Recent Posts

Emerging Voices 2015 Starts This Week

by Jessica Dorsey

Both last year’s edition and 2013’s inaugural Emerging Voices symposium were quite successful, so this week we’re kicking off our third annual edition. Through the end of August, we will be bringing you a wide variety of posts written by graduate students, early-career practitioners and academics.

Tune in over the next several weeks if you’d like to read more about excuse in international criminal law, the right to a remedy in armed conflict, water rights in South Africa and Ireland and corporate social responsibility–to name just a few of the topics some of our contributors will cover. Please feel free, as usual, to weigh in on the discussion. Thanks for following us here on Opinio Juris–we hope you enjoy this third edition of our Emerging Voices Symposium!

Weekly News Wrap: Monday, August 3, 2015

by Jessica Dorsey

Your weekly selection of international law and international relations headlines from around the world:

Africa

Middle East and Northern Africa

Asia

Europe

Americas

UN/World

Congratulations to Anna Dolidze!

by Kevin Jon Heller

Anna, who has guest-blogged for us in an academic capacity on a number of occasions (see here, here, and here), has just started a new job as Georgia’s Deputy Minister for Defence. See if you can spot her in this photo:

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Heartfelt congratulations to Anna. Academia’s loss is Georgia’s gain. I have no doubt that she will do exemplary work on behalf of her country.

Podcast Special! Why the Iran Deal is Constitutional, But Could Still End Up in U.S. Court

by Julian Ku

Due to my typical mid-summer lassitude (and a family vacation among the redwoods in California), I have not participated in the excellent legal blogosphere debate over the constitutionality of the Iran Nuclear Agreement which has included contributions from Jack Goldsmith, John Yoo, Michael Ramsey, John Bellinger, David Rivkin and many others.  Luckily for me, Prof. Jeffrey Rosen and the good folks at the National Constitution Center allowed me to share my thoughts in a podcast discussion with David Rivkin, who with his co-author Lee Casey, has argued in the WSJ that the Iran Deal is unconstitutional unless submitted as a treaty under Article II of the U.S. Constitution.  The 45-minute or so podcast can be found below, and I think it is worth listening in full.
But because I may not have made myself fully clear in the podcast, I try to summarize my thoughts here on why:  1) the Iran Deal does not have to be submitted as an Article II treaty; 2) the Iran Deal may allow individual U.S. states to impose sanctions on Iran which would likely lead to U.S. litigation.  David Rivkin does a great job explaining his views on the podcast, which are worth listening to in full as well.

A) In my view, the Iran Deal (or JCPOA) does not have to be submitted as an Article II treaty for at least two reasons.

First, the terms of the agreement, which describe its obligations as “voluntary”, indicate that it is a nonbinding “political commitment”.  Even the UN Security Council Resolution which supposedly enshrined the JCPOA into international law leaves some wiggle room for the U.S. allowing it to refuse to lift sanctions on Iran without violating the SC Resolution (or at least that is how John Bellinger reads it).

To be sure, there are indications that Iran itself doesn’t think the agreement is nonbinding and it does seem odd for the U.S. administration to make all this fuss over a 10 year agreement that is not binding, but (as Duncan has explained here and elsewhere), nonbinding political commitments are not unknown in diplomatic practice.

One example that I have been studying recently is the 1972 Shanghai Communique between the U.S. and China.   This seems a classic nonbinding diplomatic agreement which nonetheless had enormous consequences for US-China and global politics.  This and two later communiques remain crucial issues with respect to U.S. “promises” about the status of Taiwan and US promises to reduce arms sales to Taiwan.  It is not exactly the same as the Iran Deal, which purports to require its parties to take certain specific actions on certain dates, but it has some of the same flavor.

For this reason, I don’t think a promise by the President to commit the U.S. to do something beyond his term of office changes this analysis much (contra Mike Ramsey).  Presidents often promise on behalf of the U.S. to do things beyond his term, but as long as they are clear that these are political commitments, not legal ones, I don’t think a treaty is required.

Second, the JCPOA does not have to be submitted as a treaty because it doesn’t require the U.S. to change its domestic laws or even to change any domestic policy that is not already within the President’s constitutional or delegated statutory powers.  Crucially, the President has delegated authority under the various sanctions statutes to waive or lift those sanctions without getting further congressional approval.  That is by far the most important U.S. obligation under the JCPOA.  The idea of giving the president these powers to lift sanctions implies that he will seek out certain changes in behavior by the sanctioned governments and then use those promised changes (by say Iran, or in the recent past Burma) as a basis to lift the sanctions.

There is a cost for the U.S. government in going the nonbinding route.  It means that Iran should not feel itself “legally” bound to abide by the agreement, or at least those parts that are not enshrined in the UN Security Council Resolution.  For U.S. constitutional purposes, it also means that any future president can withdraw from these political commitments without any requirement of legal consultation with Congress or any concerns about violating international law.  A U.S. President is also empowered to withdraw from its UN Security Council commitments as well.  (Actually, the JCPOA itself makes it pretty easy for the U.S. president to terminate the agreement according to its own terms).  This seems only fair, however, and the administration clearly seems that this is a price worth paying to avoid the Article II treaty process.

B) State-level Sanctions on Iran Are Most Likely to End Up in Court

The individual states (e.g. New York or California) could impose certain sanctions on Iran after the deal goes into effect.  Such sanctions will probably face litigation from the U.S federal government which will claim that any state-level sanctions are preempted by the JCPOA.  But because the JCPOA is a nonbinding agreement, the preemptive effect of the JCPOA is weaker than of a full-scale treaty or executive agreement.  The outcome of such a case against state-level sanctions is far from clear and may require the federal court to consider the nature of the JCPOA more carefully. My guess is that they would find it constitutional, but might be inclined to uphold the state-level sanctions. That last finding is a close call and I would love to see that case, which could very well happen in the near future.

In short, although I don’t think the Iran Deal is a very good deal for the U.S. and I hope Congress blocks it, I don’t think the JCPOA is unconstitutional.  We will hopefully get some litigation on this point in the near future when some state rolls out its anti-Iran sanctions.  But opponents of the deal should focus on the politics (getting to 67 votes in the Senate and/or a Republican President) rather than the law.

Touchy, Touchy. What China’s Sensitivity About the Philippines Arbitration Reveals About the Strength of Its Legal Position

by Julian Ku

While I was on (my completely undeserved) vacation in California recently, I noticed more evidence that China’s government is becoming hyper-sensitive about criticism of its non-participation in the Philippines-China arbitration at the Hague.

First, a top U.S. government official stated at a conference on July 21 that, among other things, “…[W]hen they became parties to the Convention, both the Philippines and China agreed to its compulsory dispute settlement regime. Under this regime, the decision of the arbitral tribunal is legally binding on the parties to the dispute. It’s a treaty. In keeping with the rule of law, both the Philippines and China are obligated to abide by whatever decision may be rendered in the case, whether they like it or not. ”

On July 17, the New York Times published a rather bland staff editorial on the China-Philippines arbitration gently chiding China for failing to participate in that arbitral process.  Noting that China was likely to ignore the arbitration’s outcome, the NYT opined: “[China] should participate in the tribunal process if China wants to be recognized as a leader in a world that values the resolution of disputes within a legal framework.”

Both statements are pretty gentle, in my view, and Russel’s point about China’s obligation to abide by the arbitral tribunal’s rulings on jurisdiction is quite correct as a matter of law.  But it is China’s rather vociferous response that is more striking.

First, the Chinese Foreign Ministry sharply rejected Russel’s remarks.  Most curiously, it charged that the U.S. was, by “[a]ttempting to push forward the arbitration unilaterally initiated by the Philippines, [acting] like an ‘arbitrator outside the tribunal’, designating the direction for the arbitral tribunal established at the request of the Philippines.”  The spokesperson went on to say “This is inconsistent with the position the US side claims to uphold on issues concerning the South China Sea disputes.”

Second, the Chinese Ambassador to the U.S. wrote a letter to the editor of the NYT, calling its editorial “unfair.”  It also concluded that  “we do not believe that the arbitration court has jurisdiction, and as a member of United Nations Convention on the Law of the Sea, China is entitled to exclude any third-party compulsory settlement.”

I am sympathetic to China’s position that compulsory arbitration is not the way to go here, but as a legal matter, their views are hard to understand.  The UNCLOS does NOT give China the right to exclude any “third-party compulsory settlement.”  It does the opposite, and allows very limited exceptions to compulsory dispute resolution which may or may not apply here.  Furthermore, as numerous commentators have explained but which China continues to ignore, Article 288 of UNCLOS plainly gives the UNCLOS arbitral tribunal the final say on jurisdiction.  Russel was only repeating what is in the plain text of the treaty (UNCLOS) that China signed and ratified.

China’s sharply worded but legally incoherent responses are a sign that it is more nervous about the Philippines arbitration than it has let on in the past. China should just stop complaining about the arbitration and move on. It should have enough diplomatic, military, and political leverage to get past this.  It will get nowhere with its legal arguments.

Guest Post: Gone But Not Forgotten–The Ongoing Case of Jean Uwinkindi at the ICTR and MICT

by Oliver Windridge

[Oliver Windridge is a British lawyer specialising in international criminal and human rights law. The views expressed herein are those of the author and do not necessarily reflect the views of the United Nations or any other organisations affiliated to the author.]

A sometimes forgotten aspect of the International Criminal Tribunal for Rwanda’s work is the transfer of 10 of its 13 outstanding cases back to Rwanda and to France for domestic prosecution. To be precise, of the 13 outstanding cases, the ICTR have transferred two currently detained accused to France (Bucyibaruta and Munyeshyaka) and two to Rwanda (Uwinkindi and Munyagishari). The remaining nine accused remain at large, of which the ICTR transferred seven to Rwanda for domestic prosecution if and when they are arrested (Sikubwabo, Ryandikayo, Ntaganzwa, Ndimbati, Munyarugarama, Mpiranya, Kayishema), while the Bizimana and Kabuga cases remain at the ICTR, or rather the Mechanism for International Criminal Tribunals (MICT), the mechanism established to carry out functions, including trying outstanding cases, after the completion of the ICTR and ICTY mandates. But even if sometimes forgotten, transferred cases are likely to come back into the spotlight this year with MICT President Theodor Meron’s landmark 13 May 2015 decision to constitute a new referral chamber to examine whether Jean Uwinkindi, the first ICTR accused to be transferred to Rwanda, should remain in Rwanda for trial or be brought back under the auspices of the MICT for trial.

As background, in 2011 Uwinkindi became the first ICTR accused to be transferred to Rwanda for domestic prosecution under Rule 11 bis of the ICTR Rules of Procedure and Evidence. This transfer was a watershed for the ICTR, and in particular the ICTR Prosecutor, who had tried and failed on several previous occasions to transfer cases to Rwanda, all of which were subsequently tried at the ICTR ( See Munyakazi, Gatete, Kanyarukiga and Hategekimana).

Uwinkindi opposed the transfer mainly on fair trial concerns, however the Trial Chamber found that Rwanda had markedly improved its criminal justice system since denying previous applications for transfer mentioned above, and granted the Prosecution’s request to transfer, which was subsequently affirmed by the Appeals Chamber . In order to allay concerns over potential post-transfer issues, particularly over the availability and protection of witnesses, the transfer decision included a monthly monitoring system, designed to ensure any material violation of Uwinkindi’s fair trial rights in Rwanda would be brought to the attention of the ICTR President so that action, including possible revocation could be considered by the ICTR (and now MICT). The monitoring system also allowed the ICTR/MICT to examine any issues over future financial constraints including any failure by the Rwandan authorities to make counsel available or disburse funds. Therefore, since 2011 the ICTR/MICT has received monitoring reports on a monthly basis (all the reports can be accessed at the bottom of this page.). Importantly, in its 2011 referral decision the ICTR also granted Uwinkindi permanent standing to petition the ICTR/MICT.

On 16 September 2013, Uwinkindi filed a request for revocation of the 2011 referral decision, stating that the Ministry of Justice of Rwanda had failed to make the necessary funds available for his defence to allow his team to contact defence witnesses and hire defence staff and that his counsel had not been paid since February 2013. On 12 March 2014, MICT President Meron, sitting as a single judge, dismissed Uwinkindi’s request for revocation, finding that the submissions on various funding issues had been either rendered moot or were still the focus of ongoing negotiations and may be subject to further review within the Rwandan courts. President Meron did not however rule out the filing of further requests for revocation should the circumstances warrant.

In March 2015, the MICT monitor filed its March 2015 report, in which it stated, inter alia, (more…)

A Freudian Slip?

by Kevin Jon Heller

My favourite entry in the “funny placement coincidences” competition:

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I have no political point to make. I just think the photo is fantastic.

Weekly News Wrap: Monday, July 27, 2015

by Jessica Dorsey

Your weekly selection of international law and international relations headlines from around the world:

Africa

  • The Somali militant Islamist group al Shabaab attacked a Mogadishu hotel on Sunday, driving a car packed with explosives through the hotel gate and killing at least 13 people, a first responder and the rebel group said.
  • The European Union is ready to impose sanctions on Burundians failing to help end the Central African nation’s crisis, the EU’s foreign policy chief said on Thursday, following elections that Brussels and Washington say were not credible.

Middle East and Northern Africa

Asia

Europe

Americas

Oceania

UN/World

Events and Announcements: July 26, 2015

by Jessica Dorsey

Events

  • On 24 August 2015 the UCLan Institute for International and Comparative Law organises a One-Day Workshop on International and Comparative Aspects of Responding to War Crimes: Through Law and Alternative Mechanisms. This workshop will address a number of related and distinct international and comparative aspects of war crimes trials, legal policy developments, and will evaluate extra-legal responses using examples of case studies. It is aimed to gather together academics, researchers and others interested in war crimes trials, focusing on legal, historical and political issues of the war crimes trials. Please see the programme and more information here.

Calls for Papers

  • The Anti-Corruption Interest Group of the American Society of International Law, co-chaired by Andy Spalding of the University of Richmond School of Law and Phil Nichols of the Wharton School, is soliciting papers for its first conference/workshop, to be held at the University of Pennsylvania on October 2-3, 2015. Interested persons should submit a one page proposal to Ms. Lauretta Tomasco at tomascol [at] wharton [dot] upenn [dot] edu by August 1, 2015. If accepted, a proposer must supply a five page (or longer) paper by September 25, 2015. Copies of all papers will be distributed to all participants before the conference/workshop; an objective of this meeting is to thoroughly discuss the ideas contained in each paper.  Any submissions that relate to corruption are encouraged.
  • The European Convention for the Protection of Human Rights and Fundamental Freedoms has arguably been the most efficient and effective system for protecting human rights in the world. The European Court of Human Rights monitors compliance with the Convention in the 47 member states of the Council of Europe. However, it appears that there is strong disagreement between some European societies at least about certain basic values. Therefore, the conference will, among others, try to answer the following fundamental questions: What are European values? Is it possible to identify minimum common denominators of European values? Are basic European values similar in Glasgow, Khabarovsk, Rovaniemi and Ceuta? What is the approach of the European Court of Human Rights to the dilemmas posed by European values? What is the role of legal theory and legal philosophy in the search for European values? Which dilemmas and challenges are posed by the search for European values? The conference will be held at the Graduate School of Government and European Studies and the European Faculty of Law in Ljubljana Old Town on 20 and 21 November 2015. The organizers invite researchers undertaking research on the proposed topic to submit abstracts for consideration. Interested applicants should send a 250-word abstract and a CV in narrative form by 1 September 2015 to dignitas [at] fds [dot] si. Authors will be notified of acceptance by 15 September 2015. If you have any questions, please write to dignitas [at] fds [dot] si.

Our previous events and announcements post can be found here. If you would like to post an announcement on Opinio Juris, please contact us with a one-paragraph description of your announcement along with hyperlinks to more information.

Recent International Legal Scholarship on the Crisis in Ukraine

by Chris Borgen

As the fighting in Ukraine continues into its second year, recent reports have variously focused on the promise of a weapons withdrawal and the risk that there is the opening of a new front opening. Recent international legal scholarship has attempted to frame the conflict within the context of international law and consider topics such as issues of legality and responsibility, the role of international law in conflict resolution, and what the conflict itself may show about the state of  international law and the international legal profession.  Following are two recent volumes and a set of videos covering a variety of such concerns:

The first is the current volume of the US Naval War College’s International Law Reports, which contains papers prepared for an October 2014 workshop organized by the West Point Center for the Rule of Law of the U.S. Military Academy and the Stockton Center for the Study of International Law of the U.S. Naval War College. These articles tend to focus on use of force and international humanitarian law related issues including Lieutenant Colonel Shane Reeves and Colonel David Wallace on the combatant status of “little green men,” Geoff Corn on regulating non-international armed conflicts after Tadic, and Opinio Juris’s Jens Ohlin on legitimate self-defense.

I was also one of the workshop participants and my paper, Law, Rhetoric, Strategy: Russia and Self-Determination Before and After Crimea, considers how and why Russia has used international legal arguments concerning self-determination in relation to its intervention in Ukraine. I address the question “of what use is legal rhetoric in the midst of politico-military conflict” by reviewing the laws of self-determination and territorial integrity and considering Russia’s changing arguments concerning these concepts over the cases of Kosovo, South Ossetia, and Ukraine.

In March, the Centre for Polish-Russian Dialogue and Understanding and the Institute of Law Studies of the Polish Academy of Sciences hosted a conference in Warsaw that brought together international lawyers from Russia, Ukraine, across Europe. (I was one of two participants from the U.S.) Given the breadth of views, the discussion was lively. Videos of the presentations are now available online. Panel topics include self-determination and secession (1, 2), use of force issues (1, 2), reactions of the international community (1, 2), issues of recognition and non-recognition (1), and the international responsibility of states and individuals (1).

In the West, we don’t often hear the Russian analyses of the international legal issues in the Ukraine conflict, so I want to highlight contributions by Prof. Anatoly Y. Kapustin, Institute of Legislation and Comparative Law and President of the Russian International Law Association (starting at the 36th minute of the panel on reactions of the international community), Prof. Vladislav Tolstykh of Novosibirsk State University (starting at the 52nd minute of the self-determination panel), and Prof. Evgeniy Voronin of MGIMO University (starting in the 54th minute of the use of force panel).

By the way, my own talk on the self determination panel begins at the 27th minute.

Third, the new issue of the German Law Journal is devoted to a broad range of approaches to assessing the conflict. The opening section uses the perspective of public international law. The next section, as described in the introduction by issue editor Zoran Oklopcic:

upset[s] traditional approaches by interrogating the professional commitments of international lawyers, insisting on the legal and factual hybridity of the conflict, and exposing larger ideational frames and their socio-economic underpinnings that make the conflict in Ukraine legally legible in a particular way.

Following this are discussions steeped in constitutional law and theory and normative political theory. The closing section proposes broader reform agendas and reconsiderations of the roles of law and of international actors. Contributors include organizer Zoran Oklopcic on early-conflict constitution-making, Brad Roth on the rules of secession, self-determination and external intervention, Mikulas Fabry on how to uphold the territorial integrity of Ukraine, Boris Mamlyuk on the Ukraine crisis, Cold War II, and international law, Umut Ozsu on the political economy of self determination, and Jure Vidmar on the annexation of Crimea and the boundaries of the will of the people.

I invite readers to point to other examples of scholarship on the Ukraine crisis via the comments section (or an e-mail to me). I think we all hope that this will become a historical incident rather than continue as a current event.

Guest Post: The Security Council Resolution on the Iran Deal–A Way around the “Reverse Veto”

by Jean Galbraith

[Jean Galbraith is an Assistant Professor at the University of Pennsylvania Law School.] 

The Security Council’s voting procedures make it difficult to pass resolutions – and, typically, difficult to undo resolutions once passed. In an article published not long after the end of the Cold War, David Caron observed that while it is hard to address the difficulty of passing resolutions, the Security Council itself has the power to make it easier for resolutions to be undone once passed. One way, of course, is for the Security Council to put specific time limits on a resolution. But as an alternative Professor Caron suggested that the Security Council could “incorporate in any resolution taking a decision a modified voting procedure for future use in terminating the action taken.” In this way, the Security Council could get around what he described as the “reverse veto” – the default position that a resolution needs another resolution to terminate it and therefore that all P5 members must acquiesce in this termination. Professor Caron described how he had run his idea by a lawyer serving at the mission of one of the P5 but gotten a “quick and dismissive” reaction.

In the Security Council resolution endorsing the Iran deal, we now have something resembling Professor Caron’s suggestion. To see this, one must work through multiple paragraphs of Resolution 2231. To begin with, paragraph 7(a) terminates prior Security Council resolutions imposing sanctions on Iran. But the Resolution further provides that paragraph 7(a) itself can be undone – thus reinstating the prior Security Council resolutions – through what is effectively a modified voting procedure. Specifically, paragraph 11 states that if the Security Council receives a complaint from one of the parties to the Iran deal alleging that there is “significant non-performance of commitments” under the deal, then the Security Council is to “vote on a draft resolution to continue in effect the terminations in paragraph 7(a) of this resolution.” According to paragraph 12, if this draft resolution does not pass, then after a short time lag all the resolutions that had “been terminated pursuant to paragraph 7(a) shall apply in the same manner as they applied before the adoption of this resolution, and the measures contained in paragraphs 7, 8 and 16 to 20 of this resolution shall be terminated, unless the Security Council decides otherwise.” (These “snapback” provisions track the arrangement reached in the Iran deal. Also consistent with that deal, there are further related issues, including that invocation of these provisions could lead Iran to abandon the deal and also a partial limit on the reinstatement of the earlier sanctions as noted earlier on this blog by Julian Ku.)

In other words, paragraphs 7, 8, and 16-20 of Resolution 2231 will automatically terminate if a single P5 member vetoes the draft resolution that follows a complaint submitted to the Security Council by one party to the deal. This flips the usual voting procedure for terminating a resolution. Rather than needing the acquiescence of all the P5 to terminate these provisions, what is now needed is only for one P5 member to block their continuance.

Going forward, the potential for these kinds of modified voting procedures is fascinating to consider. They could increase the likelihood of getting Security Council resolutions ex ante by making it easier for these resolutions to be terminated ex post. They could also reduce the likelihood of stretched interpretations of existing resolutions. For example, if Resolution 678 authorizing the first Gulf War had provided for its own termination through a modified voting procedure, it presumably would have been so terminated before it could have been used by the United States as an asserted legal justification for the second Gulf War. On the flip side, if such modified voting procedures become part of the practice, it is possible that they could be over-used in ways that undermine the effectiveness and stability of the Security Council. It will be very interesting to see whether these kinds of mechanisms get more use in the future.

As someone who studies U.S. constitutional law as well as international law, this issue brings to mind the U.S. constitutional issue of whether a congressional statute can delegate authority to the executive branch but provide that this authority can be terminated in the future through a mere majority vote of one house of Congress (or of both houses of Congress but without Presidential signature). The first instance of this practice that I know of occurred in the Lend-Lease Act and sparked a back-and-forth between President Franklin D. Roosevelt and Attorney General Robert Jackson over the constitutionality of this practice. Ultimately, a majority of the Supreme Court held in INS v. Chadha (1983) that Congress does not have the constitutional authority to develop modified voting procedures for terminating statutory delegations. Even since Chadha, however, the practice of Congress and the President has continued to make use of such procedures, albeit often in more informal ways. In addition, the United States uses modified voting procedures in other contexts, such as the practice-based approach of allowing the President alone (without needing two-thirds of the Senate) to withdraw the United States from treaties where this withdrawal is consistent with international law.

The U.N. Charter does not specify voting procedures for terminating an existing resolution (or other ways in which a resolution might terminate of its own accord). In practice, moreover, the Security Council has long had some flexibility in interpreting its procedures under the U.N. Charter, as demonstrated by its practice of concluding that a resolution can pass with abstentions rather than affirmative votes from P5 members. To me, as to Professor Caron in his article, it seems fairly straightforward that the Security Council has the power to use a modified voting procedure as a condition for the termination of a resolution, just as it can use a fixed termination date. Resolution 2231 is an example of how such modified voting procedures for termination can be useful, and the practice may become more common in the future.

In closing, I thank Opinio Juris for letting me contribute this guest blog post.

Weekly News Wrap: Monday, July 20, 2015

by Jessica Dorsey

Your weekly selection of international law and international relations headlines from around the world:

Africa

Middle East and Northern Africa

Asia

Europe

  • A British man who was last year sentenced by a U.S. court to 12-1/2 years in prison after pleading guilty to running a website that supported the Taliban, has been released, his family said on Sunday.
  • Revelations of U.S. spying in Europe have soured transatlantic relations, prompting a White House apology and, as leak followed leak over the past two years, have fostered feelings of moral superiority among Europeans, yet EU governments are stepping up surveillance of their own citizens.
  • British pilots have participated in airstrikes over Syria on the behalf of allies such as the United States and Canada, the Ministry of Defense said on Friday.

Americas

Oceania

  • Several hundred Australian nationalists and anti-racism activists clashed with police in Melbourne on Saturday in a rare display of violence in a country where immigration is an increasingly emotive political issue.

UN/World

  • The U.N. Security Council must intervene in Burundi to prevent mass atrocities and the risk of a regional conflict, seven independent U.N. human rights investigators said on Thursday.