Joint Open Letter to the UNHCR in Lebanon

While Lebanon has hosted the largest number of refugees per capita since the armed conflict began in Syria, it has simultaneously and continuously failed to create a clear legal framework and policies for refugees, leaving them in constant insecurity. Consequently, they were left particularly vulnerable to ongoing abuses, acts of harassment from the local population, and violations of their basic human rights by state authorities. These violations were further exacerbated by several government decisions and decrees since 2015, including the government directive to UNHCR to stop the official registration of refugees. These decisions have compounded the vulnerability of refugees by complicating access to legal residency permits and limiting their freedom of movement, with repercussions on refugees’ access to livelihoods, healthcare, education, justice, and other services. 

This lack of legal framework has enabled state agents and government armed forces to carry out deportations without informing UNHCR or any other competent authority. Additionally, due to political pressures in its areas of operation, UNHCR has not been adequately cooperative or transparent with local organizations to enable them to fill in the protection gaps and take action when refugees are threatened with deportation. The sudden change in the treatment of refugees and the life-threatening forced deportations that have taken place in the past few weeks alone should justify increased cooperation between UNHCR and local organizations in Lebanon.   

Furthermore, UNHCR published a statement on the 29th of July 2022, reaffirming that returns should be “voluntary, dignified, and safe.” UNHCR has made similar and more forceful statements against forced deportations in other contexts, such as the non-return advisory for Afghanistan. Unfortunately, even this mild statement was later removed without explanation. If the primary organization for the protection of refugees is unable to advocate for the most basic requirements of returns to be applied to Syrian refugees, this signifies an even more concerning political shift for Lebanon’s refugee population and indicates an urgent need for UNHCR to expand its protection capacities by increasing multi-lateral cooperation and communication, especially around deportations.

Finally, while we understand the seriousness of the economic crisis that Lebanon has been facing since 2019, we are very concerned with the surge of a public discourse that blames Syrian refugees for this ongoing crisis, particularly over the past few months. This has fueled rising social tensions between refugees and host communities and led to acts of violence, harassment, and abuse. False allegations are being publicly disseminated, for instance, that refugees are depleting Lebanon’s scarce resources while receiving significant amounts of humanitarian aid and are responsible for high crime rates. This concerted effort in scapegoating took place in the lead-up to several raids, arbitrary arrests, and forced deportation of hundreds of Syrian refugees in the month of April alone. Using Syrian refugees as scapegoats by government representatives must be expressly and unequivocally condemned.

Since April 11th, Amnesty International, Access Center for Human Rights (ACHR), and MENA Rights Group have individually documented multiple raids and forced deportations throughout Lebanon, as well as dozens of cases of returnees being arrested and forcibly disappeared in Syria. This wave of mass arrests and forced returns was conducted by the Lebanese army instead of the General Security, even though deportations are supposedly under the latter’s jurisdiction. It is extremely concerning that the Lebanese army reportedly transferred refugees directly to the Syrian authorities, which puts them at increased danger of detention or persecution. Such practices breach international laws and agreements, including the international customary legal principle of non-refoulement, the Universal Declaration of Human Rights, and the Convention against Torture. However, they also wholly disregard the UN Commission of Inquiry on Syria’s declaration in September 2022 regarding Syria not being a safe country for return. Moreover, these practices greatly intensify the lack of safety among refugees, especially since they cannot appeal deportation decisions. 

Legal protection is one of the most important aspects of the work of UNHCR to protect refugees from violations in Lebanon. Therefore, to ensure that Syrian refugees in Lebanon are protected against deportations and propaganda that put their lives and safety in Lebanon at stake, we ask UNHCR to:

• Issue a clear statement on its position against the forced deportation of Syrian refugees in Lebanon, and reiterate the requirements for safe, voluntary, and dignified returns in a clear and direct way.
• Activate the role of UNHCR’s protection office, provide legal representation, ensure its presence and accessibility all around the country, and answer urgent requests for help for Syrian refugees at risk of deportation – many refugees have reported not receiving any response when contacting UNHCR in times of emergency.
• Lobby against all decisions that might hinder refugees’ access to protection and push for easy access to residency permits and documentation for Syrian refugees in Lebanon.
• Consolidate and improve referral mechanisms and communication between Civil Society Organizations (CSOs) and UNHCR.
• Campaign against misinformation and anti-refugee rhetoric by publishing numbers and figures that can enlighten public opinion on the reality of the Syrian presence in Lebanon, including the amount and types of aid refugees receive and the aid (in-kind or material) received by Lebanese beneficiaries and institutions.
• Confirm that UNHCR will always prioritize the protection of vulnerable refugees at risk of deportation to Syria over the request for individual data by the Lebanese government.
• Work with global partners to increase pathways to resettlement or temporary protection in 3rd countries, especially those particularly vulnerable or subjected to rights violations in Lebanon.
• Work on providing shelter to refugees who lack safety in their places of residence.
• Work with CSOs to develop a holistic and durable plan to organize refugees’ stay in Lebanon and protect refugees at risk in Syria.
• Coordinate with UNOCHA on the situation of those deported to Syria and assist the families of victims of torture in filing legal cases against the Lebanese government as per CAT Art. 3.
• Conduct a proper needs assessment process for registering/suspending refugees in Lebanon, following the official protocols/procedures to support their legal presence in the country.  

Copy to

• United Nations High Commissioner for Refugees (UNHCR)
• Office of the United Nations High Commissioner for Human Rights (OHCHR)
• UN Special Procedures of the Human Rights Council
• European Commission

Signed by

• Access Center for Human Rights (ACHR).
• Anti-Racism Movement.
• Arab Council Foundation.
• Association for Victims of Torture in UAE.
• Baytna.
• Cedar Centre for Legal Studies.
• Centre for Lebanese Studies.
• Developmental Action Without Borders – Naba’a.
• Freedom Jasmine.
• Frontliners For Change.
• HuMENA for Human Rights and Civic Engagement.
• Impunity Watch.
• International humanitarian relief-IHR.
• Irish Syria Solidarity Movement.
• Jana Watan.
• Kareemat Organization.
• Lebanese Center for Human Rights (CLDH).
• MENA Rights Group.
• MOSAIC.
• Nehna La Baad Initiative.
• Palestinian Human Rights Organization (PHRO).
• Peace and Justice for Syria.
• Refugees=Partners.
• Shift Social Innovation Hub.
• Syrian British Consortium (SBC).
• Syrian Network for Human Rights – SNHR.
• Syrian Human Rights Committee (SHRC).
• Syrians for Truth and Justice – STJ.
• The Syria Campaign.
• Urnammu for Justice and Human Rights.
• Woman Support Association.
• Youth Foundation for Development.
• Voices For Displaced Syrians Forum (VDSF) – 38 Individual Organizations.
• Refugee Protection Watch (RPW) – 8 Individual Organizations.