion to ranks (soldier chant evidence).
Throughout late 2023 and 2024, numerous filmed statements by soldiers, circulated in American owned and operated platforms, invoked the "seed of Amalek" while celebrating acts such as demolition, arson, rape and indiscriminate fire. Open‑source material shows soldiers chanting "wipe out the seed of Amalek" during operations. Third‑party verification confirms the translation and context.
By 2025, Arabic investigative outlets had documented repeated uses of the Amalek trope in battalion-level speeches, field briefings, and social-media uploads. The pattern demonstrates continuity of rhetoric, foreseeability of its interpretation, and correlation with civilian destruction. Under international law, this chronology satisfies the requirements of directness, publicness, context, and probative linkage to subsequent acts.
The foreseeability of such diffusion is part of the incitement analysis. Once a head of government employs exterminatory terminology, it predictably spreads through subordinate ranks. Such replication becomes foreseeable once leaders deploy the trope.
(e) Defending the citation.
On 16 January 2024, the Prime Minister’s Office issued a statement rejecting the claim that his use of Amalek was incitement and constituted a call for genocide, while simultaneously confirming that he had in fact referenced Amalek on 28 October and in the 3 November letter.
This denial is legally irrelevant: in cases of incitement, the fact of the utterance, its timing, its audience, and its context establish the elements, not the speaker’s later characterization.
(f) International proceedings noting incitement.
On 26 Jan 2024, the ICJ indicated provisional measures in South Africa v. Israel, where South Africa’s counsel highlighted at direct usage of the term Amalek in incitement of genocide by armed forces against an indigenous population. Among other duties, Israel was ordered to prevent and punish direct and public incitement to commit genocide pending the merits. Subsequent orders in March and May 2024 maintained and elaborated measures.
(g) Findings by UN Commission of Inquiry (2025).
On 16 Sep 2025, the UN Commission of Inquiry issued a report concluding Israel has committed genocide in Gaza, citing senior-official rhetoric, including Amalek invocations, as evidence of intent. Israel rejected the report. The Commission’s genocide finding is the first formal UN investigative determination that ties leadership speech, siege policy, and patterns of destruction into a completed genocidal crime, and it expressly treats Amalek-type language as one of the indicators of dolus specialis rather than as peripheral commentary. For purposes of this chronology, the COI report transforms earlier concerns about incitement into an authoritative, third-party confirmation that senior-official rhetoric, specifically including Amalek invocations, operated as probative evidence of genocidal intent directed at the Indigenous Palestinian population in the corridor.
(h) ICC action.
On 20 May 2024, the ICC Prosecutor applied for arrest warrants in the Situation in the State of Palestine. The Prosecutor’s public statement and independent analyses lay out the legal theory, including crimes against humanity elements relevant to persecution and extermination. While the Pre-Trial Chamber’s decision on those applications remains pending, the filing itself signals that the evidentiary record, combining leadership rhetoric, siege measures, and large-scale attacks on civilians, is sufficient, in the Prosecutor’s view, to justify seeking the arrest of named officials. In this report’s framework, the ICC action confirms that the same universe of facts that includes Amalek invocations is already being treated at the highest criminal forum as potential persecution, extermination, and related crimes against humanity committed against an Indigenous, Canaanite-descended civilian population.
3) Governing Law
The governing law applicable to this report derives from binding treaties, customary international norms, and three decades of jurisprudence from international criminal tribunals that have shaped how courts evaluate incitement, genocide, persecution, and extermination. This body of law forms a single, coherent legal framework that governs the interpretation of the public use of exterminatory terminology by senior state officials during periods of armed conflict. Within that framework, the invocation of “Amalek” against Palestinians between October 2023 and November 2025 is not a theological disagreement or a matter of rhetorical interpretation. It is conduct that triggers clearly defined legal consequences and engages the highest level of state responsibility and individual criminal liability. The Tribe of Abimelech Platform proceeds not from symbolic interpretation, but from the operative legal standards recognized by the International Court of Justice, the International Criminal Court, the United Nations human-rights regime, and international criminal jurisprudence in cases where speech operates as a weapon against Indigenous populations.
(a) Genocide Convention (1948).
The Convention on the Prevention and Punishment of the Crime of Genocide stands as the foundational instrument governing the prohibition and punishment of genocide and its incitement. It is the starting point for this analysis. The Convention defines genocide as certain prohibited acts, including killing members of the group, causing serious bodily or mental harm, inflicting conditions of life calculated to bring about physical destruction, imposing measures intended to prevent births, and forcibly transferring children, when these are committed with intent to destroy, in whole or in part, a national, ethnical, racial, or religious group as such. Its importance, however, lies not only in setting out these acts but also in identifying incitement as a crime that is independently prosecutable. That independence is crucial: it reflects the recognition by the drafters that public calls to destroy a protected population represent a danger so severe that criminal liability arises even before physical acts of destruction occur.
Article III(c), which criminalizes “direct and public incitement to commit genocide,” therefore occupies central importance in this report. The Convention does not require that genocide be successfully completed, or even begun in its physical form, for incitement to be prosecutable. International courts have repeatedly affirmed that this provision is preventative in nature, to deter the catastrophic consequences that predictably follow when senior officials call for the annihilation of a group. It treats incitement as an independent offense because of the recognized danger that public calls to destruction pose to vulnerable populations.
The Genocide Convention recognizes protected groups as national, ethnical, racial, or religious groups. Indigenous Canaanite-descended Palestinians, including the Tribe of Abimelech, fall squarely within the national and ethnical categories. Because protected status does not derive from religious classification but from objective characteristics of identity, ancestry, and continuity, the Tribe of Abimelech’s standing is fully recognized under this instrument. The Convention does not create any exemption for speech framed as religious, historical, or “symbolic.” If the content and context of the speech meet the legal threshold for direct and public incitement, responsibility attaches irrespective of the speaker’s claimed theological intent.
The Convention imposes affirmative duties on all states parties. The duty to prevent genocide is not passive. It applies from the moment a state becomes aware of a serious risk that genocide may occur. As the ICJ recognized in the Bosnia Genocide case, this duty arises the instant the state is aware of the danger; it does not wait for the danger to materialize into acts. Similarly, the duty to punish is not discretionary. States must prosecute individuals responsible for genocide or incitement wherever they may be found, with no immunity for position or office, and they must do so not only within their own territory but also wherever they have the capacity to influence outcomes. These duties bind all states parties, including those far removed from the conflict, because genocide and its incitement are considered violations of obligations erga omnes partes, owed to the entire international community.
In the present context, the public deployment of “Amalek” by state officials must be assessed under Article III(c). The content of the term in the biblical war narrative, total destruction of a population indigenous to the land being conquered, is a matter of objective textual record. The term is associated with a narrative of extermination in 1 Samuel 15. Modern speakers invoking that term in the midst of a military campaign against the Indigenous population of the same territory necessarily convey a meaning of annihilation to the intended audience. The term was publicly addressed to a protected group and to soldiers engaged in operations against that group, and it was followed by mass civilian death and destruction. Under the Convention, the question is not whether the speaker intended a theological interpretation; the standard is objective and focuses on the nature of the utterance, the circumstances of its delivery, its foreseeable effect, and its operational environment. When the invocation is followed by mass civilian death, elimination of family lines, destruction of kin-based municipal registries, starvation conditions, systematic targeting of civilian infrastructure, and large-scale displacement, the conclusion is legally inescapable: the speeches fall within Article III(c) as direct and public incitement to commit genocide.
(b) The Rome Statute of the International Criminal Court (1998)
The Rome Statute builds upon the Genocide Convention by establishing a permanent court, defining crimes within its jurisdiction, and codifying modes of individual criminal responsibility. For this report, the Statute is relevant in three principal ways: its definition of genocide (Article 6), its characterization of crimes against humanity (Article 7), and its explicit recognition of direct and public incitement as a prosecutable mode of liability (Article 25(3)(e)).
Article 6 adopts the Genocide Convention’s definition of genocide. For present purposes, the focus is not on the completion of genocide but on the Statute’s incorporation of incitement liability. Article 25(3)(e) provides that any person who directly and publicly incites others to commit genocide incurs criminal responsibility, even if genocide is never carried out. This mirrors Article III(c) of the Genocide Convention but situates it within the ICC’s regime of accountability. The Statute therefore treats incitement as an inchoate crime, consistent with the preventative purpose of international criminal law. The invocation of “Amalek”, a term whose meaning in this context is the ordered destruction of an Indigenous population, by state leaders engaged in an ongoing armed campaign fits squarely into this mode of liability, because it functions as language that can reasonably be expected to inspire or accelerate genocidal acts.
Article 7 introduces crimes against humanity, including persecution, extermination, murder, deportation or forcible transfer of population, and other inhumane acts, when committed as part of a widespread or systematic attack directed against any civilian population, with knowledge of the attack. Persecution is defined as the intentional and severe deprivation of fundamental rights contrary to international law by reason of the identity of the group or collectivity. Extermination refers to mass killing of members of a civilian population carried out as part of such a widespread or systematic attack. When Indigenous Palestinians are identified by state leaders as “Amalek,” a biblical term associated with their own Indigenous ancestors but weaponized in modern usage as justification for destroying them, the elements of persecution are met: identity-based targeting, severe deprivation of fundamental rights, and systematic conduct directed at their elimination. When that rhetoric is followed by mass killing, starvation, destruction of homes, villages, family lines, and the forcible transfer or dispersal of the population, the elements of extermination are met.
The Rome Statute thus reinforces the principle that speech is not insulated when it functions as a weapon and directly contributes to a campaign of destruction. It affirms that rhetorical targeting and military targeting of a protected Indigenous population are not independent phenomena: they are interwoven components of crimes against humanity. For the Tribe of Abimelech and related Indigenous communities, this legal structure is crucial. It confirms that the focus is not on abstract theological debates but on concrete acts and utterances by identifiable persons who hold positions of authority and whose words have operational consequences. The Statute evaluates the words in context: the status of the speaker, the audience, the operational environment, the subsequent conduct of armed forces, and the consequences for the civilian population. It treats those persons as individually accountable when they cross the line into incitement and when their conduct is tied to widespread or systematic attacks on civilians.
(c) Jurisprudential elements of incitement.
Over several decades, international criminal tribunals, particularly the International Criminal Tribunal for Rwanda (ICTR), have clarified the elements that make speech punishable as direct and public incitement to genocide. Their decisions have refined how courts analyze terms such as “direct” and “public,” how they weigh context, and how they infer intent. These elements are now reflected in practitioner digests, case-matrix tools, and legal commentaries that synthesize case law for use in investigations and prosecutions. The jurisprudence identifies four core analytical components: directness, publicness, intent, and context. These components are not abstract principles. They are applied by prosecutors and courts to determine whether the speech at issue was designed or foreseeably likely to trigger acts of destruction.
Directness does not require explicit language such as “go and kill.” International criminal jurisprudence has held that coded language, historical references, cultural motifs, and expressions capable of being understood by the intended audience may meet the threshold when they call for destruction. In this legal analysis, the relevance of the term “Amalek” does not arise from theology or any claim to ancient authority. Its significance lies in the fact that, within the Israelite war narrative recorded over 3,000 years ago, the term appears in the setting of a military campaign in which a foreign force declares a mandate of total destruction against a population already inhabiting the land. Its relevance lies in the fact that it appears in the context of a military campaign recorded over 3,000 years ago, calling for the total destruction by an outside force seeking to conquer the territory of an already inhabited land. International courts do not adjudicate ancient conflicts; they examine how modern state officials weaponize historically understood language during armed operations. When leaders invoke a term associated with annihilation at the very moment their forces are engaged in large-scale attacks on a specific identifiable Indigenous civilian population, the statement carries a well-known meaning of annihilation, functions as an instruction to replicate an annihilation order, and communicates an exterminatory objective that meets the threshold of directness for incitement under international criminal law. In the case of “Amalek,” the meaning of the term within the Israeli cultural and linguistic environment is clear: it refers to an extermination narrative, it is recognizable as such by civilian and military audiences alike, and its invocation during wartime operations carries the plain meaning of annihilation.
Publicness requires dissemination beyond a private setting. Public speeches, government channels, official letters, and media broadcasts meet this requirement. “Publicness” means that the inciting speech must be communicated to a number of individuals in a public setting or via a medium that reaches the public. Speeches carried on official government channels, letters addressed to armed forces and released through public platforms, and recorded statements disseminated through media all satisfy this criterion. The statements analyzed in this report were delivered in official addresses, released on government websites, and circulated across mainstream media. They were not private or restricted. They satisfy publicness without ambiguity.
Intent may be inferred from circumstances, patterns of speech, and subsequent acts. Courts look at the content of the speech, the status and role of the speaker, the surrounding environment of violence and dehumanization, and the subsequent behavior of the audience. While incitement does not require that genocide be completed, the actual occurrence of mass atrocities after inciting statements reinforces the inference that the speaker intended those acts or accepted the likelihood that they would occur. When senior officials invoke an exterminatory term and the armed forces subsequently destroy civilian populations on a massive scale, the inference of genocidal intent is strengthened. When state leaders label an Indigenous population as Amalek and then direct or oversee operations that result in mass killing and destruction of that population, the jurisprudential elements of incitement and genocidal intent are engaged.
Context completes the picture. Context encompasses surrounding rhetoric, operational developments, patterns of violence, and the overall environment of discrimination. The surrounding rhetoric, such as references to “human animals,” total siege declarations that deprived civilians of basic necessities, systematic obstruction of humanitarian aid, and dehumanizing language, forms the environment in which Amalek invocations are interpreted. Documented patterns of starvation, bombardment, demographic destruction, and targeted attacks on civilian infrastructure complete the contextual matrix established in ICTR and other tribunal jurisprudence. International tribunals have repeatedly emphasized that incitement cannot be evaluated in isolation; the broader environment of discrimination, violence, and hate speech is part of the legal analysis.
(d) Interim orders and obligations.
The International Court of Justice’s provisional-measures orders in South Africa v. Israel provide the final layer of governing law. On 26 January 2024, the Court found that there was a plausible case that the rights of Palestinians under the Genocide Convention were at risk of irreparable harm and required Israel, among other measures, to prevent and punish direct and public incitement to commit genocide. These orders further clarify the obligations of states when there is a plausible risk of genocide. They do not decide the merits of the genocide claim, but they do impose immediate and binding duties on the respondent state. Once the Court issues provisional measures, the respondent state is bound to comply immediately. Any continued incitement or failure to suppress it, or lack of action to investigate and punish its authors, constitutes a further breach of the Convention and of the Court’s binding order. Provisional measures therefore transform what might have been characterized as politically “controversial” statements into conduct subject to heightened legal scrutiny and clear state duties.
Subsequent orders in March and May 2024 reaffirmed and expanded these obligations in light of evolving facts on the ground. For Indigenous populations such as the Tribe of Abimelech, these orders form international recognition of the acute danger they face and codify the legal duties owed to them. The continued invocation or defense of Amalek rhetoric after the issuance of provisional measures is thus not merely political misconduct; it is a violation of international judicial authority and a legally aggravated form of incitement in a context where the highest international court has already warned of a plausible genocide risk and ordered its prevention.
Taken together, the Genocide Convention, the Rome Statute, international jurisprudence on incitement, and ICJ provisional measures establish a unified and coherent legal framework. Within this framework, the invocation of “Amalek” against Indigenous Palestinians, including the Indigenous Canaanite-descended tribes of the southern corridor and the Tribe of Abimelech, is not protected expression, symbolic commentary, or religious speech. It is an act with direct legal consequences: an actionable form of direct and public incitement to commit genocide, an element of persecution and extermination as crimes against humanity, and a violation of the rights of Indigenous peoples under international law. The governing law therefore treats this rhetoric as potential criminal conduct at the highest level of international law, activating both state responsibility and individual criminal liability.
4) Application of Law to Facts
Directness.
Directness is satisfied when language explicitly references harm against a protected group in a manner the intended audience can understand as a call to action. “Remember what Amalek did to you” is unambiguously connected to 1 Samuel 15’s narrative of total destruction. Delivered by a head of government during active military engagement, the phrase functions as an exhortation. The repetition in the 3 November 2023 letter to soldiers heightens directness, because the audience is a capable actor with the means to implement violence. International tribunals have repeatedly held that coded language, historical references, or religious invocations still qualify as incitement when their destructive meaning is clear within the cultural context of the audience.
In applying this principle to the present case, the Tribe of Abimelech notes that the Prime Minister’s invocation of “Amalek” occurred not in a vacuum, but at the precise moment when military units were entering densely populated Indigenous civilian areas and carrying out operations of overwhelming destructive capacity. The phrase carries a specific meaning within the cultural, military, and political environment of the State of Israel: it signals a remembered command of annihilation, understood by soldiers, officers, and segments of the public as a call to eliminate a designated enemy lineage. In this environment, “Amalek” is not metaphor. It is a directive embedded in a familiar narrative of conquest, invoked deliberately at a time when soldiers were positioned to operationalize its meaning.
The legal test for directness is whether the intended audience understood the speech as a call for destructive action. The soldier-filmed chants, battalion briefings, and unit-level recordings where troops celebrated “erasing the seed of Amalek” provide real-time confirmation that the Amalek rhetoric was interpreted precisely as an instruction to carry out the annihilatory conduct associated with the term. The foreseeability requirement is therefore satisfied: when a senior official issues exterminatory language to armed units poised for attack, and the audience reproduces that language while performing destructive acts, the speech meets the threshold of direct incitement under international criminal law.
Publicness.
The statements were delivered publicly, recorded, disseminated through official channels, and reproduced across media platforms. Publicness is a formal requirement under Article III(c) of the Genocide Convention. Here, the threshold is unquestionably met: government portals, press conferences, and official correspondence constitute public fora. The ICJ has consistently emphasized that even a single public inciting statement by a senior official may trigger obligations to prevent genocide.
In the present situation, the Prime Minister’s 28 October address, the 3 November letter to soldiers, subsequent press conferences, and written denials defending the Amalek reference were all circulated through official state channels. These statements reached national and international audiences and were amplified through global media, including Arabic-language outlets that published the original text and contextualized it for the regional public. The state did not attempt to conceal the statements; they were intentionally public. In international law, this is key: incitement is criminalized because public speech has the capacity to mobilize collective violence. The widespread dissemination of the Amalek rhetoric therefore compounds the gravity of the offense.
Context.
Context binds the rhetoric to the operational environment. Here, the context includes declarations of "complete siege," the "human animals" statement, and documented patterns of civilian destruction. It also includes the diffusion of Amalek-based chants among soldiers visible in multiple recorded videos. In incitement jurisprudence, context determines whether the speech is likely to contribute to unlawful acts. The combination of exterminatory terminology, dehumanization, and large-scale civilian targeting satisfies the contextual nexus. The UN Commission (2025) treated leadership statements as integral to the climate of intent.
The environment in which the Amalek rhetoric was issued included simultaneous acts that stripped Palestinians of their basic protections under international humanitarian law. The announcement of a siege, cutting electricity, food, water, and fuel, constituted the deliberate imposition of life-threatening conditions. The “human animals” statement removed moral constraints on the treatment of the population and signaled to the armed forces that ordinary civilian protections were suspended. The subsequent patterns of bombardment, destruction of residential areas, killing of family groups, and obliteration of municipal registries demonstrate that the rhetorical environment and the operational environment were mutually reinforcing.
International tribunals assess context not as background noise but as a legally significant matrix that shapes how speech is interpreted by the audience. The repeated appearance of Amalek chants in soldier videos confirms that the destructive meaning of the rhetoric was received, internalized, and operationalized in the field. The context therefore magnifies the inciting character of the speech, demonstrating that the leadership rhetoric was intimately connected to the acts perpetrated against the Indigenous population.
Intent.
Intent in genocide cases may be inferred from the totality of circumstances: scale of destruction, selection of targets, consistency of rhetoric, and foreseeable consequences. The ICJ’s January 2024 order acknowledged a "plausible" genocide risk, requiring the suppression of incitement by Israel. Intent is further illuminated through operational patterns, mass civilian casualties, destruction of family registries, starvation conditions, and elimination of entire kin groups, all of which align with the exterminatory meaning of "Amalek." In law, verbal identification of a group with a biblical command of annihilation, followed by widespread killing of that same group, is probative of genocidal intent.
In the present case, intent may be inferred from (1) the repeated invocation of an exterminatory label directed at an Indigenous population, (2) the accompanying dehumanization campaign, and (3) the scale and pattern of violence that followed. Entire family lines were eliminated. Municipal records documenting Indigenous kin structures were destroyed. Thousands of civilians were killed in their homes, shelters, and displacement sites. Siege-induced starvation and disease produced additional harm to the group as such.
International law does not require proof of subjective hatred. It requires evidence that the perpetrator meant to destroy, in whole or in part, a protected group. When senior officials publicly label an Indigenous population as “Amalek,” invoke a command narrative of annihilation, and then oversee military operations that eliminate large segments of that population, the legal inference of genocidal intent is reinforced by the observable conduct. The targeting was not random. It aligned with the rhetoric.
Crimes against humanity.
Even if genocide were not charged, the same facts constitute crimes against humanity under Article 7 of the Rome Statute. Persecution arises from severe deprivation of fundamental rights on national or ethnic grounds. Extermination arises from mass killing as part of a widespread or systematic attack on civilians. The invocation of Amalek targets Palestinians as a national and ethnic group; the subsequent destruction meets the scale requirement. The legal framework therefore supports multiple charges independent of the genocide count.
The Indigenous Palestinian population of the southern corridor, including the Tribe of Abimelech, was targeted on the basis of its identity, ancestry, and presence on ancestral land. Their homes, archives, kin-based registries, and family lines were attacked in a manner consistent with both persecution and extermination. Even absent a formal genocide determination, the underlying conduct constitutes a widespread and systematic attack directed against a civilian population. The invocation of “Amalek” therefore functions not only as evidence of genocidal intent but also as evidence of persecution and extermination under the framework of crimes against humanity.
5) Indigenous Identity, Ancestry, and Classification
The Tribe of Abimelech Platform asserts that populations called Amalek in the ancient record form part of the Canaanite ancestry of modern Palestinians in the southern corridor (Be’er Sheba–Gaza–Hebron). Thus, modern invocations of Amalek against Palestinians target an indigenous, Canaanite-descended civilian population by name. This assertion goes to classification, not theology: it places the people marked by the label inside the same historical and geographic line that runs from Bronze-Age Canaanite communities to present-day corridor families, including the Tribe of Abimelech. In legal terms, this means that when an official uses Amalek as a category for destruction, that official is not speaking in abstraction but is singling out a concrete, historically rooted national and ethnical group that qualifies as a protected group under the Genocide Convention and the Rome Statute.
Genetic and archaeological syntheses show long-term Levantine continuity from Bronze-Age Canaanite populations into modern Levantine peoples. Peer-reviewed ancient-DNA studies (Sidon BA genomes) demonstrate substantial continuity with present populations, corroborated by additional southern-Levant datasets. These findings support regional demographic persistence across millennia. In other words, the corridor does not appear in the scientific record as an empty, repeatedly replaced land; it appears as a space of deep demographic continuity, where old strata of Canaanite and Levantine ancestry carry forward into present communities. For purposes of international law, this empirical record underpins the classification of Palestinians, including the Tribe of Abimelech and related corridor families, as Indigenous and as members of a historical national/ethnical group whose presence long predates the current state structure.
When officials label Palestinians as "Amalek," they are not referring to a symbolic, mythical, or imaginary biblical enemy. They are clearly directing the term at a real, existing population, and marking the living descendants of the region’s earliest inhabitants. Especially the tribes of the southern corridor, including the Tribe of Abimelech, who are historically and demographically the continuation of the ancient Canaanite populations located in the Negev, Gaza and Hebron belt. So, the state’s use of the term Amalek is being applied directly to indigenous Canaanite-descended Palestinians, not to a fictional adversary. The very people whose continuity is recognized in mainstream scholarship, archaeology, and population studies. All acknowledge that present-day Palestinians descend from historic Levantine/Canaanite populations. Scholars openly state this. In the context of this communication to international bodies, these points are not offered as political rhetoric but as evidence that the group targeted by the Amalek label is the same Indigenous corridor population that appears in historical texts, archaeological layers, and genetic studies. That is why the label, when weaponized, constitutes persecution and incitement directed at a specifically identifiable Indigenous people rather than at a vague theological construct.
6) The Be’er Sheba Oath as Indigenous Norm of Restraint
The corridor’s oldest recorded public law is the Be’er Sheba oath, a transaction between Abimelech (Gerar) and Abraham (later renewed with Isaac), recognizing water rights and non-aggression, sealed by seven ewe-lambs and a sworn pact at the well. Whatever one’s belief, the textual record identifies this location and describes the legal content of the pact: a sworn agreement to restraint and coexistence on this ground. This makes Be’er Sheba not only a place of narrative interest but a documented site of early corridor law, where a local ruler and an incoming pastoral lineage concluded a formal covenant on water access and mutual non-hostility. For the Tribe of Abimelech, this is preserved as the first written articulation of corridor norms: water is shared according to agreement, and covenant partners are not legitimate objects of annihilatory violence.
For an indigenous legal platform, the oath functions as a standing local norm: once sworn, alliances bind; covenantal neighbors are not legitimate targets. This indigenous "well law" aligns with modern prohibitions on incitement and collective punishment. It is not offered as international positive law; it is offered as corroborative evidence of a historic regional rule of restraint consistent with today’s standards. In the present submission, the Be’er Sheba oath is therefore invoked as part of corridor jurisprudence: an ancestral norm from the time when Abimelech and Abraham agreed that those who share water and ground under oath are shielded from attack. When modern leaders call for the destruction of populations living on the same corridor, while using a term (Amalek) historically connected to peoples of this land, they are not only violating contemporary instruments like the Genocide Convention and Rome Statute; they are also acting against the oldest recorded oath-law of this territory. The convergence between indigenous corridor law and modern international law strengthens the conclusion that such inciting speech is illegitimate and unlawful on both axes.
7) Legal Consequences and Duties
Incitement is prosecutable even if genocide is not completed. States Parties must prevent and punish direct and public incitement (Genocide Convention, Art. I & III(c)). Leaders, commanders, and propagators incur potential individual criminal responsibility (Rome Statute, Art. 25(3)(e)). This means that the international legal system does not wait for the physical destruction of the group to be finished before it recognizes a crime. The moment public speech crosses the line into direct and public incitement, especially from senior officials with authority over armed forces, the obligations of prevention and punishment are triggered. For Indigenous corridor communities, including the Tribe of Abimelech, this is the core protective function of the law: it makes the weaponization of language itself a matter of criminal accountability.
Interim judicial control. The ICJ provisional-measures orders (Jan, Mar, May 2024) obligate Israel to suppress incitement, preserve evidence, and facilitate relief. Persistent use of exterminatory labels after those orders may evidence non-compliance. Once the ICJ identified a plausible risk of genocide and ordered Israel to prevent and punish direct and public incitement, the legal status of Amalek-type rhetoric changed. It ceased to be merely controversial political speech and became a test of compliance with a binding order from the principal judicial organ of the United Nations. Continued use of exterminatory labels in the face of such orders is therefore relevant not only as fresh incitement but also as proof of failure to abide by judicially imposed preventive measures.
Merits-stage risk. The UN Commission (2025) finding of genocide increases the legal exposure surrounding leadership rhetoric because it ties words to patterned acts at scale. The ICC track (warrants sought May 2024) underscores the individual-liability axis. When a UN Commission of Inquiry announces a genocide finding, it retrospectively connects inciting speech to a documented pattern of killings, destruction, and persecution. At that point, statements invoking Amalek are no longer assessable in isolation; they sit within a record in which genocidal harm has been formally identified. Simultaneously, the ICC’s warrant applications make clear that individual leaders are personally exposed. For the Tribe of Abimelech Platform, this combination, Commission finding plus ICC track, marks a transition from early warning to full legal emergency: the corridor’s Indigenous people are at risk from a leadership whose words and deeds now fall squarely inside genocide and crimes-against-humanity frameworks.
8) Remedies Sought
Immediate prohibition, by state order and platform policy, of any official use of Amalek to describe Palestinians or to guide operations; mandatory retraction of prior inciting statements; disciplinary and criminal referrals for violators. This first remedy addresses the incitement stream at its source. It demands that public authorities and command structures treat Amalek as legally contaminated language when directed at Palestinians: a term that cannot lawfully be used as an operational signal or as a descriptor of a protected civilian population. Retractions and referrals are necessary to demonstrate that the state understands this and is willing to enforce it internally, rather than shielding inciters from responsibility.
Certification of compliance to the ICJ: concrete measures adopted to prevent and punish incitement; evidence-preservation protocols; training curricula for leadership and ranks. This remedy links domestic measures to the international supervisory framework already in place. Certification of compliance means more than a political statement; it involves detailed reporting on the steps taken to implement Article I and III(c) of the Genocide Convention and to follow the ICJ’s provisional-measures orders. For Indigenous communities in the corridor, including the Tribe of Abimelech, this creates an external accountability channel to ensure that reforms are not purely cosmetic.
Public recognition that the term "Amalek," as used against Palestinians, targets an indigenous Canaanite-descended population and constitutes persecution and incitement. This remedy goes to truth and classification. It asks that international and domestic institutions acknowledge that the Amalek label, when used in present conditions, is aimed at the living descendants of the Canaanite/Levantine corridor peoples, not at an abstract category. That recognition has legal consequences: it frames prior usage as persecution and incitement and creates a normative barrier to its repetition.
Reparations framework consistent with international law: cessation, guarantees of non-repetition, and community-led memorialization acknowledging the misuse of religious language to justify harm. This final remedy looks beyond immediate speech control to long-term repair. Cessation and guarantees of non-repetition are standard components of state responsibility in international law. Community-led memorialization ensures that the Indigenous peoples who were targeted, among them the Tribe of Abimelech and related corridor families, are the ones who define how this episode is remembered. The reparations framework therefore connects legal restitution to Indigenous agency, and records that Amalek was misused as a weapon against the very populations whose ancestral presence the corridor law and texts locate here.
9) Evidence Handling and Implementation Plan
Chain of custody. Archive official web pages (statements; letters); export hashes and timestamps; preserve videos evidencing diffusion to ranks; compile sworn translations; log repositories with access controls. This chain-of-custody plan is designed to meet evidentiary standards in international proceedings and to prevent later denial or tampering. Archiving official pages and letters with cryptographic hashes creates a verifiable record that the words were in fact published. Preserving videos that show how Amalek rhetoric spread into the ranks documents the pathway from leadership speech to soldier practice. Sworn translations ensure that non-Hebrew-speaking courts can assess the content directly. Access-controlled repositories protect sensitive materials while still allowing disclosure to competent authorities.
Treaty anchors. Attach certified copies/excerpts of Article III(c) (Genocide Convention) and Articles 7/25 (Rome Statute) to submissions and motions. This step ensures that every filing is grounded in the precise treaty language that criminalizes incitement and defines crimes against humanity. By placing the treaty provisions side-by-side with the cited statements, the submission shows that the issue is not one of abstract morality but of specific, binding obligations. For the Tribe of Abimelech Platform, this also reinforces that the corridor’s Indigenous claims are anchored in the same legal instruments that states themselves have ratified.
Judicial annexes. Include certified extracts of ICJ orders (Jan 26; Mar 28; May 24, 2024) and the OHCHR press release on the 2025 COI report. These annexes document that the highest global court and the UN human-rights system have already recognized a plausible genocide risk and later a genocide finding. By annexing these materials, the Tribe of Abimelech Platform links its own evidentiary record to existing judicial and quasi-judicial determinations. That connection shows that the Indigenous complaint is not isolated; it sits within a broader architecture of international alarm and action.
Indigenous standing. Append a short corridor dossier: Be’er Sheba oath texts (citations), corridor map, names of houses/tribes (where appropriate), and continuity synopsis (peer-reviewed continuity studies). This dossier is the standing file for Indigenous identity. It displays the Be’er Sheba oath as corridor law, maps the corridor (Be’er Sheba–Gaza–Hebron) as the tribe’s ancestral space, lists key houses and lineages where disclosure is appropriate, and summarizes continuity scholarship that traces Canaanite ancestry into modern corridor populations. Together, these elements establish that the Tribe of Abimelech is not a late-invented label but an Indigenous corridor community with documented historical, textual, and scientific continuity, entitled to the protections and remedies sought.
10) Findings
Fact.
Senior Israeli officials publicly invoked Amalek while directing military operations, repeated the label in a letter to troops, and used dehumanizing language, followed by diffusion among soldiers. This factual finding rests on government records, media documentation, and visual evidence showing that the Amalek label and related dehumanizing terms were not marginal or private. They appeared in official speeches, on state platforms, and in written communications to combat units, and were then echoed in soldier chants and frontline behavior. For purposes of this report, factual sequence, leader speech, written orders, soldier uptake, is the backbone of the incitement chain.
Law.
Those utterances meet the core elements of direct and public incitement and contribute to crimes against humanity when paired with the attack’s scale and pattern. Under the Genocide Convention and Rome Statute, the combination of exterminatory language, public dissemination, and subsequent mass harm satisfies the elements of directness, publicness, intent, and contextual nexus. When evaluated against ICTR and related jurisprudence, the content and timing of the Amalek references, and their deployment during an already ongoing attack on a civilian population, align with established patterns of inciting speech in prior genocide and persecution cases.
Indigenous continuity.
Palestinians, particularly in the southern corridor, including the Tribe of Abimelech, the Tribe of Brahmiyya, the Tribe of Zamāʿirah, and related families, are the living descendants of the ancient Canaanite populations of Palestine. The Amalek label, used against them, designates the very people whose ancestral presence the texts locate here, converting the word into a targeting device. This finding synthesizes the historical, archaeological, genetic, and corridor-law materials set out above. It concludes that the population targeted by the term is not only a protected group in abstract treaty language; it is the same Indigenous corridor population whose covenantal law is recorded at Be’er Sheba and whose continuity is recognized in contemporary scholarship. That is why the label operates as a targeting device in law, not merely as rhetoric.
Duty.
Under the Genocide Convention and Rome Statute, the inciting speech must be stopped and punished, and victims protected and repaired. Interim ICJ orders already require suppression; UN COI (2025) heightens urgency. This final finding draws together obligation and urgency. The existence of ICJ provisional measures means that suppression of incitement is already a judicially mandated duty, not an optional policy choice. The Commission’s genocide conclusion and the ICC track both amplify the risk and the need for immediate, concrete measures. For the Tribe of Abimelech and other corridor peoples, this is the point at which law and survival intersect: the duty to act against inciters is now both a treaty obligation and a response to an ongoing Indigenous protection crisis.
Final thoughts
Amalek cannot be a license to kill. In international law, it is inciting speech when used to mark a protected civilian population. In our own tribal memory, it is a word of ancestry in the southern corridor, Be’er Sheba, Gaza, Hebron, where our people still live and keep the older oath-law of the well: water rights, non-aggression, covenants kept. The two frameworks, modern law and indigenous law, agree on the operative rule: no public authority may command or encourage the destruction of our families by scriptural slogan. The legal record, the treaties, and the orders already on the books require prevention, punishment, and redress, now. In this sense, the Tribe of Abimelech Platform is not asking for new rights; it is demanding enforcement of existing ones. The same corridor that first recorded a pact of restraint between Abimelech and Abraham is now the scene where that restraint must be re-imposed through international legal mechanisms to protect the descendants of those who swore by the well.
From the perspective of Indigenous identity, the use of Amalek against Palestinians in the corridor is an attack on lineage and memory as well as on life. It weaponizes a word that, in our own tradition, points back to Canaanite ancestors and corridor peoples, turning an ancestral marker into a death sentence. From the perspective of international law, the same use of the term constitutes direct and public incitement to commit genocide and contributes to persecution and extermination as crimes against humanity. The convergence of these two perspectives, Indigenous law of the well and global law of genocide prevention, creates a single clear conclusion: this rhetoric must be prohibited, its authors held to account, and its harms acknowledged and repaired. The Tribe of Abimelech Platform therefore submits this report as both a legal communication and an Indigenous declaration that the corridor’s people will not accept being named for destruction with their own ancestral word.
List of Authorities (with URLs)
Section 1 – Introduction and Purpose of the Submission
[1.1] Convention on the Prevention and Punishment of the Crime of Genocide, 9 December 1948, 78 U.N.T.S. 277, available at: https://treaties.un.org/doc/Treaties/1951/01/19510112%2008-12%20PM/Ch_IV_1p.pdf
[1.2] Rome Statute of the International Criminal Court, 17 July 1998 (entered into force 1 July 2002), available at: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
[1.3] United Nations Declaration on the Rights of Indigenous Peoples, G.A. Res. 61/295, U.N. Doc. A/RES/61/295 (13 September 2007), official text (English) available at: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf
[1.4] OHCHR, “United Nations Declaration on the Rights of Indigenous Peoples” (instrument overview), available at: https://www.ohchr.org/en/instruments-mechanisms/instruments/united-nations-declaration-rights-indigenous-peoples
[1.5] Skourtanioti et al., “Genomic History of the Bronze Age Southern Levant,” Cell (2021), ScienceDirect access at: https://www.sciencedirect.com/science/article/pii/S0092867421006699
Section 2 – Chronology of Public Incitement, Diffusion, and Denials
[2.1] Reuters, “Netanyahu evokes Biblical Amalek in Israel’s fight against Hamas,” 29 October 2023, available at: https://www.reuters.com/world/middle-east/netanyahu-evokes-biblical-amalek-israels-fight-against-hamas-2023-10-29/
[2.2] Times of Israel, “Defense minister announces ‘complete siege’ of Gaza: No power, food or fuel,” liveblog entry quoting Yoav Gallant, 9 October 2023, available at: https://www.timesofisrael.com/liveblog_entry/defense-minister-announces-complete-siege-of-gaza-no-power-food-or-fuel/
[2.3] Wikipedia entry “Yoav Gallant” (for consolidated public record of the “human animals” quote and siege declaration context), available at: https://en.wikipedia.org/wiki/Yoav_Gallant
[2.4] Wikipedia entry “Gaza Strip” (for background on siege and humanitarian context in late 2023–2024), available at: https://en.wikipedia.org/wiki/Gaza_Strip
[2.5] International Court of Justice, “Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel),” case page (orders, pleadings, and press releases), available at: https://www.icj-cij.org/case/192
[2.6] Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), Order of 28 March 2024, reproduced by United Nations, Question of Palestine, available at: https://www.un.org/unispal/document/icj-order-gaza-genocide-covention-28mar24/
[2.7] ICC Office of the Prosecutor, “Statement of ICC Prosecutor Karim A. A. Khan KC: Applications for arrest warrants in the Situation in the State of Palestine,” 20 May 2024, UN Question of Palestine reproduction, available at: https://www.un.org/unispal/document/icc-prosecutor-karim-a-a-khan-kc-requests-arrest-warrants-in-relation-to-the-situation-in-the-state-of-palestine/
[2.8] Office of the United Nations High Commissioner for Human Rights, “Israel has committed the crime of genocide against Palestinians in Gaza, says UN Commission of Inquiry,” press release, 12 June 2025, available at: https://www.ohchr.org/en/press-releases/2025/06/israel-has-committed-crime-genocide-against-palestinians-gaza-says-un
Section 3 – Governing Law
[3.1] Convention on the Prevention and Punishment of the Crime of Genocide, text as in [1.1]: https://treaties.un.org/doc/Treaties/1951/01/19510112%2008-12%20PM/Ch_IV_1p.pdf
[3.2] ICRC, “Treaties, States Parties and Commentaries – Genocide Convention, 1948,” IHL database entry (for structure and state-practice references), available at: https://ihl-databases.icrc.org/en/ihl-treaties/genocide-convention-1948
[3.3] Rome Statute of the International Criminal Court, official PDF as in [1.2]: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
[3.4] United Nations Declaration on the Rights of Indigenous Peoples (full text), as in [1.3]: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf
[3.5] OHCHR overview of UNDRIP, as in [1.4]: https://www.ohchr.org/en/instruments-mechanisms/instruments/united-nations-declaration-rights-indigenous-peoples
[3.6] International Court of Justice, South Africa v. Israel case page (for provisional-measures orders and pleadings), as in [2.5]: https://www.icj-cij.org/case/192
Section 4 – Application of Law to Facts
[4.1] Application of the Genocide Convention in the Gaza Strip (South Africa v. Israel), Order of 26 January 2024 (provisional measures), via ICJ case page (orders tab), available at: https://www.icj-cij.org/case/192
[4.2] Application of the Genocide Convention in the Gaza Strip (South Africa v. Israel), Order of 28 March 2024 (further provisional measures), United Nations Question of Palestine reproduction, as in [2.6]: https://www.un.org/unispal/document/icj-order-gaza-genocide-covention-28mar24/
[4.3] Application of the Genocide Convention in the Gaza Strip (South Africa v. Israel), Order of 24 May 2024 (additional provisional measures), accessible via the same ICJ case page orders list, available at: https://www.icj-cij.org/case/192
[4.4] ICC Office of the Prosecutor, “Statement of ICC Prosecutor Karim A. A. Khan KC: Applications for arrest warrants in the Situation in the State of Palestine,” 20 May 2024, as in [2.7]: https://www.un.org/unispal/document/icc-prosecutor-karim-a-a-khan-kc-requests-arrest-warrants-in-relation-to-the-situation-in-the-state-of-palestine/
[4.5] OHCHR, UN Commission of Inquiry press release on genocide finding, as in [2.8]: https://www.ohchr.org/en/press-releases/2025/06/israel-has-committed-crime-genocide-against-palestinians-gaza-says-un
[4.6] Rome Statute of the International Criminal Court (for Arts. 6, 7, 25(3)(e)), as in [1.2]: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
Section 5 – Indigenous Identity and Ancestral Classification
[5.1] Skourtanioti et al., “Genomic History of the Bronze Age Southern Levant,” Cell (2021), ScienceDirect article page: https://www.sciencedirect.com/science/article/pii/S0092867421006699
[5.2] United Nations Declaration on the Rights of Indigenous Peoples, as in [1.3]: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf
[5.3] OHCHR overview of UNDRIP, as in [1.4]: https://www.ohchr.org/en/instruments-mechanisms/instruments/united-nations-declaration-rights-indigenous-peoples
Section 6 – The Be’er Sheba Oath as Indigenous Norm of Restraint
[6.1] Bible text of Deuteronomy 25:17 (“Remember what Amalek did to you”), Bible Gateway, available at: https://www.biblegateway.com/passage/?search=Deuteronomy+25%3A17&version=NRSVUE
[6.2] Bible text of 1 Samuel 15 (narrative of Amalek extermination command), Bible Gateway, available at: https://www.biblegateway.com/passage/?search=1+Samuel+15&version=NRSVUE
[6.3] Genesis 21:22–34 (oath between Abimelech and Abraham at Be’er Sheba), Bible Gateway, available at: https://www.biblegateway.com/passage/?search=Genesis+21%3A22-34&version=NRSVUE
[6.4] Genesis 26:26–33 (renewal of Be’er Sheba oath with Isaac), Bible Gateway, available at: https://www.biblegateway.com/passage/?search=Genesis+26%3A26-33&version=NRSVUE
Section 7 – Legal Consequences and Duties
[7.1] Convention on the Prevention and Punishment of the Crime of Genocide, as in [1.1]: https://treaties.un.org/doc/Treaties/1951/01/19510112%2008-12%20PM/Ch_IV_1p.pdf
[7.2] Rome Statute of the International Criminal Court (Arts. 6, 7, 25(3)(e)), as in [1.2]: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
[7.3] ICRC, “Treaties, States Parties and Commentaries – Genocide Convention, 1948” (for state practice and commentary on obligations to prevent and punish), as in [3.2]: https://ihl-databases.icrc.org/en/ihl-treaties/genocide-convention-1948
[7.4] International Court of Justice, South Africa v. Israel case page with provisional-measures orders (Jan, Mar, May 2024), as in [2.5]: https://www.icj-cij.org/case/192
[7.5] OHCHR, COI press release on genocide finding, as in [2.8]: https://www.ohchr.org/en/press-releases/2025/06/israel-has-committed-crime-genocide-against-palestinians-gaza-says-un
[7.6] United Nations Declaration on the Rights of Indigenous Peoples (for UNDRIP Articles 7, 8, 10 on genocide, forced removal, and demographic integrity), as in [1.3]: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf
Section 8 – Remedies Sought (Indicative)
[8.1] Convention on the Prevention and Punishment of the Crime of Genocide (state responsibility, duties to prevent and punish), as in [1.1]: https://treaties.un.org/doc/Treaties/1951/01/19510112%2008-12%20PM/Ch_IV_1p.pdf
[8.2] Rome Statute of the International Criminal Court (state cooperation, individual criminal liability), as in [1.2]: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
[8.3] United Nations Declaration on the Rights of Indigenous Peoples (remedies, guarantees of non-repetition, recognition of Indigenous institutions), as in [1.3]: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf
[8.4] OHCHR overview of UNDRIP (for interpretive guidance on remedies and Indigenous participation), as in [1.4]: https://www.ohchr.org/en/instruments-mechanisms/instruments/united-nations-declaration-rights-indigenous-peoples
[8.5] ICJ case page and provisional-measures orders in South Africa v. Israel (remedies, cessation, guarantees of non-repetition at state level), as in [2.5]: https://www.icj-cij.org/case/192
Section 9 – Evidence Handling and Implementation Plan
[9.1] ICRC, “Treaties, States Parties and Commentaries – Genocide Convention, 1948” (for standard treaty citation and practice in evidence annexes), as in [3.2]: https://ihl-databases.icrc.org/en/ihl-treaties/genocide-convention-1948
[9.2] Rome Statute of the International Criminal Court (procedural and jurisdictional framework for evidence-driven prosecutions), as in [1.2]: https://www.icc-cpi.int/sites/default/files/RS-Eng.pdf
[9.3] ICC Office of the Prosecutor, Palestine arrest-warrant statement (illustrative of how OTP systematizes evidence about speech, siege, and attacks), as in [2.7]: https://www.un.org/unispal/document/icc-prosecutor-karim-a-a-khan-kc-requests-arrest-warrants-in-relation-to-the-situation-in-the-state-of-palestine/
[9.4] OHCHR, COI press release (for how UN investigative bodies frame chains of custody and corroboration for leadership rhetoric), as in [2.8]: https://www.ohchr.org/en/press-releases/2025/06/israel-has-committed-crime-genocide-against-palestinians-gaza-says-un
[9.5] ICRC, general IHL database landing page “Treaties, States Parties and Commentaries” (for model citation styles and annex practice), available at: https://ihl-databases.icrc.org/en
Section 10 – Findings
[10.1] Reuters, Netanyahu’s Amalek statement, as in [2.1] (for fact of public Amalek invocation during operations): https://www.reuters.com/world/middle-east/netanyahu-evokes-biblical-amalek-israels-fight-against-hamas-2023-10-29/
[10.2] Times of Israel liveblog entry on Gallant’s “complete siege” quote, as in [2.2] (for siege-and-dehumanization context): https://www.timesofisrael.com/liveblog_entry/defense-minister-announces-complete-siege-of-gaza-no-power-food-or-fuel/
[10.3] OHCHR, COI genocide press release (for the formal genocide finding and linkage to leadership rhetoric and siege policy), as in [2.8]: https://www.ohchr.org/en/press-releases/2025/06/israel-has-committed-crime-genocide-against-palestinians-gaza-says-un
[10.4] ICC Office of the Prosecutor, Palestine arrest-warrant application statement (for persecution/extermination theory), as in [2.7]: https://www.un.org/unispal/document/icc-prosecutor-karim-a-a-khan-kc-requests-arrest-warrants-in-relation-to-the-situation-in-the-state-of-palestine/
[10.5] International Court of Justice, South Africa v. Israel case page and orders (for “plausible genocide” finding, duty to suppress incitement, and state responsibility), as in [2.5]: https://www.icj-cij.org/case/192
[10.6] Skourtanioti et al., Bronze-Age Southern Levant genomic history (for Canaanite continuity finding), as in [5.1]: https://www.sciencedirect.com/science/article/pii/S0092867421006699
[10.7] United Nations Declaration on the Rights of Indigenous Peoples (for Indigenous survival, land, identity, and protection against genocide and forced removal), as in [1.3]: https://digitallibrary.un.org/record/638370/files/Declaration_indigenous_en.pdf





