2.Kahlon Moshe - Plaintiff No. 2 - was recruited to the IPS on November 26, 1967 and retired on May 1, 1992, from November 1, 1984 until his retirement, Mr. Kahlon served as an administrator in the Judea and Samaria Central Prison.
- Mr. Anwar Moadi - Plaintiff No. 3 - Recruited to the IPS on July 31, 1975 Beginning on August 23, 1994Mr. Moadi served as a security guard in prisons in Judea and Samaria, except for the period between February 4, 1986 and November 15, 1987, when he served within the Green Line in Atlit Prison.
- Mr. Zadok Sofer - Plaintiff No. 4 - was recruited to the IPS on April 4, 1960 and retired on April 30, 1990, as of January 15, 1984 Mr. Sofer served as a security guard in the prisons in Judea and Samaria; 11) The addition of the Reserve Bank is in fact an additional activity when there are 3 types of activity: Activity A, Activity B and Prison Guard.
Entitled to the boxes of the addition of a check-in - an addition to the service of the front areas; 12) In order for a prison guard to be entitled to a supplement that is required of him - "Until February 1988, guards serving in a prison in Gaza received this supplement only. Since February 1988, it has been decided, with the approval of the Wage Commissioner, to give the increment to the prison guards serving in prisons in Judea and Samaria, and the guard was to be "stationed in one of the prisons I mentioned. Needless to say, these are prisons for security prisoners from the Occupied Territories... The population is more hostile than the criminal prisoners, both from the perspective of the prisoners themselves and from the perspective of the visitors." In these prisons, the guards are in greater danger than in regular prisons; 13) On December 9, 1987, the intifada began, and from that date the way to and from the prisons and from them to their homes, as well as the type of visitors, increased the danger to the prison guards;
14) With the intensification of the intifada, it was necessary to instruct the guards serving in the prisons in Judea and Samaria on orientation in movement in the territories, open-fire regulations, and the behavior of the guards in contact with the population in Judea and Samaria.
- From the affidavit of the defense witness, Mr. Amit Streit, the facts emerge as follows:
- a) The witness has been serving, since May 1, 1990, in the position of Senior Deputy Commissioner of Wages and Labor Agreements in the Ministry of Finance, and within the framework of his position he is responsible, inter alia, for the field of wages in the defense establishment, including the IDF, the Israel Police and the Prison Service; b) The supplement is one of the levels of activity paid to career soldiers in the IDF, and is a percentage increase paid according to the criteria specified in a weighing table, where the total cumulative score according to the criteria determines the level of activity to which the unit or the career servants performing the activity are entitled. whose nature is different from the nature of the activity of the unit in which they serve; c) According to the weighing table and an in-depth examination of the application of the criteria regarding the prison guards in Judea and Samaria, it appears that they are entitled to an addition of activity C or, under certain conditions, at most, an addition of activity B; d) The supplement (which is an addition to activity A) is given in the IDF only to those whose total cumulative score from the weighing table has reached 16 points or more, while the cumulative score of Judea and Samaria prison guards, including the plaintiffs, reaches a maximum of 13 points - a score that entitles to an additional activity B at most; e) Following Government Resolution 397 (Q/33), a follow-up committee was established whose role was to monitor the changes in the salaries of career soldiers in the IDF and to determine how to apply them to the salaries of the Israel Police and in the IPS; f) The Follow-up Committee held many discussions over the years, and on January 18, 1993, it brought its decision of December 22, 1992 to the Ministerial Committee for Economic Affairs, which determined, in resolution 39, which received the validity of Government Resolution No. 678, that the Follow-up Committee's decision of December 22, 1992 "exhausts the equalization of wages between police officers and prison guards and those who serve in the regular army to this day"; g) The working conditions of the prison guards are substantially different from the working conditions of the police officers, both in their working hours and in nature; h) Notwithstanding all of the above, and after lengthy discussions between the Ministry of Police, the Ministry of Finance, and the IPS Commissioner, the Wages Commissioner decided, beyond the letter of the law, and without any commitment or agreement, to apply a reserve allowance to the prison guards serving in Judea and Samaria, on condition that they undergo periodic training on special behavior for those serving in the Occupied Territories beyond the Green Line, beginning in January 1988; i) The date was decided to be January 1988 in light of the change in security circumstances and after inter-ministerial discussions; j) There is no room to compare those who serve in the police with the prison guards in the IPS also because of the fundamental difference between the nature of the policeman's work and that of the prison guard;
- k) The nature of the work of a designated police officer within the Green Line is different from the nature of the work of a designated police officer beyond the Green Line, a difference stemming from the different population, the different scope of training, operational employment, the number of overnight stays at the bases, and inter alia from the geographical distance.
In contrast to a designated police officer, prison work in the prison area is not substantially different from that in a prison within the Green Line compared to that beyond the Green Line, neither in terms of the scope of the job, nor in the ongoing activity such as shift hours, etc., and not in the nature of the substantive activity, and therefore in this case there is no significance to geographical distance alone; 12) Only when the security circumstances have changed and as a result there is a difference between the work of the prison within the Green Line and beyond it. The Commissioner of Wages at the Ministry of Finance, by virtue of his authority, and without any legal or contractual obligation, decided to order the payment of a shekel supplement to the guards in Judea and Samaria as well, as of January 1988 - the date of the change in security circumstances; 13) The payment of a shekel supplement to the guards in Judea and Samaria was conditional on the provision of special periodic training on the subject of behavior in the Occupied Territories to those serving beyond the Green Line - training that was required due to the new security circumstances that were created and in which the guards were not accustomed by virtue of the nature of their work; 14) This periodic training was not required by the police officers in exchange for the granting of an additional check on the grounds that a police officer undergoes, in his basic and regular training by virtue of his position as a police officer, training on how to drive in the Occupied Territories, and therefore a change in security circumstances in the Occupied Territories did not require the provision of special training to a police officer, as opposed to a prison guard; 15) The weighing table - N/5 - the witness's value, where "I copied the first 7 tables from another appendix that I did not compile and what I did is the last table - the score for the Judea and Samaria prison guards".