LGBT rights in Israel
|LGBT rights in Israel|
Location of Israel
|Same-sex sexual activity legal?||Legal since 1988 (but no record of enforcement of "buggery" law before this and the attorney general declared that laws against homosexuality would not be enforced in 1963)|
|Military service||Gays and lesbians allowed to serve openly|
|Discrimination protections||Sexual orientation protection in employment and other services, both sexual orientation and gender identity protected in schools (see below)|
|Unregistered cohabitation since 1994
Same-sex marriages performed outside of Israel recognized since 2006
|Only marriages sanctioned by the religious authorities may be performed within Israel (this applies to opposite-sex couples who are not eligible for religious weddings also)|
|Adoption||Yes, both joint and step-adoption allowed (see below)|
Lesbian, gay, bisexual, transgender (LGBT) rights in Israel have advanced in recent years and have generally been seen as one of the most progressive countries in the Middle East and Asia. Same-sex sexual activity was legalized in 1988, although the law was not enforced after a 1963  court decision. Israel became the first in Asia to recognize unregistered cohabitation between same-sex couples, making it the only country in Asia to recognize any same-sex union thus far. Although same-sex marriages are not performed in the country, Israel recognizes same-sex marriages performed elsewhere, making it the first and only country in Asia to do so. Discrimination on the grounds of sexual orientation were prohibited in 1992. Same-sex couples are allowed to jointly adopt after a court decision in 2008, while previously allowing stepchild adoptions and limited co-guardianship rights for non-biological parents. Gays and lesbians are also allowed to serve openly in the military.
Recent polls have indicated that a majority of Israelis support same-sex marriage, despite some social conservatism. Tel Aviv has frequently been referred to by publishers as one of the most gay friendly cities in the world, famous for its annual Pride Parade and gay beach, earning it the nickname "the gay capital of the Middle East" by Out Magazine. According to LGBT travelers, it was ranked as the best gay city in 2011, despite reports of some LGBT violence during the 2000s, which were criticized by Prime Minister Benjamin Netanyahu and President Shimon Peres. A monument dedicated to the LGBT victims persecuted by Nazis during World War II will be erected in Tel Aviv.
- 1 Law regarding same-sex sexual activity
- 2 Gender identity/expression
- 3 Recognition of same-sex relationships
- 4 LGBT Immigration to Israel / The Law of Return
- 5 Adoption and family planning
- 6 Military service
- 7 Discrimination protections
- 8 Other court rulings
- 9 LGBT rights movement in Israel
- 10 Living conditions
- 11 LGBT in Israeli society
- 12 Palestinian issues
- 13 Summary table
- 14 See also
- 15 References
- 16 External links
Law regarding same-sex sexual activity
The State of Israel inherited its sodomy or "buggery" law from the British Mandate's legal code, but there is no record that it was ever enforced against homosexual acts that took place between consenting adults in private. However, in certain cases defendants were found guilty of "sodomy" (which according to Israeli law includes oral sex as well), apparently by way of plea bargains: those defendants had been indicted for more serious sexual offences. It was also used on occasion as "aggravating circumstances" for other sexual offences. There were also very few cases of soldiers tried for homosexual acts in military courts. The Attorney General decided in the early 1960s, and the Israeli Supreme Court ruled in 1963, that the law should not be applied to acts between consenting adults in private. The ban on consensual same-sex sexual acts was formally repealed by the national legislative assembly (Knesset) in 1988. The age of consent for both heterosexuals and homosexuals is 16 years of age.
Treatment for Gender Dysphoria in Israel can be paid for using the country's public health insurance system if a patient receives approval by the Committee for Sex Reassignment operating out of Sheba Medical Center in Tel HaShomer, which consists of an endocrinologist, a urologist, and a plastic surgeon and is organized by the Health Ministry. All Sex Reassignment Surgery operations in Israel are furthermore performed by Dr. Haim Kaplan at Sheba Medical Center under this committee's approval. However, many transsexual Israelis have had trouble getting approval for treatment by this committee due to their stringent opinions on Gender Dysphoria. Thus, many pay out of pocket for Hormone Replacement Therapy and/or go overseas for Sex Reassignment Surgery.
Recognition of same-sex relationships
Same-sex marriage cannot legally be performed in Israel. Israeli law recognizes same-sex marriages performed elsewhere. Civil marriage doesn't exist in Israel for heterosexual couples, either (except where both heterosexual spouses do not belong to any of the recognized religious communities in the country), and therefore only a marriage sanctioned by the small number of officially-recognized religious authorities can take place within Israel. (This restriction forces not only gay couples, but also all mixed-religion heterosexual couples and any person who wishes a non religious marriage, to marry outside the country.)
The State of Israel allows foreign partners of its homosexual citizenry to receive residency permits. The Civil Service Commission extends spousal benefits and pensions to the partners of homosexual employees. The Israeli State Attorney's Office has extended the spousal exemption from property-transfer taxes to same-sex couples. Israel's attorney general has granted legal recognition to same-sex couples in financial and other business matters. Attorney General Meni Mazuz said the couples will be treated the same as common-law spouses, recognizing them as legal units for tax, real estate, and financial purposes. Mazuz made his decision by refusing to appeal a district court ruling in an inheritance case that recognized the legality of a same-sex union, his office said in a statement. Mazuz did differentiate, however, between recognizing same-sex unions for financial and practical purposes, as he did, and changing the law to officially sanction the unions, which would be a matter for parliament, according to the statement.
The city of Tel Aviv recognizes unmarried couples, including gays and lesbians, as family units and grants them discounts for municipal services. Under the bylaw, unmarried couples qualify for the same discounts on day care and the use of swimming pools, sports facilities, and other city-sponsored activities that married couples enjoy.
On January 29, 2007, following a Supreme Court ruling ordering them to do so, Jerusalem registered its first gay couple, Avi and Binyamin Rose.
LGBT Immigration to Israel / The Law of Return
On June 10, 2011, the Law of Return was tested when a gay male couple, one Jewish and one Catholic made Aliyah to Israel. This couple was the first same-sex, opposite religion married couple to request joint Aliyah Status, although opposite sex married couples of opposite religions receive joint Aliyah as a matter of course. The Jewish man quickly received citizenship but the decision of citizenship for his husband was delayed by the Ministry of the Interior despite the clause in the law saying the spouse of the Jewish immigrant must also be granted citizenship. On August 10, 2011, the Ministry of the Interior granted citizenship to the non-Jewish husband as required by The Law of Return.
Adoption and family planning
Adoption by LGBT parents has only been permitted in certain restricted situations, notably when a previous connection exists between the adopting parent and the child, such as being a family member or a foster child.
On January 10, 2005, the Supreme Court ruled that a lesbian couple is able to legally adopt each other's children. During the past 15 years that Tal and Avital Jarus-Hakak have lived together, they have had a total of three children. The couple petitioned the Tel Aviv Family Court for the right to formally adopt each other's children in 1997, but the request was rejected because Israel's adoption law had no provisions for same-sex couples. The couple appealed. While they failed to get a favorable ruling in the Tel Aviv District Court, the Supreme Court accepted the case. Citing Article 25 of the Adoption Law, the Yaros-Hakaks argued that the law allows for "special circumstances" for adoption when it is for the good of the child, even if the child's parents are still alive. The only condition is that the person seeking to adopt be single. The couple argued that since the state does not recognize same-sex marriage, they are single by law. The Yaros-Hakaks added that adoption was in the best interest of the children if one of their natural mothers should die. The Supreme Court of Israel agreed, ruling 7–2 in favor of the couple.
Following the supreme court ruling, a lesbian couple was allowed to adopt each other's biological children on February 12, 2006. Before that, gay partners of parents were granted guardianship over their partner's children.
On March 10, 2009, the Tel Aviv family court ruled that former Knesset member Uzi Even and his partner, Amit Kama, could legally adopt their 30-year-old foster son, Yossi, making them the first same-sex male couple in Israel whose right of adoption has been legally acknowledged.
Lesbian couples can legally gain access to IVF and assisted insemination.
Openly gay, lesbian, and bisexual soldiers serve without hindrance in all branches of the military. Discrimination against gay, lesbian, and bisexual soldiers in recruitment, placement and promotion is prohibited in Israel. Harassment on the grounds of sexual orientation is also prohibited in the Israeli military. The military recognizes same-sex couples, including widows and widowers of the same-sex. Soldiers are also allowed to participate in Gay Pride Parades.
Since 1993, homosexuals have been allowed to serve openly in the military, including special units. This is change in the initial policy, which tended to view homosexuality as a mental illness.
In 1956, two male soldiers were put on military trial on charges of homosexual sexual intercourse, then defined as sexual conduct "against nature" and were convicted to a military prison sentence of one year, but the punishment was reduced on the grounds that homosexuality should be defined as a mental illness and not a crime. At the time, many mental health professionals did view homosexuality to be an illness and, at the time, it was considered to be liberal to treat homosexuality as disability rather than as a crime.
In the 1960s, legal opinions by the Israeli Attorney General and the Supreme Court limited the application of the criminal laws against homosexuality, but the prevailing notion that homosexuality was a disease remained. In the 1960s – 1993, gays, lesbians and bisexuals were not formally exempt or banned from military service, but the anti-gay criminal laws remained on the books, their sexual orientation was still classified as a mental illness, which limited their role within the military, and there was no protection from anti-gay discrimination or harassment in the military.
Until the 1980s, the commanders still had to report to the military psychiatric department about homosexual soldiers, despite the fact that psychological and psychiatric organizations in Israel and worldwide had, since the 1970s, stopped viewing homosexuality as a mental illness.
In 1993, the Israeli Parliament revised the military rules so that gay, lesbian and bisexual Israelis can serve openly and on an equal footing with their heterosexual counterparts.
The Israeli Defense Forces currently does not consider Gender Dysphoria to be a disqualifying condition for service. Furthermore, the IDF considers certain transition-specific medical treatment (Hormone Replacement Therapy and Sex Reassignment Surgery) and counseling to be medically necessary for those diagnosed with transsexualism and thus pays for said treatments. The IDF also determines gender specific army regulations (length of service, which gender to be housed with, whether they are to wear a male or female uniform, etc.) on a case by case basis for its transgender soldiers. However, given that Israeli law makes it difficult for its transsexuals to begin transition until they reach 18, the draft age, and does not normally allow for Sex Reassignment Surgery to be performed before the age of 21, no soldier has yet to first begin treatment for transition and additionally have SRS while serving in the IDF. Furthermore, many draftees diagnosed with Gender Dysphoria can and elect to receive exemption from military service at their own request.
Today, Israeli youth who are exempt from military service can volunteer for national service. Since June 2006, The Association of Gays, Lesbians, Bisexuals, and Transgenders in Israel (Agudah) qualifies for such service. However, a steadily increasing number of gay recruits do full military service, often in combat units. Unit 8200, one of the largest units in the Israeli army, is well known for the large number of uncloseted LGBT soldiers serving in it.
In 2013, the IDF announced they would, for the first time, allow a (MTF) transgender woman to serve in the army as a female soldier.
In 1992 legislation was introduced to prohibit employment discrimination on the basis of sexual orientation, with some exemptions for religious organizations. Since 2014, LGBT youth have been protected at different schools around the country.
Other court rulings
|This article needs additional citations for verification. (November 2012)|
- The Supreme Court ruled that the partner of a gay employee at El Al, Israel's national airline, is entitled to free airline tickets just as the spouse of any heterosexual employee is.
- The Supreme Court recognized a lesbian as the adoptive mother of the four-year-old son of her same-sex partner, and ordered the Interior Ministry to register the adoption.
- An Israeli family court on March 17, 2002 turned down an application from a lesbian couple to have their partnership union declared legal. The couple was united in a civil ceremony in Germany. The women wanted the court to recognize their partnership as a civil marriage, under Israeli law. The court said that since the women are not recognized as a family under Israeli law, the court is not authorized to rule on their case. A government lawyer who was asked by the court to give a legal opinion on the case on behalf of the Israeli government said that the state objected to granting the request.
- On December 14, 2004, the Nazareth District Court ruled that same-sex couples have the same rights as married couples in inheritance rights. This ruling overturned a Family Court ruling that an elderly man from Kiryat Shmona was not entitled to spousal rights. The man had sought the estate of his late partner, with whom he lived for several decades. The Nazareth judges ruled that the term "man and woman" as spelled out in Israel's inheritance law also includes same sex couples. Judges Nissim Maman and Gabriela Levy, who issued the majority opinion, based their decision on a loose interpretation of the term "partner" as defined in other court rulings, such as those dealing with issues related to employee benefits, and thus applied the interpretation to the inheritance law. The acting president of the Nazareth District Court, Menachem Ben-David, issued the minority opinion, arguing that the legal text should not be interpreted "contrary to the lingual significance." A government spokesperson said the ruling will be appealed.
- In December 2004, the Tel Aviv District Court ruled that the government cannot deport the Colombian partner of a gay Israeli man. The 32-year-old Colombian entered Israel on a visitors visa which has long expired and the Interior Ministry had ordered him deported. His partner is an Israeli citizen and a soldier in the Israel Defense Forces. The couple filed an emergency petition with the Tel Aviv District Court. The men were represented by the Association for Civil Rights in Israel. Judge Uzi Vogelman ruled that the government had acted illegally in attempting to deport the man. In 1999 Supreme Court ruling established that the ministry could not deport foreign nationals married to Israeli citizens. Vogelman's decision extends that to apply to common-law marriages, including same-sex couples.
- In March 2008, Israel's Interior Ministry granted a gay Palestinian from Jenin a rare residency permit to live with his partner of 8 years in Tel Aviv after he said his sexuality put his life in danger in the West Bank.
- In 2012, an Israeli lesbian couple living in London won a case in an Israeli court preventing religious people offering non-religious services from discriminating on ground of sexuality. Tal Ya'akovovich and Yael Biran were awarded NIS 60,000 (£9,500) against the Moshav Yad Hashmona events hall; their reservation at that hall had been cancelled when the owners realised the event was for a lesbian couple. The Jerusalem magistrates' court judge said that even though the function hall was run by religious people, the services themselves (i.e the hiring of an event hall and the use of their catering service) were not in themselves religious services, and so were not legally exempt. It was also held that sexual assault is not just sexual exploitation, but includes discrimination and humiliation on grounds of sexuality.
- In 2012, the first gay Israeli couple was granted a divorce by an Israeli family court. The divorce of Tel Aviv University Professor Avi Even, the first openly gay Knesset member, and Dr. Amit Kama was granted on Sunday by the Ramat Gan Family Court, according to Haaretz, which ordered the Interior Minister to register their status as divorced.
LGBT rights movement in Israel
|This section requires expansion. (May 2009)|
Israel has an active gay community, with well attended annual gay pride festivals held in Tel Aviv and Jerusalem since 1998. Pride events are also held regularly in Haifa, Beer Sheva, Petah Tikva, Hadera, Ra'anana, Eilat and Rishon LeZion.
The Jerusalem parade gained international coverage when three marchers were stabbed in 2005. The perpetrator was subsequently sentenced to twelve years in prison. An attempt by Jerusalem's mayor, a Haredi Jew, to thwart Jerusalem pride in June 2005 had been challenged in the courts. The mayor lost and was ordered to contribute funds to the event.
The World Pride Festival was planned for Jerusalem in August 2005, despite protests and opposition from members of the three major religions in Jerusalem. However, it was postponed due to Israel's pull out from Gaza Strip, which required the presence of most Israeli police forces and would thus leave the parade with little to no security. However, that parade had been plagued with threats of violence, as well as consistent grandstanding against it by some Jewish, Muslim, and Christian leaders and members of the Knesset.
In November 2006, more than two thousand members of the Haredi community jammed into streets in an Orthodox neighbourhood in a show of force aimed at pressuring authorities into cancelling the gay pride parade to be held in Jerusalem. About a dozen people were reported injured.
LGBT in Israeli society
LGBT in Israeli politics
Political discourse in Israel on Biblical David and Jonathan
David on Jonathan:
"very pleasant hast thou been unto me; wonderful was thy love to me, passing the love of women" (2 Samuel, 1:26)
"I know you have chosen the son of Jesse – which is a disgrace to yourself and the nakedness of your mother!" (1 Samuel, 20:30)
The aforementioned dispute over the interpretation of the language and meaning of the bible has turned into an important political debate between the Israeli gay community and the right wing conservative as well as the general Israeli public.
The public discourse around this issue has reached its peak, when, then Knesset member, Yael Dayan, on 10 February 1993, made her famous speech on the Knesset floor, on the need for gay rights, and while quoting from Biblical Davids' words on Jonathan.
Today, Israel's Labor Party and the New Movement-Meretz support gay rights, as did the now-defunct Shinui. Under Tzipi Livni, Kadima has reached out to the gay community. Other minor liberal or progressive political parties support a similar platform as well, including the Green Party and the Green Leaf Party. Officials from a number of parties, including Yael German of Yesh Atid, Limor Livnat of the ruling Likud-Beiteinu and openly gay Nitzan Horowitz of Meretz, backed same-sex marriage and pledged support for LGBT casuses. Representatives from other parties, including Hatnuah, Hadash and the Labor Party also pledged support. Minister Livnat, however, did state that getting the ruling Likud-Beiteinu to legislate same-sex marriage would be difficult due to differing opinions concerning the issue within the party, but promised to do her utmost to get her party behind the issue.
Nevertheless, there still have been anti-gay politicians. In 1997, President Ezer Weizman compared homosexuality to alcoholism in front of high school students. This provoked major controversy and the President received numerous calls from civil rights activists and liberal Knesset members. Shortly following, 300 people demonstrated outside of Weizman's residence, demanding his resignation.
On February 20, 2008, Shlomo Benizri, a Knesset member from the religious Shas party, a member of Prime Minister Ehud Olmert's ruling coalition, blamed earthquakes that had recently struck the Middle East on the activities of homosexuals. Benizri said in a Knesset plenary session, ""Why do earthquakes happen? .. One of the reasons is the things to which the Knesset gives legitimacy, to sodomy." He recommended that instead of merely reinforcing buildings to withstand earthquakes, the government should pass legislation to outlaw "perversions like adoptions by lesbian couples." Benizri stated that "A cost-effective way of averting earthquake damage would be to stop passing legislation on how to encourage homosexual activity in the State of Israel, which anyways causes earthquakes."
One of the first Israeli newspapers to cover the subject of gay people was a 1962 article in the now defunct "HaOlam HaZeh". Taking a sensationalist tone, the newspaper warned of a "secret underground" movement within Israel. This was the typical manner that Israeli news media would deal with LGBT issues, beyond silence, until the late 1980s.
It was then that the Tel Aviv weekly newspaper "HaIr" began to publish a chronicle about an Israeli gay man, known at the time as "Moshe", who would later reveal himself to be Gal Uchovsky. The second major shift in how Israeli media dealt with LGBT issues came in 1991, when the Histadrut Labor Federation began to include, in its official publication, a section on LGBT social and political topics.
This was followed by gradually more supportive press coverage on the Israeli LGBT community and its human rights objectives.
Films and TV programs
The first Israeli LGBT-themed film came from openly gay director Amos Guttman and was called, Nagu'a (Drifting), which Guttman was the co-writer of. The film follows a young Israeli gay man, living and working with his grandparents, who has dreams of making a film and finding true love. Guttman, who died of AIDS in 1993, would write and direct another Israeli gay-themed film titled, "Amazing Grace" (1992). Both films are considered to be autobiographies of the director. In total, Guttman directed 4 films, and 3 short-films. His portray of the Israeli gay men was dark, and his films are considered to be targeted for the LGBT community in Israel, and not to the general public.
Another notable Israeli director to tackle LGBT themes in films has been Eytan Fox. His first film, "Time Off" (1990), was the second film made in Israel to focus on gay people and he has gone onto direct, and write, several successful LGBT-themed films, including "Ba'al Ba'al Lev" (1997) and "Yossi & Jagger" (2002), "Walk on Water" (2004) and "The Bubble" (2006). Fox was also involved in the first Israeli primetime TV drama, made for a general audience, to deal extensively with LGBT-themes – Florentin.
"Florentin" (1997—2000) was an Israeli television series about a group of post-military service, Israeli twenty-somethings living in Florentin. It was the first Israeli series to have, among it major characters, someone who was gay and was part of a slow trend that had been unfolding in the 1990s with shows such as "Straight and to the Point" and "Siton".
Today, there is more programming for a LGBT audience. In 1993, the first commercial TV network in Israel, Channel 2, went on the air and it regularly dealt with LGBT social and political topics, and, in particular, helped generate greater visibility and acceptance of transgender celebrities such as Dana International.
Radio stations such as Radio Tzafon and Radio Radius both have scheduled times for guests to come on the air and talk about LGBT social and political topics. More members of the Israeli media have come out, without ruining their careers. Today, all of the three Israeli daily newspapers have openly gay editors and/or writers, and several LGBT-publications have come and gone.
- Yossi Avni-Levy is one of several senior Israeli diplomats who are openly gay. Aside from serving as consul in several European countries, he published three successful books (short stories, novellas and a novel) about gay themes under a pseudonym, before finally coming out.
- Uzi Even (Meretz Party), is an openly gay, former member of Knesset and a professor of chemistry in Tel Aviv University.
- Marcia Freedman, former Meretz Knesset member.
- Nitzan Horowitz (The New Movement), is an openly gay member of the Knesset, as well as a former Haaretz and Channel 10 news correspondent and civil rights activist.
- Saar-Ran Netanel (Meretz Party), member of the Jerusalem City Council, is openly gay.
- Itai Pinkas (formerly Meretz Party), member of the Tel Aviv City Council is openly gay. He is also a former Executive Director of The Agudah, an Israeli LGBT rights organization headquartered in the center of downtown Tel Aviv.
- Rabbi Ron Yosef (b. 1974) (Hebrew: רון יוסף) an Orthodox rabbi who helped found the Israeli organization Hod, which represents gay and lesbian Orthodox Jews. His organization has played a central role in the recent reevaluation of the role of religious homosexuals in the Israeli Religious Zionist movement.
Notable events and culture references
- On Holocaust Memorial Day 2006, gays and lesbians in Israel were invited to participate in Holocaust memorial services in Europe, acknowledging the persecution of homosexuals by the Nazis.
- Israel was one of six members of a United Nations committee that supported the Coalition Gaie et Lesbienne du Québec (Coalition of Gays and Lesbians of Quebec) having consultative status with the United Nations. The other five in favor were Colombia, Peru, Romania, Britain and the United States; and against were Burundi, China, Egypt, Guinea, Pakistan, Qatar, Russia and Sudan. With the majority against, the group's credentials were initially rejected. The United Nations did later grant the Coalition a consultative status.
- Israeli film producers and life partners, Eytan Fox and Gal Uchovsky, have included gay themes in some of their films: Walk on Water, Yossi and Jagger, and The Bubble.
- In 2013, the first public Israeli wedding between a man and an openly transgender woman (Chen Arizona) occurred. The wedding was televised by Israel’s Channel 2 evening news and watched throughout the country.
Some LGBT Palestinians have relocated to Israel, often fleeing harsh intolerance that includes physical abuse, death, or disownment. Significant expatriate groups exist in Tel Aviv and Netanya, where many live with their Israeli same-sex partners who help keep their presence in Israel hidden from the police (who would pursue them not for their sexual orientation, but for staying illegally in the country).
In 2003, Aswat was founded, which describes itself as a Palestinian lesbian support group. However, the group is headquartered in Haifa, Israel, and is geared toward Arab lesbians in Israel and the Palestinian Authority. A secret association of Aswat was founded in Ramallah in March 2007 by four gay students. The Israeli Jerusalem Open House has opened an Arab chapter called Alqaws, reaching out to gay and lesbian Palestinians.
In 2008, Israel granted a gay Palestinian a residency permit to live with his Israeli partner in Tel Aviv following death threats from Palestinians regarding his homosexuality. Aswat claimed that gays are sometimes targeted by the Israeli security services and told that they must collaborate with Israel or face being outed.
|Same-sex sexual activity legal||(since 1988)|
|Equal age of consent|
|Anti-discrimination laws in employment only|
|Anti-discrimination laws in the provision of goods and services|
|Anti-discrimination laws in all other areas (incl. indirect discrimination, hate speech)|
|Recognition of same-sex couples||(since 1994)|
|Step-child adoption by same-sex couples||(since 2005)|
|Joint adoption by same-sex couples|
|Gays and lesbians allowed to serve openly in the military||(since 1993)|
|Right to change legal gender|
|Access to IVF for lesbians|
|Commercial surrogacy for gay male couples||(since 2014)|
|MSMs allowed to donate blood||B|
- Same-sex marriage in Israel
- Unregistered cohabitation in Israel
- LGBT rights by country or territory
- LGBT rights in Asia
- Jonathan Danilowitz
- 2009 Tel Aviv gay centre shooting
- Law of Return as it related to LGBT Couples
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|Wikimedia Commons has media related to LGBT in Israel.|
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- Gay life in Israel by Chas Newkey-Burden
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