In October of 2022, the United Nations-appointed Commission of Inquiry released a report. In summary, the report found that "Israel’s occupation of Palestinian territory is unlawful under international law due to its permanence and the Israeli government’s de facto annexation policies," and requested that the issue be referred to the ICJ.

Commissioner Chris Sidoti interpreted their findings. He said, “The actions of Israeli Governments reviewed in our report, constitute an illegal occupation and annexation regime that must be addressed."

Sidoti added, “The international system and individual States must act and uphold their obligations under international law. That must begin at this session of the General Assembly with a referral to the International Court of Justice.”