13. Memorandum from the Northern Ireland
Human Rights Commission
1. The Northern Ireland Human Rights Commission
(the Commission) is a statutory body created by the Northern Ireland
Act 1998. It has a range of functions including reviewing the
adequacy and effectiveness in Northern Ireland of law and practice
relating to the protection of human rights[160],
advising on legislative and other measures which ought to be taken
to protect human rights[161],
advising on whether a Bill is compatible with human rights[162]
and promoting understanding and awareness of the importance of
human rights in Northern Ireland. [163]In
all of that work the Commission bases its positions on the full
range of internationally accepted human rights standards, including
the European Convention on Human Rights (ECHR), other treaty obligations
in the Council of Europe and United Nations systems, and the non-binding
or "soft law" standards developed by the human rights
bodies.
2. The Commission engages extensively with
the United Nations system, including involvement in the monitoring
of treaty obligations in three main ways: commenting on drafts
of the United Kingdom periodic reports, particularly in relation
to Northern Ireland; providing information to the treaty bodies,
including "shadow" or parallel reports, and attending
the examination or "dialogue with the State Party" session;
and using the comments that issue from the treaty bodies to plan
follow-up work. In that context, it welcomes this opportunity
to contribute to the Inquiry of the Joint Committee on Human Rights
(JCHR) into the Government's address of the Concluding Observations
of the Committee on the Elimination of Racial Discrimination (the
Committee).
3. This Commission submitted its own parallel
report to the Committee in June 2003, highlighting the specific
situation of minority ethnic communities in Northern Ireland.
The Concluding Observations of the Committee have informed this
Commission's communications to Government in a number of ways
including, for example, its response to "Strength in Diversity:
Towards A Community Cohesion and Race Equality Strategy"
and its response to the consultation in November 2003 which led
to the Asylum and Immigration (Treatment of Claimants etc) Act
2004. The Concluding Observations have also been brought to the
attention of the Northern Ireland administration through the Race
Forum convened by the Office of the First Minister and Deputy
First Minister (OFMDFM), and have been discussed at the Human
Rights Forum convened by the Department for Constitutional Affairs
(DCA). (This body, also known as the NGO Forum or NGO Ministerial
Forum, is referred to further below.)
4. Overall the Commission has been disappointed
at the lack of commitment on the part of Government to address
the Concluding Observations in all areas relating to race equality,
and indeed the lack of awareness displayed by Government as to
their implications for legislative and policy initiatives as indicated
in its consultation exercises. For example, the "Strength
in Diversity" document, which is intended to mark a major
commitment by Government to tackling racial discrimination, made
no reference to Government's obligations under the International
Convention on the Elimination of All Forms of Racial Discrimination
(ICERD) nor to the Concluding Observations of the Committee. Such
omissions, along with the actual substance of policy proposals
on areas relevant to ICERD, suggest that Government does not use
ICERD, and the Concluding Observations adopted by the Committee,
to inform its legislative and policy initiatives to the extent
that it should.
INCORPORATION OF
ICERD AND ARTICLE
14
5. The UK has of course consistently resisted
the recommendation by the Committee to give direct domestic effect
to the provisions of ICERD, as it resists every recommendation
from UN bodies for incorporation of treaty obligations, and it
has indicated that it does not intend to alter this position in
the foreseeable future. However, the view of this Commission is
that incorporation would give a clear signal of Government's commitment
to tackling racial discrimination as well as strengthening the
level of protection available to ethnic minorities in the UK.
6. The Committee also noted the Inter-Departmental
Review then under way into the UK's international human rights
commitments, conducted by the DCA. The Committee urged the UK
to give high priority to making the optional declaration provided
for in Article 14 of ICERD, which gives individuals the right
to petition the Committee directly with complaints against the
State.
7. The Review has now been completed and
the DCA has announced that Government will not accept Article
14. In giving reasons for this decision the DCA stated that there
is already strong domestic legislation against discrimination
against ethnic minorities. It said that the practical value of
Article 14 to the individual citizen is unclear, and that the
cost to public funds of preparing responses to individual submissions
could be significant if the right of petition were used extensively
as a means of seeking to explore the legal meaning of a treaty's
provisions.
8. There is a contradiction in Government's
reasoning. On the one hand it points to the strong anti-discrimination
legislation in the UK, which it implies is sufficient for protecting
the interests of ethnic minorities, and on the other hand it expresses
concern that the number of individuals availing of the right under
Article 14 may be high enough to raise concern over the cost to
public funds, thereby suggesting that current domestic provisions
do not, in fact, provide adequate avenues of redress for individuals
subjected to racial discrimination.
9. The Commission's view is that strong
domestic legislation does not diminish the desirability of making
the optional declaration under Article 14. Indeed, a Government
genuinely committed to eliminating racial discrimination should
welcome the further direction that the outcome of individual petition
could provide from the Committee.
ARTICLE 4
10. In its report to the Committee this
Commission raised concerns with regard to the UK's restrictive
interpretation of Article 4 of ICERD. The Commission's report
highlighted the problems experienced by, in particular, the Muslim
community in Portadown as a result of a campaign to prevent the
construction of a new mosque in the area. Stickers, posters and
leaflets were distributed across the city containing anti-Islamic
messages and suggesting that the construction of the mosque would
inevitably lead to a terrorist, Al-Qaeda presence in the region.
11. The Muslim community was intimidated
to such an extent that it made a collective decision to keep a
low public profile, to refuse offers of assistance from relevant
agencies and to not speak about its experiences to journalists.
Members of that community informed staff at this Commission that
at the height of the campaign Muslims were reluctant even to leave
their homes.
12. The Government has consistently argued
that it is not prepared to curtail freedom of expression by taking
firm action against racist propaganda, in line with the recommendations
and concerns of the Committee. However, that policy has led to
a situation whereby a community that has been particularly vulnerable
since the September 11 attacks has been forced to live in fear
and intimidation, to such a degree that it has been reluctant
to exercise its right to freedom of movement, religious observance
and expression.
13. Racist attacks have increased significantly
in Northern Ireland in recent years and there is a real need for
Government to consider the entire range of factors that could
be leading to such behaviour. That ought to include the extent
to which discriminatory and offensive messages about ethnic minorities
can be tolerated.
14. While the Commission understands the
need to protect the right to freedom of expression, it would assert
that Government has failed to strike a correct balance between
that right and others such as the right to freedom of movement,
personal security, non-discrimination and religious freedom. The
Government should follow the guidance repeatedly offered by the
UN Committee.
ATTACKS ON
ASYLUM SEEKERS
15. The Committee raised concern at reports
of attacks on asylum seekers, and noted that antagonism towards
asylum seekers helped to sustain support for extremist political
opinion. It therefore called on Government to develop public education
programmes and promote positive images of ethnic minorities, asylum
seekers and immigrants. This Commission has been disappointed
at Government's failure to address positively this recommendation.
Government has concentrated its efforts on assuaging fears of
unmanaged migration and abuse of the asylum system, at the expense
of sending out positive messages about the human stories behind
the asylum issue, the economic, social and cultural contribution
of immigrants, and the duties that UK society has to refugees
and immigrants. Government should stress the message that the
number of persons seeking asylum in the UK is going down dramatically,
at twice the rate of decline experienced across the "EU15",
while there is no corresponding decline in the global problems
that force persons to seek asylum in the first place.
16. Also in the consultation document "Strength
in Diversity" there was a misplaced emphasis on combating
abuse of the asylum system and on the supposed duty of newcomers
to the UK to learn English. The overall tenor of the document
might be said to show an assimilationist approach, rather than
an intercultural one.
17. To go some way in addressing the concerns
of the Committee, that consultation document, and several others,
could have emphasised the circumstances which lead to persons
to seek asylum, the universality of human rights, the consequent
duties of wealthy democratic states to shelter and protect persons
fleeing persecution, and the duty of all UK citizens towards such
persons. Such messages would have been more fitting in the context
of a strategy for achieving community cohesion and race equality.
18. Government's response to the recommendation
that it send out positive images of asylum seekers has also been
unsatisfactory. As this Commission pointed out in its report to
the Committee, some asylum seekers are detained in prisons in
Northern Ireland, a practice rightly abandoned in other UK jurisdictions.
Previously, the high-security HMP Maghaberry was used to hold
asylum and immigration detainees. That situation has now changed
so that male detainees are held at a holding centre on the Prison
Service estate and female detainees are held at HMP Hydebank.
However, all detainees are held at the committal unit at Maghaberry
in the first instance. It was originally intended that this only
be for a maximum period of one night. However, the Commission
has been informed that in some cases detainees have been held
for up to three nights without access to a solicitor.
19. More recently staff shortages at the
holding centre led to two Muslim detainees being moved to HMP
Maghaberry over a weekend period during the Muslim month of Ramadan.
The Commission has not been assured that such a situation will
not arise again.
20. The detention of asylum seekers alongside
persons convicted of criminal offences sends out a very negative
message. It suggests that the public needs to be protected from
those applying for refugee status in the same way as it needs
to be protected from convicted criminals. Such a message runs
directly counter to that recommended by the Committee. The UN
Committee Against Torture has joined calls for the cessation of
the imprisonment of asylum seekers and immigrants, in the Concluding
Observations it adopted on 26 November 2004.
21. The Commission also has serious concerns
about a number of laws relating to asylum in the UK. The Concluding
Observations of the Committee, which call for more equitable,
efficient and unbiased asylum procedures, are not yet being reflected
in legislation.
22. The Nationality, Immigration and Asylum
Act 2002 (Specification of Particularly Serious Crimes) Order
2004 permits Government to deport refugees convicted of serious
criminal offences. The JCHR has of course published a report on
that Order which discussed in detail the implications of the legislation
with regards to the UK's commitments under the 1951 Convention
relating to the Status of Refugees and the ECHR. This Commission
takes the opportunity to state that it shares the concerns expressed
by the JCHR. The legislation ought to be examined in light of
the Committee's Concluding Observations with regard to the need
for positive messages and public education programmes.
23. In addition, the way in which section
55 of the Nationality, Immigration and Asylum Act 2002 operated
has been found by the Court of Appeal to contravene the rights
of asylum seekers under Article 3 of the ECHR, by exposing individuals
to the risk of absolute destitution. Section 55 is no longer used,
but the Commission is concerned that it has not been repealed,
and that the UK intervened to secure scope for comparable measures
within the development of the EU Directive 2003/9/EC laying down
minimum standards for the reception of asylum seekers. While the
UN Committee did not make specific reference to section 55, it
certainly cannot be seen to be a provision that accords with an
equitable, efficient and unbiased asylum process. The Court of
Appeal's decision along with the more general concern of the Committee
adds to the case for repealing the section 55 provisions.
24. The Commission has responded to the
Home Office consultation on the implementation of Council Directive
2003/9/EC on the reception of asylum seekers. The Commission is
concerned at the way in which Government is planning to implement
that Directive, which could lead to reduced provisions for asylum
seekers despite the non-regression principle in the context of
implementing EU Directives. The Commission's response to that
consultation[164]
draws attention to the possibility that the circumstances under
which Government can reduce or withdraw support for asylum seekers
may become broader.
THE EUROPEAN
RACE DIRECTIVE
25. The Committee expressed concern that,
unlike the Race Relations Act 1976, the regulation bringing into
domestic effect the European Race Directive does not cover discrimination
on grounds of "colour" or "nationality". The
Committee was concerned that the emerging situation may lead to
inconsistencies in discrimination laws and differential levels
of protection according to the categorisation of discrimination,
and thereby create difficulties for the general public as well
as law enforcement agencies.
26. It appears that in the context of Northern
Ireland this anomaly could be resolved with the proposed Single
Equality Act, so that discrimination on grounds of "nationality"
and "colour" are prohibited and clearly override any
existing narrower protections. The consultation paper on the Single
Equality Bill has made such a proposal. However, the Commission
remains concerned that in the meantime the inconsistencies may
impact adversely on ethnic minorities and would therefore recommend
that the inconsistency be rectified as soon as possible rather
than waiting for the Single Equality Act, which could take considerable
time to reach statute.
ANTI-TERRORISM,
CRIME AND
SECURITY ACT
2001
27. The Committee expressed deep concern
about the provisions of the Anti-Terrorism, Crime and Security
Act 2001, which allow for indefinite detention without charge
or trial of non-nationals of the UK suspected of terrorism-related
activities. The Committee drew the attention of the UK to its
statement of 8 March 2002, which reminded States of their obligations
"to ensure that measures taken in the struggle against terrorism
do not discriminate in purpose or effect on grounds of race, colour,
descent, or national or ethnic origin".[165]
28. The enactment of the Anti-Terrorism,
Crime and Security Act 2001 (ATCSA) has had very serious implications
for human rights in the UK and not least for Government's obligations
under the ICERD. Serious concern was expressed by the Newton Report
at the end of last year, [166]and
the internment provisions in particular are opposed by human rights
and civil liberties groups across the UK. The JCHR is of course
aware that all those currently being detained indefinitely under
Part Four of the Act are Muslim males of Arab descent. Even if
the powers were not being used exclusively or mostly to the detriment
of one particular ethnic or racial group they still have very
serious human rights implications and ought to be discontinued.
This Commission raised the problems with the legislation in its
report to the UN Committee Against Torture and the Concluding
Observations of that Committee (adopted on 26 November 2004) reflected
those concerns by calling on Government to review as a matter
of urgency alternatives to indefinite detention. [167]
29. The Commission remains concerned at
the lack of movement in relation to the most oppressive aspects
of the ATCSA, despite the extent of the opposition to it amongst
civil society in the UK and the international human rights systems.
It will continue to lobby Government to repeal the Part Four powers
and suggests that the JCHR raise the issue again through this
Inquiry.
TRAVELLERS
30. The Committee expressed concern about
the discrimination faced by Travellers in all aspects of life
and recommended that the State develop further appropriate modalities
of dialogue between Roma/Gypsy/Traveller communities and central
authorities. The Committee may have been referring to the Promoting
Social Inclusion (PSI) Working Group convened by the Office of
the First Minister and Deputy First Minister (OFMDFM), which brought
together a number of Traveller organisations in order to inform
Government of Traveller needs and to make recommendations for
change. In its report to the Committee, this Commission asserted
that one of the major problems with that process was that Government
had failed to allocate any additional funding to implementing
the recommendations of the PSI Working Group.
31. Since the adoption of the Concluding
Observations the Commission's concerns have deepened. In contrast
to the recommendations of the Committee, Northern Ireland's Department
for Social Development (DSD) is planning to enact the Unauthorised
Encampments (Northern Ireland) Order 2004. That Order, which reflects
similar provisions in Great Britain, would empower police officers
to direct "trespassers" to leave unauthorised camps
and to remove their vehicles and other property from the land.
The legislation will have an adverse effect almost exclusively
on the rights of one minority, namely the Traveller community.
The concern of the Commission is that, in a region where there
is not one authorised transit site available for the Traveller
community, this provision essentially criminalises that community
and seriously endangers the nomadic way of life.
32. The Government may suggest that, since
the NI Housing Executive has just completed an accommodation assessment
of the needs of the Traveller community, the proposed legislation
should be read in conjunction with the findings in that assessment.
However, the implementation of any of the proposals in that assessment
is dependent on finances, and there has been no guarantee from
Government that new money will be forthcoming. In light of the
Concluding Observations of the Committee, and indeed a host of
other international standards that guarantee adequate housing
and social assistance to all persons, [168]the
Commission cannot accept that there is any justification for the
commencement of this Order before adequate alternatives have been
put in place. The Commission believes that there should be statutory
definition of a right to a nomadic or sedentary way of life, including
a right to change between both modes.
THE NATIONAL
ACTION PLAN
AGAINST RACISM
33. The Committee commended the UK's efforts
to prepare a National Action Plan against Racism (NAPAR) in pursuance
of the recommendations of the World Conference Against Racism,
Racial Discrimination, Xenophobia and Related Forms of Intolerance
and asked for updated information on the action plan in the next
periodic report. The Commission has followed closely Government's
efforts in this respect and has expressed disappointment at its
approach. The JCHR must by now be aware that Government has put
on hold any further work on the NAPAR while it attempts to formulate
a Community Cohesion and Race Equality Strategy. A Race Equality
Strategy is also being drafted by OFMDFM for Northern Ireland.
Government has indicated that it may consider these strategies
to be suitable replacements for the NAPAR.
34. This Commission has examined both Strategies
in light of the Durban Programme of Action and what was subsequently
expected of States. The Commission is not satisfied that the Strategies
meet the requirements of the Durban Programme. The Commission
has submitted a detailed response to the Home Office outlining
the discrepancies between the proposed Community Cohesion and
Race Equality Strategy and the Durban Programme of Action. Some
of the shortcomings have already been referred to above.
35. In addition, the proposed Strategy's
address of policing and criminal justice agencies is lacking insofar
as it fails to acknowledge the need for training for employees
in these areas, the persistent problems of institutional racism
within the police force, and the need to engage in appropriate
public consultation.
36. Other notable omissions include the
role and responsibilities of politicians and political parties
in tackling racism, and the balance between freedom of expression
and protecting the rights and interests of minority ethnic communities.
37. The lack of transparency which led to
the decision to stall the NAPAR process is also of concern particularly
given the UN Committee's commendation that its development was
taking place in close contact with non-governmental organisations.
The Home Office had originally convened a steering group to take
forward the drafting of the NAPAR, and at a meeting held in February
2003 had agreed to hire a consultant to work exclusively on progressing
the project. After that meeting there was no formal announcement
from Government regarding its plans with the Community Cohesion
and Race Equality Strategy and no consultation with the steering
group regarding that decision. This Commission was told of Government's
plans in March 2004 only after it contacted the Home Office expressing
its concerns on the slow progress of the NAPAR. Other consultees
and participants in the process were notified later.
38. With regard to the Race Equality Strategy
for Northern Ireland, progress has been extremely slow and a final
draft has yet to be approved by Government almost two years on
from the first draft being issued for consultation. The OFMDFM
has also failed to convene a meeting of the Race Forum for several
months.
39. The process has left a strong sense
of frustration amongst organisations working on black and minority
ethnic issues, and at the domestic and international levels is
bound to engender a lack of faith in the commitments that the
UK purports to make on international platforms.
GOVERNMENTAL FOLLOW-UP
40. In terms of Government's response to
the Concluding Observations of treaty bodies, the DCA has (following
a suggestion from this Commission) convened a number of sub-committees
composed of groups that regularly attend the NGO-Ministerial Forum.
Two meetings were held for the sub-committee on ICERD and the
Commission was represented at both. Unfortunately the exercise
was unsatisfactory in that there was never any evidence of a real
commitment to use the discussions to work towards a strategy to
address the outcomes of the treaty process. The indication from
the Home Office was that there would not be any co-ordinated response
from the UK, nor any significant change in direction in terms
of legislation impacting on race relations.
41. The Commission is generally concerned
at Government's unresponsiveness when Concluding Observations
are adopted by any of the UN Committees. It would be fitting for
Government to make a public and widely circulated statement outlining
exactly how it intends to respond to the concerns and recommendations
of Committees, and to take an inter-departmental approach in positively
addressing those concerns and recommendations in close consultation
with relevant non-governmental organisations and statutory agencies
such as our own.
42. The Commission recommends that, shortly
after each set of Concluding Observations issues from a treaty
body, Government (both central and in the devolved administrations)
should work towards the development of an action plan to address
areas of concern. In the case of ICERD, this should not be seen
as a substitute for a NAPAR but a specific programme of measures
to address those matters in which the Committee has identified
deficiencies in the state's performance of its treaty obligations.
For each of the six main UN treaties this should be a time-bound
exercise over, say, two years, followed by a report to Parliament
and to the appropriate UN body.
43. Human rights law is constantly evolving
and the obligations entered into when a treaty is signed need
to be read in the light of the development of the international
standards. The extent to which any State is prepared to keep abreast
of or indeed ahead of such developments, rather than regarding
its obligations as a legalistic matter of minimal compliance with
the black letter of the treaty as understood at the date of ratification,
is a reliable measure of its commitment to a human rights culture.
Ideally, therefore, the exercise of following up on a treaty reporting
process would incorporate some reflection on the General Comments
or General Recommendations that are issued from time to time by
the treaty bodies, and on the reports of Special Rapporteurs working
on related topics. This analysis ought to include what is in the
UN termed the "jurisprudence" on a given treaty, ie
the evolving interpretation of the treaty, with particular reference
to anything of interest in the body's conclusions on other States
Parties since the consideration of the UK Report. Account should
also be taken of any resolutions or other positions taken in relation
to the treaty's subject matter by the treaty body itself or by
higher organs in the UN system.
44. The Commission is, of course, primarily
concerned with the Northern Ireland context, but many of the obligations
under NAPAR rest with Whitehall departments other than the Northern
Ireland Office. We could not be content with a situation in which
compliance was fully secured within Northern Ireland if full and
equal protection were not afforded in Great Britain. While the
JCHR's continuing close interest in treaty compliance is enormously
helpful and welcome in this respect, we would hope to see a more
active interest in treaty monitoring and follow-up from the statutory
bodies in Great Britain, principally the equality agencies (in
the case of ICERD, presently the Commission for Racial Equality,
CRE) but also from those with oversight or inspection responsibilities
in matters that have attracted comment from the Committee.
NATIONAL HUMAN
RIGHTS INSTITUTIONS
AS AN
AID TO
TREATY COMPLIANCE
45. This Commission, although a very small
organisation with limited resources, has from its inception in
1999 engaged successively with the examination of the UK's performance
under all six of the main UN treaties to which the UK is party,
not to mention our other work at the UN, the Council of Europe
and other international human rights systems. While our contributions
to treaty monitoring are almost entirely limited to comments on
matters internal to Northern Ireland, we are the only statutory
body from the United Kingdom to have made an independent input
to the treaty processes. In relation to ICERD, people in England,
Wales and Scotland have had to rely on non-governmental organisations
to provide independent information to the UN Committee. While
Northern Ireland NGOs are also active on this treaty and others,
our contribution as a public body, and the increasing status that
agencies like ours are accorded in the UN and other human rights
systems, adds value to the excellent work done by the representative
and campaigning organisations.
46. There is increasing recognition in all
of those systems of the potential of effective institutional safeguards
for helping states to comply with their treaty obligations and
to avoid the embarrassment of being found wanting through the
formal and public examination or "dialogue" process.
The UN and other systems are highly supportive of the concept
of national institutional protections, actively work to promote
their creation and development, and are very open to input from
such institutions in treaty monitoring processes. The Northern
Ireland Human Rights Commission is recognised by the International
Co-ordinating Committee of "national human rights institutions"
(NHRIs), and hence by the UN and other systems, as an NHRI in
general compliance with the benchmark Paris Principles, [169]although
as a "category B" institution rather than a full "category
A" one on account of its sub-national jurisdiction.
47. We seriously doubt that Great Britain's
proposed Commission on Equality and Human Rights (CEHR), to be
formed by merging existing equality bodies, would be capable of
satisfying the Paris Principles standards. The JCHR should give
further consideration to the potential of either a stand-alone
human rights commission, or a substantially strengthened human
rights function within a CEHR, in terms of helping to identify
and address shortfalls in compliance with all of the UK's international
human rights obligations. The CEHR should be able to engage with
the treaty bodies in respect of England and Wales (and of Scotland,
in the absence of a fully-fledged Scottish human rights commission),
as fully and as effectively as our own Commission does in respect
of Northern Ireland. This is, of course, provided that the legislation
does not prevent it from doing so and provided also that it is
genuinely independent, properly resourced, competent and willing.
In the context of ICERD, the CRE would need to develop its own
capacity to work to the 2004 Concluding Observations, pending
its integration into the proposed CEHR which is unlikely to take
place before 2008.
December 2004
160 Northern Ireland Act 1998, s 69(1). Back
161
Ibid, s 69(3). Back
162
Ibid, s 69(4). Back
163
Ibid, s 69(6). Back
164
Available on www.nihrc.org Back
165
Statement on Racial Discrimination and Measures to Combat Terrorism,
adopted by the Committee at its 1503rd meeting on 8 March 2002
(A/57/18, pp 106-107). Back
166
Privy Counsellor Review Committee, Anti-terrorism, Crime and
Security Act 2001 Review: Report, 12 December 2003: "Part
4 raises difficult issues of principle . . . It should be replaced"
(p 5). Back
167
http://www.ohchr.org/tbru/cat/United_Kingdom.pdf Back
168
See for example Article 11(1) of the International Covenant
on Economic, Social and Cultural Rights, under which "The
States Parties to the present Covenant recognise the right of
everyone to an adequate standard of living for himself and his
family, including adequate food, clothing and housing, and to
the continuous improvement of living conditions. The States Parties
will take appropriate steps to ensure the realisation of this
right, recognising to this effect the essential importance of
international co-operation based on free consent." Back
169
The Principles Relating to the Status of National Institutions,
adopted by the Commission on Human Rights in 1992 and the General
Assembly in 1993, GA res 48/134 of 20 December 1993, Commission
on Human Rights Resolution 1992/54 of 3 March 1992. Back
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