Published in the SCLS Law Review Vol. 1. No.1
[January 2018], at pp 36-42.
Being independent in 1971, Bangladesh
chose a Westminster type Parliamentary government. Whether the system as
devised in the Constitution was purely a Westminster one is debatable.[1] Like the British
parliamentary system, a Cabinet, predominantly drawn from amongst the members
of Parliament, was placed in charge of the Executive and made accountable to the
Parliament.[2]
Like the British Crown, President of the Republic was to act as a ceremonial
head of the state.[3]
The judiciary, however, was designed more in an American fashion - an
independent branch with a constitutionally secured tenure and power of judicial
review.[4]In a conspicuous deviation
from the Westminster norms, the members of parliament were constitutionally
restrained from voting against their respective political parties.[5] As will be argued later in
this note, this peculiarity of Bangladeshi system emerged as a key degenerating
factor. For a better understanding of the argument, a historical account of the
evolution of parliamentary politics in pre- and post-independence Bangladesh is
necessary.
The
Colonial Period
A pseudo-parliamentary system was
introduced in British India in 1909.[6] This was the first ever
opening of elections, voting and native representations in the legislative and
executive councils of India.[7]The British Government was
thereby seeking to streamline the unorganised armed rebellion in different
parts of India and put it into some organised political channels.[8]The Government of India Act
1909 was later substituted by the Government of India Acts, 1919 and 1935
consecutively.
While the substantial legislative and
executive power remained within the tight grip of the colonial authority, the
Indian people got the taste of politics, elections, deliberations and
ideological and sectoral clashes in a parliamentary fashion. However, a
negative side of the story is that Indians had a faulty start in parliamentary
politics. The newly coined legislature remained a mere
deliberative forum. The British Viceroy, Governor General and other
Governors would legislate, execute and rule.It will be seen later that neither
the Pakistani nor the Bangladeshi political forces could come out of the taboo
of this misguided introduction to parliamentary system.
The
Pakistan Period
Thanks to the Indian Congress Party’s
political wisdom, the post-1947 India managed to consolidate the parliamentary
system substantially.[9]Pakistan, on the other
hand, started its journey under Mohammad Ali Jinnah as the Governor General.
Under the scheme of the Independence of India Act 1947, Governor General was
considered analogous to the Crown in Britain. The Constituent Assembly elected
for Pakistan in 1946 was to take the place and role of legislature. Prime
Minister and his cabinet would hold the executive responsibilities.
Mohamad Ali Jinnah however made an
exception. Instead of remaining a disinterested head of state, Jinnah started
dominating the legislative and executive branches of the new republic. Hopes
for a sustainable Westminster Parliamentary system was thereby nipped in the
bud. Jinnah’s death was soon followed by murder of the first Prime Minister,
increased factionalism between the East and West wings of Pakistan and
ever-increasing control of the civil-military bureaucracy over the political
process. Later, political leaders and parties were suitably manipulated to
control the majority in Constituent Assembly. The 1946 Constituent Assembly was
“dismissed” in 1954 by Governor General Golam Mohammad and a second one was
later “constituted” by him.
By the time the secondConstituent Assembly
was giving the first ever constitution to Pakistan in 1956, presidency of
Pakistan and Governorship in East and West Pakistan fell in the hands of
civil-military bureaucrats. The politicians, political parties and politics in
general stood utterly exposed and discredited. Army Chief Ayub Khan soon graved
the power in 1958 and dismissed the 1956 constitution. It was replaced by one
of his liking. After series of peculiar experiments with the system, Ayub’s
dictatorship ultimately settled in another constitution in 1962.With some
trappings of Westminster parliamentary system and American presidential system,
the 1962 constitution was a sui generic system suitable to Ayub’s dictatorial
presidency. It lasted until 1969 when Ayub was forced to resign by a political
movement spearheaded in east Pakistan. Resigning Ayub however despised his own
constitution and invited the military to power again. Army Chief Yahiya Khan
climbing the presidency put the death knell to the coffin of united Pakistan.
After a bloody war of independence, Bangladesh became a sovereign peoples’ republic
in 1971.
Lessons
from Pakistan
Overall lessons Bangladesh might have
learnt from “internal colonial rule”[10] of Pakistan were
three-fold. First, constitution must be drafted and adopted the soonest.
Second, parliament would remain a mere deliberative forum
servile to the presidential desire unless either of a full pledged Westminster
parliamentary system or American Presidential system with checks and balances
was adopted. Third, political parties and politicians need be protected from
manipulation by the civil-military elites. Bangladesh attempted all the
three but with some half-hearted commitments and a less informed perspective.
Bangladesh’s
Experiments with Parliamentary Democracy (1972-1975)
In 1971, revolutionaries formed a
Constituent Assembly and opted for an absolutist presidential government as a
war time arrangement.[11] Upon release and return
of the Father of the Nation Bangabandhu (Friend of Bengal) Sheikh Mujibur
Rahman from Pakistani jail in early 1972, a provisional constitution order was promulgated.[12] The presidential system
was substituted by a parliamentary form of government. As per the new
arrangement, Constituent Assembly formed in 1971 would now be placed in the
position of legislature. Prime Minister and his Cabinet would be accountable to
the constituent assembly. President would stand a symbolic head of state.
The Constituent
Assembly, however, was struck by an inevitable accident. Committed to adopt a
constitution within the least possible delay (first lesson from Pakistani colonial
role), the provisional constitution stripped the assembly of its legislative
power. Constituent Assembly being tasked with the sole responsibility of
framing a constitution, Cabinet remained at the helm of law making. By the
time, the Constitution was adopted on November 4, 1972,[13] virtually the whole body
of administrative and statutory public law was built by presidential orders and
executive regulations. Constituent Assembly therefore essentially remained a
mere deliberative and legitimising body. A consequence adversarial to the
second lesson Bangladesh should have learnt from Pakistani colonial role. Quite
a defective start again, parliaments of Bangladesh would remain so throughout
the later part of its political history.
Second, driven by
the third lesson from Pakistani period and seeking to stabilise and consolidate
the political parties, an anti-defection clause, famously known as Article 70,
was introduced in the constitution of 1972. As per the rule, a member of
parliament elected in the nomination of a political party would be barred from
voting against that party in the floor of parliament. Whatever amount of
initial good intention might bethere, Article 70 later constituted a“Damocles’
sword”[14] upon the back benchers
from ruling and opposition parties alike. It paved the way for Prime Ministers’
dictatorial control over the party and parliament.
The
First Parliament
Bangabandhu formed his regular government
after the First Parliament election held in March 1973 under the new
constitution of December 1972. Marred by subversive political opposition,
degrading law and order situation, economic disasters and natural calamities,
Bangabandhu declared emergency, called for his “Second Revolution” and decided
to alter the parliamentary system into a French presidential one.[15]Unlike the French system,
however, an all-party-combined-in-one system was established in February 1975.[16] President was made head
of the state and government. Parliament and independence of Judiciary was
substantially curtailed. [17]
Bangabandhu’s
Second Revolution unfortunately was short lived. Pro-Pakistani elements within
Bangladesh military seized the opportunity of his degrading popularity and
staged a brutal coup on 15 August
1975. Bangabandhu was killed along with almost all his family members, except
the two daughters one of whom, Sheikh Hasina,now leads his political party
Awami League and remains the Prime Minister of Bangladesh. Martial law was
proclaimed and it continued in forcetill 1979.
Martial
Laws and the Presidential Governments (1975-1990)
Bangladesh military followed the foot step
of their Pakistani predecessors. A series of coup and counter coup placed Major
Zia in the Presidency. Like Ayub Khan, Zia sought to legitimise his regime by
civilianising it. He continued the presidential system introduced by
Bangabandhu but wanted to bring back the multi-party system as well. Election
to the Second Parliament was held in 1979. Zia’s hastily constituted
party, Bangladesh Nationalist Party (BNP),got absolute majority over Awami
League. Awami League got revived several years after Sheikh Mujib’s
assassination. Status of the parliament under Zia’s presidential government
however remained unclear.
While Zia’s cohort
boosted the Second Parliament as an “Independent and Sovereign” one, its
inability to make the government answerable, president’s absolute authority to
dissolve the parliament and consistent by-passing of parliament through
presidential ordinances earned it the badge of a “rubber stamp”.[18] Second parliament
legitimised rather legislate.
In 1981, Major Zia
was assassinated by the freedom fighters’ section within the army. Army Chief
Hossain Mohammad Ershad seized the opportunity and captured power. After two
years of absolute Martial Law, Ershad also sought to civilianise his regime. As
part of the process, formed his own political party, Jatya Party (JP) and
arranged election to the Third Parliament in 1986.Awami League under
Sheikh Hasinaparticipated the election. BNP under Begum Khaleda Zia (Major
Zia’s widowed wife) boycotted it. The result was widely believed to be rigged
in favour of Ershad’sJatya Party. Though Awami League took the opposition
bench, the third parliament suffered from huge credibility crisis. Facing
legitimacy crisis, Ershad dissolved the Third Parliament and called for election
to the Fourth Parliament in 1988. This time, all the major political parties,
Awami League included, boycotted the election. The Fourth Parliament
comprised of some otherwise unknown political parties mockingly termed as
“Domesticated Opposition Parties”. Facing mass upsurge of late 1990, Ershad had
to dissolve the Fourth Parliament as well and quit.
Issues
haunting the post-1990 Parliaments
Operating under presidents hailing from
the garrison, the second, third and fourth parliaments had very little to offer
in terms of democratic legislation, oversight and policy formulation.[19]Apart from being used as a
legitimising tool for the presidential steps, parliaments barely got a place in
national discourse. Ordinances promulgated by the presidents massively outnumbered
the laws passed by parliaments. This insignificant existence of parliament as
an institution during the first two decades of independent Bangladesh
(1971-1991) thereforeconstituted a principal agenda for anti-Ershad movement.
Parties struggling for Ershad’s demise promised to forestall parliament in the
centre of democratic governance in Bangladesh.Reviving the parliamentary
democracy, however, was not the only challenge facingBangladesh.[20]Asshown in later
experiences, survival of parliamentary democracy in Bangladesh would depend on
some other issues directly impinging upon it.[21]
First, systematic
subjugation of the Election Commission to political executives appeared the
foremost stumbling block. Concerns surrounding a free, fair and credible parliamentary
election would occupy Bangladesh’s democracy in the days ahead.[22] Constitution would be
amended later to introduce an apolitical system of election time government in
1996.[23]That again came for a huge
prize. Despite an encouraging start, the Fifth Parliament (1991-1995) was
virtually paralyzed by continuous boycotting of the opposition parties pressing
for the apolitical caretaker government.[24]More disturbingly, the
caretaker system itself became controversial later. It was declared
unconstitutional[25]
and scrapped by Awami League in 2011.[26] Main opposition party BNP
however remained adamant over retaining the caretaker system and boycotted the Tenth
Parliamentary election of 2014. A severely incapacitated Election
Commission now remains in the same place as it were in 1980s. [27]
Second, the
historical distrust and personal animosity between Awami League Leader Sheikh
Hasina and BNP Leader Begum Khaleda Zia has haunted the development of
bi-partisan parliamentary democracy in Bangladesh. Following Awami League’s
stiff opposition in the Fifth Parliament, Begum Khaldea Zia’s party staged
almost similar show of boycott and disdain to the Seventh Parliament
(1996-2001).[28]Two
parties switching the bench by turn, the trend continued throughout the Eighth
(2001-2006) and Ninth Parliament (2009-2014).[29]
Third, the grip of
Article 70 appeared much wider than it was originally thought. Even a glossy
analysis of the working of Fifth, Seventh, Eighth, Ninth and Tenth
(2014-Present) Parliament would reveal that Article 70 has effectively
tightened the tongue of the ruling and opposition party back benchers.
Successive parliaments have invariably failed in criticising the governmental
policies and action, let alone making it accountable.[30] Absence of democratic
practice within the political parties coupled with the rise of family dynasty
in politics has been able to effectively shut down the parliamentarians in the
floor.[31] Parliamentary question,
though regularly asked and answered, disappointingly fail to touch upon key
accountability issues of the government and bureaucracy.[32]
Fourth, though the parliamentary committee system has been
consolidated to some extent,[33]it has grown asymmetrically vis-à-vis the
executive and bureaucratic apparatus of the state.[34]Though the tendency to promulgate
presidential ordinances has declined recently, the political governments have
been invariably seen to hastening the legislative proposals through the floor
and there by effectively by-pass the committee stage.[35]Research, secretarial and
political support for the parliamentary committees remain a mirage.[36]Most importantly, there is
an apparent lack of political will in changing the status quo and allowing the
committee system to stand on its foot.[37]
Fifth,Speakers and
Deputy Speakers ofsuccessive parliamentsremained loyal to their party bosses
and showed reluctance to assert least possible discretion beyond the party
line. This has resulted in an endemic disincentive for the opposition parties
to air their opposition through parliamentary channels.[38] Violence on the street
and reckless use of force as a means of demonstration and control have faded
much of the glories a workable Westminster parliamentary system is expected to
possess.[39]
Sixth, prolonged
involvement of military in the politics has substantially weakened Bangladesh’s
prospect for civilian supremacy in national discourse. Interventionist tendency
of the armed forces and the political parties’ interest in keeping the military
in touch and confidence has resulted in the forces consistently refusing to
submit themselves to parliamentary oversight. This has put Bangladesh’s
parliamentary democracy in fault line.[40]
Seventh, rise of a
bourgeois elite pumped up by illegal channelling of state resources in private
hands during the 1970-80s[41] has discouraged open and
fair access for all to the political process. Instead of favouring
accountability and good governances, the political
elites tend to tolerate corruption, lobbying and backdoor settlement with party
bosses. [42] It is therefore not unexpected that
parliamentarians picked up through such a process would be less interested in
seeing the parliament working in right spirit.[43]
Concluding
Note
The historical and institutional issues
analysed above shows how and why the Westminster parliamentary system adopted
in 1972 failed to live up to the mark. In Bangladesh Parliament as an
institution has failed to attract the attention, respect and stature necessary
for a democratic institution.[44]People of Bangladesh in
general has shown least interest in petitioning the parliament. The Parliament
has shown the least sensitiveness to popular concerns.[45]In Bangladesh, a
‘democratic’ parliament thereby continue to exist with much of its democratic
semblances.
* Assistant
Professor of Law, University of Chittagong and PhD Candidate at King’s College
London. This is an initial concept note written for submission to Professor
Robert Blackburn QC, my supervisor at the Dickson Poon School of Law, King’s
College London under the University of London, UK (October 2017).
[1] Nizam Ahmed
(1998), In search of institutionalisation: Parliament in Bangladesh, The
Journal of Legislative Studies, Vol. 4, Issue 4, pp. 34-65 at p 40. Available: http://dx.doi.org/10.1080/13572339808420572(Accessed on October
15, 2017).
[2] Constitution of
the Peoples Republic of Bangladesh (1972), Articles 55 and 57.
[3]Ibid,
Article
48(3). Article 48(3) almost conclusively restricts the Presidential authority
within the chain of the Prime Ministerial advice.
[5]Ibid,
Article
70. Article 70, famously known as the Anti-Defection Clause, puts the Members
of Parliament in the risk of losing their seat in case they decide to vote in
parliament against the party line.
[6] The Government of
India Act 1909 (Also known as the Morley-Minto Reform Act named after the
Secretary of State for India Lord Morley and the Viceroy of India Lord Minto).
[7] By 1909, the two
major political parties of India were already formed (Indian Congress in 1885
and Muslim League in 1906).
[8]Minto-Morley Reforms (1909),http://historypak.com/minto-morley-reforms-1909/ (Accessed on 22
October 2017)
[9]Zillur R. Khan
(1997), Bangladesh's Experiments with Parliamentary Democracy, Asian Survey,
Vol. 37, No. 6 (Jun., 1997), pp. 575-589 at p 575, University of California, Available:
http://www.jstor.org/stable/2645531 (Accessed on
October 15, 2017).
[11] The Proclamation
of Independence 10 April 1971 annexed to the Constitution of Bangladesh as the
Seventh Schedule.
[12] The Provisional
Constitution of Bangladesh Oder, 1972
[13] The Constitution
came into force from 16December 1972, the first anniversary of the independence
of Bangladesh.
[14] Justice Badrul
Haider Chowdhury, Former Chief Justice of Bangladesh quoted in A.K.M Shamsul
Huda, Constitution of Bangladesh, Vol 2, Rita Court, Chittagong, Bangladesh,
1997, p 560.
[16] Famously known as
BAKSAL (Bangladesh KrishakSramikAwami League), the party was placed at the helm
of a soviet style socialist system.
[17] The Constitution
(Fourth Amendment) Act 1975.
[18]AzizulHaque
(1980), Bangladesh 1979: Cry for a Sovereign Parliament, Asian Survey, Vol. 20,
No. 2, A Survey of Asia in 1979: Part II (Feb., 1980), pp. 217- 230 at p.
221-2, University of California Press.
Stable URL: http://www.jstor.org/stable/2644025 (Accessed on 15
October 2017)
[19] Nizam Ahmed
(2001) Parliamentary committees and parliamentary government in Bangladesh,
Contemporary South Asia, 10:1, 11-36, at p. 13-4, Available: http://dx.doi.org/10.1080/09584930120062010 (Accessed on
October 15, 2017).
[20]TalukderManiruzzaman
(1992), The Fall of the Military Dictator: 1991 Elections and the Prospect of
Civilian Rule in Bangladesh, Pacific Affairs, Vol. 65, No. 2 (Summer, 1992),
pp. 203-224, University of British Columbia Stable URL: http://www.jstor.org/stable/2760169 (Accessed on 15
October, 2017)
[21] Craig Baxter
(1992), Bangladesh a Parliamentary Democracy, if They Can Keep It, Current
History; Mar 1, 1992; 91, 563; Periodicals Archive Online. pp. 132-36
[22] Nizam Ahmed
(2011), Critical elections and democratic consolidation: the 2008 parliamentary
elections in Bangladesh, Contemporary South Asia, 19:2, 137-152 at p. 149;
Online: http://dx.doi.org/10.1080/09584935.2011.563282 (Accessed on:
October 15, 2017)
[23] The Constitution
(Thirteenth Amendment) Act, 1996.
[24]Craig Baxter
(1996), Bangladesh: Can Democracy Survive? Baxter, Current History; Apr 1996;
95, 600; ProQuest, pp. 182-186
[25] Civil Appeal No.
139 of 2005 with Civil Petition for Leave to Appeal No. 596 of 2005, at
www.supremecourt.gov.bd/scweb/documents/526214_13thAmet. pdf
[26] The Constitution
(Fifteenth Amendment) Act 2011
[27] Ali Riaz (2014),
Bangladesh’s Failed Election Journal of Democracy, Volume 25, Number 2, April
2014, pp. 119-130 at p. 121, Johns Hopkins University Press, Available: https://doi.org/10.1353/jod.2014.0034 (Accessed on
October 15, 2017).
[28]Boycotted by Awami
League and other major political parties, the Sixth Parliamentary election
didn’t receive public endorsement. The Sixth Parliament was dissolved within
months.
[29]EloraShehabuddin (2000), Bangladesh
in 1999: Desperately Seeking a Responsible Opposition, Asian Survey, Vol. 40,
No. 1, A Survey of Asia in 1999 (Jan. - Feb., 2000), pp. 181- 188, University
of California Press, Available online:http://www.jstor.org/stable/3021232 (Accessed on 15 October 2017)
[30]Muhammad
Mustafizur Rahman (2008), Japanese Journal of Political Science, Vol 9 (1), pp.
39–62 at p 47-48, Cambridge University Press. Available: https://doi.org/10.1017/S1468109907002812 (Accessed on:
October 15, 2017).
[31] Ahmed
ShafiqulHuque, (2011) "Accountability and governance: strengthening
extra‐bureaucratic mechanisms in Bangladesh", International Journal of
Productivity and Performance Management, Vol. 60 Issue: 1, pp.59-74 at p 68,
Available: https://doi.org/10.1108/17410401111094312 (Accessed on
October 15, 2017)
[32]Salahuddin
Aminuzzaman (1993), Institutional Processes and Practices of Administrative Accountability:
the role of JatiyoSangsad of Bangladesh, South Asian Studies; Jul 1, 1993; 10,
2; pp. 44-61 at p 55.
[33] The Seventh
Parliament amended the parliamentary rules of procedure and provided for
formation of parliamentary committees within the First Session of the
Parliament. The Ninth Parliament allocated some committee chairmanship to the
opposition party.
[34] A.T.M. Obaidullah
(2011), Standing Committees on Ministries in the Bangladesh Parliament: The
Need for Reorganisation; South Asian Survey 18(2) 317–342 at p 322, SAGE
Publications, available: https://doi.org/10.1177/0971523113513375 (Accessed on:
October 15, 2017)
[35] Nizam Ahmed
(1997) Parliament‐executive relations in Bangladesh, The Journal of Legislative
Studies, 3:4, 70-91 at p 77-8, http://dx.doi.org/10.1080/13572339708420529; Nizam Ahmed
(1998) Reforming the parliament in Bangladesh: Structural constraints and
political dilemmas, Commonwealth & Comparative Politics, 36:1, 68-91 at p
71, http://dx.doi.org/10.1080/14662049808447761 (Accessed on
October 15, 2017).
[36] Nizam Ahmed and
Shahnaz Khan (1995), The Development of Parliamentary Oversight in Bangladesh:
A Research Note Author(s): Source: Legislative Studies Quarterly, Vol. 20, No.
4 (Nov., 1995), pp. 573-583, Washington University, Available: http://www.jstor.org/stable/440194 (Accessed on
October 15, 2017)
[37] Muhammad
MustafizurRahaman (2010), The Limits of Foreign Aid in Strengthening
Bangladesh's Parliament: Analysis of the U.N.'s Strengthening Parliamentary
Democracy Project, Asian Survey, Vol. 50, No. 3 (May/June 2010), pp. 474-496 at
p 483-94, University of California Press,http://www.jstor.org/stable/10.1525/as.2010.50.3.474 (Accessed on
October 15, 2017)
[38]Rounaq Jahan and
Inge Amundsen, The Parliament of Bangladesh: Representation and Accountability
CPDCMI Working Paper 2 at p 21-27, https://www.cmi.no/publications/file/4422-the-parliament-of-bangladesh.pdf (Accessed on:
October 15, 2017)
[39] Nizam Ahmed
(2003), From Monopoly to Competition: Party Politics in the Bangladesh
Parliament (1973-2001), Pacific Affairs, Vol. 76, No. 1 (Spring, 2003), pp.
55-77 University of British Columbia Stable URL: http://www.jstor.org/stable/40023989; Nizam Ahmed
(1997), Parliamentary Opposition in Bangladesh: A Study of its Role in the
Fifth Parliament, Party Politics, Vol 3. No.2 pp.147-168, SAGE Publications, http://journals.sagepub.com/doi/pdf/10.1177/1354068897003002001, M. Moniruzzaman
(2009) Parliamentary Democracy in Bangladesh: An Evaluation of the Parliament
during 1991–2006, Commonwealth & Comparative Politics, 47:1, 100-126, DOI: https://doi.org/10.1080/14662040802659017 (Accessed on: 15
October 2017)
[40] Syed Imtiaz Ahmed
(2006), Civilian supremacy in democracies with ‘fault lines’: The role of the
parliamentary standing committee on defence in Bangladesh, Democratization,
13:02, 283-302Available: http://dx.doi.org/10.1080/13510340500523994 (Accessed: October
15, 2017).
[41]Rounaq Jahan
(1976), Members of Parliament in Bangladesh, Legislative Studies Quarterly,
Vol. 1, No. 3 (Aug. 1976), pp. 355-370, Washington University Stable URL: http://www.jstor.org/stable/439502 (Accessed: 15
October 2017).
[42]QuamrulAlam and
Julian Teicher (2012), The State of Governance in Bangladesh: The Capture of
State Institutions, South Asia: Journal of South Asian Studies, 35:4, 858-884
at p. 864; Online: http://dx.doi.org/10.1080/00856401.2012.702723 (Accessed on: 15
October 2017).
[43]Rounaq Jahan
(2015), The Parliament of Bangladesh: Representation and Accountability, The
Journal of Legislative Studies, 21:2, 250-269, AT P. 252, Online: http://dx.doi.org/10.1080/13572334.2014.975470(Accessed on: 15
October 2017).
[44]A survey conducted
in 2012 shows people of Bangladesh placed parliament even beneath the army when
the question of institutional trust comes of trust come (Steinar Askvik
andIshtiaq Jamil (2013), The Institutional Trust Paradox in Bangladesh,
Springer Science+Business Media New York, p 466-470)
[45]Statistics show
that only three out of the 248 public petitions submitted to parliament between
1991 and July 2010 were accepted. The rest were either rejected, withdrawn,
settled or simply lapsed (Nizam Ahmed (2012), Parliament and Citizens in Asia:
The Bangladesh Case, The Journal of Legislative Studies, 18:3-4, 463-478, at p
467-8, Online: http://dx.doi.org/10.1080/13572334.2012.706056(Accessed on; 15
October 2017))
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