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
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