South Africa’s submission to the International Court of Justice sets out in impressive detail the horrific consequences of Israel’s assault on Gaza – so far. Nearly half the 2.3 million residents of Gaza are children. Their plight and that of older students are described in paragraphs 44, 48-9, 52-4, 86, 88, 90, 92-3 of the submission, which are reproduced below. As UNICEF summarised it, Gaza is “the most dangerous place in the world to be a child.” The original submission, on the ICJ website, can be found here.

44. United Nations chiefs and the International Committee of the Red Cross (‘ICRC’) — no
strangers to conflict situations — have called what is unfolding in Gaza a “crisis of humanity”.176
“Humanitarian veterans who have served in war zones and disasters around the world — people who
have seen everything — [say] they have seen nothing like what they see today in Gaza” (United Nations Secretary-General).177 This is “a moral failure” causing “intolerable suffering” (ICRC President).178
“This is an apocalyptic situation now, because these are the remnants of a nation being driven into a
pocket in the south” (Under-Secretary-General for Humanitarian Affairs and Emergency Relief
Coordinator at the United Nations).179 They describe Palestinians in Gaza as “living in utter, deepening
horror” as they “continue to be relentlessly bombarded by Israel… suffering death, siege, destruction
and deprivation of the most essential human needs such as food, water, lifesaving medical supplies and
other essentials on a massive scale”; it is “apocalyptic” (United Nations High Commissioner for Human
Rights).180 “An entire population is besieged and under attack, denied access to the essentials for
survival, bombed in their homes, shelters, hospitals and places of worship” (Principals of the United
Nations Inter-Agency Standing Committee).181 Gaza is “the most dangerous place in the world to be a
child” (United Nations International Children’s Emergency Fund (UNICEF) Executive Director).182 “It
is a “living hell”, it is “a war of all the superlative, everything is unprecedented” and “[w]e are out of
words to describe what is going on” (UNRWA Commissioner-General).183

48. For Palestinian children, in particular, “[d]eath is everywhere” and “nowhere is safe”.203 A total
of over 7,729 Palestinian children have been killed in Gaza to date — over 115 Palestinian children in
Gaza are killed every day.204 It is estimated that more Palestinian children were killed in the first three
weeks in Gaza alone (a total of 3,195) than the total number of children killed each year across the
world’s conflict zones since 2019.205 The scale of Palestinian child killings in Gaza is such that United
Nations chiefs have described it as “a graveyard for children”.206 Indeed, the unprecedented rate of
Palestinian child casualties has prompted UNICEF’s spokesperson to call Israel’s attacks on Gaza a
“war on children”. He explained:
“Most crises, they impact children terribly because children are the most vulnerable, but most
have about a casualty rate of children of around 20 per cent. This is 40. This is twice as lethal
to children as many conflicts we’ve seen in the last 15 or 20 years, and unfortunately that is
because of the sheer density of population, the indiscriminate nature, and when we see that
there’s been not even lip service to safe zones having water and sanitation for children and
young girls. That same disregard for children is being shown in the bombardments. That’s why
we see 40 per cent of casualties are children. That’s why it’s a war on children.”207
49. Doctors, journalists, teachers, academics and other professionals are also being killed at wholly
unprecedented rates. To date, Israel has killed: over 311 doctors, nurses and other health workers,
including doctors and ambulance drivers killed on duty;208 103 journalists, amounting to over one per
day,209 and more than 73 per cent of the total number of journalists and media workers killed globally
in 2023;210 40 civil defence workers — responsible for helping to dig victims out of the rubble — killed
while on duty; and over 209 teachers and educational staff.211 144 United Nations employees have also
been killed, the “highest number of aid workers killed in UN history in such a short time”.212 It is estimated that “it will take years to recover the remains of people from beneath the rubble” and that
“the costly, technical process will not result in the identification of each body”.213
50. In addition to being killed by Israeli weaponry, Palestinians in Gaza are also at immediate risk
of death by starvation, dehydration and disease as a result of the ongoing siege by Israel, the insufficient
aid being allowed through to the Palestinian population, and the extreme difficulties in distributing such
limited aid that is permitted to enter the territory due to the decimation of Gaza’s infrastructure in
Israel’s military attacks.214

52. The extreme levels of bombardment and lack of any safe areas are also causing severe mental
trauma in the Palestinian population in Gaza.220 Even before the latest onslaught, Palestinians in Gaza
suffered severe trauma from prior attacks: 80 per cent of Palestinian children experienced higher levels
of emotional distress, demonstrating bedwetting (79 per cent) and reactive mutism (59 per cent), and
engaging in self-harm (59 per cent), and suicidal thoughts (55 per cent).221 Eleven weeks of relentless
bombardment, displacement and loss will necessarily have led to a further increase in those figures,
particularly for the estimated tens of thousands of Palestinian children who have lost at least one parent,
and those who are the sole surviving members of their families.222 For the families who remain intact or partially intact, “it’s about doing everything you can so your child doesn’t realise that you’ve lost
53. It is already known that “[r]epeated exposure to conflict and violence, including witnessing and
experiencing housing demolition, combined with Israel’s siege of Gaza since 2007” is “associated with
high levels of psychological distress among Palestinians”.
224 Indeed, the United Nations Security
Council in Resolution 2712 (2023) expressed its “deep concern that the disruption of access to education
has a dramatic impact on children, and that conflict has lifelong effects on their physical and mental
health”.225 That disruption and its “dramatic impact” on children must be considered, in particular, in
the context of the number of Palestinian students and educators who have been killed (4,037 and 209
respectively), and wounded (estimated at 7,259),226 and the number of Palestinian schools having been
damaged or destroyed (352, or 74 per cent of the schools in the whole of Gaza).227 Medical professionals
assess that “[t]he health effects on all Palestinian children, women, men, older people, people with
disabilities, and people of marginalised identities are immense”.228 An Emergency Coordinator for
Médecins sans Frontières interviewed on her return from five weeks in Gaza described:
“[I]t’s even worse in reality than it looks. It’s – the amount of suffering is just something…
incomparable. It’s really unbearable. I’m speechless when I try and think of the future of this
children. It’s generations of children who will be handicapped, who will be traumatized. The
very children in our mental health program are telling us that they would rather die than
continue living in Gaza now.”229
54. Alongside its military campaign, Israel has engaged in the dehumanisation, and cruel, inhuman
and degrading treatment of members Palestinians in Gaza. Large numbers of Palestinian civilians,
including children, have reportedly been arrested, blindfolded, forced to undress and remain outside in
the cold weather, before being forced on to trucks and taken to unknown locations.230 Medics and first
responders, in particular, have been repeatedly detained by Israeli forces, with many being detained
incommunicado at unknown locations.231 Videos published by Israeli media on Christmas Day appeared to show hundreds of Palestinians, rounded up inside Al Yarmouk football stadium in Gaza City,
“including children, older people and persons with disabilities, being forced to strip to their underwear
in degrading conditions”.
232 Many Palestinian detainees who have been released report having been
subjected to torture and ill-treatment, including the deprivation of food, water, shelter and access to
toilets;233 the United Nations Office for the Coordination of Humanitarian Affairs (‘OCHA’) reports
“video footage showing bruises and burns on the … bodies” of detainees.234 Images of mutilated and
burned corpses — alongside videos of armed attacks by Israeli soldiers — billed as ‘exclusive content
from the Gaza Strip’, are reportedly circulated in Israel via a social media ‘Telegram’ channel called
‘72 Virgins – Uncensored’.235

86. Experts are beginning to warn that the numbers of Palestinians dying as a result of disease and
hunger, could already be outstripping violent deaths caused by Israeli army assaults.385 There have
already been over 360,000 documented cases of communicable diseases reported in UNRWA shelters
alone, brought on or exacerbated by unsanitary conditions, hunger and lack of clean water, with the
actual numbers believed to be considerably higher.
386 As stated by the World Health Organization:
“Gaza is already experiencing soaring rates of infectious diseases. Over 100 000 cases of
diarrhoea have been reported since mid-October. Half of these are among young children under
the age of 5 years, case numbers that are 25 times what was reported before the conflict.
Over 150 000 cases of upper respiratory infection, and numerous cases of meningitis, skin
rashes, scabies, lice and chickenpox have been reported. Hepatitis is also suspected as many
people present with the tell-tale signs of jaundice.
While a healthy body can more easily fight off these diseases, a wasted and weakened body
will struggle. Hunger weakens the body’s defences and opens the door to disease.
Malnutrition increases the risk of children dying from illnesses like diarrhoea, pneumonia and
measles, especially in a setting where they lack access to life-saving health services.
Even if the child survives, wasting can have life-long impacts as it stunts growth and impairs
cognitive development…
The people of Gaza, who have already suffered enough, now face death from starvation and
diseases that could be easily treated with a functioning health system. This must stop. Food and
other aid must flow in far greater amounts. WHO reiterates its call for an immediate
humanitarian ceasefire.”387

88. On 16 November 2023, 15 United Nations Special Rapporteurs and 21 members of United
Nations Working Groups, warning of a “genocide in the making” in Gaza, observed that the level of
destruction that had by then taken place of “housing units, as well as hospitals, schools, mosques,
bakeries, water pipes, sewage and electricity networks . . . threatens to make the continuation of
Palestinian life in Gaza impossible”.391 As they note, Israel has in its bombing campaign against Gaza
used “powerful weaponry with inherently indiscriminate impacts, resulting in a colossal death toll
and destruction of life-sustaining infrastructure.”392 Israel has destroyed not only individual homes,
houses, and whole apartment blocks; it has destroyed entire streets, and entire neighbourhoods:
Shuja’iyya, a suburb of Gaza City, once home to approximately 110,000 Palestinians, appears to
now be a vast wasteland, entirely flattened as far as the eye can see.393 Its shops, schools, vibrant
market place, family homes, doctors clinics, historic streets and Ibn Uthman Mosque, and
everything that once sustained Palestinian life there has been damaged or destroyed, along with so
many of its people.394 Other areas in Gaza appear to have experienced a similar level of destruction,
including Beit Hanoun,395 Beit Lahia,396 Gaza Old City,397 Al Rimal,398 and Nuseirat refugee camp
in the South.399

90. Israel has left Gaza City’s main public library in ruins.403 It has also damaged or destroyed
countless bookshops, publishing houses, libraries,404 and hundreds of educational facilities.405 Israel has
targeted every one of Gaza’s four universities — including the Islamic University of Gaza, the oldest
higher education institution in the territory, which has trained generations of doctors and engineers,
amongst others,
406 — destroying campuses for the education of future generations of Palestinians in
Gaza. Alongside so many others, Israel has killed leading Palestinian academics, including: Professor
Sufian Tayeh, the President of the Islamic University — an award-winning physicist and UNESCO
Chair of Astronomy, Astrophysics and Space Sciences in Palestine — who died, alongside his family,
in an airstrike; Dr Ahmed Hamdi Abo Absa, Dean of the Software Engineering Department at the
University of Palestine, reportedly shot dead by Israeli soldiers as he walked away, having been released
from three days of enforced disappearance; and Professor Muhammad Eid Shabir, Professor of
Immunology and Virology, and former President of the Islamic University of Gaza, and Professor
Refaat Alareer, poet and Professor of Comparative Literature and Creative Writing at the Islamic
University of Gaza, were both killed by Israel with members of their families. Professor Alareer was a
co-founder of ‘We are Not Numbers’, a Palestinian youth project seeking to tell the stories behind
otherwise impersonal accounts of Palestinians — and Palestinian deaths — in the news.407
91. Israel has damaged and destroyed numerous centres of Palestinian learning and culture,
including: the Al Zafar Dmari Mosque and Center for Manuscripts and Ancient Documents;408 the
Orthodox Cultural Centre; the Al Qarara Cultural Museum; the Gaza Centre for Culture and Arts; the
Arab Social Cultural Centre; the Hakawi Society for Culture and Arts; and the Rafah Museum — Gaza’s
newly opened museum of Palestinian heritage, housing hundreds of cultural and archaeological
artefacts. Israel’s attacks have destroyed Gaza’s ancient history: eight sites have been damaged or destroyed, including the ancient port of Gaza (known as ‘Anthedon Harbour’ or ‘Al Balakhiya’) — the
archaeological site of a 2,000-year-old Roman cemetery listed on both the Islamic Heritage List and the
tentative UNESCO World Heritage List.
409 Israel has also destroyed Gaza City’s ‘Old City’, including
its 146-year-old historic houses, mosques, churches, markets and schools. It has also destroyed Gaza’s
more recent history of more hopeful times, including the Rashad al-Shawa Cultural Center — site of a
historic meeting between United States President Bill Clinton and Palestinian President Yasser Arafat
25 years ago — and an important cultural hub for Palestinians in Gaza, with its theatre, library and
event space.410 And Israel is destroying Gaza’s future academic and cultural potential: alongside the
352 Palestinian schools it has damaged or destroyed,411 the 4,037 students and 209 teachers and
educational staff it has killed, alongside the other 7,259 students and 619 teachers it has injured.412

93. Along with its destruction of the physical monuments to the history and heritage of the
Palestinians in Gaza, Israel has sought to destroy the very Palestinian people who form and create that
heritage: Gaza’s celebrated journalists, its teachers, intellectuals and public figures, its doctors and
nurses, its film-makers, writers and singers, the directors and deans of its universities, the heads of its
hospitals, its eminent scientists, linguists, playwrights, novelists, artists and musicians. Israel has killed
and is killing Palestinian story-tellers and poets, Palestinian farmers and fishermen, alongside Gaza’s
local legends: pastry chef Masoud Muhammad al-Qatati, killed in an Israeli airstrike on his house on 3
November 2023, whose shop’s motto ‘let the poor eat’ — and reputation for giving away the popular
Palestinian treat ‘knafeh’ to indigent customers — earned him the nickname ‘Father of the Poor’; 84-
year-old Elham Farah, from one of Palestine’s oldest Christian families — a reputed accordionist and
music teacher, known as ‘Mother Orange’ to generations of Palestinian music students for her shock of
red hair,
417 — shot dead by an Israeli sniper outside the Holy Family Church in Gaza City when she returned home for warm clothes, and was left to bleed to death;418 and Al-Shaima Saidam, the student
with the highest final high school exam grades in the whole of Palestine, killed with multiple members
of her family in a strike on Al Nuseirat refugee camp.419 Just as Israel is destroying the official memory
and records of Palestinians in Gaza through its destruction of Gaza’s archives and landmarks, it is
obliterating Palestinian personal lives and private memories, histories and futures, through bombing
and bulldozing graveyards,420 destroying family records and photographs, wiping out entire multigenerational families,421 and killing, maiming and traumatising a generation of children.422 As a
Palestinian man, in a video by UNRWA, succinctly sums up: “These are all our memories, our entire
lives . . . Now it’s all gone; everything has turned into ashes.”423