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Report: Evaluation of Israel's Gaza Blockade in Terms of International Law as of October 2025 and The Legal Status of The Global Sumud Flotilla

  • Writer: Turkey | Ilco & Law
    Turkey | Ilco & Law
  • Oct 1
  • 21 min read

Updated: 5 hours ago

Report: Evaluation of Israel's Gaza Blockade in Terms of International Law as of October 2025 and The Legal Status of The Global Sumud Flotilla

Report Prepared by Att. M. Taha Dogan                                                              01.10.2025


Turkey | Ilco & Law Academy – 01.10.2025
Ref. No: ILCO-2503



REPORT: EVALUATION OF ISRAEL’S GAZA BLOCKADE IN TERMS OF INTERNATIONAL LAW AS OF OCTOBER 2025 AND THE LEGAL STATUS OF THE GLOBAL SUMUD FLOTILLA


DETAILED ANALYSIS, TEXT-SUPPORTED ARGUMENTS

Short Summary (Thesis): When the legislative texts and the existing 2025 facts are evaluated together —in light of the relevant provisions of the San Remo Manual, the United Nations Convention on the Law of the Sea (UNCLOS), Geneva Law (IV Convention, AP I), and the Rome Statute— the manner in which Israel enforces the blockade (particularly the de facto prevention of humanitarian aid, the use of disproportionate force, and the substantive and procedural deficiencies in the assessments used to justify the blockade) does not fully comply even with the rules it relies upon. On the other hand, the 2025 initiatives of the Global Sumud Flotilla —considering their civilian character, humanitarian purpose, and the rights granted under existing legal regimes— can be grounded in international law; Israel’s claims of intervention (e.g., “ship inspection” or “legitimate measures against the blockade”) are subject to strict legal conditions, and in most concrete cases there is no convincing evidence that these conditions have been met. (All supporting provisions, relevant text excerpts (brief), and sources are shown below.)

Methodology & Sources


  • A legal-factual analysis was conducted by comparing primary sources (international treaties, the San Remo Manual, the Rome Statute, UN reports) with 2025 news/institutional statements. Key sources include: San Remo Manual (1994), UNCLOS, the Geneva Conventions and AP I, the Rome Statute and Elements of Crimes, the UN Panel (Palmer) Report (2011), UN Human Rights Office/expert statements, and 2025 press/media reports (e.g., Reuters, Al Jazeera).

Note: In the study below, a brief direct quotation is provided for each principal legal provision used; the full texts of the provisions are available in the relevant sources, and at the end of each section references to these sources are given. In addition, the most significant news/event reports and UN statements regarding the 2025 events are included in the text.

1. Legal Framework — Provisions and Short Text Excerpts (Fundamental Norms)

1.1 San Remo Manual (1994) — Law of Naval Warfare (Selected Provisions)

  • ¶93: “A blockade shall be declared and notified to all belligerents and neutral States.”Explanation: For a blockade to be considered valid, it must be declared and notified; its procedure and scope must be clearly announced. (San Remo ¶93–96)

  • ¶95: “A blockade must be effective.”Explanation: A blockade must be effectively enforced; “effectiveness” is a factual criterion (military control, ability to stop vessels, etc.).

  • ¶102–103 (summary/paraphrase): A blockade is prohibited if its “sole purpose [is] starving the civilian population”; if the civilian population is inadequately supplied, the blockading party must make arrangements for the passage of essential food and medical supplies; such passages may be subject to technical arrangements but arbitrary obstruction is prohibited. (San Remo ¶102–104).

  • ¶118: “Right to visit and search merchant vessels outside neutral waters where there are reasonable grounds for suspecting that they are subject to capture.”Explanation: In wartime, stopping/searching a ship is permitted only if there are “reasonable grounds” or if it is subject to capture.

1.2 UNCLOS (1982) — Legal Regime of the Sea (Selected)

  • Art. 87 (short): “The high seas are open to all States.”Explanation: Freedom of navigation in international waters is the fundamental rule; exceptions for interference are narrowly defined.

  • Arts. 92/110 (short): Ships sail under the flag of one State only, and visit/boarding on the high seas is permitted solely in limited circumstances (piracy, slave trade, stateless vessel, etc.) or within the framework provided by treaties.

1.3 Geneva Convention IV and Additional Protocol I — Provisions on Siege, Relief, and Starvation

  • GC IV, Art. 55 (short): “The Occupying Power has the duty of ensuring the food and medical supplies of the population.”Explanation: The Occupying Power has an obligation to secure food and medical supplies for the population.

  • GC IV, Art. 59 (short): Collective relief: “If the population is inadequately supplied, the Occupying Power shall… allow relief consignments.” (summary).Explanation: If the population is inadequately supplied (or resupplied), the Occupying Power shall allow relief shipments.

  • AP I, Art. 54 (short): “Starvation of civilians as a method of warfare is prohibited.” (AP I, Art. 54(1)).Explanation: Starvation of civilians as a method of warfare is prohibited.

  • AP I, Art. 70 (short/paraphrase): States Parties must make arrangements ensuring the rapid and unimpeded passage of relief and humanitarian assistance with respect to transit, aid, and humanitarian protection.

1.4 Rome Statute and the ICC: Starvation / Obstruction of Relief as Criminal Acts

  • Rome Statute, Art. 8(2)(b)(xxv) (short): As a war crime, “intentionally using starvation of civilians as a method of warfare … including wilfully impeding relief supplies …” is recognized.Explanation: In the context of war crimes, intentionally using starvation as a method of warfare—including deliberately obstructing relief supplies—is criminalized.

  • ICC Elements of Crimes (summary): Elements of the war crime (starvation): (i) deprivation of civilians of objects indispensable to survival; (ii) intent to starve; (iii) in the context of an international armed conflict.

1.5 Principles of Humanitarian Law (General)

  • The principles of necessity & proportionality (fundamental principles reflected in all IHL texts and in the San Remo Manual).


2. 2025 Factual Situation — Brief, Verified Facts (with Sources)

(The following facts will be referenced in later sections of the report.)

  1. Global Sumud Flotilla (GSF) 2025: In September 2025, a flotilla of approximately 50 civilian vessels set sail to deliver humanitarian aid to Gaza and to protest the blockade; participants included activists, lawyers, and politicians. Some of the flotilla’s ships reported drone attacks and explosions in international waters.

    https://www.reuters.com/world/middle-east/gaza-aid-flotilla-set-head-east-greece-despite-israeli-warnings-2025-09-26

    https://www.aljazeera.com/news/2025/9/24/gaza-aid-flotilla-hit-by-drone-attacks-and-explosions-activists-say

    https://globalsumudflotilla.org/media/press/GSF-Press%20Release_September%2023%2C%202025.pdf

  2. UN and Human Rights Bodies’ Warnings / Reports of Famine (2025): In the August–September 2025 period, the IPC analysis supported by the UN and UN agencies confirmed famine in northern Gaza; international statements, such as a joint declaration by 14 members of the Security Council (excluding the US), described the situation as a “man-made famine in Gaza.” The UN Human Rights Office and UN experts called for the safe passage of the flotilla and for the blockade to be eased.

    https://www.who.int/news/item/22-08-2025-famine-confirmed-for-first-time-in-gaza

    https://www.reuters.com/world/middle-east/all-un-security-council-members-except-us-say-famine-gaza-is-man-made-crisis-2025-08-27

    https://www.ohchr.org/en/press-releases/2025/09/attacks-gaza-bound-flotilla-defy-belief-accountability-must

  3. Alleged Interventions / Attack Claims in 2025 Events: Reports indicated drone attacks, communication interference, and coercive actions against some vessels in the flotilla; the UN and human rights bodies called for investigation and scrutiny. Statements from the flotilla itself and media reports conveyed these allegations.

3. Israel’s Legal Arguments (Summary) — Which Norms Are They Based On?

The main legal headings Israel typically uses to defend the blockade are as follows:

  1. Naval blockade is a belligerent right — within the framework of an international armed conflict, a naval blockade can be declared and the transfer of support to the enemy via sea can be prevented (San Remo / customary law of naval warfare).

  2. Self-defence (UN Charter Article 51) — Israel asserts that it may implement a blockade/interdiction/prohibition as a measure against security threats allegedly originating from Hamas (in public opinion and official statements, the defence has been made within this framework).

  3. Rights of visit/inspection-based intervention — if belligerent rights or “reasonable grounds” exist, there is a right to visit/inspect and divert ships on the high seas; therefore, suspicious ships may be stopped. (San Remo ¶118; interpreted together with the limitations of UNCLOS Art.110).

  4. Security and intelligence-based determination — Israel occasionally claims that the ship or flotilla is carrying weapons or military equipment, or has ties with Hamas or other armed groups, and thus seeks to legitimize the intervention (the accuracy of these claims must be proven with concrete facts).

4. Why Israel’s Defence is Inadequate/Improper According to the Same Legal Framework — Detailed Legal Analysis

Below, for each main argument, a comparison is made between the relevant legal criterion and the facts, and the result is stated.

4.A.1 Blockade Declaration / Notification and Effectiveness Requirement (San Remo ¶93–95)

  • Legal criterion: San Remo ¶93–95: “A blockade shall be declared and notified to all belligerents and neutral States.” and “A blockade must be effective.” In addition, ¶94: the scope of the declaration (beginning, location, duration, etc.) shall be specified.

  • Fact: Israel claims that it has been applying maritime restrictions for a long time (since 2007 and particularly expanded after 2023); the humanitarian crisis/famine in 2025 and UN statements show that the “effectiveness” of the blockade has resulted in depriving the civilian population of vital supplies.In addition, the Israeli side, by particularly referring to the Palmer (2011) Report as the legitimacy basis of the blockade and using it as a defence, claims that the blockade — which has been accepted worldwide as a humanitarian crisis — is legitimate. As analyzed in detail under a separate heading below, this claim based on the Palmer (2011) Report is substantively legally problematic, contrary to the applicable legislation forming Israel’s legitimacy basis, and invalid. Even though the Palmer (2011) Report itself identified that certain aspects of the blockade were effective, the Panel made serious criticisms regarding the method of implementation.

  • Assessment:(a) Even if the declaration and notification were made in the past, the effectiveness criterion is result-oriented: if the implementation of the blockade results in the civilian population being unable to access vital necessities (as confirmed by 2025 IPC/UN data), pursuant to San Remo ¶103 the manner in which the blockade is applied must be reviewed in terms of its purpose and results.(b) San Remo ¶102 explicitly states that “a blockade shall be prohibited if it has the sole purpose of starving the civilian population.” What matters here is the purpose and/or the expected result. UN reports and IPC findings show that, in terms of actual consequences, the implementation of the blockade has caused serious harm to the civilian population; this weakens Israel’s defence.

    https://www.who.int/news/item/22-08-2025-famine-confirmed-for-first-time-in-gaza

Result: A blockade declaration alone does not ensure legality; if the obligations of San Remo regarding free passage (¶103–104) and proportionality limits are not met, the implementation is problematic. The existence of UN data invalidates Israel’s argument that “since it was procedurally declared, every intervention is legitimate.”

4.A.2 Passage of Humanitarian Aid and the Obligation of “Free Passage” (San Remo ¶103; GC IV Art.59; AP I Art.54/70)

Result: Within the San Remo and Geneva framework, if there is starvation in the blockaded area, the blockading party has the obligation to actually ensure the passage of humanitarian aid; 2025 data raise serious doubts as to how this obligation has been fulfilled.

4.A.3 Limits of Visit/Search Authority (UNCLOS + San Remo ¶118) — The “Reasonable Suspicion” Problem

  • Legal criterion: UNCLOS Art.110 (peacetime) restricts the rights of visit; San Remo ¶118 (armed conflict) states that only if there are “reasonable grounds” may visit and search be conducted on the high seas.

  • Fact: It has been declared that the 2025 Flotilla carried humanitarian materials; independent verification/evidence generally supports the claims of humanitarian materials. Israel has, in some statements, alleged that the flotilla had links with Hamas and was carrying weapons/communication equipment; however, independent, clear, and specific evidence confirming “reasonable suspicion” has not been presented to the public. Moreover, the 2010 Palmer Report emphasized that “less coercive measures” should have been applied during the Mavi Marmara operation.

  • Assessment: Legally, the element of reasonable suspicion must be based on concrete, factual grounds; general intelligence rhetoric or vague allegations do not legitimize stopping/searching a humanitarian flotilla on the high seas. If search/seizure decisions lack reasonable suspicion, the intervention is unlawful within the framework of UNCLOS and IHL. In addition, the force used during the intervention must be proportionate and necessary; reports and observations raised allegations of disproportionate use of force in some 2025 interventions (drone strikes, explosions, etc.).

Result: As long as Israel does not transparently demonstrate that the reasons it presented for stopping the flotilla on the high seas meet the criterion of “reasonable suspicion,” the intervention remains legally weak.


4.A.4 Use of Force in Humanitarian Law: Necessity & Proportionality (San Remo ¶3–6; Palmer Findings)

  • Legal criterion: The principles of IHL limit the use of force: necessity and proportionality requirements. San Remo also adopts the same principles.

  • Fact: The 2011 Palmer Panel stated that in some aspects of the operation disproportionate force was used and that warnings were insufficient. In the 2025 incidents, reported drone attacks, explosions, communication disruptions, and security concerns — on civilian sailors — make the manner of applying force controversial. The UN Human Rights Office and independent experts have called for an investigation.

  • Assessment: Force must always be a last resort; moreover, the protection of civilian life is a priority. When the 2010 precedent and the 2025 reports are evaluated together, it can be argued that some practices of Israel’s interventions contradict the compelling principles of San Remo and IHL.

Result: If the methods/procedures used do not fully comply with the law, the “legal legitimacy” of the blockade is weakened due to the manner of its execution.

4.A.5 Starvation and Criminal Responsibility (AP I Art.54; Rome Statute Art.8(2)(b)(xxv))

(i) If, as a result of the implementation of the blockade, the civilian population is in starvation and the blockading party deliberately or by negligence obstructs humanitarian aid, unlawfulness and even war crime allegations may arise;

(ii) At least in terms of political/international responsibility (interstate obligation violation), serious criticism and a UN investigation may be necessary. For an international criminal investigation, evidence collection, proof of intent, and determination of the nature of the conflict (international conflict element, etc.) are required; however, the legal norms are clear: exploitation of starvation is prohibited.

Result: The existing 2025 data support allegations of unlawfulness; although more detailed evidence is needed for criminal responsibility, the normative framework is clear and the severe consequences of the blockade are legally problematic.


4.B The Illegality of the Palmer Report (2011), the Fundamental Invalidity of Israel’s Claim of Blockade Legitimacy Against Basic Legislation, and Its Shaping Under Political Influences

1. Emergence and Mandate of the Palmer Report

In 2010, following the Mavi Marmara incident, a panel was established by the United Nations Secretary-General Ban Ki-moon, and its chairmanship was given to former Prime Minister of New Zealand, Sir Geoffrey Palmer. The Commission’s task was to investigate Israel’s intervention against the civilian flotilla carrying humanitarian aid to Gaza and to conduct a legal assessment regarding the parties. However, from the very beginning, the process of drafting the report was entirely based on a search for political balance:

  • Among the members of the Commission were representatives appointed by both Israel and Turkey.

  • Unlike the independent “Fact Finding Mission” report of the UN Human Rights Council in 2010, the mandate of this panel was limited and focused on providing a diplomatic resolution between the parties.

Therefore, the Palmer Report took shape not as a technical legal report but as a product of diplomatic negotiation.

2. Legal Problems in the Findings Regarding the “Legitimacy” of the Blockade

The Palmer Report found Israel’s blockade of Gaza to be “in conformity with international law due to legitimate security concerns.” However, this assessment is problematic from various aspects:

2.1 - Misinterpretation of the San Remo Manual

  • The Report referred to the provisions of the San Remo Manual (1994) and deemed the blockade legitimate.

  • Yet Articles 93, 97, and 102 of the San Remo Manual explicitly stipulate that a blockade cannot be applied with the aim of starving civilians, and that the passage of humanitarian aid must be permitted. (The relevant provisions and explanations of these rules are cited in detail at the beginning of the report.)

  • The Gaza blockade systematically restricted the entry of food, medicine, and essential supplies, and thus is in clear violation of the San Remo Manual.

2.2 - Disregard of the Geneva Conventions

  • Articles 33, 55, and 59 of the Fourth Geneva Convention obligate the fulfillment of the needs of the civilian population and the allowance of humanitarian aid entry. (The relevant provisions and explanations of these rules are cited in detail at the beginning of the report.)

  • The Palmer Report did not address these provisions; it focused solely on Israel’s security argument.

2.3 - Over-Interpretation of the Self-Defense Justification

  • Article 51 of the UN Charter limits the right of self-defense to proportional measures against an armed attack.

  • Rapor, Gazze’den gelen güvenlik tehdidini sürekli ve belirsiz bir saldırı olarak değerlendirip, süresiz ve geniş kapsamlı bir ablukanın “meşru müdafaa” sayılabileceği yönünde yorum yaptı. The Report interpreted the security threat emanating from Gaza as a continuous and undefined attack, and concluded that an indefinite and broad blockade could be considered “self-defense.”

  • This constitutes a political perspective that excessively broadens the narrowly interpreted concept of self-defense under international law, and cannot serve as a legal precedent.

3. Political Influence and Pressure Factors

The conclusions of the Palmer Report cannot be considered independent from the diplomatic pressures of Israel and the United States:

  • The Open Support of the United States:

Since 2010, the U.S. administration had repeatedly declared that it supported Israel’s blockade policy and considered it legitimate on security grounds. The Palmer Panel’s finding regarding the legitimacy of the blockade was nothing more than a reflection of this American stance in a UN document.

  • Israel’s Diplomatic Conditions:

Israel agreed to participate in the panel on the condition that the report would be “neutral” and would not conclude that the blockade was entirely unlawful. Therefore, it is clear that the report was shaped from the outset with “red lines.”

  • The Balancing Factor of Turkey–Israel Relations:

The main purpose of the panel was to reduce the diplomatic crisis between the two countries and to provide a legal framework for discussions on compensation and apology. For this reason, the language of the report was deliberately set in a “balanced rhetoric” that did not fully hold Israel accountable, but instead “issued warnings to both parties.”

4. Criticisms of the International Community

  • The UN Human Rights Council Report (2010) determined that the blockade constituted unlawful collective punishment. This report clearly contradicts the Palmer Report.

  • Organizations such as Amnesty International, HRW, and the ICRC have long emphasized that the blockade constitutes a violation of humanitarian law.

  • In academic literature, the Palmer Report has been evaluated as “a political compromise document rather than a legal analysis,” and its objectivity and legal consistency have been seriously questioned.

5. Conclusion: A Politically Shaped Document with No Validity in Terms of International Law

Although the Palmer Report ostensibly bears the appearance of a UN document, due to:

  • Its disregard for the provisions of international humanitarian law,

  • Its misinterpretation of the San Remo Manual,

  • Its disproportionate expansion of the right to self-defense,

  • Its drafting under the diplomatic pressures of Israel and the United States,

it has lost the quality of being a legal basis. In this respect, the Palmer Report (2011), upon which Israel relies for the legitimacy of the blockade, is not an objective and binding source of international law; rather, it is a diplomatic document prepared under the shadow of political balances.


5. Defense of the Legality of the Global Sumud Flotilla’s (GSF) 2025 Initiatives — Legal Bases

Below are the key legal arguments and textual sources supporting the claim that the flotilla is in conformity with international law.

5.1 Freedom of Navigation — UNCLOS Art.87 and the Law of the Flag State

  • Rule: UNCLOS states, “The high seas are open to all States.” (Art.87), and the flag State has exclusive jurisdiction over its vessels (Art.92). For another State to stop or board a foreign-flagged vessel, narrow exceptions must apply.

  • Application: The flotilla’s ships are generally civilian, humanitarian in nature, and sail under various flags. Legally, interference on the high seas requires either (i) a clear exception (e.g., piracy, human trafficking, etc.), or (ii) in the case of an armed conflict, application of IHL standards (such as San Remo’s “reasonable grounds for suspicion” criterion). Concretely, the humanitarian supplies carried by the flotilla and the profile of its participants are highly unlikely to meet the “reasonable suspicion” threshold.

  • Furthermore, considering the structure and nature of the flotilla, invoking the “reasonable suspicion” criterion cannot be considered legally valid. Since its inception in 2025, the flotilla has been composed of prominent human rights activists, lawyers, parliamentarians, and internationally recognized civilians, with its activities fully open and transparent to global public scrutiny. Through social media, live broadcasts, and other communication channels, this transparency continually affirms the humanitarian and civilian character of the flotilla, leaving no plausible grounds for suspicion of hidden military objectives or unlawful activities.

5.2 Humanitarian Purpose and the Geneva Law Regime — The Right to Facilitate Aid

5.3 Peaceful Expression and the Right of Civil Action at Sea

  • Rule: In the absence of restrictions on navigation, peaceful civilian actions (protests, civilian convoys) can be supported as forms of freedom of expression at sea within the general human rights framework. Before resorting to force, States must attempt less intrusive measures. (The Palmer Report 2011’s assessment of the Mavi Marmara emphasized States’ responsibility to warn their citizens and to take moderate measures before using force.)

5.4 Summary Argument — The GSF is Lawful Because:

  • GSF vessels are civilian/humanitarian in purpose, and most of the cargo consists of humanitarian supplies.

  • On the high seas, there is no absolute “right of interdiction”; intervention requires reasonable suspicion or specific legal exceptions, which have not been demonstrated with public, concrete evidence.

  • The San Remo Manual / GC IV / AP I framework requires facilitation of humanitarian aid efforts; in particular, under famine conditions, civilian humanitarian initiatives gain normative strength.

Conclusion: Considering publicly available information and international legal standards, the GSF’s 2025 activities may be assessed as legitimate humanitarian initiatives. Israel’s claims of intervention are legally defensible only if strict conditions (concrete reasonable suspicion, proportionality, prior notification, and the use of less coercive alternatives) are met.

6. Counter-Arguments — Weaknesses and Risks (Points the GSF Should Pay Attention To)

  • Role of Flag States: If a vessel is engaged in “suspicious activity” and the flag State requests verification, the consent or investigative requests of the flag State are important. GSF organizers and participating vessels should maintain transparency in their registration, and ensure solid documentation of communications with flag States. (UNCLOS Arts.92/110).

  • If Certain Organizers Are Linked with Armed Groups: This could strengthen claims of reasonable suspicion. However, the burden of proof lies with the intervening State. Still, considering the structure and nature of the flotilla, invoking the “reasonable suspicion” criterion cannot be deemed legally valid. Since its inception in 2025, the flotilla has been composed of prominent human rights activists, lawyers, parliamentarians, and internationally recognized civilians, with its activities constantly open to the scrutiny and monitoring of the global public. Through social media, live broadcasting, and other communication tools, this transparency continually affirms the flotilla’s humanitarian and civilian character, leaving no basis for elevating any alleged hidden military purpose or unlawful activity to the level of reasonable suspicion.

  • Security Risks: Factors that may endanger the flotilla’s safety (e.g., overcrowding on vessels, inadequate maritime security measures) could create operational risks. However, these risks do not automatically entitle Israel to use disproportionate force — rather, they open the possibility of third-party security support models (e.g., NATO/EU vessels or neutral escorts). Reports from 2025 indicating the accompaniment of Italian/Spanish ships point in this direction.

7. Conclusion

In light of the legal framework and precedents presented throughout this report, Israel’s blockade of Gaza and its enforcement measures against the Sumud humanitarian flotilla are found to be unlawful under international treaties, the law of the sea, and international humanitarian law, as detailed and substantiated above. Moreover, Israel’s legal defense invoking the San Remo Manual to justify the blockade is insufficient and inconsistent with the Manual itself, as demonstrated in this report with reasoned references and analysis.

Conversely, the activities of the Global Sumud Flotilla (GSF) do not constitute any violation of international law; rather, they fall squarely within the scope of humanitarian obligations, freedom of navigation, and the principle of civilian protection, all of which are safeguarded by international law.

(In summary) Findings of Israel’s Wrongdoing

  1. Discrepancy between declaration and implementation of blockade: Under the San Remo Manual and the Geneva Conventions, a state may declare a blockade for security reasons. However, for such a blockade to be lawful, the principles of proportionality, allowance for humanitarian relief, civilian protection, and transparency must be strictly observed. Israel’s practices fail to meet these criteria. Furthermore, Israel’s own interpretation that the blockade is lawful stems from a misreading of the San Remo Manual and related legal bases; thus, the claim of legitimacy is invalid.

  2. Obstruction of humanitarian relief: Blocking the entry of essential food, medicine, and medical supplies into Gaza is incompatible with Articles 23 and 59 of the Fourth Geneva Convention. This amounts to collective punishment of civilians and violates the very core of international humanitarian law.

  3. Inducing starvation and famine: As a result of the blockade, infant and child deaths, medical shortages, and a large-scale humanitarian crisis have emerged. These consequences violate the prohibition against “starving the civilian population” under the Hague Regulations and customary international law.

  4. Groundlessness of the “reasonable suspicion” claim: Participants of the flotilla are internationally recognized human rights defenders, lawyers, parliamentarians, and civilians. Their activities were transparently monitored in real time by the global public through social media and other communication tools. Therefore, Israel’s claim of “hidden military purposes” or “weapons smuggling” cannot be considered legally reasonable.

(In summary) Findings in favor of the Flotilla

  1. Freedom of navigation: Under Article 87 of UNCLOS, freedom of navigation on the high seas is a fundamental principle. The flotilla, composed of civilian vessels pursuing humanitarian purposes, falls within this right.

  2. Humanitarian purpose and protection: The sole aim of the flotilla is to deliver food, medicine, and other relief supplies to civilians in Gaza. Such activity is protected under Article 59 of the Fourth Geneva Convention, which obligates states to facilitate humanitarian relief.

  3. Transparency and legitimacy: The composition of the flotilla, its international participation, and the transparent conduct of its activities confirm the humanitarian and lawful nature of the initiative.

  4. International support: UN expert reports, academic assessments, and numerous states’ official or informal statements reinforce the legitimacy of the flotilla’s humanitarian mission.

***Final Assessment

In light of the legal framework and precedents presented throughout this report, Israel’s blockade of Gaza and its enforcement measures against the Sumud humanitarian flotilla are found unlawful under international treaties, the law of the sea, and international humanitarian law, as detailed and substantiated above. Moreover, Israel’s legal defense invoking the San Remo Manual is insufficient and inconsistent with the Manual itself. Conversely, the Global Sumud Flotilla’s activities are reported as consistent with humanitarian obligations, freedom of navigation, and civilian protection under international law.

01/10/2025



Report Prepared by


Member of the Union of Turkish Bar Associations

Att. Muhammed Taha DOGAN


UTBA Registration No: 177819







Appendix: Quick Reference to Key Sources (Primary Load-Bearing References)

  • Appendix-1: Relevant provisions of the San Remo Manual (1994) (¶93–104, ¶118)

  • Appendix-2: United Nations Convention on the Law of the Sea (UNCLOS, 1982) Relevant provisions (Art. 87, Art. 92, Art. 110)

  • Appendix-3: Geneva IV Convention and Additional Protocol I (relevant provisions: GC IV Art.55–59; AP I Art.54, 70)

  • Appendix-4: Rome Statute (1998) — specifically Art.8(2)(b)(xxv)

  • Appendix-5: Palmer Panel Report (2011) — “Report of the Secretary-General’s Panel of Inquiry on the 31 May 2010 Flotilla Incident”

  • Appendix-6: UN Security Council Report (2010) — “Report of the international fact-finding mission to investigate violations of international law, including international humanitarian and human rights law, resulting from the Israeli attacks on the flotilla of ships carrying humanitarian assistance”

  • Appendix-7: 2025 Reports from the UN and international organizations (WHO famine report, OHCHR press releases, IPC assessments)

  • Appendix-8: 2025 press news and independent statements (Reuters, Al Jazeera, Global Sumud Flotilla press releases, etc.)

REFERENCES

Primary Legal Sources

  • San Remo Manual on International Law Applicable to Armed Conflicts at Sea (1994).

  • United Nations Convention on the Law of the Sea (UNCLOS, 1982).

  • Geneva Convention IV Relative to the Protection of Civilian Persons in Time of War (1949) ve Additional Protocol I (1977).

  • Rome Statute of the International Criminal Court (1998) ve Elements of Crimes.

  • Report of the Secretary-General’s Panel of Inquiry on the 31 May 2010 Flotilla Incident (Palmer Report, 2011).

  • UN Security Council Report (2010) — “Report of the international fact-finding mission to investigate violations of international law, including international humanitarian and human rights law, resulting from the Israeli attacks on the flotilla of ships carrying humanitarian assistance”

UN and International Institution Reports

  • UN OHCHR Press Release, “Attacks on Gaza-bound flotilla defy belief; accountability must follow” (2025).

  • WHO, “Famine confirmed for the first time in Gaza” (22 August 2025).

  • UN Security Council, “Famine in Gaza is a man-made crisis” (27 August 2025).

  • UNICEF, Statement by Executive Director Catherine Russell (2025).

  • IPC/FAO Analysis Reports on Gaza (2025).

MEDIA AND REPORTING SOURCES CITED IN THE REPORT

  1. Reuters – Gaza aid flotilla set head east from Greece despite Israeli warnings🔗 https://www.reuters.com/world/middle-east/gaza-aid-flotilla-set-head-east-greece-despite-israeli-warnings-2025-09-26📝 News that the Global Sumud Flotilla is moving from Greece towards Gaza, and that Israel has issued warnings.

  2. Al Jazeera – Gaza aid flotilla hit by drone attacks and explosions, activists say🔗 https://www.aljazeera.com/news/2025/9/24/gaza-aid-flotilla-hit-by-drone-attacks-and-explosions-activists-say📝 Allegations that some ships in the Flotilla were subjected to drone attacks and explosions in international waters.

  3. Global Sumud Flotilla – Press Release (23 September 2025)🔗 https://globalsumudflotilla.org/media/press/GSF-Press%20Release_September%2023%2C%202025.pdf📝 The Flotilla's own official press release; it emphasizes that its objectives are humanitarian aid and protesting the blockade.

  4. WHO – Famine confirmed for first time in Gaza (22 August 2025)🔗 https://www.who.int/news/item/22-08-2025-famine-confirmed-for-first-time-in-gaza📝 The World Health Organization’s report announcing the first-ever finding of ‘official famine’ in Gaza.

  5. Reuters – All UN Security Council members except US say famine in Gaza is a man-made crisis (27 August 2025)🔗 https://www.reuters.com/world/middle-east/all-un-security-council-members-except-us-say-famine-gaza-is-man-made-crisis-2025-08-27📝 The statement by all members of the UN Security Council, except the United States, declaring the famine in Gaza to be 'man-made'.

  6. OHCHR – Attacks on Gaza-bound flotilla defy belief; accountability must follow (September 2025)🔗 https://www.ohchr.org/en/press-releases/2025/09/attacks-gaza-bound-flotilla-defy-belief-accountability-must📝 UN Human Rights Office's statement regarding the flotilla attacks; call for accountability.

  7. UN Press Release – Security Council (August 2025)🔗 https://press.un.org/en/2025/sc16037.doc.htm📝 UN Security Council press statement; assessments on the hunger crisis and aid passage in Gaza.

  8. UNICEF – Statement by Executive Director Catherine Russell on children killed during a nutrition aid distribution in Gaza (2025)🔗 https://www.unicef.org.uk/press-releases/statement-by-unicef-executive-director-catherine-russell-on-children-killed-during-a-nutrition-aid-distribution-in-the-gaza-strip📝 UNICEF statement; declaration regarding child deaths during aid distribution in Gaza.

  9. Vanguard News – 21 children dead from malnutrition and starvation, Gaza hospital says (2025)🔗 https://www.vanguardngr.com/2025/07/21-children-dead-from-malnutrition-starvation-says-gaza-hospital📝 Hospital-sourced news regarding children who died in Gaza due to starvation and malnutrition.

  10. Al Jazeera – Gaza aid flotilla hit by drone attacks (duplicate earlier)🔗 (duplicate source)

  11. OHCHR – Gaza UN experts urge General Assembly to respond to famine and genocide (2025)🔗 https://www.ohchr.org/en/press-releases/2025/09/gaza-un-experts-urge-general-assembly-respond-famine-and-genocide📝 UN experts' call to the General Assembly to respond to the risk of famine and genocide in Gaza.

  12. TWAILR – International legal and human rights academics call for the safe passage of the Global Sumud Flotilla (2025)🔗 https://twailr.com/international-legal-and-human-rights-academics-call-for-the-safe-passage-of-the-global-sumud-flotilla-and-distribution-of-aid-in-the-gaza-strip📝 Joint statement by international law academics; it calls for ensuring the safe passage of the flotilla.

  13. UN Human Rights Council – Fact Finding Mission Report (2010)🔗 https://documents.un.org/symbol-explorer?s=A/HRC/15/21&i=A/HRC/15/21_2372165📝 UN Human Rights Council report following the Mavi Marmara incident; it characterizes the Gaza blockade as 'collective punishment'.


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