The failure at the 63rd International Labor Conference (Geneva, 1977) to adopt the Report of the Committee on the Application of Conventions and Recommendations was regarded by many delegates as yet another example of denial of due process by that organization and may have influenced the United States in its decision to withdraw from ILO. The decision of the Conference, although primarily political, had certain legal implications in so far as it suggested that an occupying power, such as Israel, may not apply international labor conventions to which it is a party to territories that it occupies.