2025 UNHRC Commission of Inquiry Report on Gaza Genocide

The Independent International Commission of Inquiry on the Occupied Palestinian Territory, including East Jerusalem, and Israel was established in 2021 to investigate crimes by all parties.[1] Created by the United Nations Human Rights Council to investigate alleged violations of international law, it subsequently examined the actions of Israeli authorities and security forces during the Gaza war.[3] By the September 2025 publication, that investigation had lasted almost two years.[1]

The commission had three members: Navi Pillay, Miloon Kothari, and Chris Sidoti.[4] In July 2025, their resignations were reported, with departures scheduled to take effect on different dates later that year.[4] Pillay served as chair when the September report was presented and publicly explained its conclusions about responsibility at the highest levels of Israeli authority.[2]

The investigation concerned conduct during the Israel–Hamas War, which followed the Hamas-led terrorist attack of October 7, 2023.[3][5] Its eventual legal analysis addressed the actions of Israeli civilian and military authorities, the conduct of Israeli security forces, and the relationship between official statements and military operations.[1] Israel did not cooperate with the commission’s work, and its diplomatic mission in Geneva accused the inquiry of pursuing a political agenda against Israel.[2]

A separate commission document preceded the September conference-room paper: a 22-page report, designated A/80/337, transmitted by the UN Secretary-General on August 14, 2025, pursuant to Human Rights Council resolution S-30/1.[6] That document examined land and housing in the Occupied Palestinian Territory and Israel and included a summary of the commission’s findings concerning the crime of genocide.[6] It was a related report rather than the 72-page legal analysis issued on September 16.[6][7]

The institutional setting distinguished the inquiry from a court proceeding: the commission operated independently, and its report did not officially represent the position of the United Nations as a whole.[2] Publication did not itself impose legally binding requirements on Israel or on the conduct of the war.[2] The paper also did not examine individual criminal responsibility under the Rome Statute.[1]

On September 16, 2025, the commission issued a 72-page conference-room paper titled Legal analysis of the conduct of Israel in Gaza pursuant to the Convention on the Prevention and Punishment of the Crime of Genocide.[7] Submitted to the Human Rights Council, the paper bore the document symbol A/HRC/60/CRP.3.[7] Its central conclusion was that Israeli authorities and security forces had committed, and were continuing to commit, genocide against Palestinians in Gaza.[1]

The commission framed its finding in terms of reasonable grounds to conclude that four of the five acts of genocide identified in the 1948 Genocide Convention had occurred.[1] The four acts were killing members of the group; causing serious bodily or mental harm to members of the group; deliberately inflicting conditions of life calculated to bring about the group’s physical destruction, in whole or in part; and imposing measures intended to prevent births within the group.[1] Its analysis therefore addressed several categories of conduct rather than resting its conclusion on killings alone.[1]

The legal reasoning examined both the underlying prohibited acts, described as actus reus, and the specific intent required for genocide, described as dolus specialis.[1] The commission treated official statements and the conduct of Israeli forces as evidence bearing on intent, alongside the acts it considered to fall within the Convention’s categories.[1][3] Its conclusion concerned the alleged intention to destroy Palestinians in Gaza as a group, in whole or in part.[1]

The evidentiary material described in coverage of the report included interviews with witnesses, doctors, and victims, together with analysis of satellite imagery.[2] The commission also considered the scale of deaths and injuries, restrictions on humanitarian assistance, displacement, and the destruction of fertility clinics.[2] These elements formed part of its account of both physical harm and conditions affecting the survival of Palestinians in Gaza.[2]

The report attributed severe killing and injury to Israel and described a total siege, including the blocking of humanitarian aid, as having led to famine.[2] It also alleged systematic destruction of Gaza’s health and education systems.[2] Aid restrictions, displacement, and the destruction of civilian infrastructure thus appeared within its broader assessment of conditions of life, rather than solely within its discussion of deaths directly caused by military operations.[1][2]

Other conduct identified in the report included systematic sexual and gender-based violence, direct attacks on children, and widespread and systematic attacks on religious and cultural sites.[2] The commission also cited failure to comply with International Court of Justice orders.[2] Its discussion of measures intended to prevent births included the destruction of fertility facilities, which featured among the examples of conduct used to support the overall legal analysis.[2][8]

For the intent element, the commission relied on statements by Israeli civilian and military authorities that it characterized as dehumanizing or as calling for vengeance, destruction, and annihilation.[1] It interpreted those statements as evidence of an intention to destroy Palestinians in Gaza, in whole or in part.[1] Statements by Prime Minister Benjamin Netanyahu were among those treated as direct evidence of intent.[2]

The commission’s argument combined its reading of official language with its assessment of military conduct.[1][3] The distinction mattered to the structure of its findings: the report separately considered whether prohibited acts had occurred and whether the evidence supported the specific genocidal intent required by the Convention.[1] It did not present the scale of destruction alone as the entirety of its reasoning; statements by senior officials were central to the reported analysis of intent.[1][2]

Pillay said responsibility for the alleged crimes rested with Israeli authorities “at the highest levels.”[2] She described the campaign as having continued for almost two years with the specific intent to destroy Palestinians as a group in Gaza.[2] In explaining the commission’s conclusions, she drew a comparison with Rwanda and said that dehumanization of victims helped enable “merciless killing.”[2]

The report named President Isaac Herzog, Netanyahu, and then-Defense Minister Yoav Gallant as individuals whom the commission said had incited genocide.[1] It further concluded that Israeli authorities had failed to take action to punish them.[7] These conclusions about incitement accompanied the report’s wider findings about the conduct of Israeli authorities and security forces.[1]

The commission also concluded that Israel had failed to prevent and punish genocide.[1] Its reasoning included alleged failures to investigate genocidal acts and prosecute alleged perpetrators.[1] The paper did not, however, examine individual criminal responsibility under the Rome Statute.[1] Its identification of officials in connection with incitement therefore formed part of a commission inquiry rather than an adjudication of individual criminal liability under that statute.[1]

The recommendations directed at Israel included ending the conduct the commission identified as genocide and complying with the International Court of Justice’s provisional-measures orders of January 26, March 28, and May 24, 2024.[1] The commission also called for restored UN access and aid to Gaza, investigation and punishment of genocide and incitement, and an end to the policy it described in relation to starvation.[1]

The report addressed recommendations to other states as well as to Israel.[1] It urged UN member states to use reasonably available means to prevent genocide, stop arms transfers and other assistance, and investigate or prosecute individuals and companies within their jurisdictions accused of assisting genocide or incitement.[1] Its proposed response thus extended beyond Israeli authorities to the conduct of governments, individuals, and businesses outside Israel.[1]

These recommendations were calls for action by the commission, not measures it could itself enforce.[9] The paper did not examine individual criminal responsibility under the Rome Statute.[1] Publication likewise did not automatically create legally binding requirements governing Israel’s military operations.[2]

Israel rejected the report on its publication, with Foreign Minister Gideon Sa’ar calling it “distorted and false” and alleging that it relied on Hamas falsehoods.[1] The Foreign Ministry also described the commissioners as antisemitic “Hamas proxies.”[3] Ambassador Daniel Meron accused the commission of political bias, while other reported Israeli responses characterized the findings as “scandalous” and “fake.”[8]

The Foreign Ministry’s response connected its rejection of the commission’s conclusions to the October 7 attack, saying that Hamas had attempted genocide in Israel that day.[3] It also cited a study by Bar-Ilan University’s Begin-Sadat Center for Strategic Studies that it said refuted the genocide allegations.[3] The ministry called for the commission to be dissolved.[3] These statements formed part of Israel’s response to the inquiry, rather than an alternative judicial determination of the allegations.[3]

The Israeli diplomatic mission in Geneva similarly accused the commission of advancing a political agenda against Israel.[2] This response followed Israel’s refusal to cooperate with the inquiry.[2] The public rejection addressed both the substance of the genocide accusation and the commissioners’ conduct and credibility.[1][3]

The World Jewish Congress issued a response on September 16 questioning the inquiry’s impartiality.[10] It described the commission’s conclusions as reflecting “one-sided narratives rather than objective investigation.”[10] The organization also highlighted that publication coincided with the commissioners’ resignations and argued that the timing reinforced its concerns about impartiality.[10] The departures had previously been reported as taking effect on different dates later in 2025.[4]

The accusation also met rejection from the United States government.[5] Both the Israeli and US governments vehemently denied the characterization of Israel’s conduct as genocide.[5] At the same time, the commission’s findings entered congressional debate through statements and a later introduced resolution.[11][12]

On September 18, 2025, Representative Rashida Tlaib discussed the report in a speech in the US House of Representatives.[11] She said the commission had concluded that the Israeli government was committing genocide in Gaza and entered a link to the report in the Congressional Record.[11] Her speech described the commission as calling on countries to take immediate concrete action to prevent and punish genocide, including ending weapons transfers and pursuing accountability.[11]

Tlaib summarized that recommendation by saying, “It calls on all countries to take immediate concrete actions to prevent and punish genocide.”[11] The statement was her description of the report’s recommendations in a House speech, rather than a quotation established here as wording taken directly from the commission paper.[11] The actions she identified corresponded to the broader recommendations for external states reported at the time of publication.[1][11]

A later congressional measure, H.Res. 876, was introduced in the House on November 13, 2025.[12] Its recitals stated that the commission had concluded on September 16 that Israel had committed and was continuing to commit genocide against Palestinians in Gaza.[12] The measure’s status was that of an introduced resolution; its recitals were not an adopted finding of the House.[12]

Those recitals listed the same four categories of acts: killing members of the group, causing serious bodily or mental harm, deliberately inflicting destructive conditions of life, and imposing measures intended to prevent births.[12] They presented these as acts within the scope of the Genocide Convention and described statements by Israeli officials as evidence of genocidal intent.[12] The wording belonged to the introduced resolution’s account of the commission’s findings, not to a separately issued UN report or a verbatim extract established from the September paper.[12]

The report’s institutional limits remained relevant to these political responses: the commission was not a legal body speaking for the UN as a whole.[9] Its reports could nevertheless contribute to diplomatic pressure and gather evidence for possible later use by courts.[9] The immediate consequences described in the available material were recommendations and government responses, rather than penalties imposed by the inquiry.[1][9] The report also prompted public criticism and congressional discussion.[11][12]

The principal dispute surrounding the report concerned its genocide conclusion, particularly the relationship between alleged prohibited acts and the interpretation of Israeli officials’ statements as proof of intent.[1][13] Israel rejected both the findings and the commission’s impartiality, while critics challenged the treatment of evidence and the report’s account of the war’s context.[1][13] The inquiry’s conclusions remained distinct from an adjudication of individual criminal responsibility, which the paper did not examine under the Rome Statute.[1]

UN Watch argued that the commission selectively interpreted statements by Israeli leaders, relied on unverified casualty figures and media reports, and gave insufficient attention to Hamas’s role and military activity.[13] It also disputed the commission’s interpretation of statements by Herzog, Netanyahu, and Gallant in support of its incitement findings.[7] These were criticisms advanced in a rebuttal, not independently established findings about the report’s evidentiary reliability.[13]

A separate criticism concerned the report’s treatment of the Hamas-led terrorist attack of October 7, 2023.[13] UN Watch argued that the paper omitted essential details of the attack, the hostage crisis, and Hamas’s role as an active belligerent, while opening its account of the war with Israel’s military offensive.[13] This was part of UN Watch’s broader criticism of the paper’s scope and contextual framing.[13]

An opinion article in Globes questioned the English translation and context used for an October 7 statement by Netanyahu referring to the “wicked city.”[14] Its writer argued that interpretation of official statements was central to the report’s case, while acknowledging that Israeli officials had made calls for destruction or displacement.[14] The article’s objections concerned how rhetoric was used to establish genocidal intent, rather than disputing that such rhetoric featured prominently in the commission’s reasoning.[14]

The report’s documentary legacy also requires distinguishing between the September conference-room paper and the related August report.[6][7] It also requires separating both from subsequent congressional references.[12] A/HRC/60/CRP.3 was the 72-page legal analysis issued on September 16; A/80/337 was a separate 22-page report transmitted on August 14.[6][7] The later House resolution recorded the commission’s conclusions in its own recitals and did not constitute either a new commission report or an adopted House determination.[12]