enemy of human rights' as UN Watch claimed." Phyllis Bennis, a signer of the letter, wrote that HRW stated in a reply on January 1, 2013 that the UN Watch letter was filled with "inaccuracies and falsehoods" and that Falk was asked to resign from HRW to comply with long-standing HRW policy. Appointments at United Nations United Nations Human Rights Inquiry Commission for the Palestinian territories In 2001, Falk served on a United Nations High Commissioner for Human Rights (OHCHR) Inquiry Commission for the Palestinian territories with John Dugard, a South African based in Leiden University in the Netherlands, and Kamal Hussein, former foreign minister of Bangladesh. Falk stated the two main issues: "One is evaluating whether the conditions of occupation are such as to give the Palestinians some kind of right of resistance. And if they have that right, then what are the limits to that right?" "The other issue at stake in this current inquiry is to evaluate how Israel as the occupying power is carrying out its responsibility to protect the society that is subject to its control." After its investigation the commission issued a report, "Question of the violation of human rights in the occupied Arab territories, including Palestine." Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967 On March 26, 2008, the United Nations Human Rights Council (UNHRC) appointed Falk to a six-year term as a United Nations Special Rapporteur on the situation of human rights in the Palestinian territories occupied since 1967. Falk replaced South African international law professor John Dugard, who left his post in June 2008 after seven years. Falk's appointment expired in May 2014. Response to appointment The appointment of Falk was made by a consensual decision by the 47 members of the UN's Human Rights Council. Although Jewish groups tried to persuade the European Union and Canada to oppose Falk's appointment, the EU did not intervene, and Canada did not oppose although it distanced itself via a statement. According to a UN press release, Israel's Ambassador to the United Nations Itzhak Levanon strongly criticized the appointment stating that Falk had written in an article that it was not "an irresponsible overstatement to associate the treatment of Palestinians with the criminalized Nazi record of collective atrocity" and argued that "someone who had publicly and repeatedly stated such views could not possibly be considered independent, impartial