Israel’s Military Justice Law (MJL), 4715-1955, as amended, established a system for the adjudication of IDF active service soldiers, reservists, and military contractors accused of having committed military or criminal offenses while in service. The MJL provides for adjudication by military courts or alternatively through disciplinary proceedings depending on the gravity of the offense and the rank of the accused. Although the MJL has been amended numerous times, there have not been any significant statutory changes to the IDF adjudication system since the MJL’s entry into effect in 1955. Reform of the IDF’s adjudication in disciplinary proceedings, and especially in cases involving sexual offenses, has instead evolved through changes in military policies in response to new challenges posed with the passage of time and requirements imposed by Israel’s Supreme Court. Some important changes to the adjudication system include the removal of the determination of adjudication from the chain of command in some cases and new requirements for legal training or IDF-specific training in dealing with sexual harassment offenses.
This report provides a general overview of the law and policies governing military justice adjudication in Israel and particularly the evolution of adjudication of sexual offenses.
II. Reform of the Military Justice System
Several changes have taken place in recent years that impacted the adjudication of sexual offenses within the IDF. These include the way in which the determination of whether to pursue an adjudication is made and the forum for such a determination. Unlike the adjudication of other violations of military law, the decision of whether to adjudicate sexual offenses in disciplinary proceedings can only be made by the MAG’s attorneys and not by commanders.
An additional development in adjudication of “lighter” sexual offenses in disciplinary proceedings is the requirement that presiding adjudication officers (AOs) be at least at the rank of Lieutenant Colonel and have either a legal education or special training in handling sexual harassment cases at the IDF School of Military Justice. Israel’s Military Advocate General (MAG) maintains a database of AOs who are qualified to adjudicate sexual harassment cases. The selection of the AO for such disciplinary proceedings from the database is made by the MAG and not by a commander.
Additional changes occurred based on the Supreme Court’s judicial review and the requirements established by the Court to follow rules that exist in criminal litigation. Whereas decisions of the Appeals Court Martial (ACM) may be subjected to review by the Israeli Supreme Court upon special authorization only when there arises “[a] legal question [that presents an] important, difficult or novel [legal issue],” the MJL does not expressly provide for Supreme Court review of commanders’ decisions in disciplinary proceedings. However, the Supreme Court has extended its jurisdiction to disciplinary decisions based on general principles of due process. In a case involving IDF disciplinary adjudication, the Court voided a commander’s decision to convict and sentence a soldier based on procedural defects found in the disciplinary adjudication—defects that, according to the Court, deprived the soldier of his right to due process.
The IDF has faced new challenges as a result of an increased focus on holding disciplinary adjudications to the same requirements that apply to criminal adjudications. A private member bill by Knesset Member (KM) Miri Regev to reform the MJL and meet these challenges is now pending. The bill proposes to establish a third mechanism for military adjudication by establishing military disciplinary courts in addition to the existing military courts and disciplinary proceedings. The bill proposes that offenses under the Law for the Prevention of Sexual Harassment, 5758-1998, be adjudicated by the proposed military disciplinary courts.
III. Military Justice System: Current Structure and Adjudication Authorities
A. General Overview
The MJL established two mechanisms for the adjudication of cases involving soldiers suspected of committing offenses during their military service: adjudication by military courts, and disciplinary adjudication by AOs and commanders.
Military courts serve as courts of criminal adjudication and are authorized to impose penalties of long-term imprisonment and even death, as well as rank demotion. Military courts conduct their hearings in accordance with Israeli criminal law and comply with criminal procedure requirements and general rules of evidence.
The second mechanism established by the MJL is disciplinary adjudication. This type of adjudication is primarily intended to provide commanders in the field with an effective tool for disciplining their subordinates. Disciplinary adjudication differs from criminal adjudication. Unlike criminal proceedings, soldiers are not entitled to legal representation in disciplinary proceedings. In addition, decisions in disciplinary proceedings are made by commanders who usually do not have a legal education. Moreover, the levels of sentencing that can be imposed by commanders in disciplinary proceedings are limited compared to those available to military judges.
B. Adjudication by Military Courts
The decision as to whether to adjudicate a matter by military court is made by the MAG. The MAG is appointed by the Minister of Defense and therefore is not subordinate to the General Staff Commander.
Based on the MJL,
[m]ilitary courts are authorized to hear all cases that involve IDF service members, in the regular and reserve services. Indictments relating to all offences against the laws of the State of Israel, including general jurisdiction relating to offenses committed anywhere in the world in times of war and peace. In the case of non-military offenses, parallel jurisdiction exists between the civilian and military court systems.
Under such circumstances, the forum of trial rests in the discretion of the Military Advocate General, and is determined according to the degree of correlation between the offense and military service. In certain cases, military courts also hold jurisdiction over civilians employed specifically by the military under contract; those who have received weapons from the army under certain conditions and restrictions; and those belonging to the reserve forces.
There are five courts of first instance: a District Court Martial, a Naval Court Martial, a Special Court Martial, a Field Court Martial, and a Traffic Court Martial. The MJL also established an Appeal Court Martial, which hears appeals from all of the first-instance courts.
According to information posted on the IDF website,
Military Courts of first instance are generally comprised of three judge panels. The head of the panel is a professional judge, with a legal education and judicial experience. The judge belongs to the military courts unit and is appointed by the president of the State of Israel, in a process that is similar to the appointment of judges in the State’s civilian legal sector.
The two other members of the panel generally do not have a legal background and are officers who serve in the units belonging to the court’s regional district. Court decisions are passed by a majority and are subject to appeal.
Hearings held in the Military Court of Appeals are generally presided over by a three judge panel, with at least two of the judges having a legal background. Most judges at the Military Court of Appeals have a great deal of judicial experience acquired while previously sitting in a military court of first instance.
According to the MJL, “[i]n judicial matters, a military judge is not subject to any authority save that of the law, and is not subject in any way to the authority of his commanders.”
C. Disciplinary Adjudication
Except for cases involving sexual offenses, the determination of whether to adjudicate a matter in disciplinary proceedings is generally made by commanders and not by the military prosecutor.
1. Type of Offenses That May Be Adjudicated in Disciplinary Proceedings
According to the MJL, “where a soldier below the rank of Lieutenant General is charged with a military offense the penalty for which does not exceed three years’ imprisonment, and which was perpetrated either in Israel or outside of it, a disciplinary officer shall have power to try him disciplinarily.”
Among offenses that are considered “a military offense” for the purpose of disciplinary adjudication are offenses under the Law for the Prevention of Sexual Harassment, 5758-1998. Unlike offenses such as rape or battery, which are adjudicated by military courts outside of the chain of command, other “lighter” offenses under the Law, such as treating a person in an offensive way because of her or his gender or sexual orientation, are usually handled in special disciplinary proceedings.
Some military offenses that are usually adjudicated in summary disciplinary proceedings include offenses against IDF discipline, noncompliance with military uniform requirements, violations of requirements for the proper handling of weapons, and certain traffic violations.
2. AO’s Qualifications and Authorities
Unless otherwise authorized by the General Staff Commander, disciplinary adjudication is conducted by an AO of the same unit in which the defendant serves. In addition to adjudicating complaints, AOs are also authorized to cancel and transfer complaints to military courts for adjudication as long as no verdict has been rendered.
While AOs are not required to have a legal education, they must successfully complete IDF military justice training. The authority of an AO to adjudicate defendants of various military ranks depends on his or her own military ranking. AOs who are unit commanders are authorized to adjudicate any soldier who serves in their unit. Furthermore, AOs who were designated by the unit commander, subject to conditions established by that commander, may adjudicate soldiers serving in their unit even if these soldiers are not subordinate to them in the chain of command.
The MJL recognizes the right of a soldier to request disciplinary adjudication by a higher-ranking AO or by a military court. A transfer of adjudication to the latter may, however, be redirected by the Military Advocate General upon his/her discretion.
3. Handling of Complaints
A complaints against a suspected offender may be filed by his or her own commander, as well as by AOs and by tenured, non-officer personnel with a higher military rank than the suspected offender, subject to conditions enumerated in the General Staff Order (GSO) 33.0302.
Accordingly, a commander may file a complaint if “he knows or has a reasonable basis to assume that one of his subordinates committed an offense.” The commander may also file a complaint based on a report issued by the military police documenting reasonable suspicion that the unit’s soldier committed an offense, where that report is transferred to him or her by the unit’s adjutant. AOs and tenured non-officer personnel are similarly authorized to file complaints. A complaint filed against a soldier must be recorded in a digital system designated for this purpose by the IDF.
Disciplinary adjudication is conducted by AOs subject to compliance with the following conditions:
- The AO rank is at least one rank higher than that of the defendant;
- The AO is the commander of the defendant or the commander of the unit that authorized him or her to adjudicate the defendant, subject to conditions and restrictions that were determined by the unit’s commander; and
- The defendant serves in the same unit in which the AO is stationed.
Special rules apply to the adjudication of specific groups of defendants, including military prisoners, lawyers, physicians, and officers who are direct subordinates of the Chief of Staff.
IV. Handling of Sexual Offenses
Sexual offenses in the IDF are handled differently than other offenses. In accordance with GSO 33.0145, sexual harassment constitutes both criminal offenses and civil wrongs and can be addressed by either criminal or disciplinary adjudication as well as by the filing of a claim for compensation. The responsibility for the development and implementation of policies for the prevention of “harm of a sexual nature” is shared by the General Staff Command Advisor for Women’s Matters through the Equal Employment Office (EEO), by unit commanders, and by adjutant officers.
A. Filing and Investigation of Sexual Offenses
GSO 33.0145 provides that victims of sexual offenses may seek assistance, treatment, and guidance by contacting their commanders (except where the commander is the alleged offender themselves), soldiers appointed by the commander to handle sexual harassment complaints, or the unit’s medical or mental health officers, as well as EEO personnel. Victims may be reassigned to a different unit after having being heard and following consultation with their commander.
Commanders who have been informed of allegations of sexual offenses must report such complaints to adjutant officers and in their absence to the EEO, to their own unit commanders, and to the MAG. A report alleging perpetration of sexual offenses will not be forwarded to a commander if the soldier requested confidentiality or when the commander is the subject of the complaint.
Upon receipt of a complaint an adjutant officer must interview the complainant, fill out a complaint form, and open a file for a sexual offense complaint. The complainant may then choose to have the complaint investigated either by an investigative officeror by the Military Investigative Police (MIP).
When there is suspicion of violence, as in allegations of rape, forced sodomy, etc., the complaint file must be transferred to the MIP (or the Israeli police when the alleged perpetrator is a civilian), even in the absence of the complainant’s consent.
In addition to having their complaints investigated and adjudicated by the IDF, complainants are entitled to file a civil complaint against their alleged perpetrators.
B. Determination of Adjudication and AOs Required Qualifications
All findings of investigations, either by the MIP or investigative officers, must be forwarded to the MAG. The determination of whether to adjudicate sexual offenses in disciplinary proceedings can only be made by the military advocate and not by commanders.
Disciplinary proceedings in cases involving sexual offenses must always be presided over by AOs who have a rank of at least Lieutenant Colonel and legal education or specific training in handling sexual harassment cases from the IDF School of Military Justice. AOs that adjudicate such matters are selected from a database that contains the names of graduates of that training. AOs who preside over the adjudication of sexual harassment cases must usually not belong to the same unit as the alleged offender. With the MAG attorney’s authorization, however, the defendant may be adjudicated by a Senior AO of a rank of Lieutenant Colonel or higher, who belongs to the same unit as that of the defendant, as long as the AO has had the training necessary to adjudicate such offenses.
The removal of disciplinary determination authority from the military chain of command in lighter offenses by selecting AOs from the database was supported by defense attorneys specializing in this field.
C. Proposals for Reforming the Military Justice System
A private Knesset Member bill was introduced by KM Miri Regev in March 2013 to reform the MJL by introducing a third venue for military adjudications in addition to the existing courts-martial and disciplinary adjudications. At the time this report was completed, this bill was still pending.
KM Regev’s bill proposes to establish military disciplinary courts that will be authorized to adjudicate every soldier, except officers at a rank of Lieutenant Colonel or higher, who are accused of perpetrating offenses under the MJL or under the Law for the Prevention of Sexual Harassment, 5758-1998.
The bill proposes that disciplinary courts be composed of three judges: the president of the disciplinary court, who must be a lawyer with a rank of Lieutenant Colonel or higher and be selected directly by the General Staff Commander, and two military judges, who need not have legal educations. According to the explanatory notes of the bill, the objective of ensuring that the president of the disciplinary court be a lawyer and selected by the highest commander is to strengthen both the commanding and the substantive character of this court.
The proposed disciplinary courts will follow the procedural rules that apply in district courts-martial but will not entertain pretrial proceedings. The bill further proposes that the disciplinary courts, unlike courts-martial, not be bound by the law of evidence except in cases involving privileged evidence in accordance with Chapter three of the Evidence Ordinance (New Version), 5731-1971, as amended.
According to the explanatory notes to the bill the need for the establishment for a third mechanism of military adjudication arises from the fact that reality has changed over time. The rigid division between purely criminal adjudications and disciplinary adjudications no longer provides an adequate response in a variety of cases, including sexual harassment cases, that exist in a “grey area.”
Proponents of the bill argue that this state of affairs has led to a situation in which offenses whose severity arguably made them subject to military discipline were nonetheless adjudicated by the military courts because of the “inadequacy of disciplinary law” under the circumstances of the case, whereas offenses that were investigated by the MIP and in which extensive and complicated investigative material was gathered were adjudicated in disciplinary proceedings, either because of evidentiary difficulties or because of their lesser degree of importance.
V. The Role of Civilian Courts
A. Review of Military Court Decisions
In accordance with the MJL, a decision of the Appeals Court Martial (ACM) may be subjected to review by the Israeli Supreme Court if special permission for review in the ACM’s decision itself or upon authorization by the President of the Supreme Court or his or her Deputy. The MJL provides that such authorization will be granted only when there arises “[a] legal question [that presents an] important, difficult or novel [legal issue].”
The eligibility for review of ACM decisions was analyzed in the 2007 Supreme Court decision in Colonel Ataf Zahar’s case. Mr. Zahar was convicted in 2006 by a military court of five counts of rape and indecent acts and was sentenced to six years of imprisonment, payment of compensation to his victim, and demotion to the lowest military rank of private. Following the ACM’s rejection of his appeal over both the conviction and the sentencing, Mr. Zahar requested authorization for appeal from the Supreme Court.
In rejecting the appeal request, Supreme Court President Dorit Beinish specifically addressed the authority of the Court to authorize an appeal of an ACM decision. She determined that by restricting authorization for appeal only to cases that presented an important, difficult, or novel legal issue, the legislature respected
. . . the uniqueness of the military courts system as a whole judiciary system with both first and appeal instances that suit the army’s special needs and behavior norms; and on the other hand, gave weight to the need to maintain harmony with principles of our [the Israeli] legal system, and maintain the unity that is necessary [based] on the system as a whole and the penal laws specifically, including uniformity in case law.
Having reviewed the arguments of both parties, Beinish concluded that the ACM decision was based on well-established legal precedent and did not present any important, difficult, or novel legal question that justified an additional review by the Supreme Court.
Expressing support for the appellant’s demotion in rank and rejecting his claim for “injustice,” Justice Edmond Levi added that
. . . the appellant is not worthy of carrying any commanding rank, because his high rank and superior position enabled him to commit offenses that are excessive in their severity and which arouse disgust, and which may deprive of sleep anybody who sends his son or daughter to serve in the army.
In October 2012 Mr. Zahar was released from prison after a military parole board reduced his sentence by nine months.
B. Review of Decisions Adopted in Military Disciplinary Proceedings
Although not expressly authorized under the MJL, the Supreme Court has also extended judicial review to decisions made in the course of disciplinary proceedings. In a 2005 leading decision the Court voided a commander’s decision in a disciplinary proceeding based on procedural defects. The case involved the adjudication of a soldier for unbecoming behavior for his refusal, while on vacation from his unit, to follow police orders to evacuate a mobile home bound for Judea and Samaria (the West Bank).
The Court noted, among other errors, that there was no record of “details regarding witnesses, testimony and/or documents presented” during the hearing, nor was there any written reasoning for the commander’s decision. The absence of these documents, the Court held, prevented the MAG from “exercising the authority acquired . . . under section 168(b) of the Law in an informed way . . . .” While recognizing that the process in the case was subject to several procedural flaws, Justice Michael Cheshin in a minority opinion opined that only flaws that result in injustice may, under the MJL, void a legal process. Cheshin rejected the claim that such injustice had been proven in this case.
VI. Effectiveness of the System of Adjudication of Sexual Offenses
In response to a request by the Movement for Freedom of Information, the IDF released a report in 2012 containing the following statistical data regarding filing and processing of sexual harassment complaints from 2007 to 2011. The report was issued in August 2012.
Table: IDF Sexual Harassment Data, 2007–2011
No. of Complaints Received
No. of Files Opened
Source: Noam Barkan, Rise in Reporting of Sexual Harassment in IDF, Yediot Acharonot, Aug. 5, 2012, at 8 (in Hebrew), also available on the Movement for Freedom of Information website, at http://www.meida.org.il/wp-content/uploads/ 2012/09/sexual-harassment-IDF.pdf.
According to a senior IDF source cited in the report, it is hard to say whether this significant rise in the number of complaints signified an increase in the number of sexual harassment cases in the military, or whether it merely reflected rising awareness of the subject, resulting from a comprehensive IDF campaign to root out sexual harassment in its ranks. The campaign included the establishment of a special IDF support center that provides support for victims of sexual harassment. A public campaign against sexual harassment in the military was reportedly initiated in February 2013.
VII. Bibliography of Scholarly Articles
This report addresses the evolution of military adjudication in Israel and the current law that applies to handling cases involving sexual offenses. The report and the analysis of applicable law is based primarily on a review of primary legal sources, including statutes, military comments, and case law. Secondary sources such as publications of the IDF School of Military Justice, newspaper articles, and information posted online by organizations have also been reviewed. Several of these written sources are cited in the footnotes. The following articles, while not entirely current, provide additional information on the Israeli system of military justice:
(1) Lindsy Nicole Alleman, Who Is In Charge, and Who Should Be? The Disciplinary Role of the Commander in Military Justice Systems, 16 Duke J. Comp. & Int’l L. 169 (2006), http://scholarship.law.duke.edu/cgi/viewcontent.cgi?article=1110&context=djcil.
(2) Menachem Finkelstein & Yifat Tomer, The Israeli Military Legal System – Overview of the Current Situation and a Glimpse into the Future, 52 A.F. L. Rev. 137 (2002), http://www.afjag.af.mil/shared/media/document/AFD-081204-027.pdf.
(3) Fifty Years for Military Justice – Proceedings of a Conference Held at the Israel Institute for Democracy, Commencement Session, and Second Session (Development of the Military; Justice Law) (1999), in 14 Mishpat Ve-Tsava [Law and the Army] 11 & 53, respectively, also available at http://www. law.idf.il/SIP_STORAGE/files/7/267.pdf and http://www.law.idf.il/SIP_STORAGE/ files/9/269.pdf (both in Hebrew).
Senior Foreign Law Specialist
 Military Justice Law (MJL), 4715-1955, 9 Laws of the State of Israel [LSI] 184 (1956).
 Israeli citizens, both men and women, who are eighteen years of age are subject to the military draft and to reserve service duties following completion of the initial draft. See Defence Service Law (Consolidated Version) 5746-1986, 40 LSI 112 (5746-1985/86).
 Irena Fine & Maayan Sagie, School for Military Justice, IDF, Adjudication Under Disciplinary Law, para. 2.4, at 14 (May 2011), http://www.law.idf.il/sip_storage//FILES/2/982.pdf (in Hebrew).
 General Staff Order (GSO) 33.0145, Prohibition on Inflicting Harm of a Sexual Nature (1979, as amended on 10/16,79), § 39, IDF, http://dover.idf.il/IDF/pkuda/330145.doc (in Hebrew); Fine & Sagie, supra note 4.
 Id. § 39A & B.
 MJL § 440I(b) (translated by author, R.L.).
 See, e.g., HCJ 266/05 Flint v. Colonel Efroni (decision rendered Jan. 12, 2005), http://elyon1.court.gov.il/files/ 05/660/002/O03/05002660.o03.pdf (in Hebrew); see also discussion in Part V(B) of this report.
 MJL (Amendment – Establishment of a Disciplinary Court) Bill, 5773-2013 (submitted Mar. 13, 2013 in the 19th Knesset), http://www.knesset.gov.il/privatelaw/data/19/483.rtf (in Hebrew). The bill is identical to an earlier bill submitted by KM Miri Regev and KM Aryeh Bibi in the 18th Knesset.
 Law for Prevention of Sexual Harassment, 5758-1998, Sefer HaHukim [SH] No. 1661, p. 166.
 MJL § 21 .
 MJL §§ 373A & 476.
 See Explanatory Notes to the Military Justice Law (Amendment – Establishment of a Disciplinary Court) Bill, 5773-2013, supra note 9, at 4.
 See MJL § 22.
 MJL § 177.
 MJL § 183.
 IDF MAG Corps, supra note 16.
 MJL § 43.
 Id. § 44.
 Id. § 46.
 Id. § 74.
 Id. § 75.
 Id. § 184.
 Id. § 136(a), as amended (translated by author, R.L.).
 Law for Prevention of Sexual Harassment, 5758-1998, SH No. 1661, p. 166.
 Rape is punishable by twenty years of imprisonment under the MJL if committed by an individual, and by a life sentence if committed by three soldiers together. MJL § 75.
 For discussion of the handling of sexual offenses in the IDF, see discussion in Part III of this report.
 Superior Command (SC) Order No. 5.0301, Authorities of Adjudication Officers and Restrictions on Authorities of General Staff Commander (June 1, 1989, as amended Dec. 29, 2005), § 23, http://dover.idf.il/IDF/pkuda/h/ 050301.doc (in Hebrew).
 MJL § 139.
 GSO No. 33.0302, Disciplinary Law §§ 58–61.
 Id. § 57.
 Id § 20.
 Id. § 10.
 MJL §§ 148–51.
 GSO 33.0302, §§ 2–3.
 The Israeli Adjutant Corps is a support corps in the IDF Human Resources Directorate tasked with assisting IDF commanders in dealing with manpower issues. The Adjutant Corps is headed by a Superior Adjutant Officer. Adjutant Corps soldiers serve in all IDF units and serve as a liaison between individual soldiers and the ranking commands. For additional information, see the IDF website, http://www.idf.il/1361-10641-he/Dover.aspx (last visited July 11, 2013).
 Id. § 12.
 Id. § 21.
 Id. §§ 27–32.
 Id. § 7.
 For information on the service of women in the IDF, see General Staff Commander, Advisor for Matters Involving Women, IDF, http://dover.idf.il/IDF/info/civilians/info_civilians_yohalan_he/default.htm (in Hebrew, last visited July 11, 2013).
 GSO 33.0145, §§ 3–5.
 Id. § 9G.
 Id. § 14.
 Id. § 15A–B.
 Id. § 15C.
 Id. § 25A.
 Id., Addendum A.
 Id. § 18.
 GSO 33.0304, Inquiry and Investigation by Military Police (1962, as amended), IDF, http://dover.idf.il/IDF/ pkuda/330304.doc addresses the authorities and the procedures that are followed by investigative officers.
 Id. § 16.
 Id. § 19.
 Fine & Sagie, supra note 4, para. 2.4, at 14.
 GSO 33.0145 § 39; see also Fine & Sagie, supra note 4, para. 2.4, at 14.
 Reference to this database appears in Hanan Greenberg, For the First Time: IDF Is Establishing a “Patrol” of Adjudication Officers, Maariv (Apr. 2, 2012), http://www.nrg.co.il/online/1/ART2/352/548.html (in Hebrew).
 GSO 33.0145, § 39b.
 Greenberg, supra note 62.
 MJL (Amendment – Establishment of a Disciplinary Court) Bill, 5773-2013, by KM Miri Regev (submitted Mar. 13, 2013), http://www.knesset.gov.il/privatelaw/data/19/483.rtf (in Hebrew).
 Law for Prevention of Sexual Harassment, 5758-1998, SH No. 1661, p. 166.
 MJL (Amendment – Establishment of a Disciplinary Court) Bill, 5773-2013, proposed part C2.
 Id. at 4–5.
 Id., proposed part D.
 Evidence Ordinance (New Version), 5731-1971, 2 LSI (New Version) 198 (1972).
 MJL (Amendment – Establishment of a Disciplinary Court) Bill, 5773-2013, p. 4 (translation by author. R.L.).
 MJL § 440I(a).
 Id. § 440I(b) (translated by author, R.L.).
 CrimA Permission Request 8731/06 Ataf Zahar v. Chief Military Prosecutor (decision rendered on Apr. 30, 2007), http://elyon1.court.gov.il/files/06/310/087/O04/06087310.o04.pdf.
 Id., Beinish decision (translated by author, R.L.).
 Id. para. 16.
 Gili Cohen, IDF Colonel Who Raped Female Soldier to Be Released 9 Months Early, Haaretz (Oct. 24, 2012), http://www.haaretz.com/news/national/idf-colonel-who-raped-female-soldier-to-be-released-9-months-early.premium-1.471892.
 HCJ 266/05 Flint v. Colonel Efroni, para. 7 (decision rendered Jan. 12, 2005), http://elyon1.court.gov.il/ files/05/660/ 002/O03/05002660.o03.pdf (in Hebrew).
 Id. para. 7.
 Id. paras. 10–11.
Last Updated: 11/03/2014