A/HRC/39/65 of informal housing, and corruption in government systems. The massive scale of destruction, displacement and death wrought by seven years of conflict has created more hurdles for individuals seeking to protect their rights, in particular for refugees, internally displaced persons and female-headed households. Displaced persons are particularly affected owing to their limited access to basic information and greater vulnerability. Governments have not only the right but also the obligation to develop a framework for reconstruction and development, and the protection of property rights. In this context, and since at least 2013, the domestic Syrian legal framework has been undergoing significant changes concerning property rights. 91. During the period under review, much attention was paid to Presidential Decree (or “Law”) No. 10, which expands and modifies Presidential Decree No. 66/2012. The Commission has regularly drawn attention to the promulgation of laws and decrees that may appear to be legitimate attempts to reform land laws and accelerate reconstruction but do not take into account the situation of displaced persons. Law No. 10, for example, does not appear to take into account the issue of missing persons, female-headed households, good faith transactions undertaken in areas outside of government control, barriers to protecting property rights remotely or the lack of civil documentation of a large proportion of those displaced.28 In addition, the Commission’s review of existing legislation indicates that Presidential Decree No. 19/2012 on counter-terrorism allows for persons convicted of a wide range of offences to have their property confiscated by the State. Investigations into these legal developments are ongoing. VI. Ongoing investigations 92. Throughout 7 April, numerous aerial attacks were carried out in Douma, striking various residential areas. A vast body of evidence collected by the Commission suggests that, at approximately 7.30 p.m., a gas cylinder containing a chlorine payload delivered by helicopter struck a multi-storey residential apartment building located approximately 100 metres south-west of Shohada square. The Commission received information on the death of at least 49 individuals, and the wounding of up to 650 others. 93. While the Commission cannot make yet any conclusions concerning the exact causes of death, in particular on whether another agent was used in addition to chlorine that may have caused or contributed to deaths and injuries, it recalls that the weaponization of chlorine is prohibited under customary international humanitarian law and under the Convention on the Prohibition of the Development, Production, Stockpiling and Use of Chemical Weapons and on Their Destruction, ratified by the Syrian Arab Republic in 2013. 94. After the fall of ISIL in Raqqah and Dayr al-Zawr governorates in October and December 2017 respectively, a number of issues continue to prevent the feasibility of civilian return. Such issues include the large-scale destruction of civilian homes and infrastructure, including hospitals, schools and other protected objects, and electricity and water lines, lack of reconstruction, unexploded ordnance contamination left by the coalition led by the United States of America and affiliated SDF in Raqqah (see para. 65 above), and the lack of clearance of mines, booby traps and improvised explosive devices left by ISIL as part of its withdrawal strategy from both governorates. The absence of basic services poses significant obstacles; the Commission has for example received information according to which some civilians in Dayr al-Zawr drink unpotable water directly from the Euphrates River. It has also received allegations of arbitrary arrest by SDF forces manning checkpoints in both Raqqah and parts of Dayr al-Zawr. Protection concerns, ongoing unlawful internment of internally displaced civilians by the SDF in the north of the Syrian Arab Republic (A/HRC/37/72, annex III, paras. 1–18), and lack of access to telephone and Internet lines continue to curtail access to victims and witnesses. 28 In particular, many Syrian lawyers consulted by the Commission point to the requirement to have the powers of attorney cleared by the intelligence branches before they can be recognized. 17

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