 Israeli treatment of non-Israelis in territories occupied by Israel, for the past forty years, has been compared to South Africa's treatment of non-whites during the apartheid era – by various parties including the Congress of South African Trade Unions, Jimmy Carter, archbishop Desmond Tutu, and Israel Attorney-General Michael Ben-Yair.In 2009, South Africa's Human Sciences Research Council released a 300-page study that concluded that Israel practiced colonialism and apartheid in the Occupied Palestinian Territories.The term apartheid in the context of the West Bank is used in relation to certain Israeli policies in force in the area.