Non-recognition terminology: PA daily refers to Israel as "1948 territories"

Headline: “Death of a criminal prisoner from Jerusalem in an Israeli rehabilitation center”
     “A criminal prisoner from Jerusalem passed away yesterday [Jan. 16, 2017] at a rehabilitative work center in the village of Tamra within the 1948 territories (i.e., Israel).
The prisoner was Mahmoud Nabil Bseileh, 17, from Al-Mawlawiya Street in the Al-Sa’adiya neighborhood of Jerusalem. He passed away early yesterday morning at the rehabilitation center, and had been imprisoned for the past two years on a criminal background.”