Amicus Curiae Brief — Markwayne Mullin, Secretary, Department of Homeland Security, et al., Petitioners v. Dahlia Doe, et al.

Supreme Court briefApr 13, 2026

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NOS. 25-1083 AND 25-1084

IN THE

SUPREME COURT OF THE UNITED STATES

MARKWAYNE MULLIN, SECRETARY, DEPARTMENT OF

HOMELAND SECURITY, ET AL.,

PETITIONERS

v.

DAHLIA DOE, ET AL.

RESPONDENTS

DONALD J. TRUMP, PRESIDENT OF THE UNITED STATES,

ET AL.,

PETITIONERS

v.

FRITZ EMMANUEL LESLY MIOT, ET AL.,

RESPONDENTS

ON WRITS OF CERTIORARI BEFORE JUDGMENT

TO THE UNITED STATES COURTS OF APPEALS

FOR THE SECOND AND DISTRICT OF COLUMBIA CIRCUITS

BRIEF AMICI CURIAE OF SYRIAN JUSTICE

AND ACCOUNTABILITY CENTRE AND

TAHRIR INSTITUTE FOR MIDDLE EAST POLICY

IN SUPPORT OF RESPONDENTS IN NO. 25-1083

CHRIS GAIR

COUNSEL OF RECORD

GAIR GALLO EBERHARD LLP

1 E WACKER DR., SUITE 2600

CHICAGO, IL 60601

CGAIR@GAIRGALLO.COM

(312) 600-4900

LAYLA ABI-FALAH

OF COUNSEL

SYRIAN JUSTICE AND

ACCOUNTABILITY CENTRE

COUNSEL FOR AMICI

TABLE OF CONTENTS

TABLE OF AUTHORITIES .............................................. ii

STATEMENT OF INTEREST .............................................1

SUMMARY OF ARGUMENT ............................................2

ARGUMENT ...................................................................6

1. THE CONDITIONS THAT GAVE RISE TO

TEMPORARY PROTECTED STATUS (TPS) DESIGNATION

FOR SYRIA .....................................................................6

2. THE POST-CONFLICT TRANSITION IN SYRIA IS

CHARACTERIZED BY A SECURITY VACUUM AND

COMPETITION FOR CONTROL AMONG THE FORCES OF THE

INTERIM GOVERNMENT AND OTHER ARMED FACTIONS

WHO CONTINUE TO BE ACTIVE THROUGHOUT THE

COUNTRY .......................................................................8

3. SYRIA REMAINS A COUNTRY PLAGUED BY

WIDESPREAD AND ONGOING INTERNAL AND

INTERNATIONAL ARMED CONFLICT AND VIOLENCE ......16

4. HUMANITARIAN CONDITIONS IN SYRIA ARE

DIRE ............................................................................35

CONCLUSION ..............................................................39

ii

TABLE OF AUTHORITIES

MISCELLANEOUS

Access Center for Human Rights, Housing Land and

Property: A Legal, Political and Humanitarian

Barrier to Refugee Return (Jan. 2026),

https://achrights.org/en/2026/01/20/16188/..............

................................................................... 36, 37, 38

Al Jazeera, Israel says it his Syrian army camps in

the south after Druze ’attacked’ (Mar. 20, 2026),

https://www.aljazeera.com/news/2026/3/20/israelsays-it-hit-syrian-army-camps-in-the-south-afterdruze-attacked. ..................................................... 25

Amnesty International, Syria: A year after Assad’s

fall, the rights of survivors and families must

guide transition (Dec. 8, 2025),

https://www.amnesty.org/en/latest/news/2025/12/s

yria-a-year-after-assads-fall-rights-of-survivorsmust-guide-transition/.......................................... 25

Amnesty International, Syria: Authorities must

investigate abductions of Alawite women and girls

(July 28, 2025),

https://www.amnesty.org/en/latest/news/2025/07/s

yria-authorities-must-investigate-abductions-ofalawite-women-and-girls/ [hereinafter Authorities

must investigate]. ................................................. 31

Amnesty International, Syria: New investigation

reveals evidence government and affiliated forces

iii

extrajudicially executed dozens of Druze people in

Suwayda (Sept. 2, 2025),

https://www.amnesty.org/en/latest/news/2025/09/s

yria-new-investigation-reveals-evidencegovernment-and-affiliated-forces-extrajudiciallyexecuted-dozens-of-druze-people-in-suwayda/. ... 27

Amnesty International, Syria: To Guarantee

Atrocities don't Repeat (May 16, 2025),

https://www.amnesty.org/fr/documents/MDE24/92

10/2025/en/ [hereinafter Guarantee Atrocities

don’t Repeat]. .......................................................... 7

Ashawi, K. & Hasano, M., Syrians trickle home from

sanctuary at Russian air base, Reuters (Mar. 14,

2025), https://www.reuters.com/world/middleeast/syrians-trickle-home-sanctuary-russian-airbase-2025-03-14/. .................................................. 21

Autin, A. Collective Efforts Essential for Justice in

Syria, Human Rights Watch (Dec. 8, 2025),

https://www.hrw.org/news/2025/12/08/collectiveefforts-essential-for-justice-in-syria. .................. 6, 7

Bachelet, M., U.N. High Comm’r for Human Rights,

Oral Update to the Human Rights Council on the

extent of conflict-related deaths in the Syrian Arab

Republic (Sept. 24, 2021),

https://www.ohchr.org/en/statements-andspeeches/2021/09/oral-update-extent-conflictrelated-deaths-syrian-arabrepublic?LangID=E&NewsID=27531. ................... 7

iv

Doctors without Borders, Syrians share stories of

violence and displacement from temporary

shelters in the northeast (Feb. 11, 2025),

https://www.msf.org/syrians-share-storiesviolence-and-displacement-temporary-sheltersnortheast. .............................................................. 38

Doctors Without Borders, What does Syria look like

a year since the fall of Assad? (Dec. 11, 2025),

https://www.doctorswithoutborders.org/latest/what

-does-syria-look-year-fall-assad. .............. 35, 36, 38

Frelick ,B., As Many Syrian Refugees Return Home,

Others Cannot, Human Rights Watch (Dec. 10,

2024),

https://www.hrw.org/news/2024/12/10/manysyrian-refugees-return-home-others-cannot. ...... 34

Genç, Özge, How Damascus Reclaimed Syria’s

Northeast, and What Integration Now Means,

Middle East Council on Global Affairs (Feb. 4,

2026), https://mecouncil.org/blog_posts/syria-sdfintegration-agreement-2026-analysis/. ................ 14

Grandi, F. UN High Commissioner for Refugees,

Statement at the Brussels Syria Conference (Mar.

17, 2025), https://www.unhcr.org/news/speechesand-statements/high-commissioner-s-statementbrussels-syria-conference-0. ................................. 40

Holtz, M.,Examining Extremism: Hayat Tahrir AlSham (HTS), Center for Strategic and

International Studies (Aug. 3, 2023),

https://www.csis.org/blogs/examiningextremism/examining-extremism-hayat-tahrir-alsham-hts. ................................................................ 9

v

Human Rights Watch, Northeast Syria: Apparent

War Crime by Türkiye-Backed Forces (Jan. 30,

2025),

https://www.hrw.org/news/2025/01/30/northeastsyria-apparent-war-crime-turkiye-backed-forces

........................................................................ .14, 29

Human Rights Watch, Syria: Accountability Lacking

for Sweida Abuses (Jan. 15, 2026),

https://www.hrw.org/news/2026/01/15/syriaaccountability-lacking-for-sweida-abuses. .......... 38

Human Rights Watch, Syria: Civilian Protection

Lacking in Northeast Escalation (Jan. 25, 2026),

https://www.hrw.org/news/2026/01/25/syriacivilian-protection-lacking-in-northeast-escalation.

............................................................................... 27

Human Rights Watch, Syria: Constitutional

Declaration Risks Endangering Rights (Mar. 25,

2025), https://www.hrw.org/news/2025/03/25/syriaconstitutional-declaration-risks-endangeringrights. .................................................................... 10

Human Rights Watch, Syria: End Coastal Killing

Spree, Protect Civilians (Mar. 10, 2025),

https://www.hrw.org/news/2025/03/10/syria-endcoastal-killing-spree-protect-civilians.................. 19

Human Rights Watch, Syria: March Atrocities

Demand Senior Level Accountability (Sept. 23,

2025), https://www.hrw.org/news/2025/09/23/syriamarch-atrocities-demand-senior-levelaccountability. ...................................................... 26

vi

Human Rights Watch, Syria: Türkiye-backed Armed

Groups Detain, Extort Civilians (May 14, 2025),

https://www.hrw.org/news/2025/05/14/syriaturkiye-backed-armed-groups-detain-extortcivilians ........................................................... 14, 32

Human Rights Watch, Syrian Archive, Syrians for

Truth & Justice, “Are you Alawi?” Identity-Based

Killings During Syria’s Transition, Summary

(Sept. 23, 2025),

https://www.hrw.org/report/2025/09/23/are-youalawi/identity-based-killings-during-syriastransition. ....................................................... 17, 20

Human Rights Watch, US, EU, UK: Lift Syria

Sanctions Hindering Recovery (Feb. 18, 2025),

https://www.hrw.org/news/2025/02/18/us-eu-uklift-syria-sanctions-hindering-recovery [hereinafter

Lift Syria Sanctions]....................................... 35, 36

Human Rights Watch, World Report 2013: Syria

(2013), https://www.hrw.org/worldreport/2013/country-chapters/syria ....................... 6

Human Rights Watch, World Report 2026: Syria

(2026), https://www.hrw.org/worldreport/2026/country-chapters/syria ...13, 14, 19, 20,

26, 35, 38, 39

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, ¶¶ 2, 5, 7-8, 77, U.N. Doc.

A/HRC/58/CRP.2 (Dec. 6, 2024). .......................... 37

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, ¶10, U.N. Doc. A/HRC/61/62 (Mar. 12,

vii

2026) .... 10, 11, 12, 13, 14, 15, 16, 17, 20, 21, 25, 29,

30, 31, 32, 33, 34, 37, 39

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, ¶19, U.N. Doc. A/HRC/59/CRP.4 (Aug.

11, 2025) ....................... 10, 12, 15, 17, 18, 19, 20, 21

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, ¶32, U.N. Doc. A/HRC/61/CRP.7 (March

27, 2026) ............................. 13, 22, 23, 24, 25, 26, 30

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, Summary, U.N. Doc. A/HRC/58/66 (Mar.

19, 2025) .............................................................. 8, 9

lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, U.N. Doc. A/HRC/24/CRP.2 (Sept. 13,

2013) ...................................................................... 36

Pinheiro, P., Chair of the Syria COI, Oral Update to

the Human Rights Council (Jun. 27, 2025),

https://www.ohchr.org/en/statements-andspeeches/2025/06/oral-update-mr-paulo-sergiopinheiro-chair-independent...........18, 21, 33, 34, 37

Pinheiro, P. Chair of the Syria COI, Oral Update to

the UN General Assembly’s Third Committee (Oct.

30, 2025), https://www.ohchr.org/en/statementsand-speeches/2025/10/statement-paulo-pinheirochair-independent-international-commission .... 20,

26, 37

Syria Justice and Accountability Centre (SJAC),

Documenting Attacks on Medical Facilities in

Syria (Feb. 23, 2016),

viii

https://syriaaccountability.org/documentingattacks-on-medical-facilities-in-syria/. ................ 36

SJAC, Inside the Coastal Incidents Trial – Assad

Regime’s Affiliates #1: All Eyes on Me (Jan. 28,

2026), https://syriaaccountability.org/inside-thecoastal-incidents-trial-1-all-eyes-on-me/. ............ 26

Special Comm. to Investigate Israeli Practices

Affecting the Human Rights of the Palestinian

People and Other Arabs of the Occupied

Territories, ¶¶ 36-37, 64, U.N. Doc. A/80/365 (Sept.

5, 2025). ................................................................. 15

Special Procedures of the UN Human Rights

Council, Communication to the Syrian Arab

Republic, 1, Ref. No. AL SYR 1/2025 (Mar. 26,

2025),

https://spcommreports.ohchr.org/TMResultsBase/

DownLoadPublicCommunicationFile?gId=29777

[hereinafter AL SYR 1/2025].............................. 7, 8

Special Procedures of the UN Human Rights

Council, Communication to the Syrian Arab

Republic, 1-2, Ref. No. AL SYR 6/2025 (Aug. 26,

2025),

https://spcommreports.ohchr.org/TMResultsBase/

DownLoadPublicCommunicationFile?gId=30242

[hereinafter AL SYR 6/2025]................................ 11

Special Procedures of the UN Human Rights

Council, Communication to the Syrian Arab

Republic, 2, Ref. No. AL SYR 5/2025 (July 15,

2025),

https://spcommreports.ohchr.org/TMResultsBase/

ix

DownLoadPublicCommunicationFile?gId=30176

......................................................................... 31, 32

Special Procedures of the UN Human Rights

Council, Communication to the Syrian Arab

Republic, 2, Ref. No. UA SYR 2/2025 (Mar. 27,

2025),

https://spcommreports.ohchr.org/TMResultsBase/

DownLoadPublicCommunicationFile?gId=29798

......................................................................... 18, 20

Special Procedures of the UN Human Rights

Council, Communication to the Syrian Arab

Republic, Ref. No. AL SYR 7/2025 (Aug. 12, 2025),

https://spcommreports.ohchr.org/TMResultsBase/

DownLoadPublicCommunicationFile?gId=30247 31

U.N. High Comm’r for Human Rights , The

Situation of Human Rights in the Syrian Arab

Republic, ¶¶ 33-91, U.N. Doc. A/HRC/18/53 (Sept.

15, 2011). ................................................................. 6

U.N. High Comm'r for Refugees (UNHCR), Press

Release, A million Syrians have returned home,

but more support needed so millions more can

follow (Sept. 24, 2025),

https://www.unhcr.org/news/pressreleases/million-syrians-have-returned-homemore-support-needed-so-millions-more-can. ....... 35

UNHCR, A Year of Turmoil: Conflicts, Crises and

Displacement in 2024 (Dec. 26, 2024),

https://www.unhcr.org/news/stories/year-turmoilconflicts-crises-and-displacement-2024. ................ 8

UNHCR, Operational Framework: Voluntary Return

of Syrian Refugees and IDPs 2025 (Feb. 2025),

x

https://www.unhcr.org/sites/default/files/202502/UNHCR_Operational_Framework%201_0.pdf.

............................................................................... 40

UNHCR, Position on Returns to the Syrian Arab

Republic, ¶4 (Dec. 2024),

https://www.refworld.org/sites/default/files/202412/unhcr_position_on_returns_to_syria__16_dec_2024.pdf. ........................................... 39, 40

UN Security Council, Press Release, Security

Council ISIL (Da’esh) and Al-Qaida Sanctions

Committee Removes One Entry from Its Sanctions

List, U.N. Press Release SC/16306 (Feb. 28, 2026),

https://press.un.org/en/2026/sc16306.doc.htm....... 9

UNHCR, Situation in northeast Syria: Flash Update

(Jan. 31, 2026),

https://www.unhcr.org/sites/default/files/202602/unhcr-northeast-syria-situation-flashupdate.pdf. ............................................................ 28

U.N. Office for the Coordination of Humanitarian

Affairs (UN OCHA), Syrian Arab Republic:

Humanitarian Overview Issue No. 4 (Mar. 16,

2026),

https://www.unocha.org/publications/report/syrianarab-republic/syrian-arab-republic-humanitarianoverview-issue-no-4-january-february-2026...28, 38

UN OCHA, Syrian Arab Republic: Humanitarian

Situation Report No. 7 (June 30, 2025),

https://www.unocha.org/publications/report/syrianarab-republic/syrian-arab-republic-humanitariansituation-report-no-7-23-june-2025-enar. ............ 36

xi

UN OHCHR, Press Release, “The future of Syria is

in the balance:” UN Commission sounds alarm on

renewed violence amid hopes for justice and peace

(Oct. 30, 2025), https://www.ohchr.org/en/pressreleases/2025/10/future-syria-balance-uncommission-sounds-alarm-renewed-violence-amidhopes. .................................................................... 34

UN OHCHR, Press Release, Türk calls for

immediate steps to ensure protection of people in

Suweida and across Syria (July 18, 2025),

https://www.ohchr.org/en/pressreleases/2025/07/turk-calls-immediate-stepsensure-protection-people-suweida-and-acrosssyria....................................................................... 23

OHCHR, Syria: Distressing scale of violence in

coastal areas (Mar. 11, 2025),

https://www.ohchr.org/en/press-briefingnotes/2025/03/syria-distressing-scale-violencecoastal-areas ................................................... 20, 21

UN OHCHR, Press Release, UN experts urge

restoration of peace, human rights and security in

North-East Syria (Jan. 29, 2026),

https://www.ohchr.org/en/pressreleases/2026/01/un-experts-urge-restorationpeace-human-rights-and-security-north-east-syria.

............................................................................... 28

UN OHCHR, Press Release, UN Syria Commission

calls for protection of civilians, humane treatment

of ex-combatants and the safeguarding of evidence

of crimes (Dec. 16, 2024),

https://www.ohchr.org/en/press-

xii

releases/2024/12/un-syria-commission-callsprotection-civilians-humane-treatment-ex .......... 38

UN OHCHR, Syria: One year since regime change,

more should be done to stop violations, achieve

justice (Dec. 5, 2025),

https://www.ohchr.org/en/press-briefingnotes/2025/12/syria-one-year-regime-change-moreshould-be-done-stop-violations............................. 30

United Nations, Security Council hears of persistent

and evolving Da’esh threat, UN NEWS (Feb. 10,

2025),

https://news.un.org/en/story/2025/02/1159966. ... 15

U.S. Dept. of State, Media Note, Amendments to the

Terrorist Designations of al-Nusrah Front (May

31, 2018), https://20172021.state.gov/amendments-to-the-terroristdesignations-of-al-nusrah-front/. ........................... 9

U.S. Dept. of State, Press Statement, Revoking the

Foreign Terrorist Organization Designation of

Hay’at Tahrir al-Sham (July 7, 2025),

https://www.state.gov/releases/office-of-thespokesperson/2025/07/revoking-the-foreignterrorist-organization-designation-of-hayat-tahriral-sham.................................................................... 9

U.S. Dept. of State, Press Statement, Terrorist

Designations of the al-Nusrah Front as an Alias

for al-Qa'ida in Iraq (Dec. 11, 2012), https://20092017.state.gov/r/pa/prs/ps/2012/12/201759.htm .... 9

Working Group on Enforced or Involuntary

Disappearances, Enforced or involuntary

xiii

disappearance, ¶87, U.N. Doc. A/HRC/60/35 (July

21, 2025). ............................................................... 30

World Health Organization, Syria Crisis (Dec. 20,

2024),

https://www.who.int/emergencies/situations/syriacrisis. ..................................................................... 37

STATEMENT OF INTEREST

Pursuant to Supreme Court Rule 37, the Syria

Justice and Accountability Centre (SJAC) and the

Tahrir Institute for Middle East Policy (TIMEP)

respectfully submit this brief amici curiae in support

of Respondents Dahlia Doe, Sara Doe, Nesma Doe,

Laila Doe, Waleed Doe, Mustafa Doe, and Ahmad

Doe.

SJAC is a human rights organization working

for meaningful justice and accountability in Syria

with a goal of establishing a lasting peace. As part of

its mission, over the last ten years SJAC has collected

and documented violations of human rights and

international humanitarian law in Syria with the aim

of facilitating current and future transitional justice

and accountability efforts. In fact, since the fall of the

regime of Bashar Assad, SJAC has interviewed 435

witnesses who were victims of arbitrary detention,

torture, disappearance, death under torture,

extrajudicial executions, and sexual violence. SJAC is

currently monitoring trial proceedings in Syria

relating to events in 2025. SJAC also assists

authorities in investigating and building cases for

prosecution, uses forensic techniques to identify

missing persons and mass graves, and creates justice

policy initiatives.

No counsel for a party authored this brief in whole or in part,

and no counsel or party made a monetary contribution intended

to fund the preparation or submission of the brief.

2

The Tahrir Institute for Middle East Policy

(TIMEP) works to ensure that perspectives from the

Middle East and North Africa are part of the policy

discourse to foster transparent, accountable, and just

societies. For more than twelve years, TIMEP has

served as a leading policy voice on Syria, delivering

expertise to decision-makers in the United States and

across the world on Syria's political, security,

economic, and justice profiles. It has informed the

work of policymakers, serving as a bridge between

them and Syrian scholars, researchers, civil society,

and victim groups inside the country and in the

diaspora. The institute has tracked and reported on

country conditions, including the risks facing ethnic

and religious minorities and the government's plans

for economic recovery. It has also conducted in-depth

studies of the country's laws and policies and

monitored the situation in neighboring and host

countries, positioning it to offer practical assessments

on the factors impacting displacement and refugee

return.

SUMMARY OF ARGUMENT

Over the past fourteen years, Syria has been

ravaged by armed conflict. On March 29, 2012, the

Secretary of the Department of Homeland Security

(DHS) designated Syrian refugees in the United

States for Temporary Protected Status (TPS) after

finding that there were ongoing extraordinary and

temporary conditions in Syria that prevented Syrian

nationals from returning in safety. In 2013, the

Secretary extended the TPS designation based on

both extraordinary and temporary conditions and

3

ongoing armed conflict. DHS extended the Syria

designation on several additional occasions. On

September 19, 2025, DHS Secretary Kristi Noem

terminated the designation, asserting that, after

consulting with the Department of State, the fall of

the regime of Bashar Assad had ended the armed

conflict. She concluded that the previous conflict was

followed by “local clashes” and ultimately “sporadic

episodes of violence,” and that as result, Syrian

refugees should return to Syria.

In reality, however, since the fall of the brutally

repressive Assad regime in December 2024 Syria

remains in a state of internal and international

armed conflict and continues to suffer extraordinary

and temporary conditions that preclude the safe,

dignified and sustainable return of refugees.

First, the interim government has been unable

to consolidate power since the beginning of the

transition, giving rise to a security vacuum as armed

groups continue to operate throughout the country.

Hay’at Tahrir al-Sham (HTS), a group previously

designated as an Al-Qaeda-linked terrorist

organization, and other former opposition armed

factions which committed grave human rights abuses

and atrocities during the preceding fourteen-year

armed conflict were integrated into the interim

government as part of its newly-formed security

apparatus. This has contributed to fear and mistrust,

particularly among minority communities. Countless

other armed factions also remain active in the

country, committing unspeakable violence, including

grave human rights abuses and atrocities. These

groups include factions affiliated with interim

4

government forces, Bedouin, tribal and other

irregular fighters allied with the government, proformer government fighters (PFGF), the Suwayda

Military Council and other Suwayda-based Druze

armed groups, Kurdish-led Syrian Democratic Forces

(SDF), the Türkiye-backed Syrian National Army

(SNA), and terrorist groups including Islamic State of

Iraq and the Levant (ISIL).

Second, since December 2024, the country

continues to face widespread and continuous violence

resulting in grave human rights violations and

abuses. Two major waves of large-scale violence

against civilians in the coastal, western and central

regions of the country in March 2025 and in Suwayda

since July 2025, resulted in over 3,100 deaths,

villages burned to the ground, and the displacement

of tens of thousands, disproportionately affecting

minority Alawite and Druze communities. Despite a

recent cease-fire agreement and an integration

process, violence also continues to plague the

northeast region of the country, where internal armed

conflict among armed factions and the interim

government disproportionately affects minority

Kurdish communities and contributes to a worsening

humanitarian crisis in the region. Beyond such

conflicts, the country continues to witness other forms

of violence targeting civilians, including abductions,

arbitrary detention, enforced disappearance, torture,

sexual and gender-based violence, and kidnappings.

Israel has also engaged in periodic bombings,

including in Damascus, as well as an expansion of its

occupation of territory in Syria.

5

The United States Department of State has

itself acknowledged the dangerous conditions in

Syria. It maintains an active advisory against travel

to Syria based on the risk of terrorism, unrest,

kidnapping, hostage taking, crime, and armed

conflict. The State Department warns that no part of

Syria is safe from violence and that hostage-taking,

terrorism, unexploded ordnance, and aerial

bombardment pose significant risk of death or serious

injury.

Third, the country remains gripped by dire

humanitarian conditions, continuing violations of

housing, land, and property rights, and an ongoing

displacement crisis, which have all worsened in the

face of continuing violence. Currently, 90% of Syrians

live below the poverty line and about half the

population struggles to access basic necessities,

including adequate food and safe water. Years of

nbconflict have devastated civilian infrastructure,

including countless homes, entire villages, hospitals,

schools, roads, water facilities, and electrical grids.

Access to public services, including health care and

education, as well as life-saving humanitarian aid, is

severely limited. Millions of Syrians remain displaced

throughout the country, with risks of durable

demographic change. Meanwhile, remnants of war,

including landmines and unexploded ordnance,

continue to injure civilians, particularly children.

Since the fall of Assad, the situation in the

country has remained extremely volatile. These

conditions pose extreme danger to any returning

Syrian TPS holders until the country is stabilized.

6

ARGUMENT

1. The conditions that gave rise to Temporary

Protected Status (TPS) Designation for Syria.

Hafez Assad and his son and successor Bashar

Assad presided over more than fifty years of brutal

and repressive dictatorial rule in Syria. 1 Following

public uprisings across Syria in March 2011, Bashar

Assad engaged in a violent crackdown characterized

by gross human rights violations, 2 which ultimately

developed into an “entrenched armed conflict” 3

lasting fourteen years, during which a range of gross

human rights violations and crimes under

international law were committed by the Syrian

government. These included, inter alia, killings,

chemical attacks, widespread torture and other illtreatment, arbitrary detention, forced disappearance,

extrajudicial executions, sexual and gender-based

violence, forced displacement, and deliberate

targeting of civilians and civilian infrastructure, such

as hospitals, residential buildings, schools, and water

1 Alice Autin,

Collective Efforts Essential for Justice in Syria,

Human

Rights

Watch

(Dec.

8,

https://www.hrw.org/news/2025/12/08/collective-effortsessential-for-justice-in-syria.

2025),

The Situation of Human

Rights in the Syrian Arab Republic, ¶¶ 33-91, U.N. Doc.

2 U.N. High Comm’r for Human Rights,

A/HRC/18/53 (Sept. 15, 2011).

Human Rights Watch, World Report 2013: Syria (2013),

https://www.hrw.org/world-report/2013/country-chapters/syria.

3

7

stations,

including

bombardments. 4

through

sieges

and

Serious abuses were also committed by

government allies, armed groups opposing the

government, terrorist groups, and the Kurdish-led de

facto authorities and their allies, including, inter alia,

arbitrary arrests and kidnappings, summary killings,

unlawful and indiscriminate attacks, and torture. 5

In 2021, the Office of the UN High

Commissioner for Human Rights (OHCHR) compiled

a list of 350,209 identified individuals killed in the

conflict 6 and the Independent International

Commission of Inquiry on the Syrian Arab Republic

(Syria COI) estimated that over 100,000 individuals

4

Special Procedures of the UN Human Rights Council,

Communication to the Syrian Arab Republic, 1, Ref. No. AL SYR

1/2025

(Mar.

26,

2025),

https://spcommreports.ohchr.org/TMResultsBase/DownLoadPu

blicCommunicationFile?gId=29777 [hereinafter AL SYR

1/2025]; Autin, supra note 1; Amnesty International, Syria: To

Guarantee Atrocities don't Repeat (May 16, 2025),

https://www.amnesty.org/fr/documents/MDE24/9210/2025/en/

[hereinafter Guarantee Atrocities don’t Repeat].

5 Autin,

note 4.

supra note 1; Guarantee Atrocities don’t Repeat, supra

6 Michelle Bachelet, U.N. High Comm’r for Human Rights, Oral

Update to the Human Rights Council on the extent of conflictrelated deaths in the Syrian Arab Republic (Sept. 24, 2021),

https://www.ohchr.org/en/statements-andspeeches/2021/09/oral-update-extent-conflict-related-deathssyrian-arab-republic?LangID=E&NewsID=27531.

8

had disappeared. 7 As of the fall of the Assad regime

in December 2024, the UN Refugee Agency (UNHCR)

estimated that nearly 14 million people “remained

displaced either inside Syria or in neighboring

countries.” 8

2. The post-conflict transition in Syria is

characterized by a security vacuum and competition

for control among the forces of the interim

government and other armed factions who continue to

be active throughout the country.

On 8 December 2024, Bashar Assad and his

Government were “ousted from power . . . by a

coalition of armed groups led by Hay’at Tahir alSham.” 9 On January 29, 2025, Ahmed al-Sharaa was

appointed interim President of Syria for a transition

period of five years until a new constitution could be

adopted and elections held. 10 Al-Sharaa had

previously served as the leader of Hay’at al-Sham

supra 4 (citing lndep. Int'l Comm’n of Inquiry

on the Syrian Arab Republic, ¶ 94, U.N. Doc. A/HRC/46/54 (Jan.

21, 2021)).

7 AL SYR 1/2025,

8

UNHCR,

Displacement

A Year of Turmoil: Conflicts, Crises and

(Dec.

26,

2024),

in

2024

https://www.unhcr.org/news/stories/year-turmoil-conflictscrises-and-displacement-2024.

9 lndep. Int'l Comm’n of Inquiry on the Syrian Arab Republic,

Summary, U.N. Doc. A/HRC/58/66 (Mar. 19, 2025) [hereinafter

Syria COI 2025 Report].

10

Id. at ¶13.

9

(HTS), 11 which was formerly designated as a terrorist

organization by the U.S. Department of State 12 (until

8 July 2025)13 and UN Security Council (until

February 2026). 14

The HTS-led Military Operations Command

announced “the repeal of the 2012 Constitution of the

Syrian Arab Republic, the dissolution of the

parliament, the disbandment of the former

Government’s military and security forces and the

dissolution of the Baath Party.”15 Subsequently,

11 See Mackenzie Holtz, Examining Extremism: Hayat Tahrir

Al-Sham (HTS), Center for Strategic and International Studies

(Aug.

3,

2023),

https://www.csis.org/blogs/examiningextremism/examining-extremism-hayat-tahrir-al-sham-hts.

12 U.S. Dept. of State, Press Statement, Terrorist Designations

of the al-Nusrah Front as an Alias for al-Qa'ida in Iraq (Dec. 11,

2012),

https://20092017.state.gov/r/pa/prs/ps/2012/12/201759.htm; Media Note,

U.S. Dept. of State, Amendments to the Terrorist Designations

of al-Nusrah

Front

(May

31,

2018),

https://20172021.state.gov/amendments-to-the-terrorist-designations-of-alnusrah-front/.

13 U.S. Dept. of State, Press Statement, Revoking the Foreign

Terrorist Organization Designation of Hay’at Tahrir al-Sham

(July 7, 2025), https://www.state.gov/releases/office-of-thespokesperson/2025/07/revoking-the-foreign-terroristorganization-designation-of-hayat-tahrir-al-sham.

UN Security Council, Press Release, Security Council ISIL

(Da’esh) and Al-Qaida Sanctions Committee Removes One Entry

from Its Sanctions List, U.N. Press Release SC/16306 (Feb. 28,

2026), https://press.un.org/en/2026/sc16306.doc.htm.

14

15 Syria COI 2025 Report,

supra note 9, at ¶13.

10

President al-Sharaa signed a constitutional

declaration on March 13, 2025. 16 A new government

was ultimately “announced with key portfolios

composed of former [HTS] leadership.” 17 These efforts

were met with objections by the de facto authorities

in the northeast and some leaders in Suwayda, among

others, claiming that the new government and the

declaration were “not reflective of the aspirations of

Syria's multi-ethnic and multi-religious population”

and expressing “concern[s] about the consolidation of

power within the executive with limited institutional

oversight.” 18

To fill the security vacuum left by the

dissolution of the former government’s Syrian Arab

Army and multiple security agencies, former HTS

leaders were also appointed to lead the Ministries of

Defense and Interior. 19 Additionally, “dozens of

former opposition armed factions . . . agreed to

integrate into a newly unified army under the

Syria: Constitutional Declaration Risks

(Mar.

25,

2025),

Rights

16 Human Rights Watch,

Endangering

https://www.hrw.org/news/2025/03/25/syria-constitutionaldeclaration-risks-endangering-rights.

lndep. Int'l Comm’n of Inquiry on the Syrian Arab Republic,

¶10, U.N. Doc. A/HRC/61/62 (Mar. 12, 2026) [hereinafter Syria

COI 2026 Report].

17

18

Id.

Id. at ¶ 16; lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, ¶19, U.N. Doc. A/HRC/59/CRP.4 (Aug. 11, 2025)

[hereinafter Syria COI Alawi Report].

19

11

[Ministry of Defense].” 20 However, in the absence of

“human rights vetting,” entire former opposition

factions and their leadership, including HTS, the

Türkiye-backed Syrian National Army, and the

National Liberation Front, as well as terrorist groups

and foreign fighters, were integrated, despite their

well-documented history of committing grave human

rights violations and atrocities and being subjected to

sanctions for human rights abuses. 21 Despite their

formal integration, such factions’ reporting lines

remained “largely intact” as they operated “in

practice . . . with a degree of autonomy . . . .” 22

Similarly, under the Ministry of Interior, a new

“General Security” force, known as “Internal Security

Forces (ISF)” was formed, with former HTS and other

opposition armed group members integrated, “also

without prior human rights vetting.” 23

Ultimately, while the interim government has

promised to “ensure that no armed factions would

operate outside of the state,” 24 the reality over the

past sixteen months has been starkly different,

20 Syria COI 2026 Report,

supra note 17, at ¶17.

Id.; Special Procedures of the UN Human Rights Council,

Communication to the Syrian Arab Republic, 1-2, Ref. No. AL

21

SYR

6/2025

(Aug.

26,

2025),

https://spcommreports.ohchr.org/TMResultsBase/DownLoadPu

blicCommunicationFile?gId=30242 [hereinafter AL SYR 6/2025]

22 Syria COI 2026 Report,

23

Id. at ¶18.

24

Id. at ¶20.

supra note 17, at ¶17.

12

characterized by continued presence and operations

by groups not absorbed by the state, including

factions of Kurdish-led Syrian Democratic Forces

(SDF), Türkiye-backed Syrian National Army (SNA),

ISIL, and other terrorist groups, Druze and Bedouin

armed factions, pro-former government fighters

(PFGFs), and other unaffiliated groups. Israel has

also engaged in armed intervention in Syria.

Some former members of the Syrian Arab

Army under Assad “joined new armed groups

consisting of pro-former government forces (PFGFs)

or so-called ‘remnants of the regime.’” These forces,

“comprised of thousands of fighters,” are described as

“loyal to the previous regime and its former senior

commanders,” and therefore refuse to hand over

weapons or settle their status. 25 Since the fall of the

former government, these groups have conducted

continuous operations throughout the country's

coastal areas, including Latakia, Homs, and Hama,

against General Security forces or Internal Security

Forces. 26

In the Druze-majority southern governate of

Suwayda, the Suwayda Military Council—“an armed

coalition established in February 2025 in the Druzemajority Suwayda Governorate following the fall of

the Assad government”—and other Suwayda-based

armed groups also exist outside the state security

25 Syria COI Alawi Report,

supra note 19, at ¶16, n.16.

supra note 17, at ¶ 20; Syria COI Alawi

Report, supra note 19, at ¶¶ 24-27, 49-59.

26 Syria COI 2026 Report,

13

apparatus. 27 As the interim government sought to

integrate all groups and unify all Syrian territories

under its control, tensions mounted between the

government and “influential local actors in Suwayda

due to mistrust of the new authorities as well as fears

of political marginalization.” 28 Suwayda had enjoyed

a “level of self-governance in the years prior” to the

fall of the former government and as a result “some

Druze leaders were reluctant to disarm or fully accept

state security deployment in the governorate,” but

rather “sought to maintain a certain level of

autonomy.” 29

Such

leaders

distrusted

the

government’s intentions, particularly in light of their

past as members of a former terrorist organization

and the resulting implications for religious

minorities. 30 Additionally, pro-government Bedouin

or tribal forces exist in counterpoint to the Druze in

Suwayda. Those forces have worked with the Internal

Security Forces, including in running checkpoints in

the governorate. 31

27 lndep. Int'l Comm’n of Inquiry on the Syrian Arab Republic,

¶32, U.N. Doc. A/HRC/61/CRP.7 (March 27, 2026) [hereinafter

Syria COI Druze Report]; Syria COI 2026 Report, supra note 17,

at ¶ 20; Human Rights Watch, World Report 2026: Syria (2026),

https://www.hrw.org/world-report/2026/country-chapters/syria

[hereinafter HRW World Report 2026].

28 Syria COI Druze Report,

supra note 27, ¶12.

29

Id. at ¶¶12-14.

30

Id. at ¶15.

31

Id. at ¶¶12, 24, 26, 29-32.

14

After the fall of Assad, Kurdish-led Syrian

Democratic Forces (SDF) continued to control and

administer much of northeast Syria, despite its initial

agreement to integrate into the Syrian army. 32

However, as of January 2026, “SDF’s territorial

footprint has contracted significantly” 33 in the

aftermath of recent hostilities. On January 30, 2026,

the SDF once again agreed to integrate into the

Syrian army; however, the progress and ultimate

implementation of the integration remains unclear,

as does control over areas in the northeast. 34

Moreover, Türkiye-backed Syrian National Army

(SNA) factions “continue to detain, mistreat and

extort civilians in northern Syria,” particularly

Kurdish civilians 35 and are being integrated into

Syria’s armed forces. 36

HRW World Report 2026, supra note 27; Syria COI 2026

Report, supra note 17, at ¶¶ 21, 23.

32

How Damascus Reclaimed Syria’s Northeast, and

What Integration Now Means, Middle East Council on Global

33 Özge Genç,

Affairs (Feb. 4, 2026), https://mecouncil.org/blog_posts/syria-sdfintegration-agreement-2026-analysis/.

34 HRW World Report 2026,

supra note 27.

See Human Rights Watch, Northeast Syria: Apparent War

Crime by Türkiye-Backed Forces (Jan. 30, 2025),

35

https://www.hrw.org/news/2025/01/30/northeast-syriaapparent-war-crime-turkiye-backed-forces

[hereinafter

Northeast Syria].

Syria: Türkiye-backed Armed Groups

(May

14,

2025),

Civilians

36 Human Rights Watch,

Detain,

Extort

https://www.hrw.org/news/2025/05/14/syria-turkiye-backedarmed-groups-detain-extort-civilians [hereinafter Türkiyebacked Armed Groups].

15

Additionally, terrorist groups such as Islamic

State of Iraq and the Levant (ISIL), Saraya Ansar al

Sunna, Turkistan Islamic Party and Firqat alGhuraba remain a serious threat in Syria. 37

Since December 8, 2024, Israel has

“consolidate[d] and expand[ed] its occupation of the

Syrian Golan” by taking “control of further Syrian

territory east of the occupied Golan” and establishing

a military presence. 38

Unaffiliated groups also pose a threat to the

government’s goal of ensuring no armed factions

operate outside the aegis of the state, engaging in

hostilities alongside the above identified groups as

well as the interim government, taking up arms

spontaneously and conducting revenge killings, and

contributing to other forms of violence plaguing the

transitional period, including targeted abductions,

kidnappings, arbitrary detentions and enforced

disappearances. 39

37 Syria COI 2026 Report, supra note 17, at ¶ 22. See also United

Nations, Security Council hears of persistent and evolving

UN

NEWS

(Feb.

10,

2025),

Da’esh

threat,

https://news.un.org/en/story/2025/02/1159966.

38 Special Comm. to Investigate Israeli Practices Affecting the

Human Rights of the Palestinian People and Other Arabs of the

Occupied Territories, ¶¶ 36-37, 64, U.N. Doc. A/80/365 (Sept. 5,

2025).

See Syria COI Alawi Report, supra note 19, at ¶ 61; Syria COI

2026 Report, supra note 17, at ¶ 71.

39

16

In short, interim government forces are

“operat[ing] alongside a diverse range of armed actors

with varying degrees of alignment and autonomy.” 40

Continued internal armed conflicts involving the SDF

and former SNA factions, ISIL, Druze armed factions

in Suwayda and PFGFs along the coast as well as the

expansion of Israel’s occupation of territory in Syria

and the “related international armed conflict,”

illustrate “the limits of central authority” by the

interim government. 41 As a result, by early 2026,

parts of the country, including large parts of Suwayda

governorate, Al-Hasakah governorate in the

northeast, and territory controlled by Israel, remain

outside the interim government's control. 42

Ultimately, the continued presence and operations by

such groups illustrate the true fragility and volatility

of the transition in Syria.

3. Syria remains a country plagued by widespread

and ongoing internal and international armed conflict

and violence.

Since December 2024, Syria has experienced

multiple waves of large-scale violence against

civilians. The most significant were in coastal,

western and central areas in March 2025 and in

Suwayda in July 2025. Syria has also seen ongoing

and continuous internal armed conflict involving

40 Syria COI 2026 Report,

41

Id. at ¶ 80.

42

Id. at ¶ 23.

supra note 17, at ¶23.

17

various armed factions throughout the country,

including interim government forces, SDF, SNA

factions, ISIL, Druze armed factions, and PFGFs;

hostilities between government factions and SDF in

the northeast in January 2026; terrorism-related

attacks and violence; ongoing patterns of revenge

attacks and targeted killings, kidnappings,

abductions,

arbitrary

detentions,

enforced

disappearances, other forms of detention-related

violations, torture, and sexual and gender-based

violence by a range of actors. These conditions go

beyond “local clashes” and “sporadic episodes of

violence” and rather illustrate widespread and

continuous violence and armed conflict which

preclude the possibility for safe return of Syrian TPS

holders.

Since early 2025, a climate of retributive and

retaliatory violence and mounting sectarian tensions

threatened the overall security landscape in the

country. Violent actors ranging from terrorist groups

such as ISIL to “rogue local groups” carried out

revenge attacks and assassinations amongst rising

hate speech and “derogatory sectarian threats against

Alawis,” stoking high levels of fear and insecurity

amongst affected Alawi communities, amongst other

minorities. 43 The UN Independent International

Commission of Inquiry on the Syrian Arab Republic

Id.; Syria COI Alawi Report, supra note 19, at ¶¶ 29-30, 38-40,

62-63, 101; Human Rights Watch, Syrian Archive, Syrians for

Truth & Justice, “Are you Alawi?” Identity-Based Killings

During Syria’s Transition, Summary (Sept. 23, 2025),

https://www.hrw.org/report/2025/09/23/are-you-alawi/identitybased-killings-during-syrias-transition.

43

18

(Syria COI) has documented such revenge attacks

across several governorates since late January 2025,

including killings in the villages of Fahil and

Maryameen, Anz and Arzeh in Hama and Homs. 44

The COI explained how “[m]en who had reportedly

handed over their weapons through the . . .

disarmament process were ill-treated and executed"

in the absence of State protection. 45 Against this

background, Syria witnessed repeated large-scale

violence targeting minority communities in both the

coastal and western-central regions as well as in the

Suwayda governorate, contributing to a “climate of

fear and insecurity amongst many Syrians

throughout the country.” 46

January 2025. In January 2025, the interim

government “deployed security forces in the coastal

area of Latakia and Tartus, an area predominantly

inhabited by Alawite people and a stronghold of the

remnants of the Assad regime.” 47 Violations in the

44 Paulo Pinheiro, Chair of the Syria COI, Oral Update to the

Human

Rights

Council

(Jun.

27,

2025),

https://www.ohchr.org/en/statements-andspeeches/2025/06/oral-update-mr-paulo-sergio-pinheiro-chairindependent.

45

Id.

46 Syria COI Alawi Report,

47

supra note 19, at ¶1.

Special Procedures of the UN Human Rights Council,

Communication to the Syrian Arab Republic, 2, Ref. No. UA SYR

2/2025

(Mar.

27,

2025),

https://spcommreports.ohchr.org/TMResultsBase/DownLoadPu

blicCommunicationFile?gId=29798 [hereinafter UA SYR

2/2025].

19

context of “combing” operations, including summary

killings, were widely reported by human rights civil

society organizations. 48 In one instance on January

23, 2025, security forces conducted a combing

campaign in Fahel and Mreimin villages, detaining,

beating, torturing and killing residents, raiding the

villages, and looting homes. Killings were also

reported in the nearby villages of Kherbet Elhamam,

Al Ghazila, Kherbet Al Tin and Al Qabu and reports

by local groups also point to several instances of

arbitrary detention across north-west rural Homs. 49

March 2025. With tensions mounting, a series

of events beginning in March 2025 in Syria’s coastal

region quickly ignited a widespread conflagration. An

attack by pro-former government forces (PFGFs)

against interim government forces in Hama, Latakia,

and Tartous governorates sparked “a wave of

identity-based violence across the region.” 50 Interim

government forces, affiliated armed groups, and

unidentified armed individuals “swept through

Alawi-majority areas of Tartous, Lataki and Hama,”

in a “centrally coordinated military operation” aimed

at targeting former remnants of the Assad regime. 51

Human Rights Watch, Syria: End Coastal Killing Spree,

(Mar.

10,

2025),

Civilians

https://www.hrw.org/news/2025/03/10/syria-end-coastal-killingspree-protect-civilians.

48

Protect

49 Syria COI Alawi Report,

supra note 19, at ¶¶41-45.

50

Id. at ¶¶ 48-59; HRW World Report 2026, supra note 27.

51

Id.

20

These armed actors not only engaged in a fight

against PFGF combatants, “but also targeted

civilians

belonging

to

religious

minorities,

particularly Alawites but also Shia Muslims, among

others,” 52

committing

large-scale

summary

executions, torture, kidnapping and enforced

disappearance, abuse of detainees, deliberate

destruction of property and forced displacement. 53

Armed groups “went door to door,” looting and

burning homes and executing entire families in their

homes or in public executions, including children,

women and older persons. 54 These attacks were

carried out “on a sectarian basis” as perpetrators

consistently asked civilians whether they were Sunni

or Alawi. 55

52 UA SYR 2/2025,

supra note 47, at 2.

Id.; HRW World Report 2026, supra note 27; Paulo Pinheiro,

Chair of the Syria COI, Oral Update to the UN General

Assembly’s

Third

Committee

(Oct.

30,

2025),

https://www.ohchr.org/en/statements-andspeeches/2025/10/statement-paulo-pinheiro-chair-independentinternational-commission; OHCHR, Syria: Distressing scale of

(Mar.

11,

2025),

violence

in

coastal

areas

https://www.ohchr.org/en/press-briefing-notes/2025/03/syriadistressing-scale-violence-coastal-areas [hereinafter Distressing

scale].

53

supra note 47, at 2; Are you Alawi?”, supra

note 43; Distressing scale, supra note 53.

54 UA SYR 2/2025,

Syria COI Alawi Report, supra note 19, at ¶73; Are you

Alawi?”, supra note 43; Distressing scale, supra note 53.

55

21

In total at least 1,426 people were killed in the

coastal regions, mostly civilians. 56 Tens of thousands

of Alawis were displaced from their homes and

villages in Latakia, Tartus, Homs and Hama, of whom

over 40,000 fled into Lebanon. 57 Thousands more

sought refuge at a Russian air base. 58 While interim

authorities announced “the end of security operations

in the coastal areas on 10 March,” 59 in reality, PFGFs

“continued operations throughout 2025 in the coastal

areas.” 60

April and May 2025. In the wake of the grave

violence committed against the Alawis, sectarian

violence also began to take hold in the Suwayda

governate against the Druze community. Mounting

sectarian tensions between the Druze and Bedouins

and tribal forces in the southern region, clashes

targeting the Druze community in Jaraman,

Achrafiyeh-Sahnaya in Rural Damascus and Sura alKabira in April and May 2025, and a series of

kidnappings, clashes and assaults on Druze property

56 Syria COI Alawi Report, supra note 19, at ¶1, n.1 (citing the

findings of the National Inquiry on the March Coastal Events).

57 Pinheiro,

supra note 43.

Syrians trickle home from

sanctuary at Russian air base, Reuters (Mar. 14, 2025),

58 Khalil Ashawi & Mahmoud Hasano,

https://www.reuters.com/world/middle-east/syrians-tricklehome-sanctuary-russian-air-base-2025-03-14/.

59

Distressing scale, supra note 53.

60 Syria COI 2026 Report,

supra note 17, at ¶20.

22

in early July 2025 61 set the stage for the ensuing

violence.

July 2025 to present. The events in Suwayda in

July 2025 illustrate how even a single act of violence

can lead to widespread armed conflict in today’s

Syria. On July 11, 2025, a Druze merchant was

abducted at an Internal Security Forces checkpoint

staffed by members of Bedouin and tribal forces. 62 In

the days that followed, Druze and Bedouin fighters

carried out reciprocal abductions of several men. 63 As

violence erupted between Druze armed forces and

pro-government Bedouin fighters, the interim

authorities “announced a formal intervention to

restore order.” The government forces included a

combination of regular forces and affiliated Bedouin

and tribal fighters. They ended up “encounter[ing]

armed resistance from Suwayda Military Council and

other Suwayda-based armed groups (SMCAGs)). 64

After government forces and accompanying Bedouin

and tribal fighters entered Suwayda city, widespread

attacks on civilians began, including pervasive

“murders, direct and indiscriminate attacks,

arbitrary arrests and abductions, torture and illtreatment, pillage, attacks on civilian property,

sexual and gender-based violence, including rape and

outrages upon personal dignity,” such as the cutting

61 Syria COI Druze Report,

62

Id. at ¶¶24, 26.

63

Id. at ¶26.

64

Id. at ¶¶ 29-30, 32.

supra note 27, ¶¶ 21-22, 25.

23

of moustaches of elderly Druze men, a deeply

offensive and humiliating act, “and attacks on

buildings dedicated to religion, accompanied by

discriminatory sectarian insults aimed primarily at

the Druze community.” 65

Government forces then withdrew under a

cease-fire; but in the wake of that withdrawal,

SMCAGs launched a second wave of violence against

Bedouin civilians. 66 Specifically, SMCAGs “engaged

in murder, direct and indiscriminate attacks on

civilians, torture and ill-treatment, arbitrary

detention, forced displacement, outrages upon

personal dignity, attacks on buildings dedicated to

religion and pillage directed at the Bedouin

community.” 67

Reports of that violence against the Bedouins.

alongside mounting hate speech and disinformation

targeting the Druze, in turn led to the mobilization of

thousands of tribal fighters alongside fighters

Id. at ¶37. See also Special Procedures of the UN Human

Rights Council, Communication to the Syrian Arab Republic,

Ref.

No.

AL

SYR

7/2025

(Aug.

12,

2025),

https://spcommreports.ohchr.org/TMResultsBase/DownLoadPu

blicCommunicationFile?gId=30247; Press Release, OHCHR,

65

Türk calls for immediate steps to ensure protection of people in

(July

18,

2025),

Suweida

and

across

Syria

https://www.ohchr.org/en/press-releases/2025/07/turk-callsimmediate-steps-ensure-protection-people-suweida-and-acrosssyria.

66 Syria COI Druze Report,

67

Id.

supra note 27, at ¶41.

24

affiliated with the interim government forces. During

this wave of the conflict, tribal fighters engaged in

targeted killings, arbitrary detention, outrages on

personal dignity, pillage, including through the

widespread looting and systematic burning of homes

in mixed or predominantly Druze villages, attacks on

civilian objects, and attacks on religious buildings. 68

The July incidents resulted in a conservative

estimate of 1,700 people killed, the vast majority of

which were members of the Druze community, with

hundreds of Bedouins and government forces also

killed. 69 Nearly 200,000 people were displaced. 70 In

interviews conducted by the Syria COI with

internally displaced persons from Druze and Bedouin

communities, individuals from both communities

expressed continuing fear of violence and indicated

that they “do no feel safe to return to their villages

which are currently under the control of government

and Druze armed groups respectively.” 71

The armed conflict in Suwayda continues to the

present. 72 For example, in mid-March 2026, fighting

broke out between government forces and fighters

from local tribes against opposing Druze factions in

68

Id. at ¶¶ 42-44.

69

Id. at ¶ 48.

70

Id.

71

Id. at ¶ 55.

72

Id. at ¶2.

25

the western countryside of Suwayda. Mortar shells

fell on areas under the control of Druze factions. The

shelling later hit residential neighborhoods in the city

of Suwayda. 73

Efforts to hold offenders liable for both waves

of violence have been minimal and ineffectual. The

interim authorities established a National Inquiry on

the March Coastal Events, which presented its

findings on July 22, 2025, 74 and a National Inquiry on

the July Suwayda violence, which presented its

findings on March 17, 2026. 75 With respect to coastal

violence, authorities shared assurances during a

press conference that it would hold some 400 fighters

accountable. To date, however, only one case has been

pursued, commencing in Aleppo on November 18,

2025, with only 14 defendants 76--low-level soldiers,

seven of whom are affiliated with the former

government, and seven of whom are affiliated with

the interim government. SJAC is monitoring that

trial and has found it to be cursory in nature, also

Israel says it his Syrian army camps in the south

(Mar.

20,

2026),

Druze

’attacked’

73 Al Jazeera,

after

https://www.aljazeera.com/news/2026/3/20/israel-says-it-hitsyrian-army-camps-in-the-south-after-druze-attacked.

74 Syria COI 2026 Report,

supra note 17, at ¶28.

75 Syria COI Druze Report,

supra note 27, at ¶138.

See Amnesty International, Syria: A year after Assad’s fall,

the rights of survivors and families must guide transition (Dec.

76

8, 2025), https://www.amnesty.org/en/latest/news/2025/12/syriaa-year-after-assads-fall-rights-of-survivors-must-guidetransition/.

26

noting that the court and justice sectors lack the

capacity to truly hold perpetrators accountable. 77

Ultimately, the failure to hold senior military or

civilian leaders accountable will only continue to

promote a culture of impunity. 78

While the context and triggers of the

escalations in March and July 2025 were different,

“they all ignited sectarian strife and deepened

mistrust in the authorities’ ability to protect all

Syrians and unify the country during the transitional

period” as well as end the cycle of impunity and hold

perpetrators to account, “rais[ing] grave concerns that

the stage is set for further violence unless swift action

is taken.” 79 A member of a Syrian-led civil society

organization noted that, “[t]his is not about a single

week in March” or July; rather, “[i]t is an indicator of

a broader pattern that needs to be addressed.” 80

Specifically, the horrific violence against minority

communities is “another grim reminder of the deadly

consequences of impunity for sectarian-based killings

See SJAC, Inside the Coastal Incidents Trial – Assad Regime’s

Affiliates #1: All Eyes on Me (Jan. 28, 2026),

77

https://syriaaccountability.org/inside-the-coastal-incidentstrial-1-all-eyes-on-me/.

78

See HRW World Report 2026, supra note 27.

79 Syria COI Druze Report,

note 52.

supra note 27, at ¶22; Pinheiro, supra

Syria: March Atrocities Demand Senior

(Sept.

23,

2025),

Accountability

80 Human Rights Watch,

Level

https://www.hrw.org/news/2025/09/23/syria-march-atrocitiesdemand-senior-level-accountability.

27

in Syria, which has emboldened government and

affiliated

forces

to

kill

without

fear

of

accountability.” 81

January 2026. As the interim government

sought to gain control over all Syrian territory,

hostilities escalated in northeastern Syria in early

January 2026 between interim authorities and

Kurdish-led Syrian Democratic Forces (SDF),

contributing to a wider deterioration of the security

environment in the northern region and country

overall. On January 6, 2026, Syrian interim

government forces and SDF began fighting in two

predominantly Kurdish neighborhoods in Aleppo. 82 A

wider military confrontation began on January 17 as

Syrian government forces gained control of Raqqa and

Deir ez-Zor and moved towards areas in al-Hasakah

governorate. Although the parties agreed to stop

hostilities the following day, the state of the ceasefire

has remained precarious. 83 The UN Office for the

Coordination of Humanitarian Affairs (OCHA) has

Amnesty International, Syria: New investigation reveals

evidence government and affiliated forces extrajudicially

executed dozens of Druze people in Suwayda (Sept. 2, 2025),

81

https://www.amnesty.org/en/latest/news/2025/09/syria-newinvestigation-reveals-evidence-government-and-affiliatedforces-extrajudicially-executed-dozens-of-druze-people-insuwayda/.

Syria: Civilian Protection Lacking in

(Jan.

25,

2026),

Escalation

82 Human Rights Watch,

Northeast

https://www.hrw.org/news/2026/01/25/syria-civilian-protectionlacking-in-northeast-escalation.

83

Id.

28

reported that “the overall environment remained

unpredictable in February [2026]”. 84 UN experts have

“condemned shocking alleged violations” by parties to

the hostilities, “including reports of summary

executions, attacks on civilians, torture and the

desecration of bodies and graves” as well as “reports

of insecurity, violence, and breakouts at detention

facilities, including escapes by alleged ISIL

members.” 85

Disruptions to water electricity, essential

infrastructure and humanitarian aid further

compounded the precarious context. 86 Over 190,000

individuals, mainly women and children, from

Aleppo, Al-Hassakeh, and ArRaqqa governorates

have been displaced since early January.87 Moreover,

hostilities between SDF and former SNA factions,

84 OCHA,

No.

Syrian Arab Republic: Humanitarian Overview Issue

(Mar.

16,

2026),

4

https://www.unocha.org/publications/report/syrian-arabrepublic/syrian-arab-republic-humanitarian-overview-issue-no4-january-february-2026 [hereinafter Humanitarian Overview

Issue No. 4].

85 Press Release, OHCHR, UN experts urge restoration of peace,

human rights and security in North-East Syria (Jan. 29, 2026),

https://www.ohchr.org/en/press-releases/2026/01/un-expertsurge-restoration-peace-human-rights-and-security-north-eastsyria.

86

Humanitarian Overview Issue No. 4, supra note 84.

Situation in northeast Syria: Flash Update (Jan. 31,

2026), https://www.unhcr.org/sites/default/files/2026-02/unhcrnortheast-syria-situation-flash-update.pdf.

87 UNHCR,

29

backed by Turkish forces, have continued in the north

and northeast since late 2024, as indirect and remote

fire attacks by both sides have resulted in civilian

deaths, casualties and displacement. 88 Attacks have

also damaged civilian infrastructure, affecting access

to electricity and water. 89 Ultimately, Human Rights

Watch has found that “[t]he SNA and Turkish forces

have demonstrated a clear and troubling pattern of

unlawful attacks against civilians and civilian

objects.” 90

Israeli Defense Forces have launched air

strikes across Syria since December 8, 2024, including

“over 1000 reported airstrikes as well as ground

operations in southern governorates, resulting in

“civilian casualities, population displacement,

property damage and destruction, arbitrary

detention, transfer of detainees and restrictions on

fundamental freedoms.” 91 During the hostilities in

Suwayda, Israel conducted several “airstrikes on

locations in Damascus and rural Damascus between

30 April and 3 May [2025]” and a “series of airstrikes

across southern Syria” as well as on the Ministry of

Defense’s General Staff complex in Damascus in midJuly 2025, causing significant casualties amongst

88 Syria COI 2026 Report,

supra note 17, at ¶¶ 90-92.

89

Id. at ¶ 92.

90

Northeast Syria, supra note 35.

91 Syria COI 2026 Report,

supra note 17, at ¶¶ 82, 111-129

30

government forces. 92 These Israeli actions have been

characterized as an international armed conflict. 93

Beyond such instances of internal and

international armed conflict, other forms of violence,

including abductions, arbitrary detentions, enforced

disappearances

and

other

detention-related

violations; sexual and gender-based violence against

women from minority communities; recruitment of

child soldiers; and torture and ill-treatment have

been carried out by security forces of the interim

authorities, groups affiliated with them, elements

associated with the former government, local armed

groups and unidentified armed individuals. 94

Since December 2024, there have been several

reports of enforced disappearance of persons

belonging to minority communities, namely Alawis. 95

Alawi women and girls have been disproportionally

affected by patterns of targeted abductions, enforced

disappearances and other forms of gender-based

violence carried out by unidentified armed actors as

well as organized crime groups or individual

92

Syria COI Druze Report, supra note 27, at ¶¶ 22, 38, 48.

93

Syria COI 2026 Report, supra note 17, at ¶ 80.

See OHCHR, Syria: One year since regime change, more

should be done to stop violations, achieve justice (Dec. 5, 2025),

94

https://www.ohchr.org/en/press-briefing-notes/2025/12/syriaone-year-regime-change-more-should-be-done-stop-violations.

95 Working Group on Enforced or Involuntary Disappearances,

Enforced or involuntary disappearance, ¶87, U.N. Doc.

A/HRC/60/35 (July 21, 2025).

31

criminals. UN experts noted that “the recent pattern

observed seems to indicate a specific and systematic

targeting of Alawite women and girls” in “multiple

locations across Syria.” 96 In one case, “perpetrators

were identified as foreign fighters nominally

integrated with government forces under the

[Ministry of Defense].” 97 In some cases, abductees

were subjected to sexual violence, including gang

rapes, child and forced marriages. 98 During July 2025

hostilities, Druze and Bedouin women were also

taken hostage, detained or abducted by armed actors,

including tribal fighters and ISF personnel. 99 The

Syria COI and UN experts have also noted concerns

regarding “the treatment of victims upon release,

particularly by the General Security” forces. 100 The

Syria COI has reported that in two cases it

96

Special Procedures of the UN Human Rights Council,

Communication to the Syrian Arab Republic, 2, Ref. No. AL SYR

5/2025

(July

15,

2025),

https://spcommreports.ohchr.org/TMResultsBase/DownLoadPu

blicCommunicationFile?gId=30176 [hereinafter AL SYR

5/2025].

97 Syria COI 2026 Report,

supra note 17, at ¶ 71.

Id. at ¶ 73; AL SYR 5/2025, supra note 95, at 2. See also

Amnesty International, Syria: Authorities must investigate

abductions of Alawite women and girls (July 28, 2025),

https://www.amnesty.org/en/latest/news/2025/07/syriaauthorities-must-investigate-abductions-of-alawite-women-andgirls/ [hereinafter Authorities must investigate].

98

99 Syria COI 2026 Report,

supra note 17, at ¶ 79.

100 Syria COI 2026 Report,

supra note 17, at ¶74; AL SYR 5/2025,

supra note 95, at 3.

32

investigated “after government forces secured the

release of victims, the victims themselves were

subsequently arrested and investigated for moralityrelated crimes.” 101 This case illustrates a broader

pattern of challenges faced by families of missing

persons when engaging with both the police and the

General Security forces. 102 Amnesty International

has explained that “[t]he authorities in Syria have

repeatedly promised to build a Syria for all Syrians,

yet they are failing to stop abductions and

kidnappings of women and girls, to prevent physical

abuse, forced marriage and . . . to effectively

investigate and to prosecute those responsible.” 103

Additionally, detention-related violations have

been committed by several actors across Syrian

territory. In the northeast, for example, SDF have

committed detention-related violations, including

arbitrary detention, incommunicado detention,

deaths in custody and enforced disappearance. They

have also been reported to engage in child

recruitment. 104 Additionally, according to Human

Rights Watch, “hundreds remain detained in SNArun, Turkish-supervised prisons.” 105 Moreover,

detention-related violations were perpetrated by

101 Syria COI 2026 Report,

102 AL SYR 5/2025,

103

supra note 91, at 4.

Authorities must investigate, supra note 97.

104 Syria COI 2026 Report,

105

supra note 17, at ¶74.

supra note 17, at ¶¶ 94, 99.

Türkiye-backed Armed Groups, supra note 36.

33

interim security forces against Alawi men and boys in

the context of "combing” operations across Latakia,

Tartus, Homs and Hama governorate. 106 Detainees

were held in unofficial locations and in official

detention facilities of security branches and prisons

where torture and ill-treatment were rampant. 107 The

Syria COI documented how “[m]embers of

[g]overnment security forces . . . used rifle butts,

sticks, pipes, bars, cables, and . . . a nail-studded stick

to assault [detainees]” including while naked.

Detainees were also "subjected to humiliating and

degrading treatment, including various forms of

torture” such as mock executions, whipping, electric

shocks, sexual violence, among others. 108 In several

cases, detainees were held incommunicado for a range

of periods; government forces denied holding

detainees, amounting to enforced disappearance; and

deaths in custody were reported. 109

Terrorist groups also continue to contribute to

the violence. ISIL has attacked civilian and interim

government forces in the northern regions of the

country, including Deir ez-Zor, Raqqa, and AlHassakah. 110 Additionally, in May 2025, ISIL

“launched deadly attacks on interim government

106 Syria COI 2026 Report,

107

Id. at ¶¶ 46-48.

108

Id. at ¶ 48.

109

Id. at ¶¶ 50, 52.

110 Pinheiro,

supra note 43.

supra note 17, at ¶¶ 44-55.

34

forces and US-backed elements in Southern Syria,

marking its first coordinated operations in the postAssad era.” 111 There were also deadly attacks on the

Mar Elias church in Damascus on June 22, 2025,

which reportedly killed 25 people and injured 63

others, as well as the Ali Bin Abi Talib Mosque in

Homs city on December 26, 2025, which reportedly

killed at least eight civilians. Both serve as horrific

examples of ongoing terrorism-related violence in the

country. 112

The UN Commission of Inquiry has concluded

that the situation in Syria is “fragile and

unpredictable” and the “rapidity of . . . change in Syria

is inherently volatile.” 113 It focused on the risks of

“repeated massacres and human rights violations. . .

.” 114

111

Id.

112 Syria COI 2026 Report,

113 Bill Frelick,

Cannot,

supra note 17, at ¶100.

As Many Syrian Refugees Return Home, Others

Human

Rights

Watch

(Dec.

10,

2024),

https://www.hrw.org/news/2024/12/10/many-syrian-refugeesreturn-home-others-cannot.

Press Release, OHCHR, “The future of Syria is in the

balance:” UN Commission sounds alarm on renewed violence

amid hopes for justice and peace (Oct. 30, 2025),

https://www.ohchr.org/en/press-releases/2025/10/future-syriabalance-un-commission-sounds-alarm-renewed-violence-amidhopes.

114

35

4. Humanitarian conditions in Syria are dire.

According to Human Rights Watch, over 90

percent of Syrians live below the poverty line. 115 Over

half the population struggles to access basic

necessities, including adequate food and safe water.

At least 16.5 million required aid, yet as of

September 2025, UNHCR announced that only 24%

of required funds were available. 116 Fourteen years of

conflict have “decimated civilian infrastructure,

severely affecting access to shelter, health care,

electricity, education, public transportation, water

and sanitation.” 117 Entire towns are uninhabitable;

schools, hospitals, roads, water facilities, and

electrical grids are damaged; public services are

barely functional; and the economy is in freefall, with

reconstruction needs estimated to exceed $250

billion. 118 Ultimately, “the absence of services

115 HRW World Report 2026,

supra note 27.

116 Id.; Press Release, UNHCR, A million Syrians have returned

home, but more support needed so millions more can follow

(Sept.

24,

2025),

https://www.unhcr.org/news/pressreleases/million-syrians-have-returned-home-more-supportneeded-so-millions-more-can.

supra note 27. See also Doctors

Without Borders, What does Syria look like a year since the fall

(Dec.

11,

2025),

of

Assad?

https://www.doctorswithoutborders.org/latest/what-does-syrialook-year-fall-assad.

117 HRW World Report 2026,

Human Rights Watch, US, EU, UK: Lift Syria Sanctions

(Feb.

18,

2025),

Recovery

https://www.hrw.org/news/2025/02/18/us-eu-uk-lift-syriasanctions-hindering-recovery [hereinafter Lift Syria Sanctions].

118

Hindering

36

undermines any prospects for dignified and

sustainable living.” 119 The healthcare system, for

example, is in “critical condition, with over half of

Syria’s hospitals nonfunctional, and with severe

shortages of medical and other necessary supplies,” 120

as attacks on healthcare were a “weapon of war.” 121

Over one million returnees since the fall of Assad

have only served to place “additional pressure” on

these scarce resources and fragile systems. 122

Additionally, “[v]iolations of housing, land and

property rights pose a significant barrier to dignified[,

safe and sustainable] return of many Syrian refugees

and internally displaced,” as over 87% of Syrian

refugee property owners have reported their homes as

uninhabitable, destroyed, or severely damaged

following “deliberate widespread destruction and

looting of cities, towns and villages by former

119 Access Center for Human Rights, Housing Land and

Property: A Legal, Political and Humanitarian Barrier to

(Jan.

2026),

Refugee

Return

https://achrights.org/en/2026/01/20/16188/.

120

Lift Syria Sanctions, supra note 118.

See, e.g., lndep. Int'l Comm’n of Inquiry on the Syrian Arab

Republic, U.N. Doc. A/HRC/24/CRP.2 (Sept. 13, 2013); SJAC,

Documenting Attacks on Medical Facilities in Syria (Feb. 23,

2016), https://syriaaccountability.org/documenting-attacks-onmedical-facilities-in-syria/.

121

supra note 117; OCHA, Syrian Arab

Republic: Humanitarian Situation Report No. 7 (June 30, 2025),

122 Doctors Without Borders,

https://www.unocha.org/publications/report/syrian-arabrepublic/syrian-arab-republic-humanitarian-situation-reportno-7-23-june-2025-enar.

37

Government forces and non-state armed groups.” 123

Moreover, barriers to access to documentation (e.g.,

property or land deeds or personal identification

documents) and an overall fragmented, dysfunctional,

politicized, and inadequate housing, land and

property system under the interim authorities,

alongside “the broken judicial and record-keep system

inherited from” the former government, obstructs

efforts of reclaiming housing, land and property

rights. 124 Obstacles to the safe and dignified return of

female-headed households is further compounded by

discriminatory property and inheritance laws which

preference men. 125 Ultimately, such housing, land

and property violations, if left unaddressed, “risk

fueling further violence.” 126

Syria also continues to grapple with “one of the

largest displacement crises in the world,” 127 as an

estimated 5.54 million Syrians, mainly women and

children, remain internally displaced within the

country as of March 2026, living in overcrowded

camps, informal settlements and makeshift

Pinheiro, supra note 52. See also lndep. Int'l Comm’n of

Inquiry on the Syrian Arab Republic, ¶¶ 2, 5, 7-8, 77, U.N. Doc.

A/HRC/58/CRP.2 (Dec. 6, 2024).

123

124 Access Center for Human Rights,

supra note 43.

125 Syria COI 2026 Report,

126

supra note 119; Pinheiro,

supra note 17, at ¶61.

Id. at ¶56

World Health Organization, Syria Crisis (Dec. 20, 2024),

https://www.who.int/emergencies/situations/syria-crisis.

127

38

shelters. 128 Explosive remnants of war, including

landmines and unexploded ordnance, represent

another continuous threat to civilians, causing severe

injuries and fatalities, particularly amongst

children. 129 Current and ongoing international and

internal conflicts further compound these issues, as

deliberate hampering of access to humanitarian

aid, 130 destruction of critical infrastructure, including

attacks on healthcare and dams, looting and pillaging

of homes and villages by interim government forces

and other armed groups, and displacement of entire

communities across the country 131 have continued.

Within this troubling context, women, who have

been disproportionately affected by the preceding

128 Humanitarian Overview Issue No. 4, supra note 84; Doctors

without Borders, Syrians share stories of violence and

displacement from temporary shelters in the northeast (Feb. 11,

2025), https://www.msf.org/syrians-share-stories-violence-anddisplacement-temporary-shelters-northeast.

129 Doctors Without Borders,

supra note 117.

HRW World Report 2026, supra note 27; Human Rights

Watch, Syria: Accountability Lacking for Sweida Abuses (Jan.

15,

2026),

https://www.hrw.org/news/2026/01/15/syriaaccountability-lacking-for-sweida-abuses.

130

131 See Press Release, OHCHR, UN Syria Commission calls for

protection of civilians, humane treatment of ex-combatants and

the safeguarding of evidence of crimes (Dec. 16, 2024),

https://www.ohchr.org/en/press-releases/2024/12/un-syriacommission-calls-protection-civilians-humane-treatment-ex;

Access Center for Human Rights, supra note 119 (noting that

fighting in March and July 2025 resulted in the displacement of

over 110,000 individuals).

39

conflict and the events which have followed since,

continue to be “largely excluded from transitional

decision-making and political processes.” 132

CONCLUSION

Shortly after the fall of former government, the

UN Refugee Agency (UNHCR) published its position

on returns to the Syrian Arab Republic. It explained

that “[a]t this moment in time, Syria continues to be

affected by attacks and violence in parts of the

country;

large-scale

internal

displacement;

contamination of many parts of the country with

explosive remnants of war; a devastated economy and

a large-scale humanitarian crisis. . . .” 133

Against this background, UNHCR continues to

call on States not to “forcibly return Syrian nationals.

. . to any part of Syria.” 134 Additionally, “[i]n view of

the current uncertainty of the situation in Syria,

UNHCR calls on asylum States to suspend the

issuance of negative decisions on applications for

international protection by Syrian nationals or by

stateless persons who were former habitual residents

of Syria. The suspension of the issuance of negative

decisions should remain in place until such time as

HRW World Report 2026, supra note 27; Syria COI 2026

Report, supra note 17, at ¶ 33, 105.

133 UNHCR, Position on Returns to the Syrian Arab Republic, ¶4

(Dec. 2024), https://www.refworld.org/sites/default/files/202412/unhcr_position_on_returns_to_syria_-_16_dec_2024.pdf.

132

134

Id.

40

the situation in Syria has stabilized . . . .”135

Specifically, “UNHCR does not consider that the

requirements for cessation of refugee status for

beneficiaries of international protection originating

from Syria have currently been met.” 136 UN High

Commissioner for Refugees, Filippo Grandi,

explained “[i]t is too early to remove protection

safeguards.” 137

The facts underlying these conclusions have

not changed. By any measure, Syria remains in a

state of armed conflict. Widespread violence by

various factions continues to threaten civilian

populations across the country, particularly

minorities. Compounding the effects of such violence,

critical

humanitarian

conditions,

continuing

violations of housing, land, and property rights, and

an ongoing displacement crisis prevent the safe,

dignified and sustainable return of any Syrian

refugee.

Id. at ¶6. See also UNHCR, Operational Framework:

Voluntary Return of Syrian Refugees and IDPs 2025 (Feb. 2025),

135

https://www.unhcr.org/sites/default/files/202502/UNHCR_Operational_Framework%201_0.pdf.

136

Id. at ¶7.

Filippo Grandi, UN High Commissioner for Refugees,

Statement at the Brussels Syria Conference (Mar. 17, 2025),

https://www.unhcr.org/news/speeches-and-statements/highcommissioner-s-statement-brussels-syria-conference-0.

137

41

Respectfully submitted,

/S/ CHRIS GAIR

COUNSEL OF RECORD

GAIR GALLO EBERHARD LLP

1 E WACKER DR., SUITE 2600

CHICAGO, IL 60601

CGAIR@GAIRGALLO.COM

(312) 600-4900

LAYLA ABI-FALAH

OF COUNSEL

SYRIAN JUSTICE AND ACCOUNTABILITY CENTRE

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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