This research took about seven months to complete and edit, it also required constant defense and analyzing the most horrifying content. I truly hope you will take the time to read, share, learn, and spread the stories of the brave Palestinian women who continue to endure these horrors. Your support in my mission to write and do this work is appreciated more than words can describe.

On February 9^th, 2025, an Israeli soldier gunned down an 8-month pregnant Palestinian woman named Sundus Jamal Shalabi.^[1] She is one of the many murdered^[2] since the assault on Gaza that began October 7^th, 2023, which has revealed a devastating pattern: the systematic targeting of Palestinian women as a calculated strategy of, what this Note characterizes as, genocide under prolonged occupation.^[3] The pattern, here, refers to the systematic and repeated conduct in targeting specific victims, evidenced later in the Note through direct statements, statistics, and disproportionate impact on women. For example, on September 22^nd, 2025, Australian doctors working in Gaza, described doing a “C-Section on a beheaded lady,” in 2024, a doctor at Kuwaiti Hospital in Rafah described a similar situation in delivering a baby from their dying mother; these are but two examples of the impact of femicide on Palestinian women, families and society.^[4] Femicide is defined as an intentional killing with gender-related motivation, as the most extreme manifestation of violence against women.^[5] Femicide and genocide are conceptually linked through their shared logic of group destruction, but they are not synonymous. Femicide centers gender as the axis of annihilation, whereas genocide targets a protected group defined by nationality, ethnicity, race, or religion. Palestinian women are killed both because they are women and because they are Palestinian, untying social capacity for continuity.^[6] Despite decades of jurisprudence recognizing gender-based violence (rape, sexual assault, and other gender-based sex crimes) as a component of genocide, femicide itself remains undefined within international criminal law, and has never been codified or prosecuted as a distinct method of group destruction. This conceptual and doctrinal absence leaves a legal void: without explicit recognition, systematic killings of women that function as instruments of genocide, such as those witnessed in Gaza, fall through the cracks of existing accountability mechanisms. Recognizing femicide in its own right, and as a distinct method used to carry out genocide, is therefore essential, for it reveals how gendered killing functions as both a manifestation and a mechanism of genocidal intent.

At least 28,000 Palestinian women have been killed to date, with thirty-seven mothers killed daily. These statistics reflect not merely casualties of “war” but also evidence of deliberate gender-based destruction.^[7] The Independent International Commission of Inquiry on the Occupied Palestinian Territory (OPT), including East Jerusalem, stated in a 2025 report that “Israel has targeted civilian women and girls directly,”.^[8] While Israel’s bombardment, siege, and starvation campaigns in Gaza have prompted widespread allegations of genocide, this Note highlights a critical yet underexamined dimension: the systematic targeting of Palestinian women’s reproductive capacity as a tool of group destruction.^[9] Through killings, the dismantling of maternal healthcare, and other forms of gender-specific violence, Israel’s conduct satisfies multiple acts prohibited under the Genocide Convention, particularly Article II(d)’s ban on “measures intended to prevent births within the group”.^[10]An Obstetrician in Gaza, stated that “This is a war against women. Thousands of women have been killed and hundreds of thousands are living in extremely precarious conditions. The number of women and girls who have died from complications related to pregnancy and childbirth remains unknown.”^[11]

The scale and pattern of harm directed toward women in Gaza has manifested in multiple forms. These include the destruction of Gaza’s primary fertility clinic, which reportedly contained approximately 4,000 embryos; repeated strikes on maternity wards; attacks on residential structures where women and children were sheltering; and the creation of conditions in which an estimated 50,000 pregnant women lack access to essential medical care.^[12] According to a United Nations press briefing, between March 18 and April 9, 2025, during the period following the breakdown of a “ceasefire”, thirty-six airstrikes reportedly targeted areas occupied exclusively by women and children.^[13] The United Nations Population Fund, World Health Organization, Doctors without Borders, United Nations Children’s Fund (UNICEF) and Human Rights Watch have further documented the purposeful breakdown of maternal healthcare and infant mortality.^[14] In one instance, Human Rights Watch notes that due to insufficient medical infrastructure, as many as four to five newborns were placed in a single incubator, with most not surviving.^[15]

The impact on women in Gaza extends beyond direct violence. According to the United Nations, approximately 155,000 women were either pregnant or breastfeeding, with an estimated 5,500 expected to give birth each month — many while facing severe food insecurity, as 95% of the population was reported to be experiencing starvation-level conditions.^[16] Access to maternal healthcare has been critically impaired. Reports indicate that women have been prevented from reaching hospitals, including by sniper fire, forcing deliveries in unsafe and unsanitary conditions.^[17] The widespread destruction of medical infrastructure has contributed to a marked increase in preventable infant deaths and, according to some accounts, a 300% rise in miscarriages.^[18] These conditions, arising within the framework of a prolonged occupation, have been characterized by many legal scholars, such as Raz Segal, Ugur Umit Ungor, and William Schabas, as constituting acts of genocide under Article II of the Genocide Convention.^[19]

The consequences of the conflict have reverberated throughout Palestinian society. Over 3,000 women have reportedly been widowed, more than 17,000 children orphaned, and over 50,000 children killed or injured, most commonly those between the ages of six to ten.^[20] This large-scale disruption, which this Note argues constitutes acts of genocide, has placed unprecedented burdens on surviving women, who are left to sustain family and community life amid the widespread destruction of infrastructure and social support systems.^[21] The mass displacement of 2.1 million Palestinians, of whom 1.7 million are reportedly experiencing conditions of forced starvation, has had particularly severe implications for women and mothers seeking to protect and care for their families.^[22]

I argue that the systematic targeting of Palestinian women in Gaza constitutes femi-genocide, the use of femicide as an operational tool of genocide. The conduct of the Israeli leadership and officials, especially the killing of women and girls, fulfills the actus reus and evidences the specific intent (dolus specialis) required under the Genocide Convention. Femicide here operates as an instrument to destroy a group: by erasing the bodies through which life continues, it extinguishes both present and future generations. Through this lens, I reconceptualize gender-based persecution as a structural means of annihilation, situating Gaza within a broader jurisprudential trajectory of reproductive and demographic destruction. I conclude by addressing the dual layers of accountability, individual criminal liability under international criminal law and state responsibility under customary international law, and proposes a reframing of femicide within international legal doctrine as an operational mechanism of genocide rather than a parallel phenomenon.

By situating these acts at the intersection of international criminal law and human rights law, this analysis contributes to both genocide studies and international criminal law scholarship. As Palestinian women continue to face heightened risks amid ongoing occupation and armed conflict, recognizing the gendered dimensions of mass violence is essential to advancing legal accountability and informing effective prevention strategies.

This Note does not seek to re-establish that the campaign in Gaza constitutes genocide in the broader sense. That claim has already been advanced by South Africa in proceedings before the International Court of Justice and supported by extensive documentation from organizations such as Human Rights Watch and Amnesty International.^[23] These analyses have emphasized how Israel’s blockade, bombardment, and starvation policies may satisfy the legal threshold for genocide and reveal an overarching intent to destroy the Palestinian people. Yet they have largely not addressed the gendered dimensions of that intent— how the systematic targeting of women as the bearers of the group’s reproductive and social continuity functions as a means of achieving the group’s destruction. Addressing this dimension does not propose a distinct form of intent apart from the dolus specialis required for Genocide. Rather, it demonstrates how femicide can operate as evidence of genocidal intent, revealing the perpetrator’s understanding that destroying the reproductive capacity of a group is integral to destroying the group itself.

On September 16, 2025, the United Nation’s Human Rights Council published their legal analysis of Israel’s violence, coming to the conclusion that Israel’s Genocide has deliberately deprived civilians of food, water, and shelter in what it describes as “collective punishment,” yet the differential impact of such deprivation on women remains underexamined.^[24] Legal scholars have recognized that “Gender permeates all aspects of the crime of genocide,” but this insight has been largely absent from public legal discourse on Gaza .^[25]

This Note fills that gap by examining how attacks on Palestinian women’s survival, reproductive health, and in sustaining family life may function both as evidence and as instruments of group destruction…

In Prosecutor v. Akayesu, the court stated that genocide “embodies a special intent . . . which demands that the perpetrator clearly seeks to product the act as charged.” This intent can be inferred from systematic patterns of violence and explicit statements.

In the case of Gaza, multiple converging factors support an inference of genocidal intent. The shift in the demographics of those killed is stark: whereas less than 14% of Palestinians killed in prior bombardments between 2008 and 2023 were women and girls, from October 2023 to January 2024, 70% of deaths in Gaza were women and children, 1,000,000 women and girls have been displaced, and there exists no safe spaces for women survivors of gender-based violence. This dramatic change reflects a transformation in the nature and aims of the military campaign. Intent can also be inferred from words.

Public statements from senior Israeli officials, reflect a rhetorical framework that dehumanizes Palestinians and normalizes large-scale violence. Israeli President Isaac Herzog: “It’s an entire nation out there that is responsible . . . This rhetoric about civilians not being aware, not involved, it’s absolutely not true”; Heritage Minister Amichai Eliyahu suggesting nuclear weapons could be “one of the possibilities” for Gaza”; Agriculture Minister Avi Dichter: “We are now rolling out the Gaza Nakba”; National Security Minister Itamar Ben-Gvir stated that “my right for life comes before their right to movement,” “their” being Palestinians in Gaza; and IDF spokesperson Daniel Hagari: “The emphasis is on damage and not on accuracy”.

One frequently cited example is Prime Minister Benjamin Netanyahu’s invocation of “Amalek” in late 2023, a biblical reference historically associated with the total destruction of an enemy population. This statement, among others, has been interpreted by some legal scholars and international observers as evidence of genocidal rhetoric, potentially indicative of intent under Article II of the Genocide Convention…

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^[1] See reports in: WAFA News Agency, Pregnant Woman Killed by Israeli Forces in Nour Shams Refugee Camp (Feb. 9, 2025), https://english.wafa.ps/Pages/Details/154452; Middle East Eye, Israeli Forces Kill Two Palestinian Women and Unborn Child in Nour Shams (Feb. 9, 2025), https://www.middleeasteye.net/news/israel-forces-kill-two-palestinian-women-unborn-child-nour-shams; Al Jazeera, Israel Kills Two Women, Including Pregnant 23-Year-Old, in West Bank Raid (Feb. 9, 2025), https://www.aljazeera.com/news/2025/2/9/israel-kills-eight-month-pregnant-woman-in-occupied-west-bank-raid; B’Tselem, Israeli soldiers shot and killed a pregnant woman, used her relative as a human shield, and killed another woman when they blew up her front door (May 18, 2025) (Israeli human rights organization Israel’s “open fire” policy), https://www.btselem.org/firearms/20250518_soldiers_kill_two_women_one_of_them_pregnant_and_use_man_as_human_shield_in_balata_refugee_camp.

^[2] The term “murder” is used here consistent with its definition under international criminal law. Under ICL, murder as a crime against humanity is defined as “unlawfully and intentionally causing the death of a human being,” requiring that the perpetrator either intends to kill or intends to inflict grievous bodily harm likely to cause death while being reckless as to whether death ensues. The mens rea includes both direct and indirect forms of intention. While domestic legal systems may vary in their precise definitions of murder (including degrees of murder, distinctions between murder and manslaughter, and specific mental state requirements), the ICL definition largely converges with common domestic law understandings of intentional unlawful killing. Notably, under ICL, it is not required to recover the body to prove beyond reasonable doubt that a person was murdered; the fact of a victim’s death can be inferred circumstantially from other evidence. International Criminal Law & Practice Training Materials: Crimes Against Humanity, Module 7, § 7.2.2.2.2, at 18 (ICLS 2024), https://iici.global/wpd/wp-content/uploads/2024/02/icls-training-materials-sec-7-cah1.pdf (Citing, Prosecutor v. Akayesu, Case No. ICTR-96-4-T, Judgment, ¶ 589 (Sept. 2, 1998); Prosecutor v. Delalić et al. (”Čelebići”), Case No. IT-96-21-T, Judgment, ¶ 439 (Nov. 16, 1998); Prosecutor v. Strugar, Case No. IT-01-42-A, Appeal Judgment, ¶ 270 (July 17, 2008).

^[3] ‘Genocide’ will be used as a term of rhetoric to set the context in which indignities take place. Since the ICJ has not ruled on South Africa’s submitted 800-page indictment, this Note characterizes the violence that has taken place as Genocide; See also Amnesty Int’l, ‘You Feel Like You Are Subhuman’: Israel’s Genocide Against Palestinians in Gaza, (2024), https://www.amnesty.org/en/documents/mde15/8668/2024/en/; Occupation refers to the effective control of territory by foreign armed forces. The definition coming from the 1907 Hague Regulation, a “territory is considered occupied when it is actually placed under the authority of the hostile army,” Hague Regulations (1907) on the Laws and Customs of War on Land, annex, art. 42. See generally Ilan Pappé, The Ethnic Cleansing of Palestine (2006).

^[4] Frank Chung, ‘C-Section on a Beheaded Lady’: Aussie Doctors Describe Horror Conditions at Gaza Hospital, NEWS.COM.AU (Sept. 22, 2025), https://www.news.com.au/world/middle-east/csection-on-a-beheaded-lady-aussie-doctors-describe-horror-conditions-at-gaza-hospital/news-story/fef9379380c233530524fe331aa5d521; Ruth Michaelson, Gaza Doctors Save Baby from Womb of Mother Killed in Israeli Airstrike, GUARDIAN (Apr. 22, 2024), https://www.theguardian.com/world/2024/apr/22/gaza-doctors-save-baby-womb-mother-killed-israeli-airstrike-rafah.

^[5] Five Essential Facts to Know About Femicide, UN Women (Nov. 25, 2024), https://www.unwomen.org/en/articles/explainer/five-essential-facts-to-know-about-femicide (“Femicide (or feminicide, as it is referred to in some contexts) is defined as an intentional killing with a gender-related motivation. It is different from homicide, where the motivation may not be gender-related.,” UN Women); For purposes of this analysis, the term “gender-related motivation” follows the definition of “gender” in Article 7(3) of the Rome Statute, referring to the two sexes, male and female, as understood within the society concerned. This Article adopts that binary framing not to exclude other gender identities but because the conduct examined here, the systematic killing of women in Gaza, targets women specifically as women, Rome Statute of the International Criminal Court art. 7(3), July 17, 1998, 2187 U.N.T.S. 90. See, e.g., Lisa Davis, Dusting Off the Law Books: Recognizing Gender Persecution in Conflicts and Atrocities, 20 Nw. J. Hum. Rts. 1 (2021) (arguing for greater recognition of gender-based persecution as a distinct international crime); Alessia Nicastro, Addressing Femicide Through International Criminal Law: The Need for a Binding Legal Framework, Yale J. Int’l L. (Jan. 26, 2025) (arguing for femicide to be recognized as a core gendered method of group destruction).

^[6] Report of the Special Rapporteur on Violence Against Women and Girls, Its Causes and Consequences, U.N. Doc. A/HRC/59/47 (May 2025).

^[7] Rasha Khatib, Martin McKee & Salim Yusuf, Counting The Dead in Gaza: Difficult but Essential, 404 The Lancet 237, 237 (2024) (independent estimates discuss the true death toll exceeding 186,00).; U.N. Women, U.N. Women Estimates Over 28,000 Women and Girls Killed in Gaza Since October 2023 (May 19, 2025), https://www.un.org/unispal/document/un-women-press-release-19may25/; Press Release, Off. of the U.N. High Comm’r for Hum. Rts., Onslaught of Violence Against Women and Children in Gaza Unacceptable: UN Experts (May 6, 2024), https://www.ohchr.org/en/press-releases/2024/05/onslaught-violence-against-women-and-children-gaza-unacceptable-un-experts; See Angelica Wahono, Reproductive Violence in Gaza: A Gendered Atrocity Under International Law (Feb. 10, 2025), https://4genderjustice.org/our-latest-posts/reproductive-violence-in-gaza-a-gendered-atrocity-under-international-law/ (arguing that the destruction of Gaza’s maternity hospitals, IVF facilities, and maternal-care infrastructure demonstrates a calculated assault on Palestinian reproductive autonomy, amounting to reproductive violence and potentially genocide under art. II(d) of the Genocide Convention).

^[8] Independent International Commission of Inquiry on the Occupied Palestinian Territory, Including East Jerusalem, and Israel, “More Than a Human Can Bear”: Israel’s Systematic Use of Sexual, Reproductive and Other Forms of Gender-Based Violence Since 7 October 2023, U.N. Doc. A/HRC/58/CRP.3 (Mar. 13, 2025), https://www.un.org/unispal/document/report-of-the-commission-of-inquiry-israel-gender-based-violence-13march2025/.

^[9] Médecins Sans Frontières (Doctors Without Borders), U.S.-Backed Aid Distribution Points in Gaza Are Sites of Orchestrated Killing (Aug. 7, 2025), https://www.doctorswithoutborders.org/latest/us-backed-aid-distribution-points-gaza-are-sites-orchestrated-killing, (reporting that Israeli and U.S. authorities have turned aid distribution sites in Gaza into “sites of orchestrated killing,” using starvation as a weapon of war and enforcing a siege that prevents the entry of life-saving supplies. The siege, imposed since March 2025, has effectively deprived civilians of food, water, and medicine); U.N. Press Release, Security Council, As Israel’s Aerial Bombardments Intensify, “There Is No Safe Place in Gaza,” Humanitarian Affairs Chief Warns Security Council, U.N. Press Release SC/15564 (Jan. 12, 2024), https://press.un.org/en/2024/sc15564.doc.htm.

^[10] Convention on the Prevention and Punishment of the Crime of Genocide art. II(d), Dec. 9, 1948, 78 U.N.T.S. 277; Declaration on the Elimination of Violence against Women, art. 1 (“”violence against women” means any act of gender-based violence that results in, or is likely to result in, physical, sexual or psychological harm or suffering to women, including threats of such acts, coercion or arbitrary deprivation of liberty, whether occurring in public or in private life.”); Independent Commission, supra note 130.

^[11] Id.

^[12] Nadine Shubailat & Camilla Alcini, Over 4,000 IVF Embryos Destroyed in 1 Shelling at Gaza’s Largest Fertility Center, Director Says, ABC News (Apr. 24, 2024, 9:21 AM), https://abcnews.go.com/International/4000-ivf-embryos-destroyed-1-shelling-gazas-largest/story?id=109350404; Obstetric Violence: An Overlooked Tool of Genocide in Gaza, The Kvinna till Kvinna Found. (Dec. 12, 2024), https://kvinnatillkvinna.org/2024/12/12/obstetric-violence-an-overlooked-tool-of-genocide-in-gaza/; Israel Continues to Deliberately Bomb UN-Run Shelter Centres, Killing Displaced People Inside, Euro-Med Hum. Rts. Monitor (June 25, 2024), https://euromedmonitor.org/en/article/6381; 50,000 Women Pregnant in Gaza Amid Decimation of Its Health System, Al Jazeera (Dec. 24, 2023), https://www.aljazeera.com/news/2023/12/24/50000-women-pregnant-in-gaza-amid-decimation-of-its-health-system.

^[13] UN Finds 36 Israeli Strikes on Gaza Killed Only Women and Children, FRANCE 24 (Apr. 11, 2025), https://www.france24.com/en/middle-east/20250411-un-finds-36-israeli-strikes-on-gaza-killed-only-women-and-children; Office of the U.N. High Commissioner for Human Rights, Gaza: Increasing Israeli “Evacuation Orders” Lead to Forcible Transfer of Palestinians (Apr. 11, 2025), https://www.ohchr.org/en/press-briefing-notes/2025/04/gaza-increasing-israeli-evacuation-orders-lead-forcible-transfer (reporting that a 6 Apr. airstrike on the Abu Issa family’s residential building in Deir al Balah killed one girl, four women, and one four-year-old boy, illustrating the gendered and civilian toll of Israeli attacks).

^[14] WHO, Women and newborns bearing the brunt of the conflict in Gaza, UN agencies warn, https://www.who.int/news/item/03‐11‐2023‐women‐and‐newborns‐bearing‐the‐brunt‐of‐the‐conflict‐in‐gaza‐un‐agencies‐warn; Médecins Sans Frontières (Doctors Without Borders), Gaza: Maternal and Child Health Suffer Under a Decimated System (July 18, 2024), https://www.doctorswithoutborders.org/latest/gaza-maternal-and-child-health-suffer-under-decimated-system (“Some women are delivering prematurely, often with postpartum complications exacerbated by their living conditions…Once women give birth, they must quickly return to unsanitary conditions, often in tents, where lack of food and constant stress put them and their newborns at further risk.”);

^[15] Belkis Wille, Hum. Rts. Watch, “Five Babies in One Incubator”: Violations of Pregnant Women’s Rights Amid Israel’s Assault on Gaza (2025), https://www.hrw.org/report/2025/01/28/five-babies-one-incubator/violations-pregnant-womens-rights-amid-israels-assault; Impossible Choices in Gaza: ‘Women Are Giving Birth Prematurely Because Of Terror,’” UNFPA, February 23, 2024, https://www.unfpa.org/news/impossible-choices-gaza-%E2%80%9Cwomen-are-giving-birth-prematurely-because-terror%E2%80%9D.

^[16] Facts and Figures: Women and Girls During the War in Gaza, United Nations (Mar. 5, 2024), https://www.un.org/unispal/document/facts-and-figures-women-and-girls-during-the-war-in-gaza-un-women-2/; Strip: Acute Food Insecurity Situation for 1 May–15 June and Projection for 16 June–30 Sept. 2024, Integrated Food Sec. Phase Classification (2024), https://www.ipcinfo.org/ipc-country-analysis/details-map/en/c/1157065/.

^[17] How the Israeli Army Besieged Nasser Hospital, Médecins Sans Frontières (Apr. 4, 2024), https://www.doctorswithoutborders.org/latest/how-israeli-army-besieged-nasser-hospital; UNFPA, supra note 15; HRW, supra note __.

^[18] Press Release, Off. of the U.N. High Comm’r for Hum. Rts., Onslaught of Violence Against Women and Children in Gaza Unacceptable: UN Experts (May 6, 2024), https://www.ohchr.org/en/press-releases/2024/05/onslaught-violence-against-women-and-children-gaza-unacceptable-un-experts; Int’l Planned Parenthood Fed’n, Press Release: Gaza Nine Months On, Pregnant Women Carry the Burden of Conflict (July 9, 2024), https://www.ippf.org/media-center/press-release-gaza-nine-months-pregnant-women-carry-burden-conflict; ActionAid USA, Doctors in Gaza Report a Rise in Miscarriages as Pregnant Women Face Severe Stress and a Lack of Food (June 6, 2024), https://www.actionaidusa.org/news/doctors-in-gaza-report-a-rise-in-miscarriages-as-pregnant-women-face-severe-stress-and-a-lack-of-food/ (discussing surge in miscarriage due to stress, starvation, and destruction of infrastructure).

^[19] Amnesty International Investigation Concludes Israel Is Committing Genocide Against Palestinians in Gaza, Amnesty Int’l (Dec. 5, 2024), https://www.amnesty.org/en/latest/news/2024/12/amnesty-international-concludes-israel-is-committing-genocide-against-palestinians-in-gaza/; Sondos Asem, Top Genocide Scholars Unanimous That Israel Is Committing Genocide in Gaza: Dutch Investigation, Middle East Eye (May 17, 2025), https://www.middleeasteye.net/news/top-genocide-scholars-unanimous-israel-committing-genocide-gaza-investigation-finds.

^[20] Statement, UNICEF, ‘Unimaginable Horrors’: more than 50,000 children reportedly killed or injured in the Gaza Strip (May 27, 2025), https://www.unicef.org/press-releases/unimaginable-horrors-more-50000-children-reportedly-killed-or-injured-gaza-strip; One Million Traumatised Gaza Children Need Urgent Mental Health Support for Depression, Anxiety and Suicidal Thoughts: UN, The New Arab (Jan. 24, 2025), https://www.newarab.com/news/one-million-traumatised-gaza-children-need-mental-health-support; Mohamed A. Hussein & Mohammed Haddad, Gaza’s Stolen Childhood: Who Were the Thousands of Children Israel Killed?, Al Jazeera (Mar. 26, 2025), https://www.aljazeera.com/news/longform/2025/3/26/gazas-stolen-childhood-the-thousands-of-children-israel-killed.

^[21] Press Release, Israeli Attacks on Educational, Religious and Cultural Sites in the Occupied Palestinian Territory Amount to War Crimes and the Crime Against Humanity of Extermination, UN Commission Says, OHCHR (June 10, 2025), https://www.ohchr.org/en/press-releases/2025/06/israeli-attacks-educational-religious-and-cultural-sites-occupied (reporting the UN Commission’s finding that Israeli attacks on civilian infrastructure in the OPT amount to war crimes and crimes against humanity, including extermination).

^[22] Gaza: Evidence Points to Israel’s Continued Use of Starvation to Inflict Genocide Against Palestinians, Amnesty Int’l (July 3, 2025), https://www.amnesty.org/en/latest/news/2025/07/gaza-evidence-points-to-israels-continued-use-of-starvation-to-inflict-genocide-against-palestinians/; Kellie Leeson, The Hunger Crisis in Gaza: The Impact on Women and Girls, Women’s Refugee Commission (July 28, 2025), https://www.womensrefugeecommission.org/blog/addressing-the-hunger-crisis-in-gaza/; U.N. Population Fund (UNFPA), Gaza Famine a Catastrophe for Mothers and Infants (Aug. 22, 2025), https://www.un.org/unispal/document/unfpa-press-release-22aug25/ (“In Gaza today, famine is no longer a dark threat – it has set in. For pregnant and breastfeeding women and their newborns, it is a possible death sentence.”)

^[23] Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (S. Afr. v. Isr.), Application Instituting Proceedings and Request for the Indication of Provisional Measures, ICJ Pleadings (Dec. 29, 2023); Amnesty Int’l, supra note 3.

^[24] Human Rights Council, Legal Analysis of the Conduct of Israel in Gaza Pursuant to the Convention on the Prevention and Punishment of the Crime of Genocide, U.N. Doc. A/HRC/60/CRP.3 (Sept. 16, 2025).

^[25] Ruby Mae Axelson & Prachiti Venkatraman, Reproductive Violence in Palestine: The Need for a Feminist Approach to Justice, Opinio Juris (Feb. 1, 2024), https://opiniojuris.org/2024/02/01/reproductive-violence-in-palestine-the-need-for-a-feminist-approach-to-justice/.