One of the earliest examples of the effort to obscure the legal status of the Occupied Territories by avoiding the term “occupation” is in a memo sent on June 22nd, 1967, by Michael Comay, the Foreign Minister’s political advisor the ministry’s deputy executive director.

The effort to withstand pressures on Israel to comply with its duties under the Fourth Geneva Convention was at the heart of the policy to avoid legal terminology that hint to the Convention’s applicability to the Occupied Territories. “Our UN delegation and our diplomatic missions must be aware that locally, we avoid discussions with the ICRC on the status of the territories and the status of the ICRC in them,” explained Comay the need to avoid the use of legal terms enumerated in the convention, such as “occupied territories” and “occupying power”. Comay suggested alternatives: “Using the term TERRITORIES OF THE MILITARY GOVERNMENT or TERRITORIES UNDER ISRAEL [sic] CONTROL. Externally, I prefer the second option.”

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Comay Memo, June 22nd, 1967: "Cautionary remarks with respect to the use of certain terms"