Weekly News Recap (12-18 July 2021)




USA: Court Found Syria, Iran, and Three Iranian Banks Responsible for Sponsoring Terrorism

On 12 July, the US District Court for the District of Columbia found Syria, Iran, the Islamic Revolutionary Guard Corps (‘IRGC’), the Iranian Ministry of Intelligence and Security (‘MOIS’), and three Iranian banks (Markazi, Melli, and Saderat) liable for Hamas’ murder of American nationals Eitam and his wife Na’ama Henkin, in 2015. This was the first instance, in which US courts have found Iranian Banks: Markazi, Melli or Saderat liable for a terror attack by a foreign terrorist organisation against a U.S. national. Hamas attacked and killed Eitam and Na’ama Henkin in front of their four children when they were driving in the West Bank. The orphaned children and the estates of their parents filed suit in 2019 under the terrorism exception clause to the Foreign Sovereign Immunities Act, upon which victims of an attack by foreign terrorist organisations and their close family members can bring claims against state sponsors of terrorism, government agencies, and any commercial instrumentalities of those states. None of the defendants responded to the lawsuit.



UK: Lawsuit Brought by 40 000 Nigerians Against Shell Over Oil Spill

On 12 July, it was reported that the Royal Dutch Shell Plc has abandoned its final attempt to argue that a major lawsuit brought by thousands of Nigerians over an oil spill in the West African country should be heard in Nigeria rather than the U.K. In February 2021, the UK Supreme Court had ruled that Shell’s parent company could be sued in English courts for the actions of its Nigerian subsidiary. The Supreme Court, however, left the door open for Shell to argue that it was more appropriate to leave any action against the local unit to Nigerian courts. Shell’s legal team has, according to the parties to the proceedings, declined to bring arguments for having the case heard in Nigeria. It has reportedly also conceded that the Nigerian subsidiary will now be joined to claims made in England against the parent company. Daniel Leader, the legal counsel for the claimants, called this a significant win for the affected communities because it means they can finally bring their case to trial. About 40,000 members of Nigeria’s Ogale and Bille communities allege that Royal Dutch Shell and SPDC, its local subsidiary, are jointly responsible for oil contamination they’ve suffered in the Niger Delta since the 1980s. Shell has a fraught history in Nigeria, where it had been linked to a series of oil spills, which it blames in part on sabotage.


ECtHR: Turkey’s Emergency Expropriation Proceedings Against Owners of Land Submerged by Water from the Pembelik Hydroelectric Dam Held in Violation

On 13 July, the ECtHR issued a judgement in Yel and Others v. Turkey, on the right to property pursuant to Article 1 of Protocol No. 1. The applicants are seven Turkish nationals who were born between 1926 and 1988 and live in Istanbul, Ankara, Elazığ, Balıkesir and Bingöl. They were co-owners of land that has been submerged by water from the Pembelik hydroelectric dam. The case concerns emergency expropriation proceedings conducted and completed on the basis of Council of Ministers decrees and administrative decisions that were initially subject to a stay of execution before being declared void by the Supreme Administrative Court. The applicants claimed there had been a violation on the grounds of their right to a fair hearing under on Article 6. The Court held that there had been a violation of Article 1 of Protocol No. 1.


ECtHR: Bulgarian Measures on the Forfeiture of Alleged Criminal Assets a Violation of the Protection of Property

On 13 July, the ECtHR issued a judgement in the case of Todorov and Others v. Bulgaria and held unanimously that there had been a violation of Article 1 of Protocol No. 1, in respect of four applications, and no violation in respect of the other three applications. The case concerned the seizure of property belonging to the applicants, believed to be the proceeds of crime. In the latter three applications, the Court found in particular that the domestic courts had examined the issues thoroughly and balanced the rights of the applicants with the public good. However, in the first four mentioned cases the Court found there had been a violation of the right to property because the domestic courts had failed to establish a link between the goods forfeited and criminal activity or between the value of the property and the difference between income and expenditure was found. The ordering of forfeiture had thus been disproportionate. There are approximately 40 similar applications pending before the Court.


CJEU: Poland Ordered to Suspend the Application of National Provisions Relating to the Powers of the Disciplinary Chamber of the Polish Constitutional Tribunal

On 14 July, the Court of Justice of the European Union (CJEU) issued an order for Poland to suspend the application of national provisions relating to the powers of the disciplinary chamber of the Polish Supreme Court, thus granting the interim measures requested by the European Commission. It ruled that Poland’s system of disciplining judges is “not compatible” with EU law. The CJEU held that the system does not provide all the guarantees of impartiality and independence, and, in particular, is not protected from the direct or indirect influence of the Polish legislature and executive. The CJEU upheld all the complaints made by the Commission and found that Poland had failed to fulfil its obligations deriving from EU law and ordered Poland to take the measures necessary to rectify the situation. The European Commission previously brought the case before the CJEU, claiming that Poland was undermining the rule of law. Poland created a “disciplinary chamber” that has the power to rule on Polish judges’ independence and lift their immunity so they can face criminal prosecution. The Polish government claimed that these reforms are key in the fight against corruption. In 2020, the CJEU ordered Poland to suspend the chamber as the European Commission claimed a majority of its members were loyal to the ruling PiS party and suggested it was being used as an instrument to push judges into complying with the party line.


Poland: Constitutional Tribunal Ruled that Interim Measures Imposed by the CJEU Violates Polish Constitution

On 14 July, the Polish Constitutional Tribunal ruled that the interim measures ordered by the Court of Justice of the European Union (CJEU) in the area of the functionality of the judiciary, are inconsistent with the Polish Constitution. The Tribunal held that Poland does not have to comply with the CJEU’s order. A panel of judges led by Stanislaw Piotrowicz, a former PiS MP and communist-era prosecutor, said the CJEU could not impose such orders. During the hearing Pawel Filipek, a lawyer representing the office of Poland’s ombudsman warned that a decision that conflicted with EU law could ultimately have far-reaching consequences and puts into question Poland as a member of the EU.


France: Court Postponed Proceedings Against Lafarge on Corporate Accountability for Complicity in Crimes Against Humanity in Syria

On 15 July, the Cour de Cassation, France’s highest appeal court, announced it was postponing its decision on charges against Lafarge, a cement manufacturer, on charges of “complicity in crimes against humanity” over its operations in Syria in 2013 and 2014. The decision has been moved to 7 September 2021. The company of Lafarge is indicted for “financing a terrorist company”, “endangering the life of others” and “violation of an embargo” with two former officials of the group; the ex-director of corporate security, Jean-Claude Veillard and one of the ex-directors of the Syrian subsidiary, Frédéric Jolibois, have also been indicated but have appealed against the lawsuits. The criminal investigation opened in June 2017, with Lafarge SA being suspected of having paid in 2013 and 2014, via its subsidiary Lafarge Cement Syria (LCS), nearly 13 million euros to terrorist groups, including ISIS, and to intermediaries, in order to maintain the activity of its site in Syria, as the country plunged into war. The group is also suspected of selling cement from the factory to ISIS and paying intermediaries to source raw materials from jihadist factions.



ICC: Pre-Trial Chamber Confirmed Charges Against Paul Gicheru for Offences Against the Administration of Justice

On 15 July, the ICC’s Pre-Trial Chamber A, confirmed charges of offences against the administration of justice against Paul Gicheru and committed him to trial. The Chamber found that there are substantial grounds to believe that Mr Gicheru committed, as a co-perpetrator, or under alternative modes of liability, offences against the administration of justice pursuant to Art. 70(1)(c) of the Rome Statute between April 2013 and the closure of the ICC’s case against the Ruto and Sang. The offences were allegedly committed to further a common plan implemented by a group of persons including Mr Gicheru, with the ultimate goal of undermining the Prosecution’s case. Most notably, in relation to the witnesses, Mr Gicheru and other members of the common plan allegedly identified, located, and contacted the witnesses, offered and/or paid them financial or other benefits, and/or threatened or intimidated them, in order to induce them to withdraw as Prosecution witnesses, refuse to or cease cooperating with the Prosecution and/or the Court, and/or to recant the evidence which they had provided to the Prosecution. In cases concerning offences against the administration of justice pursuant to Art. 70 of the Rome Statute, parties do not have the possibility to appeal a decision on the confirmation of the charges.



CJEU: A Prohibition on Wearing Any Visible Form of Expression of Political, Philosophical or Religious Beliefs in the Workplace May be Justified

On 15 July, the Court of Justice of the European Union (CJEU) ruled in joined cases C-804/18 and C-341/19 WABE and MH Müller Handel, that a prohibition on wearing any visible form of expression of political, philosophical or religious beliefs in the workplace may be justified by the employer’s need to present a neutral image towards customers or to prevent social disputes. However, the Court held that the justification must correspond to a genuine need on the part of the employer. The Court notes that the wearing of signs or clothing to manifest religion or belief is covered by the “freedom of thought, conscience and religion.” In addition, for the purposes of the application of Directive 2000/78, the terms ‘religion’ and ‘belief’ must be analysed as two facets of the same single ground of discrimination. In the present case, the rule at issue appears to have been applied in a general and undifferentiated way, since the employer concerned also required an employee wearing a religious cross to remove that sign. Thus, in those circumstances, a rule such as that does not constitute, with regard to workers who observe certain clothing rules based on religious precepts, direct discrimination on the grounds of religion or belief. The Court furthermore notes that in assessing the need for an employer’s policy of neutrality towards its customers, its freedom to conduct a business, as well as, adverse effects to its business if no neutrality policy is implemented must be taken into account. In reconciling the rights and interests at issue, the national courts may take into account the specific context of their Member State and, in particular, more favourable national provisions on the protection of freedom of religion.


The Netherlands: The Hague District Court Convicted Syrian National on a War Crime Charge

On 16 July, the International Crimes Chamber of The Hague District Court in the Netherlands convicted Ahmad al Khedr on a war crime charge for the execution of captured Syrian official Qussai Mahmoud al Ali. The Court handed down a sentence of 20 years of imprisonment. The Court acquitted him of terrorism charges for leading Ghuraba’a Mohassan armed group. Mr. al Khedr was absent from the criminal trial. The Court found that Mr. al Khedr played a leading role in the execution of the victim. Mr. al Khedr had been charged on a count of terrorism for the killing, however, the Court concluded it was an act of “revenge”, rather than carrying an intent to commit a terrorist act. Regarding the charges of terrorism for leading the Ghuraba’a Mohassan armed group the Court found that the available evidence was insufficient to establish that the combat group could be regarded as a terrorist organisation during the period that the suspect was its commander. Mr. al Khedr was therefore acquitted of participation in a terrorist organisation.



EU: 27 Member States to Impose Sanctions on Lebanese Political Leaders

On 12 July, Josep Borrell, High Representative for Foreign Affairs and Security Policy, declared before the European Union Foreign Affairs Council that there is an urgent need “to have a Lebanese government, in order to avoid a crackdown of the country, fully able to implement the reforms and protect its population.” At this occasion, EU Ministers agreed that a sanctions regime against those who are responsible for the situation should be established. Led by France, the initiative is aimed at overcoming the governance gap, preventing the implosion of the economy, as well as, prolonged suffering of the population. The move is part of a broader international efforts to form a stable government capable of implementing crucial reforms to emerge, after 11 month of political chaos and economic collapse following the blast that ravaged the Beirut port. Nearly a year after the 4 August explosion which killed 200 people, wounded thousand and devastated the capital, Lebanon is still  facing “a major emergency situation for a population that is in distress”, said the French Foreign Minister Jean-Yves Le Drian. The EU’s objective is to complete a balanced sanction regime by the end of July. Criteria for EU sanctions such as travel bans and assets freezes for Lebanese politicians are likely to include corruption, obstructing efforts to form a government, financial misdeeds, and human rights abuses. On 15 July, protesters clashed with army after the designated Prime Minister Saad Hariri resigned, nine months after his nomination, over “key differences” with President Michel Naim Aoun, admitting he was unable to form a government.



OHCHR: Law Enforcement Officials Must be Held Accountable for Crimes Against People of African Descent

On 12 July, at the occasion of an interactive dialogue with the Human Rights Council on systemic racism and violations of international human rights law against Africans and people of African descent by law enforcement agencies, Michelle Bachelet, UN High Commissioner for Human Rights, told the HRC that the murder of George Floyd was a tipping point, which had shifted the world’s attention to the human rights violation routinely endured by Africans and people of African descent. The UN Commissioner’s report on the “Promotion and protection of the human rights and fundamental freedoms of Africans and of people of African descent against excessive use of force and other human rights violations by law enforcement officers” shows that children of African descent are often subjected to racial discrimination in schools and that systemic racism was heightened by intersectionality. Her office received information about at least 190 deaths of people of African descent by law enforcement officials, 98 percent of which were in Europe, Latin America and North America. The report provides for four interconnected pillars of action: 1) States acknowledgment of systematic racism; 2) accountability of law enforcement officials; 3) respect of the right to freedom of expression and peaceful assembly; and 4) the establishment of comprehensive truth mechanisms. Many participants to the dialogue pointed out that the root causes of discrimination were connected to the legacies of transatlantic slave trade and colonialism and called former colonial powers and those engaged in forms of neo-colonialism to acknowledge their responsibility in creating systems of structural discrimination, to dismantle these racist structures, to ensure accountability, and to make reparations to all victims of colonialism, slavery and apartheid.




Ethiopia: UN Appeals for Faster Passage for Aid Convoys to the Tigray Region

On 13 July, UN humanitarians actors appealed for far quicker access to Ethiopia’s embattled Tigray region, after the first aid trucks in days to reach the local capital, Mekelle, encountered multiple checks delaying their arrival. All signals are turning to red in Tigray, bringing the threat of a major humanitarian crisis in the region. In a statement on Eritreans refugees in Tigray, the UN High Commissioner for Refugees, Filippo Grandi, expressed his concerned about the life conditions and violence directed against refugees. He further called  on “all Parties and actors to not only comply with international legal obligations, including the protection of civilians, but also to stop using and manipulating refugees to score political points.” Although conditioned to State consent and subject to their right of control, customary international humanitarian law (IHL) provides for the obligation of Parties to the conflict to allow and facilitate rapid and unimpeded passage of humanitarian relief for civilians in need. Nonetheless, humanitarian actors repeatedly underlined how damaging the delays to the convoy’s arrival had been. On 12 July, the World Food Programme’s (WPF) Emergency Coordinator based in Mekelle, Tommy Thompson, highlighted that while WFP welcomed “clearance for the Government Ethiopia” for a convoy of 50 trucks, which arrived in Mekelle with 900 metric tons of food and emergency supply, double this number of trucks is needed to meet the vast humanitarian needs in the region. Latest World Health Organisation’s reports from the region further warned that most health facilities are damaged beyond repair, that hospitals are “barely functioning”, and that this situation constitutes a fertile ground for diseases to spread. Additionally, the UN Food and Agriculture Organisation alerted that the upcoming seasonal rains in hunger-stricken northern Ethiopia offers a tight window of opportunity for farmers to reboot local food production. Taking stock of the situation, on 13 July, the UN Human Rights Council adopted a resolution condemning serious violations of human rights, of IHL, and of international refugee law allegedly committed by all Parties to the conflict since the start of the conflict on 4 November 2020. The resolution also stressed the need for accountability.






UNHCR: 270,000 Newly Displaced This Year in Afghanistan

On 13 July, the UN High Commissioner for Refugee (UNHCR) reported that the worsening security situation across Afghanistan in the wake of foreign troop withdrawal and Taliban advances has forced an estimated 270,000 from their homes since January. This brings the total number of international displaced persons (IDPs) to more than 3.5 million and further raises the likelihood of an imminent humanitarian crisis in the country. Escalation of the conflict, insecurity and violence are the predominant reasons forcing Afghans to flee their home land. Protracted conflict coupled with the impact of COVID-19 and with deepening poverty are all factors heightening civilian suffering. According to the UN Assistance Mission in Afghanistan (UNAMA), the number of civilian casualties has risen 29 percent during the first quarter of 2021 compared to last year. So far, the UNHCR gathered a number of testimonies from IDPs that witnessed incidents of extortion by non-State armed groups, and the presence of IEDs on major roads. The UNHCR further warned that a failure to reach a negotiated settlement between the Parties to the conflict will lead to further displacement, both inside and outside Afghanistan borders. However, with the announced withdrawal of international forces, actions on the battlefield have outpaced efforts at the peace negotiation table. On 14 July, Taliban captured the strategic border crossing of Sping Boldak (frontier with Pakistan) and are continuing to make significant territorial gains; in a rare post-presidential public appeal, former U.S. President George W. Bush whose administration launched the invasion of Afghanistan in 2001, said that the withdrawal of NATO troops was a mistake and expressed his concerns about the danger of “unspeakable harm” Afghan women and girls are facing. Indeed, the UNAMA has reported widespread killing, ill-treatment, persecution, and discrimination. The Turkish President Recep Tayyip Erdogan has offered to guard and run the Kabul airport, the security of which is essential for an international diplomatic and humanitarian presence in the country. On 15 July, galvanised by their successful military campaign, the Taliban have offered a tree-month ceasefire in exchange for the release of 7,000 insurgents prisoners detained by Afghans authorities, as well as, for the removal of Taliban leaders’ names from the UN sanctions list.






Colombia: Peace Process at Critical Juncture

On 13 July, Special Representative of the Secretary-General and Head of the UN Verification Mission in Colombia, Carlos Ruiz Massieu, briefed the UN Security Council (UNSC) on the latest developments under the accord that ended five decades of fighting between the government and the Revolutionary Armed Forces of Colombia (FARC-EP). Mr. Ruiz Massieu told the UNSC that events that were previously unthinkable in Colombia have been made possible through the historic 2016 Peace Agreement. In April, seven former high-level FARC-EP combatants officially accepted responsibility for kidnappings committed during the armed conflict. In early July, 11 army officers and a civilian were indicted in relation to assassinations and forced disappearances presented as deaths in combat. Under the auspices of the Truth Commission, victims and former FARC-EP expressed their perspectives on the peace process and agreed on the unjustifiable pain caused by war. Achievements of this institution which has been created to guarantee justice, truth, reparation and non-repetition, constitute the first steps towards the success of the Peace Agreement. The UN Special Representative further insisted on the importance of joint initiatives between civil society and State entities, and of the active participation of both women and former combatants in peacebuilding and development efforts. He stressed however that the peace process is still not fully completed as violence against former FARC-EP members, social leaders, and communities at large persist in certain regions, e.g. Montes de María, along the Pacific Coast and in parts of the South and the Northeast of the country. Deep-rooted violence in Colombia is fuelled by a combination of factors, including persistent violence and stigmatisation against former combatants and members of the Comunes party, actions of illegal armed groups and criminal organisations thriving in areas affected by poverty, illegal economy and the limited presence of the State. In May, the UN Commissioner for Human Rights, Michelle Bachelet had voiced her “deep concern” at recent events in the city of Cali, including reports of several deaths and violence amid national strike.





UN: Coup and COVID 19 Fuelling Perfect Storm in Myanmar

On 14 July, Tom Andrews, Special Rapporteur on human rights situation in Myanmar warned that surging COVID-19 cases as Delta variant spread, a collapsed health system, and deep mistrust of the military junta are a “perfect storm” of factors that could lead to further major loss of life in the country. Reiterating his appeal last week for Emergency Coalition for the People of Myanmar, to provide emergency humanitarian aid to the country, amid reports of severe shortages of vital medical supplies and oxygen, he further highlighted that “emergency” assistance for Myanmar was desperately needed to save lives and as the highest attainable standard of health is one of the fundamental rights of every human being and that right is being denied to most within Myanmar. He further stated that the junta “lacks the resources, the capabilities, and the legitimacy” to bring the crisis under control and that the crisis in Myanmar is particularly lethal because of the pervasive mistrust of the military junta. He called upon the international community to help facilitate a politically neutral body to coordinate a COVID response that includes a vaccination programme “that the people of Myanmar will trust.” The Special Rapporteur also raised alarm over the situation of Myanmar’s vulnerable communities, including prisoners held in overcrowded facilities. Nearly 6,000 people have been arbitrarily detained in Myanmar since the military overthrew the elected Government and seized power on 1 February. In addition, approximately 900 people, including children, have been killed and countless more wounded.


UNAIDS: ‘Tear Down Inequalities’ to End COVID Pandemic

On 14 July, the UNAIDS released a new report titled “UNAIDS Global AIDS Update 2021”, according to which  people living with HIV are at a higher risk of severe COVID-19 illness and death, yet the vast majority are denied access to life-saving vaccines; although key populations and their sexual partners account for 65 per cent of new HIV infections, they are largely left out of both HIV and COVID-19 responses, including 800,000 children living with HIV. The UNAIDS report, also illustrates how COVID-19 lockdowns & restrictions have disrupted HIV testing, with many countries showing a steep drop in diagnoses of the disease, referral to care services and HIV treatment initiations. And according to the report there were some 1.5 million new HIV cases recorded last year which were predominantly among transgender women, sex workers, gay men, intravenous drug users and their sexual partner, which accounts for 65 % of the world, and these populations also accounted for 93% of the new HIV infections outside sub-Saharan Africa, and 35 % within. While HIV testing and treatment have been scaled up massively over the past 20 years, service gaps remain much larger for children than for adults, according to the report and in the past year treatment coverage was 74 per cent for adults but just 54 per cent for children – leaving some 800,000 in the lurch.  Winnie Byamyima, UNAIDS chief remarked that it has been 40 years into the fight against HIV and unless the inequalities are not torn down, people-centred, rights based approaches are not taken up and work together with communities to reach everyone in need, a pandemic cannot be defeated


UNICEF: Major Fallout in Routine Childhood Vaccinations Due to the COVID-19 Pandemic According to New WHO and UNICEF Data

On 15 July, in the latest set of comprehensive worldwide childhood immunization figures- the first official figures reflect global service disruptions due to COVID-19, which states that 23 million children missed out on basic vaccines through routine immunization services in 2020 – 3.7 million more than in 2019. Up to 17 million children likely did not receive a single vaccine during the year, widening already immense inequities in vaccine access with most of these children live in communities affected by conflict, in under-served remote places, or in informal or slum settings where they face multiple deprivations including limited access to basic health and key social services. Dr Tedros Adhanom Ghebreyesus, the WHO Director-General, said that even as countries are struggling to get their hands on COVID-19 vaccines, the global community has gone backwards on other vaccinations, leaving children at risk from devastating but preventable diseases like measles, polio or meningitis. Compared to 2019, 3 million more children globally did not get their first measles dose, and 3.5 million more children missed their first dose of the vaccine for diphtheria, tetanus and pertussis, known as DTP-1. A troubling picture has also emerged in the Americas region, due to factors that include funding shortfalls, vaccine misinformation, and instability with only 82 per cent of children have been inoculated, which is down from 91 per cent in 2016. 


UN: Positive Steps Needed to Break the ‘Political Stalemate’ in Libya

On 15 July, Ján Kubiš, UN Special Envoy, who also heads the UN Support Mission in Libya (UNSMIL) warned the UNSC that the independent tracks of implementing Libya’s ceasefire agreement, political progress, and economic reform were in danger of going into reverse, further underscoring the “overwhelming demand and expectations” of both Libya’s citizens and the international community for timely elections, which are necessary to complete the country’s democratic transition. The UN official expressed deep concern over the wider consequences of the political and electoral stalemate and warned that if the impasse is not resolved quickly, it could reverse the positive momentum seen just a few months.  While the overall humanitarian situation in Libya has improved, there are challenges that still remain in ensuring that returned internally displaced people (IPD) have adequate and sustained access to basic services, such as healthcare and education facilities. A growing concern is the forced evictions targeting IDP communities by Libyan authorities as are migrants and refugee attacks, which are a reminder that “forced evictions without due process are human rights violations” according to the UN Official. He concluded on a positive note stating that the Committee of Libyan Experts on Combating Violence Against Women adopted in June the first comprehensive draft legislation in the Middle East region on combating violence against women.


UNHCR: Attacks by Armed Group Displaced 20,000 Civilians in Eastern DRC

On 16 July, UNHCR called for urgent and enhanced measures to protect civilians in eastern Democratic Republic of the Congo (DRC), where a series of recent attacks by an armed group has displaced nearly 20,000 people in North Kivu province. Armed groups continue to devastate civilian lives despite DRC’s President Felix Tshisekedi launching a state of emergency on 6 May in North Kivu and its neighbouring Ituri province. Babar Baloch, UNHCR Spokesperson stated that nearly two million people have been uprooted by insecurity and violence in the North Kivu province alone, over the past two years. UNHCR and its partners are supporting local authorities to register forcibly displaced families, and assess and respond to their needs.  More than 100,000 displaced people were assisted with emergency shelters in 2020 – and almost 14,000 so far in 2021 – but needs remain high as attacks by armed groups continue to displace people in the province, with many forced to flee multiple times. He further said that the agency and its partners are doing the vital work of documenting human rights violation while more resources are urgently needed as UNHCR’s appeal for our DRC operations of US$ 205 million is only 36 per cent funded.


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