Addressing the Principal Root Cause of Forced Migration Through a Vibrant Peace Movement

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By James C. Simeon, Associate Professor, School of Public Policy and Administration, Faculty of Liberal Arts & Professional Studies, York University, Email: jcsimeon@yorku.ca

It is now common knowledge, or should be, that the mass production of refugees is overwhelmingly due to wars. Astonishingly, more than half of the world’s refugees (52%) and others in need of international protection come from just three countries: Syrian Arab Republic; Ukraine; and Afghanistan.[1] In fact, 87 percent of all people who were refugees at the end of 2022 came from only 10 countries and all of them wracked by war, save Venezuela, a special case.[2] The other six included: South Sudan; Myanmar; Democratic Republic of Congo; Sudan; Somalia; and Central African Republic.[3] Many of these countries have been embroiled in wars for decades. The relationship between war and forced displacement and refugeehood is crystal clear. The time for addressing seriously the principal root cause of mass forced migration is long overdue. The world must become a more peaceful place or the ever-escalating numbers of those being forcibly displaced will continue to grow. It is likely well past the capacity of the world’s international organizations and humanitarian agencies to manage and to deal appropriately with all those who have been forced to flee.[4]

What is called for, and a necessity, as quickly as reasonably possible, is a reinvigorated international peace movement and a broad-based coalition of like-minded States, and grassroots organizations and advocates, with the support of the United Nations (UN), to apply pressure on those States that have been at war for decades to bring a cessation to hostilities and to commence a peace negotiation and settlement. But, even more significantly, we must all come to accept that there is a fundamental “right to peace” that can never be breached, and that war is an abomination that not only unleashes the most serious international crimes, but mass produces refugees and leaves in its wake nothing but destruction and human misery and results in the severest violations of our human dignity. Once we are able to achieve such a global paradigm shift in consciousness, can we ever hope to rid the world of serious political violence that produces mass forced displacement. Consequently, those who work to advance the rights of refugees must align with those who are working to advance the cause of world peace. Together, they can work toward achieving a more peaceful world while advancing the protection of the world’s forcibly displaced and, especially, refugees.

The World’s Rapidly Escalating Political Violence

This is an exceedingly enormous challenge, to say the very least, given the number of conflicts that are raging in the world at present. Consider the following relevant and important statistics regarding the state of the world’s conflicts. The Geneva Academy’s Rule of Law in Armed Conflict Online Portal (RULAC) is monitoring 114 armed conflicts in the world today. Some of these armed conflicts are recent and others have been raging for more than 50 years.[5]

Using the Uppsala Conflict Data Program definition, which described war as “a state-based conflict or dyad which reaches at least 1000 battle-related deaths in a specific calendar year,” and the fatality figures for conflicts, that include any combatants killed in action as well as any civilians who were deliberately killed (for example, by bombings or other attacks), the World Population Review, Countries Currently at War/Countries at War 2024, lists the following: 14 countries with 1,000 to 10,000 casualties (2022), and 39 countries with 1 to 10,000 casualties (2023).[6] This still represents a large portion of the 193 Member States of the United Nations – more than 20 percent or one-fifth of the Member States of the UN.

According to the Armed Conflict Location and Event Data Project, a crisis monitoring group in the United States, notes the following:

Conflict is now widespread and pervasive: 12% more conflict occurred in 2023 compared to 2022, and ACLED records an increase of over 40% compared to 2020. One in six people live in an actively conflicted area. In 234 countries and territories covered by ACLED, the majority — 168 — saw at least one incident of conflict in 2023. Over 147,000 conflict events are recorded, and at least 167,800 fatalities.[7]

The essential point here is that the world presently is a violent place with hundreds of thousands of people being killed in political violence, including wars, however, they are defined and measured. But, just as significantly, hundreds of millions of people are being forcibly displaced because of all these protracted armed conflicts and wars that are taking place across the globe. The UNHCR alone anticipates that they will have to provide for 130.8 million forcibly displaced people in 2024.[8]

Modern Warfare: The Breeding Ground for the “Atrocity Crimes”

Sadly, modern warfare is the breeding ground for the “atrocity crimes:” war crimes; “ethnic cleansing;” crimes against humanity; and genocide. One should probably include the crime of aggression here as well. It is, undoubtedly, a serious international crime. Indeed, it has been called the supreme international crime, and has been, of course, criminalized, as the “crime against peace” or aggression.[9]
As are all the others, under the Rome Statute of the International Criminal Court (ICC), save “ethnic cleansing” that is not a distinct international crime per se.[10] It likely falls under crimes against humanity.[11]

Nonetheless, you may consider the assertion that the “atrocity crimes” are rife in modern warfare to be a rather ‘bold and contentious’ assertion. But if you were only to consider what is commonly practiced in modern warfare then you may come to agree. For instance, any or all of the following: the deliberate targeting of civilian non-combatants and infrastructure such as power plants, water facilities, bridges and dams; the deliberate targeting of ambulances and hospitals, the use of terrorism to instill fear to break the morale of the population and its military forces; the use of torture to extract information from people and to terrorize the population; the use of prohibited weapons such as poison gas, incendiary weapons, including, white phosphorus, thermobaric weapons or other prohibited weapons such as vacuum bombs, barrel bombs, and indiscriminate bombardments. And, these examples are only the tip of the iceberg, as it were.

People flee war zones not only because they do not wish to become collateral damage or be caught in the crossfire of opposing sides but because of the ‘atrocity crimes’ that can be inflicted on them. Being deliberately targeted because you are a national of the country that is being invaded.[12] Consider what has been happening in Ukraine, with the investigations of serious international crimes in the Russian-Ukraine War. More than 50 Russian soldiers have been convicted and sentenced for crimes committed in Ukraine. Ukraine has registered more than 98,000 cases in the courts for the crimes of aggression and war crimes.[13]

On March 17, 2023, the Pre-Trial Chamber of the International Criminal Court, after an investigation for war crimes, crimes against humanity, and genocide in Ukraine, issued arrest warrants for Vladimir Putin, President of the Russian Federation, and Maria Lvova-Belova, Commissioner of Children’s Rights in the Office of the President of the Russian Federation, on charges of allegedly being responsible for the war crime of unlawful deportation of population (children) and that of the unlawful transfer of population (children) from occupied areas of Ukraine to the Russian Federation under articles 8(2)(a)(vii) and 8(2)(b)(viii) of the Rome Statute.[14] And, about a year later, the Pre-Trial Chamber of the ICC also indicted Sergei Ivanovich Kobylash, Lieutenant General of the Russian Armed Forces and Commander of the Long-Range Aviation of the Aerospace Force, and Viktor Nikolayevich Sokolov, Admiral of the Russian Navy and Commander of the Black Sea Fleet, each are allegedly responsible for the war crime of directing attacks on civilian objects (article 8 2(b) (ii)) and war crimes for causing excessive incidental harm to civilians or damaging civilian objects (article 8 2(b)(iv)) and crimes against humanity of inhuman acts (article 7 1(k)) of the Rome Statute.[15]

And, further, South Africa brought an application against Israel on the Convention on the Prevention and Punishment of the Crime of Genocide for the conduct of its war with Hamas in Gaza.[16] On January 26, 2024, the International Court of Justice (ICJ) issued its Order on the application for provisional measures that essentially called for Israel to fulfill its obligations under the Convention.[17] And, on March 6, 2024, South Africa requested additional provisional measures and a modification of the January 26, 2024 ICJ Order based on a change in the deteriorating situation in Gaza and, in particular, the spread of famine and starvation. The ICJ issued a modification of its Order of January 26th and called for Israel, without delay and in full co-operation of the United Nations, to allow for the urgently needed humanitarian assistance in the Gaza.[18] This case, in the midst of an ongoing war, is hugely important and potentially a significant one for the ICJ, and ongoing war in the Gaza.[19]

Undoubtedly, modern warfare is exemplified by the “atrocity crimes,” in addition, of course, to the death, destruction, trauma, and mayhem and the mass forced displacement that are a direct consequence. These are precisely the reasons why ‘perpetual peace’ has been sought so fervently for so long, and, especially, since war has become illegal and the legal use of force, highly sanctioned and constrained, through the establishment of the United Nations in the 20th Century.[20]

The Self-Evident Benefits of Ending Existing Wars

What can be done to reduce the number of wars and armed conflicts in the world today? By doing so it would not only start reducing the number of the world’s forcibly displaced people and, specifically, refugees, it will also decrease the number of people who are killed, maimed, or otherwise traumatized by extreme political violence.

If only one of the three major wars that are raging in Syria, Ukraine, or Afghanistan, can be ended then this could have a dramatic effect on the number of the world’s refugees. All three are now protracted armed conflicts that have been ongoing for years and in the case of Afghanistan since at least 2001, but, even prior to that.[21] The prospects for ending the Russia-Ukraine War anytime soon seems highly unlikely and, likewise, for the ongoing conflicts in Syria and Afghanistan.

The war between Hamas and Israel in the Gaza does not appear to be likely settled in the near term either, despite the International Court of Justice’s ruling on the preliminary measures.[22]

The United Nations is, of course, tasked with the maintenance of international peace and security.[23] Yet, as noted above, the extent of ongoing conflict in the world suggests that much more needs to be done if the current trends are to be altered and reversed. Undoubtedly, the world would be much worse off without the UN, but, despite its peacemaking, peacekeeping, and peacebuilding efforts the situation appears to be getting progressively worse.[24]

What also must be acknowledged and reined in, curtailed, and controlled is the arms manufacturing and sales industries that are profiting excessively off all the wars and protracted armed conflicts in the world today.[25] As Amnesty International notes,

A global Arms Trade Treaty (ATT) imposing strict rules to regulate international arms transfers has been in force for over five years, yet global arms trading is still on the rise and continues to fuel human rights abuses. This is because some of the largest arms exporters like Russia and the USA have not ratified the treaty. And even countries that have ratified the treaty fail to comply with it, and transfer weapons and munitions to places where they risk being used to commit serious violations of international humanitarian law, including possible war crimes.[26]

The Stockholm International Peace Research Institute provides a wealth of information on arms and military expenditures, international arms transfers, arms export controls, and multilateral sanctions and embargoes, among other key items that fuel wars and armed conflicts.[27] It has been reported that the global defence spending increased by nine percent in 2023 to some $2.2 trillion.[28] Further, it is anticipated that defence spending will continue to increase due to “heightened geopolitical tensions.”[29] Reducing the number of wars and protracted armed conflicts will not only reduce military expenditures but, hopefully, redirect some of the savings to other pressing priorities such as social programs; for example, health care, housing, education, childcare, environmental protection, and so on.

Advancing the Peace Agenda to Resolve the Ever-Escalating Numbers of Those Forcibly Displaced

What is needed the most is a reinvigorated international peace movement that demands that wars and armed conflicts need to end. The effectiveness of the peace movement in previous decades led to a number of major achievements. Two of these include the anti-Vietnam War protests of the 1960s that ended the war and the anti-nuclear movement of the 1980s that led to the signing of the Intermediate-Range Nuclear Forces Treaty (INF) in Washington, DC, in 1987.[30] A reinvigorated peace movement could contribute to ending one or more of the major conflicts in the world today that are contributing to the ever-escalating mass forced displacement.

If war is the principal cause of forced displacement, then the peace movement is the natural ally to the protection of refugees. Ending and preventing wars from occurring will not only save lives but save all those who might be forced to flee their homes to save their lives and to be able to exercise their most fundamental human rights.

What is further needed, in combination with a reinvigorated global peace movement, is a broad-based coalition of like-minded States and grassroots organizations and activists and the support of the United Nations to apply sustained pressure on those States that have been embroiled in armed conflict for decades to reach a cessation of hostilities and to commence peace negotiations and a settlement.

There should be a coming together of UN agencies such as UNHCR (Office of the United Nations High Commissioner for Refugees), IOM (International Organization for Migration), and UNRWA (United Nations Relief and Works Agency for Palestine Refugees in the Near East) to try and spearhead “peace, humanitarian, and development” initiatives to move as many wars and armed conflicts as possible towards a ceasefire and peace negotiations.[31] It is in the interest of all these UN agencies, and the UN, as a whole, to end the forced displacement of all those as a consequence of wars or armed conflicts.[32]

In this regard, there may be an advantage to starting out with the smallest conflicts, in terms of the size of the States involved, to see whether it would be possible to end these conflicts first. Progressively moving on to concentrate on ever larger wars and armed conflicts. The size of the States matters as it would be presumably easier to influence smaller States than larger ones. Trying to influence and exert pressure on a superpower is obviously exceedingly difficult, in contrast, to a smaller State with less economic and geopolitical influence.

There also must be a paradigm shift with respect to how peace is perceived in the world. Firstly, it is important to acknowledge that there is a human right to peace.[33] The United Nations General Assembly adopted the Declaration on the Right to Peace in 2016, and in 1984 the UN General Assembly adopted the Declaration on the Rights of Peoples to Peace.[34] It is patently obvious that without peace there cannot be the full enjoyment of any other fundamental human rights. When the right to peace is accepted as one of the most important, if not the most significant and essential human right, and war is accepted as an abomination that severely breaches all essential human rights and human dignity, including, of course, the right to peace, then, death and mayhem, chaos, and, the moral turpitude that is wrought by war will continue to be the order of the day[35] and the world will continue to experience ever-escalating numbers of the world’s forcibly displaced persons. Achieving such a new consciousness and understanding will fall largely, undoubtedly, on our world’s educators, from JK (junior kindergarden) through to post-doctoral studies.[36] One can only hope that all the educators of the world are up to undertaking this tremendous challenge.

[1] UNHCR, Global Trends, Forced Displacement in 2022. (Copenhagen, Denmark: Statistics and Demographic Section, UNHCR Global Data Service, 2023),  https://www.unhcr.org/sites/default/files/2023-06/global-trends-report-2022.pdf. (accessed January 28, 2024), p. 3.

[2] Ibid., p. 19.

[3] Ibid., See Figure 9, Refugees, people in refugee-like situations and other people in need of international protection by country of origin – end of 2022.

[4][4] UNHCR, “High Commissioner’s forward,” Global Appeal 2024, https://reporting.unhcr.org/global-appeal-2024-6383. (accessed January 29, 2024) The UNHCR’s budget requirements for 2024 are $10.622 billion US. (p. 8)

[5] Geneva Academy, RULAC: Rule of Law in Armed Conflicts. Geneva Academy of International Law and Human Rights, 2024.

https://www.rulac.org/#:~:text=Launched%20in%202007%2C%20the%20Rule,conflict%20under%20international%20humanitarian%20law. (accessed January 29, 2024)

[6] “Countries Currently at War/Countries at War 2024,” World Population Review, 2024, https://worldpopulationreview.com/country-rankings/countries-currently-at-war. (accessed January 29, 2024)

[7] Armed Conflict Location and Event Data Project (ACLED), ACLED Conflict Index, Updated January 2024, “How much conflict is occurring in the world?” https://acleddata.com/conflict-index/. (accessed January 29, 2024)

[8] UNHCR, Global Appeal 2024, Geneva, Switzerland, UNHCR, 2024, https://reporting.unhcr.org/global-appeal-2024-6383. (accessed January 30, 2024), p. 6.

[9] Rome Statute of the International Criminal Court, adopted in Rome 17 July 1998, in force 1 July 2002, UNTS, vol. 2187, No. 38544. Article 8bis, Crime of aggression; Article 15bis, Exercise of jurisdiction over the crime of aggression (State referral, proprio motu); Article 15ter, Exercise of jurisdiction over the crime of aggression (Security Council referral).

[10] Ibid., Article 6, Genocide; Article 7, Crimes against humanity; Article 8, War crimes.

[11] “What is R2P?” Global Centre for the Responsibility to Protect, https://www.globalr2p.org/what-is-r2p/#:~:text=The%20Responsibility%20to%20Protect%20populations%20from%20genocide%2C%20war%20crimes%2C%20crimes,Summit%20Outcome%20Document%20in%202005. (accessed January 29, 2024); “What is R2P? The Responsibility to Protect: A Background Briefing,” Global Centre for the Responsibility to Protect, 14 January 2021, https://www.globalr2p.org/publications/the-responsibility-to-protect-a-background-briefing/. (accessed January 29, 2024)

[12] James C. Simeon, “Ending Endless Wars,” Peace Magazine, July 1, 2022, https://peacemagazine.org/archive/v38n3p18.htm. (accessed January 30, 2024)

[13] RFE/RL’s Ukrainian Service, “Kyiv Says More Than 50 Russian Soldiers Have Been Convicted Since Russia’s Full-Scale Invasion,” RadioFreeEurope, RadioLiberty, July 16, 2023, https://www.rferl.org/a/ukraine-russian-soldiers-convicted-war-crimes/32505625.html. (accessed January 30, 2024)

[14] International Criminal Court, “Situation in Ukraine: ICC Judges issue arrest warrants against Vladimir Vladmirovich Putin and Maria Alekseyevne Lvova-Belova,” Press Release, March 17, 2023, https://www.icc-cpi.int/news/situation-ukraine-icc-judges-issue-arrest-warrants-against-vladimir-vladimirovich-putin-and. (accessed January 30, 2024)

[15] International Criminal Court, Press Release, 5 March 2024, “Situation in Ukraine: ICC judges issue arrest warrants against Sergie Ivanovich Kobylash and Viktor Nikolayevich Sokolov, https://www.icc-cpi.int/news/situation-ukraine-icc-judges-issue-arrest-warrants-against-sergei-ivanovich-kobylash-and. (accessed April 5, 2024)

[16] International Court of Justice, Press Release, “The Republic of South Africa institutes proceedings against the State of Israel and requests the Court to indicate provisional measures.” No. 2023/77, 29 December 2023, https://www.icj-cij.org/sites/default/files/case-related/192/192-20231229-pre-01-00-en.pdf. (accessed April 5, 2024);

[17] International Court of Justice, Press Release, “Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), The Court indicates provisional measures,” No. 2024/6, 26 January 2024, https://www.icj-cij.org/sites/default/files/case-related/192/192-20240126-pre-01-00-en.pdf. (accessed April 5, 2024)

[18] International Court of Justice, Press Release, “Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), The Court indicates additional provisional measures,” No. 2024/26, 28 March 2024, https://www.icj-cij.org/sites/default/files/case-related/192/192-20240328-pre-01-00-en.pdf. (accessed April 5, 2024); See International Court of Justice, Application of the Convention on the Prevention and Punishment of the Crime of Genocide in the Gaza Strip (South Africa v. Israel), Latest Developments, https://www.icj-cij.org/case/192. (accessed April 5, 2024)

[19] Paul Taucher and Dean Aszkielowicz, “South Africa has made its Genocide case against Israel in court. Here is what both sides said and what happens next,” The Conversation, January 15, 2024, https://theconversation.com/south-africa-has-made-its-genocide-case-against-israel-in-court-heres-what-both-sides-said-and-what-happens-next-221017#:~:text=Read%20more%3A%20South%20Africa%20is,the%20Palestinian%20people%20being%20met. (accessed April 5, 2024)

[20] US Department of State, Office of the Historian, Milestones: 1921-1936, “The Kellogg-Briand Pact, 1928,”  https://history.state.gov/milestones/1921-1936/kellogg#:~:text=The%20Kellogg%2DBriand%20Pact%20was,signed%20on%20August%2027%2C%201928. (accessed April 5, 2024); Oona Hathaway and Scott Shapiro, The Internationalists: An Their Plan to Outlaw War. (New York: Simon & Schuster, 2017); Oona Hathaway and Scott Shapiro, “International law and its transformation through the outlawry of war,” International Affairs, Vol. 95, No. 1, January 2019, pp. 45-62, https://academic.oup.com/ia/article/95/1/45/5273581. (accessed April 5, 2024); Dylan Matthews, “How war became a crime,” Vox, March 6, 2022, https://www.vox.com/22959938/crime-war-kellogg-briand-ukraine-conquest. (accessed April 5, 2024); Erin Pobjie, “The Meaning of the Prohibited ‘Use of Force’ in International Law,” MPIL Research Paper Series, No. 2022-27, SSRN, November 18, 2022, https://papers.ssrn.com/sol3/papers.cfm?abstract_id=4285189. (accessed April 5, 2024)

[21] BBC News, “Taliban are back – what next for Afghanistan?” War in Afghanistan, 2001 – 2021, 30 August 2021, https://www.bbc.co.uk/news/world-asia-49192495. (accessed January 30, 2024); “Afghan War, 1978-1992,” Britannica, https://www.britannica.com/event/Afghan-War. (accessed January 30, 2024); “List of Wars Involving Afghanistan,” Wikipedia, The Free Encyclopedia,

https://en.wikipedia.org/wiki/List_of_wars_involving_Afghanistan. (accessed January 30, 2024)

[22] Stephanie van den Berg, Bassam Masoud and Nidal Al-Mughrabi, “World Court stops short of Gaza cease fire order for Israel,” Reuters, January 27, 2024, https://www.reuters.com/world/middle-east/israel-braces-world-court-ruling-focuses-attack-south-gaza-2024-01-26/. (accessed January 30, 2024)

[23] United Nations, Peace, dignity, equality on a healthy planet, “Maintain International Peace and Security,” https://www.un.org/en/our-work/maintain-international-peace-and-security#:~:text=Preventive%20Diplomacy%20and%20Mediation,diplomacy%2C%20good%20offices%20and%20mediation. (accessed January 30, 2024)

[24]  James C. Simeon, “Peacemaking, Peacekeeping, and Peacebuilding” Peace Magazine, Jan-Mar 2024, pp. 12-13. https://www.peacemagazine.org/archive/?id=2999&fbclid=IwAR0AbtrVXQaJN-DHNk-Krk4nqE8KNzk7mLZyumoJvPkbTkK6z50ApA-7i6E. (accessed January 30, 2024)

[25] A. Trevor Thrall, “Arms Sales: Pouring Gas on the Fires of Conflict,” CATO at Liberty, Cato Institute, July 2, 2018, https://www.cato.org/blog/arms-sales-pouring-gas-fires-conflict#:~:text=Or%20do%20wars%20cause%20arms,Syria%2C%20Yemen%2C%20and%20Iraq. (accessed April 10, 2024);

[26] Amnesty International, “Arms Control,” (2024), https://www.amnesty.org/en/what-we-do/arms-control/. (accessed April 10, 2024)

[27] Stockholm International Peace Research Institute, sipri, The independent source for global security, https://www.sipri.org/. (accessed April 10, 2024)

[28] Dan Sabbagh, “Global defence spending rises 9% to record $2.2tn,” The Guardian, February 13, 2024, https://www.theguardian.com/world/2024/feb/13/global-defence-spending-rises-9-per-cent-to-record-22tn-dollars#:~:text=Global%20defence%20spending%20increased%20by,assessment%20by%20a%20military%20thinktank. (accessed April 10, 2024)

[29] Ibid.

[30] Jayita Sarkar, “Whither Pax Atomica? – The Euromissiles Crisis and the Peace Movement of the Early 1980s,” Nuclear Proliferation International History Project, Wilson Center, undated, https://www.wilsoncenter.org/publication/whither-pax-atomica-the-euromissiles-crisis-and-the-peace-movement-the-early-1980s#:~:text=The%20INF%20treaty%20and%20the,in%201987%20in%20Washington%2C%20DC. (accessed January 30, 2024) ; London School of Economics and Political Science, “Peace Activism in the UK during the Cold War, An online resource for exploring the British peace movement during the height of the Cold War,” https://www.lse.ac.uk/ideas/projects/peace-security/cnd-archives. (accessed January 30, 2024)

[31] James C. Simeon, “The forcibly displaced, the triple nexus, and the sustainable peace challenge,” The RLI Blog on Refugee Law and Forced Migration, September 6, 2022, https://rli.blogs.sas.ac.uk/2022/09/06/the-forcibly-displaced-the-triple-nexus-and-the-sustainable-peace-challenge/. (accessed January 30, 2024)

[32] United Nations, Peacebuilding, “Humanitarian, Development and Peace Nexus,” https://www.un.org/peacebuilding/content/humanitarian-development-and-peace-nexus#:~:text=Strengthening%20the%20collaboration%20between%20Peace,be%20achieved%20without%20one%20another. (accessed January 30, 2024)

[33] James C. Simeon, “Realizing the Human Right to Peace,” Peace Magazine, Vol. 39, No. 2, April-June 2023, https://peacemagazine.org/archive/v39n2a6.htm. (accessed January 30, 2024); Tuba Turan, “The 2016 UN General Assembly Declaration on the Right to Peace: A Step Towards Sustainable Positive Peace within Societies?” Human Rights Law Review, Vol. 23, No. 2, June 2023, https://academic.oup.com/hrlr/article/23/2/ngad007/7125971. (accessed January 30, 2024)

[34] Ibid.

[35] “moral turpitude,” definition, Mirriam Webster Dictionary,  https://www.merriam-webster.com/legal/moral%20turpitude. (accessed January 31, 2024); Legal Information Institute (LII), Cornell Law School, “moral turpitude,” https://www.law.cornell.edu/wex/moral_turpitude. (accessed January 31, 2024); “Moral turpitude,” Wikipedia, The Free Encyclopedia, https://en.wikipedia.org/wiki/Moral_turpitude. (accessed January 31, 2024) Wherein it states: “Moral turpitude is a legal concept in the United States and until 1976 in Canada that refers to ‘an act or behavior that gravely violates the sentiment or accepted standard of the community.’” Emphasis in the original.

[36] To quote Nelson Mandela, “Education is the most powerful weapon which you can use to change the world.” See Kelsey Pelzer, “Get Inspired to Make an Impact With These 75 Famous Nelson Mandela Quotes,” Parade, July 18, 2023, https://parade.com/1074913/kelseypelzer/nelson-mandela-quotes/#:~:text=1.,and%20got%20back%20up%20again.%E2%80%9D. (accessed January 31, 2024)