Local Authorities Normalize Illegality:

15 Discriminatory Circulars Against Syrians Documented Between April 9 and 24, 2024

Following the Cypriot President’s demand to the president of the European Commission Ursula Von der Leyen, to mediate between them and the Lebanese authorities, for the latters to prevent the boats of Syrian refugees from going to Cyprus, Von der Leyen visited Beirut this month in the company of the Cypriot president.
During their meeting with president Mikati, they discussed the role of lebanon as sentinel of the EU countries. Von der Leyen also announced offering a grant of 1 billion dollars to Lebanon, in return for this role.

Looking at these meetings and ongoing pressures, the reason behind the wide militia-like campaign, launched by the state and its political parties for a while now to expel the Syrian refugees, and accusing them of all sorts of crimes, becomes clear.

The repercussions of the Lebanese Forces Party coordinator Pascal Suleiman’s assassination on Syrian refugees have been immense. The first week saw an escalation in discriminatory campaigns and threats of expulsion by municipalities and security forces, in addition to ongoing political and media incitement campaigns. Most notably, several local authorities – including municipalities, municipal federations, and governors – issued discriminatory circulars asking citizens to report Syrian individuals residing within their jurisdictions to verify their identification documents and threaten them with expulsion. These circulars also impose restrictions on the movement, housing, and work of Syrians, some of which exceed the jurisdiction of local authorities. In this context, Public Works Studio monitored the circulars issued between April 9 and 24, 2024, and analyzed 15 of them, aiming to highlight the collective punishment of a group of residents, fueled by systematic political and media propaganda that seeks to incite against Syrians at every opportunity, without restraint.

We have read these circulars (you will find the complete list at the bottom of the article) according to their implications in four areas:

  1. Securitization (transforming society into individuals who monitor each other, spy on each other, and report each other to the security forces),
  2. Housing,
  3. Movement and presence in public spaces,
  4. Work / Labor conditions,

As a result of this reading, we conclude that the Lebanese authorities are continuously violating the rights of Syrian refugees by restricting their movement and displacing them from their homes in violent and discriminatory practices that limit their ability to work, go to school, and live their lives normally. We condemn these circulars, which have led to an unprecedented escalation of violence targeting Syrian refugees in Lebanon. Additionally, they expose Syrian refugees to arbitrary arrests, torture, and deportation, while cases have been documented – which we will review at the end of the text – where some of these circulars have been implemented, resulting in forced evictions in explicit violation of Lebanese laws.

On Securitization

All the issued circulars emphasize the need to continue the surveying process and complete the database required by General Security, as well as to follow the Ministry of Interior’s directive mandating that every Syrian within the municipal area must obtain legal residency. They also prohibit non-Lebanese individuals from residing, working, or driving in the town without a valid residency and work permit. It is worth noting that the circular issued by the Minister of Interior and Municipalities, Judge Bassam Mawlawi, on May 2, 2023, to governors, district commissioners, municipalities, and mukhtars, called on the concerned parties to register all refugees residing within each town’s jurisdiction and to issue certificates accordingly. The circular also required that no transaction or certificate be processed without verifying the individual’s registration with the municipality and possession of legal residency in Lebanon. Additionally, a field survey of all businesses and freelancers managed by Syrian refugees was to be conducted to ensure they held legal licenses.

However, the ministry’s decision does not provide any guidelines or safeguards to ensure that the aforementioned local authorities refrain from engaging in discriminatory practices or implementing measures that could lead to human rights violations, such as further displacement and eviction of Syrian refugees.

Moreover, recent municipal circulars go far beyond these requirements. For example, the municipality of Anfeh announced in its circular the opening of volunteer opportunities for the town’s youth to support the police and municipal guards due to the enthusiasm some showed for protecting the town and its residents under the current circumstances. Similarly, the municipality of Jbeil asked citizens to report violations via a hotline and requested that individuals and commercial establishments cooperate with the municipality by providing information or observations that could help achieve security and stability. The municipality of Rashdebine also requested town residents to cooperate and report the presence of refugees residing illegally. Meanwhile, the circular from the municipality of Jounieh threatened to raid suspicious places with security agencies and advised citizens not to expose themselves to danger, urging them to contact municipal police to report any suspicious activity.

These “requests” constitute security-tightening tools aimed at turning citizens into informants for the police state, inciting them against each other as part of the Lebanese state’s systematic discriminatory campaign. This initiative transforms the relationship between citizens and the state into an intelligence-based relationship, where citizens are compelled to show obedience by spying on their neighbors, family, and friends. It also directs social relationships in a harmful and toxic direction, turning them into relationships of surveillance and reporting, thereby creating an atmosphere of distrust and suspicion amongst people.

On Movement and Public Space

In line with previous trends of imposing illegal restrictions on the movement and mobility of Syrian refugees, the majority of these circulars contain violations of the right to freedom of movement and presence in public spaces. Some municipalities justify these measures by citing the need to enforce traffic laws, such as seizing illegal vehicles and confiscating unregistered vehicles or those driven by individuals without proper residency. However, it is very clear how this pretext has become an additional tool in the state’s incitement campaign to deprive Syrian refugees of their rights, alongside policies and practices aimed at pressuring them to return to their homeland.

In this context, on September 22, 2023, the governor of Beirut announced that he had tasked the Beirut Municipal Guard Brigade with controlling the use of motorcycles in the capital, arguing that “many gangs use motorcycles at night for theft and drug trafficking (…), and what shocks us is that 90% of the motorcycle owners are non-Lebanese.” Similarly, on October 5, 2023, the Minister of Interior directed the Internal Security Forces to “launch a campaign to crack down on illegal motorcycles, particularly within the Greater Beirut area extending from the Damour River to the Nahr al-Kalb River, and to stop motorcycles driven by Syrians without Lebanese residency,” after it was found that “the use of motorcycles had increased and they were being driven by Syrians, some of whom exploit this to commit theft, shootings, or drug trafficking.”

Additionally, some local authorities (through six circulars) announced curfews: the municipality of Jbeil banned the movement of foreign workers in Jbeil in the evenings; the Union of Municipalities of Bsharri prohibited Syrians from being in public places from 6 PM to 5 AM; the municipality of Kfarhazir banned the movement of Syrians from 8 PM to 6 AM; the municipality of Lihfed prohibited the movement of refugees from 6 PM to 6 AM; the municipality of Rashdebine also banned their movement from 7 PM to 6 AM; and the Union of Municipalities of Jurd al-Aala Baakline prohibited the movement of motorcycles (even legal ones) after 8 PM.

The municipality of Kfar Hazir goes even further by banning gatherings of refugees, monitoring their movements, and reporting any suspicious activity to security agencies. Meanwhile, the municipality of Baabdat prohibits Syrian refugees from gathering on roads and between buildings, especially after 8 PM.

These discriminatory, illegal, and violating practices by local authorities remind us of the media portrayal of children swimming in a pool in central Beirut as something unusual. The organized media campaign to promote racism and hatred against Syrian refugees frames their mere presence in public spaces as a threat. Lebanese local media have directly contributed to portraying the social and economic rights of Syrian refugees, particularly their right to be in public spaces, as diminishing the rights of Lebanese citizens. Consequently, imposing such restrictions on movement and presence in public spaces and depicting it as normal is a justification for the deteriorating economic, security, and social situation in the country. It legitimizes the deprivation of a specific group of its fundamental rights. Thus, the state appears to be replicating militia practices, punishing a particular group in its quest to secure a lucrative deal or further aid from the European Union.

On Housing

In the housing sector, most circulars align with the directive issued by the Minister of Interior on May 2nd, 2023, which emphasized prohibiting the rental of property to any Syrian individual before they are registered with the municipality and their legal documents, especially a valid residency, are verified. These circulars include the following details:

  • Mandating landlords to register rental contracts.
  • Requiring municipalities to be provided with the tenants’ legal documents.
  • Informing the municipality of any new rental agreements, otherwise holding landlords accountable for the tenants’ actions.
  • Reminding landlords of strict measures and penalties against those who rent to individuals without legal documents.
  • Requiring the registration of rental contracts with the municipality along with the provision of the non-Lebanese tenant’s documents, under threat of reassessment of property units and issuing cost schedules in the landlord’s name, including retroactive fees for previous years.
  • Prompt and direct notification of landlords about every Syrian family residing or intending to reside on their property and reporting unregistered rentals, under the threat of bearing the responsibility for not declaring such information.

Up to this point, municipalities are operating within the guidelines of the Minister of Interior’s directive, although there are reservations regarding the problematic nature of this directive, which fails to provide any guidelines or safeguards to ensure that local authorities refrain from engaging in discriminatory practices or implementing measures that could lead to human rights violations. However, the daily practices of security forces and municipalities demonstrate that such violations are inherent in their dealings with refugees.

Additional issues arise regarding the request of many municipalities for all Syrians residing within their jurisdiction, who do not possess these permits and legal documents for legal residence, to leave within specific deadlines: 10 days in the case of Jbeil Municipality; 15 days in the Union of Municipalities of Bsharri; until the end of April in the case of Fatri Municipality; 15 days in Rashdebine Municipality; 15 days in the decision of the Governor of the North; immediate eviction in the case of Jounieh Municipality. On the one hand, the threat of eviction constitutes an overreach of municipal authority, which is limited to requesting eviction first if it is found that the building or part of it is at risk of collapse (after a series of procedures involving the appointment of an expert engineer to inspect the building and issue a report, among others). The other situation in which local authorities may initiate eviction proceedings without a court order is if there is what is referred to legally as “exceptional circumstances,” during which the government acquires, for necessary purposes, powers that usually fall outside its legal jurisdiction. However, with reference to the decision of the State Council issued on February 8, 2018, which annulled the directives of the General Security Directorate for the year 2015, considering that “the crisis of Syrian refugees in Lebanon does not meet the legal conditions that can be described as ‘exceptional circumstances’,” public authorities, and by extension, local authorities, cannot invoke the exceptional nature of the refugee crisis and bypass the jurisdiction of the judicial authority to request eviction without a court order.

On the other hand, the eviction deadlines given constitute a violation of residents’ rights as they are insufficient to realistically allow them to secure alternative housing arrangements before the scheduled eviction date. International law emphasizes that eviction operations should not result in the displacement of individuals or expose them to violations of other human rights. The state is responsible for taking all appropriate measures, to the maximum extent of its available resources, to ensure the provision of suitable alternative housing, if the affected individuals are unable to meet their needs themselves.

Furthermore, these directives do not mention any mechanisms for objection or appeal against eviction decisions, which contradicts international law that requires states to provide fair judicial remedies and legal assistance to affected parties when making eviction decisions, and to compensate them when necessary.

Threatening to send in security forces to raid violators and force them to evacuate residential buildings, or instructing municipal police to assist security forces in raiding violators to evacuate buildings, is another indication of the arbitrary nature of these evictions, which rely on intimidation through the use of violence and coercion for evacuation, in violation of both international law and local criminal law. In the case of Nahr Ibrahim Municipality, for example, the directive warns owners of residential and commercial buildings who rent to Syrians or foreigners who do not meet residence requirements to deport them immediately. This is also an illegal practice, as mentioned earlier, as landlords are not entitled to immediate eviction of tenants without a judicial order regardless of the circumstances.

On Labor

In the workplace, most directives involve conducting surveys of Syrians in each town to ensure that workers possess valid work permits, and to prohibit citizens from sponsoring any foreign worker without a valid residency, under penalty of deportation. Additionally, there are efforts to crackdown on violations in commercial establishments operated by Syrians without proper legal permits, with the issuance of fines and closure notices if they do not comply. Some directives use terms that reflect how our society views workers as commodities rather than individuals with rights. Some directives require citizens not to “use” any foreign worker who does not possess the necessary employment conditions and documents. Others specify that anyone “employing foreign workers” must verify their legal permits, and in case of non-compliance, report to the municipality within 48 hours for legal action against the violators.

The directives issued by municipalities raise constitutional concerns, as they grant local authorities powers that they do not possess, and they restrict the movement and work of individuals within their jurisdiction for unconstitutional reasons. This turns villages and cities into legally autonomous administrations capable of issuing their own decisions independently of labor laws and the constitution.

For example, the Federation of Municipalities of Jurd El Aakoura in Bhamdoun ordered the closure of all illegal establishments and commercial stores operated by foreigners until their legal status is settled. They also forbade employers to have all their employees or workers be foreigners. Similarly, the Federation of Municipalities of Bsharri imposed a 15-day deadline on foreign workers to settle their status or vacate, while prohibiting Syrians from investing in any institution or commercial store, and preventing them from engaging in any profession that violates the Ministry of Labor’s decisions. Additionally, they enforce strict adherence to the daily wage set by the federation, which is $10 per day for workers.

Similarly, the municipality of Fatri in the district of Jbeil prohibits citizens from employing any agricultural or other worker in a workshop, who is not a resident of the town, or else they will be treated as illegal persons. This decision creates artificial boundaries between areas and villages, as if they were separate countries or federations.

Furthermore, the executive directives issued by the municipality of Al Okaibeh prohibit any non-Lebanese person from practicing any profession or freelance work reserved for the Lebanese workforce, which is again unconstitutional due to the lack of clarity on how to determine jobs that are reserved for the Lebanese workforce.

The danger of implementing these decrees: Forced evictions as an example

During the time between April 24th to 28th, the Housing Monitor received a number of calls from the Jounieh area, including five Syrian families living in Lebanon for the past several years, including 17 children aged between 10 days and 12 years. The callers reported that the municipality was targeting them by sending vague eviction notices, citing “residency without legal papers.” They also reported that the Jounieh municipality was evicting a large group of residents in the St. Elie complex, which consists of 4 buildings, one of which is closed under order of condemnation, another is unfinished, and two buildings each containing 70 apartments. The complaints came from a building with 26 rented housing units, housing between 50 to 70 families and young people living alone, all under threat of eviction, during the deadline announced by the municipality, which issued written eviction notices within 24 hours. The police showed up and executed the notices on time. One family, for example, was forced to stay with the wife’s brother, then moved to stay with the husband’s brother near the project, and the two families (11 people) still share one room.

After contacting a municipality member, we learned that the legal documents that the municipality claimed were unavailable and were the reason for the eviction, were: a registered lease contract at the municipality, a valid work permit, a sponsor residing in the same municipality where the Syrian resident works, a registration number with the UN High Commissioner for Refugees, and a valid residency permit. This argument aligns with the general directive of Jounieh municipality and other directives that mandate illegal practices as mentioned. Neither the police nor the municipality has the right under any circumstances to carry out an eviction without a judicial order, according to Lebanese laws.

These directives legalize unconstitutional, illegal, and illegitimate actions, encroaching on the basic rights of refugees to movement, presence in public space, housing, and work, inciting the Lebanese society against them, creating fake and illegal boundaries between regions, villages, and cities, and imposing evictions based on people’s nationality without giving reasonable notice to find alternative housing. These directives also contribute to creating a more exploitative and oppressive reality for refugees, placing them in a state of dire poverty, hopelessness, and lack of support. It is essential to note that the way in which the authorities, both central and local, deal with refugees reflects how society treats the most vulnerable individuals, and is based on the logic that the more powerful are the more rightful, and that the state is willing to violate the constitution to plunder the rights of the disadvantaged.

Housing Land Management and Planning Aley District El Koura District Jbeil District Keserwan District Keserwan-Jbeil Governorate Lebanon Mount Lebanon Governorate North Lebanon Governorate