Category Archives: Commentary

Lost in transition – EU financed legal aid programme between Serbia and Kosovo falters

by Massimo Moratti

Since 2012, I have been informing the readers on some key developments in the field of property rights, as they emerged from the practice of a legal aid project in Serbia for refugees from Bosnia and Croatia as well as displaced persons from Kosovo*. The November 2011 – June 2015 phase of the project (which has been funded by the EU Delegation to Serbia since 2008) was implemented by a team of lawyers and barristers I had the privilege of leading.

Many of the blog readers might wonder what happened with the Project since the last post two years ago, and I am glad to use this opportunity to provide an update on subsequent developments. At that time, the project was due to end in June 2014, but received a one year cost extension from the EU Delegation to the Republic of Serbia. The project was financed under the Instrument for Pre-Accession (IPA), the main fund to support countries that are in the EU accession process.

Under the terms of the IPA, a local public institution, in this case the Serbian Government’s Office for Kosovo and Metohija (the OKiM), was designated as beneficiary of the Project. Accordingly, the OKiM provided free legal aid to displaced persons from Kosovo via outsourcing to a consortium of private companies and NGOs, which in turn implemented the project under the EU flag.

This is the standard arrangement for EU funding, but in this specific case, where the divide between Serbia and Kosovo* institutions remains wide, it was crucial to make sure that a team of EU-funded lawyers could operate between the two legal systems, engaging in de facto conduct that I defined as “shuttle legal aid”.

For those not familiar with the practicalities of the issue, it is worth recalling that there are, according to the Serbian authorities, around 200,000 displaced persons from Kosovo. It is unclear how many of them have not yet solved their property issues. While displaced persons are mostly in Serbia, their properties and other assets are located in Kosovo, and any attempt at ensuring the protection of their rights needs to be conducted before the institutions of Kosovo*.

However, the two legal system do not recognize each other’s documents, and there is no functioning post or telephone system between Kosovo* and Serbia. Lawyers and legal aid NGOs from Serbia are often reluctant to travel to Kosovo, both because of logistical and security issues and due to lack of familiarity with the institutional setting of the former Serbian province. Lawyers from Kosovo do not seem interested in conducting any outreach to potential clients in Serbia and more important than everything else, displaced persons themselves do not have the financial means to pay for legal expenses.

The EU-funded legal aid programme presented a solution to these problems, since it could operate in both Kosovo and in Serbia. The positive aspects were numerous: the project bridged the institutional gaps between the two systems, it was staffed with an adequate number of lawyer and barristers familiar with national and international law, and its proceedings were completely free for the IDPs (including coverage of court fees and expenses).

Indeed, besides successfully representing thousands of persons in administrative and court proceedings, the Project generated valuable information, in that it could closely observe the workings of the courts of Kosovo* in the context of property cases. Most of these cases involved disputes about the possession of property where an inter-ethnic element was present, which raised the profile and the tension in many of these disputes.

The project had a unique point of view, namely that of the claimants and their legal representatives and it could accordingly witness how legal proceedings took place “from the bottom” and very often without other international observers present. This unique point of view allowed the project to use its cases to collect information on court practice and in this manner legal aid became a “fact finding” tool, regularly reporting its findings on its website and from time to time on this blog.

The topics covered were some of the most contentious in Kosovo. Moreover, they involved the issue of property rights, where, as consistently highlighted in the EU Progress Reports about Kosovo, progress was slow or non-existent.

In the course of its work, the Project successfully represented displaced persons who were trying to challenge the illegal occupation, and in some cases demolition, of their properties. In other cases, the Project initiated criminal and civil proceedings cases against persons who acquired property via “fraudulent transactions”, highlighting patterns indicating that the forgery of property documents and records was not just an act of few corrupt individuals, but in certain areas a concerted effort to grab land to be used for business purposes.

In several landmark cases before the Constitutional Court of Kosovo, it was also possible to highlight how an internationally funded mass claims mechanism, the Kosovo Property Agency (KPA) had itself violated the rights to property and fair trial by refusing to solve property disputes or to award compensation to claimants.

However, like all projects, this one too came to an end on 12 June 2015. Continue reading

Sargsyan and Chiragov: The Strasbourg Court takes aim at frozen conflicts?

by Rhodri C. Williams

Last week I joined Philip Leach of the European Human Rights Advocacy Centre (EHRAC) in Strasbourg to present the European Court of Human Rights’ June 2015 judgments in two cases related to the Nagorno-Karabakh conflict to government representatives at the Council of Europe, at a briefing event organised by the European Implementation Network and the Open Society Justice Initiative.

The cases were Sargsyan v Azerbaijan and Chiragov v. Armenia, which were effectively joined by being relinquished from their original chambers to the same composition of the Grand Chamber in 2010. Both judgments found continuing violations of the applicants’ rights to property and their homes (as well as an effective remedy) based on their displacement in the early 1990s and subsequent inability to return to or access their properties.

While not (yet) signaling the initiation of a pilot judgment procedure, the court notes that the cases typify repetitive claims resulting from the respondent states’ failure to peacefully resolve the Nagorno-Karabakh conflict, reiterate the “primordial” importance of subsidiarity to the functioning of the Convention system, and recommend that both states take immediate steps to address property claims on their own steam:

…it would appear particularly important to establish a property claims mechanism, which should be easily accessible and provide procedures operating with flexible evidentiary standards, allowing the applicant and others in his situation to have their property rights restored and to obtain compensation for the loss of their enjoyment. (Sargsyan, para. 238, Chiragov, para. 199)

Taken together, the judgments represent intriguing developments at a number of levels. Continue reading

Property issues in Libya: A reminder that the road to sustainable peace still goes via root causes

by Rhodri C. Williams

What to say about Libya? Despite the slide from the country’s post-revolutionary and chaotic new normal to civil war, it is still too early to give up hope. While Libya may have yet to scrape bottom, many of the factors that argued for a sustainable recovery from Gaddafi’s long nihilistic night remain latent. And despite the increasing subordination of Libya’s politics to the influence of regional competitions and actors, the country still remains to some degree a case apart, churning in the region’s ideological divisions without the despair-inducing ethnic and sectarian fractures that threaten the Mashriq.

It seems a very long time since my work in Libya, on property issues that stalled (at best), displacement issues that exploded, and rule of law issues that have descended to a near farce, with mass trials of senior Gaddafi regime officials wrapping up amid power cuts and procedural irregularities. By all accounts, Ibrahim Sharqieh’s grim prediction that the lustration law forced through in 2013 would be the equivalent of the Iraqi de-Baathification process has been vindicated, as the heavily militarized winners of the revolution collapsed into open conflict with each other. Then comes IS in Sirte, refugee catastrophes in the Mediterranean, and the needless death of good and selflessly devoted Libyans.

The temptation is strong in such situations to cut losses and contain damage. For Europe, for instance, earlier efforts to build up a Libyan state that could be a responsible partner on migration issues have now given way to desperate proposals to unilaterally stem migration that bypass and undermine what remains of the Libyan state. Fortunately, the UN Special Envoy to Libya, Bernardino Leon, has shown extraordinary persistence, chivvying two sides that refuse to recognize each other into 80% of a peace deal even as economic collapse looms. Another refusal to write Libya off came last month, when the Legatum Institute revived the moribund debate over property issues in Libya.

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How quickly a year goes when the international architecture is coming down around your ears

by Rhodri C. Williams

Its not really the twelve months since Maidan that counts. Sure, that was heady, scary stuff, a slightly compressed version of the astonishments of Tahrir, but with every reason to be aware this time of just how quickly the other shoe was likely to drop. The anniversary of real note will come in March, at one year since we realised the magnitude of that other shoe. To wit – a permanent, nuclear-armed member of the UN Security Council engages in aggression against a neighbouring country. Thump.

I was probably less surprised than some. Before moving to Stockholm in 2009, I’d lived in Finland for five years, where I grew used to neighbourly behaviour ranging from aerial incursions to shock increases in finished wood duties that doubled the cost of a house extension. So when the Swedes suddenly woke up to Russian submarine raids, simulated bombing runs and other anti-social behaviour, it felt a bit like deja-vu.

The difference between then and now is of course Crimea. An aerial incursion on its own is a misdemeanour. But a pattern of incursions by the country that just jettisoned the taboo against aggression is in a different category. And, without justifying Iraq in 2003 for a moment, there really is no comparison. If Bush had formally annexed Saskatchewan to punish Canada for withdrawing from NAFTA, maybe then we could talk.

The silver lining in all this is that Putin’s regime is exposing itself as a rogue government rather than actually rolling back the non-aggression norm. For a sense of what the world would look like if Russia was the rule not the exception, one needs to look to earlier anniversaries. In my research on the Åland Islands of Finland, for instance, I came across a 77-year old article from the Spectator setting out a far more unruly Baltic in which the centrally-located archipelago constituted “the most important strategical issue in Northern Europe.”

At the time, various groupings involving Sweden, Germany, Russia and forces in Finland actively considered occupying and re-militarizing Åland in order to pre-empt the damage that could result from others doing it first. In effect, security was to be won at the expense of your neighbours rather than achieved in cooperation with them. Tensions around Åland never fully went away as indicated by recent revelations (here in Swedish) that Sweden maintained a secret occupation force in case the Soviet Union were to invade Finland.

But we truly are living in a different world now than in 1938, and one in which collective security is being tested as rarely before, but remains an article of faith. A striking example comes from Ben Judah’s recent reportage in Politico on the long lead-up to the annexation of Crimea. Former Polish foreign minister Radek Sikorski describes attempts in 2013 by Russia to offer Poland a stake in the partition of Ukraine – an offer that fell entirely flat in a democratic country that had long since oriented itself toward European integration:

Russia has attempted to involve Poland in the invasion of Ukraine, just as if it were a post-modern re-run of the historic partitions of Poland. “He wanted us to become participants in this partition of Ukraine,” says Sikorski. … This was one of the first things that Putin said to my prime minister, Donald Tusk, [soon to be President of the European Council] when he visited Moscow. He went on to say Ukraine is an artificial country and that Lwow is a Polish city and why don’t we just sort it out together. Luckily Tusk didn’t answer. He knew he was being recorded.”

The fact that Russia’s behaviour increases and emphasises its isolation will remain cold comfort as long as it remains unclear what Putin really wants. If, as some maintain, he just wants de facto security guarantees, then Minsk II can be the end of the Ukrainian conflict if the West can show enough strategic patience to calm the situation down. If as others claim, he will continue to push as far as he can go on every front, then Western strategic patience will be seen as encouragement. Hard not to be somebody’s useful idiot in this brave new world.

Rest in peace Mohamed Al-Sweii

Mohamed images-63221My colleague from my time with UNHCR in Libya, Sam Cheung, passed on the tragic news that Dr. Mohamed Al-Sweii was killed in the heavy fighting in Benghazi earlier this week. In the laconic delivery of the Alwasat article, as filtered through google translate:

…the deceased came out of his workplace Benghazi Medical Center to check on his family and as soon as he entered the area which is witnessing violent clashes was shot in the head, killing him instantly.

The first time I met Dr. Al-Sweii, in March 2012, he was waiting for us at a beachside cafe in Tripoli’s fashionable Gargaresh district. He received us with a dazzling grin, in big fashionable traffic cop glasses and an immaculate suit. I can’t recall exactly what I made of him at the time but I probably assumed at first he was just another one of the good-time boys cruising around liberated Tripoli in shiny cars and tight Italian t-shirts. My notes from early in the meeting are not without a dose of humanitarian snark in the margins (“not clear if has heard of the Guiding Principles on Internal Displacement”).

Whatever my first impressions, though, the rest of my notes spoke volumes. As the sun sank red to the Mediterranean, Mohamed walked me through a comprehensive aid delivery program built on the same goodwill and amateur enthusiasm that was powering every other government function and public service in Libya at the time. The difference being that his efforts targeted the virtual untouchables of the revolution, the communities driven out from their homes, persecuted and made to bear collective guilt for four decades of humiliation under the ousted dictator Muammar Gaddafi.

The next time I met Mohamed, it was in the cavernous bullet-riddled former Mercedes dealership in the center of town where he spent his days coordinating aid delivery, escaping to unwind in the cool breezes of Gargaresh only late in the afternoon. It was perhaps at this time I heard the whole story of how he had been a medical student in Benghazi when the revolution broke out and volunteered to fly back and forth to the front lines at Ajdabiya, rescuing battle-wounded overnight revolutionaries in a jerry-rigged ambulance.

Dr. Mohamed put a face on those turbulent times for me. It was him, young and idealistic, suppressing his fear by the things he could do with his own mind and his hands, who would build up a new and better country.

Now, three years after the revolution, Mohamed found himself back in Benghazi, once again risking his own life to save those injured in a far murkier and more ambiguous conflict. People like Mohamed, or the human rights lawyer Salwa Al-Bugaighis murdered last June in Benghazi are the most important resource Libya has. A country denied institutions cannot afford to lose the individuals who give of themselves most freely.

Rest in peace Doctor Mohamed. Libya, heal thyself.

“The Endorois decision” – Four years on, the Endorois still await action by the Government of Kenya

by Rebecca Marlin

Rebecca Marlin is currently the Legal Fellow at Minority Rights Group International (MRG) in London. She earned her B.A. from Wellesley College and her J.D. from Fordham University School of Law. During her time at MRG she will be working extensively with the Endorois to achieve implementation of the 2010 African Commission decision granting them rights to Lake Bogoria.

For the Endorois of Kenya’s Lake Bogoria, the process of reclaiming their land from the government of Kenya has been one step forwards and two steps back. In 2003, MRG and partner organisation Centre for Minority Rights Development (CEMIRIDE), acting on behalf of the Endorois Welfare Council, went before the African Commission on Human and Peoples’ Rights to demand that the Kenyan government recognise the rights of the Endorois to Lake Bogoria.

The Endorois had inhabited Lake Bogoria for over 300 years before being evicted by the government in the 1970s. In 2010, the Endorois won the landmark case Centre for Minority Rights Development and Minority Rights Group International (on behalf of Endorois Welfare Council) v Kenya. The land rights aspects of this groundbreaking decision have been discussed on this blog here and some of the regional implications here.

A pattern of empty promises emerges

Immediately following the Commission’s ruling in February 2010, the government of Kenya welcomed the decision, promising to begin implementation. A large celebration of the decision was held at Lake Bogoria; the Minister of Lands was in attendance and the momentous occasion was broadcast on television nationally. Kenya’s progressive National Land Policy had been enacted only a few months prior to the ruling and, with a forward-thinking new Constitution in the drafting stages, it seemed the decision might soon be translated into restitution of land, compensation, and benefit-sharing for the Endorois.

However, in May 2010, a report on implementation due to be submitted by the government of Kenya to the African Commission failed to arrive. Throughout 2010 and 2011, the government of Kenya failed to take any significant action on the recommendations. One MP openly challenged the Minister of Lands in Parliament about this delay in January 2011; the official response from the Minister was that he would not be able to take any action until he received an official sealed copy of the 2010 decision – despite the fact that the decision had been officially adopted and published one year earlier. A sealed copy was thereafter delivered to the Minister, but this did little to improve the situation.

When pressed on the matter, the government continues to affirm that it supports the decision and is taking steps to carry out the Commission’s recommendations. Yet, steps taken by the government indicate the exact opposite and new legislation on Lake Bogoria threatens to further separate the Endorois from their land.

Continue reading

Scotland chooses a bird in the hand

by Rhodri C. Williams

I declined to comment in advance on the Scottish referendum in part because I have been too busy to blog much at all, but also in part because it is none of my business. The wonderful thing about free and fair referenda like this is that they render outside observations almost entirely superfluous. Unless you actually have information that bears directly on the outcome – like EU experts – you are just projecting your own concerns onto somebody else’s drama – like the Spanish government panicking about Catalonia’s impending independence bid. Or China freaked out by any state reaction to regional agitation short of obsessive centralized control.

Perhaps the most spectacular example of such projection has been Russia’s cringe-inducing effort to project its new non-linear warfare to Caledonia. As described in the Guardian, a Russian monitoring team has rubbished the vote there because the rooms where the ballots were counted being “too big”. The same article quotes a Russia Today host questioning the high turnout as “what you would expect in North Korea”. Perhaps they are expecting the Scots to begin demanding an intervention by little green men? Perhaps they had a few geographically challenged paratroopers in the belly of the superannuated bomber they sent to buzz Scotland on referendum day?

As nicely skewered by the “Darth Putin – KGB” twitter account, Russia was clearly hoping that a truly legitimate independence referendum in Scotland would not only distract London from things like sanctions but also somehow cast unearned retroactive legitimacy on the shambles Russia staged in Crimea. However, as observed by Thomas De Waal at the time, the Crimea referendum was not only aggression masquerading as self-determination (even accepting that minorities can secede from states that have blatantly violated their rights, this did not apply in Crimea), but also a departure from what Scotland has now consolidated as international best practice for negotiated democratic decision-making on sovereignty.

Despite some post-referendum ugliness in Glasgow, the Russians’ blatant attempt to make hay on a genuinely democratic referendum, and their misreading of public sentiment afterwards may at least give both sides something to chuckle about. Is it really so inconceivable that placing the fate of a nation in its own hands would not inspire widespread and passionate participation? RT’s cynicism on this point says far more about the state of contemporary Russia than it does about Scotland. Notwithstanding the bruised feelings on both sides, Kevin McKenna points out that the combination of passion and civility throughout the campaign does all sides proud:

Scotland has delivered to the world a new gold standard in how modern political democracy ought to function. This was achieved during a struggle that was as passionate, raw and emotional as anything ever previously encountered in these islands. Yet not a bullet was fired and nor were there any physical casualties. The conduct of those chiefly involved in both campaigns was exemplary and, if not entirely chivalrous, certainly characterised by dignity and mutual respect.

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Petition against watering down of World Bank safeguard policies

Having obtained and analysed a draft of proposed new World Bank social and economic policies, my colleagues at Inclusive Development International (full disclosure – I am on the IDI Advisory Board) have circulated a petition demanding that the Bank follow its own first principles in this matter – in that the draft submitted for upcoming consultations should provide for conditions “no worse off” than those that prevailed under the old policy.

There are alarming indications that the current draft standard fails to meet even this minimum threshold. The full text of the petition setting out these concerns can be downloaded here, and I have reprinted IDI’s summary version below. Concerned individuals and organizations are welcome to join the petition anytime before Monday at 12 pm (EST) by sending an email to IDI Managing Director David Pred (david@inclusivedevelopment.net).

–//–

Dear Friends,

As many of you will have already heard (depending on which lists you’re on), the World Bank has presented to its Board an appalling draft of its new social and environmental safeguards policies.  The Board Committee on Development Effectiveness (CODE) will be meeting on July 30th to decide whether the draft is “fit for purpose” and should be opened up for public consultations.

A leaked version of the draft Social and Environmental Framework that we have reviewed effectively turns back the clock 30 years to the days before people and the environment were protected from harm by binding Bank policies.  At the same time, the Bank is proposing to significantly scale up its lending and get back in the business of high-risk mega-projects.  All this while slashing its operational budget and the resources available for project due diligence, monitoring and supervision.  Remember the Chixoy dam in Guatemala? The Sobradinho dam in Brazil?  Narmada in India?  We’ll be seeing plenty more of these human rights disasters if the Bank moves forward with this draft.

For those of us concerned about the global land grabbing crisis, this draft opens the floodgates to more massive land grabs, forced evictions, and dispossession of poor communities –  financed with our public purse.

Some of the most alarming proposed changes include:

  • An ‘opt out’ option for governments that decide they don’t want to apply the Indigenous People’s policy.
  • Major dilutions of the Bank’s current standards on “involuntary resettlement,” including the requirement for borrowers to submit and the Bank to review and approve – prior to project approval – a comprehensive resettlement plan that ensures affected people are not harmed and have an opportunity to share in the benefits of the project.
  • Exclusion of land titling projects from the coverage of the resettlement policy, leaving people like Cambodia’s Boeung Kak Lake community whose homes were demolished after they were determined not to have ownership rights by a Bank titling project completely unprotected from forced eviction. 
  • Totally inadequate protections against land-grabbing, despite an alarming reference indicating that Bank projects could involve large-scale transfers of land for agricultural investment. 
  • The elimination of essential appraisal and supervision requirements, which made the Bank itself accountable for non-compliance with the policies.

The World Bank released a statement last year pledging that its new safeguards would be informed by the Voluntary Guidelines on the Responsible Governance of Tenure and that “additional efforts must be made to build capacity and safeguards related to land rights.”  This commitment, which we welcomed at the time, has translated into one vague line in the draft framework about assessing risks or impacts associated with land tenure, which fails to articulate any policy objectives related to access to land or security of tenure, while many of the protections in the current Bank policies have been eviscerated as outlined above.

We have drafted the attached statement on land rights to send to CODE by Monday morning with the message that this draft is a non-starter for consultation and must be sent back for major revisions.   It has been endorsed so far by Asian Indigenous People’s Pact, Forest Peoples Program, Ulu Foundation, Urgewald (Germany), Friends of the Earth (US), Indigenous Peoples Links, Jamaa Resource Initiative (Kenya), Institute for Policy Studies, Center on International and Environmental Law, Lumière Synergie pour le Développement (Senegal) and Inclusive Development International. 

Will you add your voice to the global outcry?  Please consider signing on as an organization or an individual and sharing this with anyone else you think would want to join. 

In solidarity,

David and Natalie 
Inclusive Development International

 

 

Happy Midsummer’s Eve – and World Refugee Day

by Rhodri C. Williams

Every now and then the various preoccupations of this blog collide in unexpected ways. Today is such a day. Sitting here on Åland, its the first day of my summer vacation and time for the rites of Midsummer Eve, a pagan celebration the observance of which is an important part of the local community’s sense of itself. It is a day of rootedness in traditions carried out on a particular piece of turf since time out of mind by people connected through the ages by language and a sense of cultural continuity and the simple fact of their abiding presence.

All of which makes the contrast with this day’s other guise so jarring. It is World Refugee Day and not just any such day, but the one that has seen the greatest spike in conflict-related displacement since World War II. As this village’s 30 families raise the midsummer pole tonight, over 50 million people in other parts of the world have been violently uprooted from their communities, their traditions, their homes and their lands. It is a truly grim milestone and one that will cast a shadow over this and many future midsummer evenings to come.

International Humanitarian Law more clear and more debated than ever – updated

by Rhodri C. Williams

The immediate inspiration for this post was the fact that the International Committee for the Red Cross (ICRC) recently put online its vast and expanding database on which norms of International Humanitarian Law (IHL) are now deemed to have attained the status of customary international law (CIL), binding on all parties to armed conflicts whether or not they have ratified (or otherwise assented to be bound by) the treaties that give rise to these rules.

The database consists of both a comprehensive listing of the rules now deemed applicable and a compendium of practice, both that which supports the emerging rules and objections against its validity (anyone want to take some wild guesses on what states frequently feature in the latter category?) In the new online version, the practice of some seven further states and a number of international tribunals have been added. The new database constitutes a highly accessible and useful tool alongside ICRC’s additional databases on treaty ratification and application by States Parties.

The good news is that there has been considerable progress in this area. I have written on this blog and elsewhere about the role of soft-law documents like the 1998 UN Guiding Principles on Internal Displacement in consolidating a human rights based approach that has transformed humanitarian action in the post-Cold War period. This transformation has brought new possibilities for advocacy by pairing the cautiously phrased and state-centric provisions of IHL with the less ambiguous and more individual-oriented rules of international human rights law (IHRL).

Moreover, because advocacy for the Guiding Principles has focused on engaging willing states (at the risk of to some extent being co-opted by them), they have been far more successful than most soft-law standards, to the extent of having been incorporated in numerous national laws and policies (compiled by the Brookings Institution here) as well as a groundbreaking regional convention adopted by the African Union. This, in turn, has provided support for customary IHL to more vigorously address areas such as the prohibition against arbitrary displacement (including in internal conflicts), the right of voluntary return for internally displaced persons (IDPs) as well as the state obligation to respect their property rights.

However the new force and reach that a rights-based approach has given to IHL has brought new risks as well. Most obviously, by encouraging humanitarian actors to condemn violations of human rights (such as forced displacement) and demand accountability and remedies (such as restitution), the rights-based approach may create dangerously high expectations on the part of beneficiaries of aid while simultaneously undermining the perceived impartiality of humanitarian actors. In the worst cases – and we do not have to look far to find them – this limits the access of humanitarian actors to vulnerable populations and puts their own security at risk.

As a result, this ongoing retrenchment of the rules of conflict has opened up new policy debates, most recently in the extremely difficult humanitarian arena of the Syrian conflict. The latest iteration came with the 28 April 2014 publication of an open letter signed by 35 eminent legal scholars. The letter noted that 3.5 million civilians – over a third of those in urgent humanitarian need in Syria – are living in areas accessible only from neighbouring countries. However, because Syria has denied consent to humanitarian actors operating in Syria to send cross-border aid, these civilians face a catastrophe.

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