Published online by Cambridge University Press: 14 October 2015
Humanity is at once the most universally and uncritically accepted humanitarian principle. It is not, however, without controversy. This article defines the principle of humanity and then explores its inherent tensions, related to universality and particularism, inclusion and exclusion, and equality and inequality. The article concludes with a call to operationalize and concretize humanity through three sets of transformative practices and everyday actions. Together these embody the relational nature of humanity, and suggest ways forward in reforming humanitarianism.
1 David McCormick, “Ebola is a Threat to All of Humanity Warns U.S. Official as Fatalities in West Africa Surge to Over 1,900 and a Second Cluster of Cases is Confirmed in Nigeria”, Daily Mail, 3 September 2014, available at: www.dailymail.co.uk/news/article-2741765/Missionary-infected-Ebola-discuss-recovery.html (all internet references were accessed in May 2015).
2 Documented at: www.christmastruce.co.uk/article.html.
3 Sommaruga, Cornelio, “Humanity: Our Priority Now and Always. Response to ‘Principles, Politics, and Humanitarian Action’”, Ethics and International Affairs, Vol. 13, 1999, p. 26CrossRefGoogle Scholar.
4 Pictet, Jean, “The Fundamental Principles of the Red Cross: Commentary”, International Review of the Red Cross, Vol. 210, 1979, p. 135Google Scholar. Aside from humanity, the Fundamental Principles of the Movement are impartiality, neutrality, independence, voluntary service, unity and universality. By contrast, humanitarian actors tend to refer to humanity, impartiality, neutrality and independence as the four classic or traditional humanitarian principles.
5 Ibid.
6 Ibid.
7 ICRC, The Fundamental Principles of the International Red Cross and Red Crescent Movement, In Brief, Geneva, 8 August 2014, available at: www.icrc.org/eng/resources/documents/publication/p4046.htm.
8 Donini, Antonio, “The Far Side: The Meta Functions of Humanitarianism in a Globalised World”, Disasters, Vol. 34, Suppl. 2, 2010, p. 220CrossRefGoogle Scholar.
9 Charter of the United Nations, 26 June 1945, 1 UNTS XVI (entered into force 24 October 1945). The Charter is available in its entirety online, including the Preamble, at: www.un.org/en/documents/charter/preamble.shtml. Universal Declaration of Human Rights, 10 December 1948, 217 A (III), available at: www.un.org/en/documents/udhr/.
10 Ilana Feldman and Miriam Ticktin, “Introduction: Government and Humanity”, in Ilana Feldman and Miriam Ticktin (eds), In the Name of Humanity: The Government of Threat and Care, Duke University Press, Durham, NC, 2010. See also Jennifer Hyndman, Managing Displacement: Refugees and the Politics of Humanitarianism, University of Minnesota Press, Minneapolis, MN, 2000; and Ilana Feldman and Miriam Ticktin (eds), In the Name of Humanity: The Government of Threat and Care, Duke University Press, Durham, NC, 2010.
11 On the inequality of exchange, see Marcel Mauss, The Gift: Forms and Functions of Exchange in Archaic Societies, trans. I. Cunnison, Martino, Mansfield Center, CT, 2011, first published 1954.
12 In the words of the author, “When we tweeted the accusation that the world didn't care, many people retweeted it. But most didn't click the link to read our stories. Perhaps they wanted to be seen to care. Perhaps they believed that people should care. But they didn't care enough to read what we had written.” Barry Malone, “You Probably Won't Read this Story about Syria”, Al-Jazeera, 17 March 2015, available at: www.aljazeera.com/blogs/middleeast/2015/03/wont-read-piece-syria-isil-iraq-isis-150317125900133.html.
13 E.g., Alexander Betts, “Forget the ‘War on Smuggling’, We Need to Be Helping refugees in Need”, The Guardian, 25 April 2015, available at: www.theguardian.com/commentisfree/2015/apr/25/war-on-trafficking-wrong-way-to-tackle-crisis-of-migrant-deaths.
14 Henri Dunant, A Memory of Solferino, ICRC, Geneva, 1986, first published 1862.
15 Michael Barnett, Empire of Humanity: A History of Humanitarianism, Cornell University Press, Ithaca, NY, 2011.
16 See, for example, Giladi, Rotem, “A Different Sense of Humanity: Occupation in Francis Lieber's Code”, International Review of the Red Cross, Vol. 94, No. 885, 2012CrossRefGoogle Scholar.
17 This dehumanization holds for the victims and, sometimes, for their tormentors and killers. The individuals from Islamic State/ISIS who are responsible for the gruesome beheadings of aid workers and journalists (Steven Sotloff, James Foley and Peter Kassig, among others) dehumanized their victims to enable the violence. At the same time, the lack of identifiable features, even extending to the location of the murders, makes it easier to dehumanize the perpetrators.
18 Hannah Arendt, The Origins of Totalitarianism, Harvest, San Diego, CA, 1979, p. 299. See also David Grossman, On Killing: The Psychological Cost of Learning to Kill in War and Society, Back Bay Books, Hachette, New York, 2009; J. Glenn Gray, The Warriors: Reflections on Men in Battle, Bison Books, Lincoln, NE, 1998.
19 Sam Keen, Faces of the Enemy: Reflections of the Hostile Imagination, Harper & Row, San Francisco, CA, 1986.
20 Guantanamo Bay refers to the US military detention centre on the naval base of the same name on the island of Cuba. Abu Ghraib is an Iraqi prison, used first by Saddam Hussein and later by the US military, at which many Iraqis were housed in inhumane conditions, abused, humiliated and tortured. On Abu Ghraib, see Seymour M. Hirsh, “Torture at Abu Ghraib”, The New Yorker, 10 May 2004, available at: www.newyorker.com/magazine/2004/05/10/torture-at-abu-ghraib.
21 In early January 2015, two gunmen attacked the offices of the French satirical magazine Charlie Hebdo, killing twelve people. The gunmen were affiliated with the Yemeni branch of al-Qaeda. BBC News, “Charlie Hebdo Attack: Three Days of Terror”, BBC News, 14 January 2015, available at: www.bbc.com/news/world-europe-30708237.
22 See, for example, Taylor Teaford, “Helping Humanity and Advancing American Interests”, War on the Rocks, 2 October 2014, available at: http://warontherocks.com/2014/10/helping-humanity-and-advancing-american-interests/#. In the blog post, the author advocates for expanding US military presence in West Africa through its Ebola response.
23 While King did not use the term “humanity”, he does appeal to humanity-as-sentiment through the connectedness of blacks and whites in the United States: “Injustice anywhere is a threat to justice everywhere. We are caught in an inescapable network of mutuality, tied in a single garment of destiny. Whatever affects one directly affects all indirectly.” Martin Luther King Jr, Letter From a Birmingham Jail, 16 April 1963, p. 2, available at: https://kinginstitute.stanford.edu/king-papers/documents/letter-birmingham-jail.
24 See, for example, M. Barnett, above note 15; and Craig Calhoun, “The Imperative to Reduce Suffering: Charity, Progress, and Emergencies in the Field of Humanitarian Action”, in Michael Barnett and Thomas G. Weiss (eds), Humanitarianism in Question: Politics, Power, Ethics, Cornell University Press, Ithaca, NY, 2008, available at: www.hhh.umn.edu/img/assets/28237/3%20Calhoun.pdf.
25 Larissa Fast, Aid in Danger: The Perils and Promise of Humanitarianism, University of Pennsylvania Press, Philadelphia, PA, 2014.
26 Geneva Convention (I) for the Amelioration of the Condition of the Wounded and Sick in Armed Forces in the Field of 12 August 1949, 75 UNTS 31 (entered into force 21 October 1950); Geneva Convention (II) for the Amelioration of the Condition of the Wounded, Sick and Shipwrecked Members of Armed Forces at Sea of 12 August 1949, 75 UNTS 85 (entered into force 21 October 1950); Geneva Convention (III) relative to the Treatment of Prisoners of War of 12 August 1949, 75 UNTS 135 (entered into force 21 October 1950); Geneva Convention (IV) relative to the Protection of Civilian Persons in Time of War of 12 August 1949, 75 UNTS 287 (entered into force 21 October 1950).
27 Coupland, Robin, “Humanity: What Is It and How Does It Influence International Law?”, International Review of the Red Cross, Vol. 83, No. 844, 2001, p. 972Google Scholar. See also Coupland, Robin, “The Humanity of Humans: Philosophy, Science, Health, or Rights?”, Health and Human Rights, Vol. 7, No. 1, 2003, pp. 159–166CrossRefGoogle Scholar; and Thomas W. Laqueur, “Mourning, Pity, and the Work of Narrative in the Making of ‘Humanity’”, in Richard Ashby Wilson and Richard Brown (eds), Humanitarianism and Suffering: The Mobilization of Empathy, Cambridge University Press, Cambridge, 2009.
28 See R. Coupland, “Humanity”, above note 27.
29 The advantage of defining something by its absence is its precision. While clearly important to any conceptualization of humanity, confining the principle of humanity to its negative meaning significantly narrows its scope since this only prohibits certain acts and does not encourage the compassion, respect or dignity implied in Pictet's conception or other articulations of the principle of humanity. Johan Galtung, a prominent peace scholar, offers a similar critique of definitions of peace that are limited to the absence of war. Galtung, Johan, “Violence, Peace and Peace Research”, Journal of Peace Research, Vol. 6, No. 3, 1969CrossRefGoogle Scholar.
30 R. Coupland, “Humanity”, above note 27, p. 988. See also Jonathan Glover, Humanity: A Moral History of the 20th Century, 2nd ed., Yale University Press, New Haven, CT, 2012.
31 Ruti G. Teitel, Humanity's Law, Oxford University Press, Oxford, 2011, p. 13. Legal theorist Costas Douzinas offers a counterpoint, distinguishing between the empirical universalism of the number of States that have ratified a given treaty and an idealized, normative universality of the human rights regime. He writes: “The community of human rights is universal but imaginary; universal humanity does not exist empirically and cannot act as a transcendental principle philosophically.” Douzinas, Costas, “Humanity, Military Humanism and the New Moral Order”, Economy and Society, Vol. 32, No. 2, 2002, p. 160Google Scholar.
32 Arguments such as Teitel's are akin to the International Commission on Intervention and State Sovereignty (ICISS)-defined “Responsibility to Protect” (R2P). The ICISS hallmark report from 2001 makes the case for the responsibility of the international community to uphold human rights – in situations of genocide, war crimes, ethnic cleansing or crimes against humanity – in the event that a State is unwilling or unable to offer such protection. ICISS, Responsibility to Protect, International Development Research Centre, Ottawa, 2001. It thereby subordinates State sovereignty to the responsibility to protect. UN Security Council Resolution 1674, 28 April 2006, based on R2P, codifies into law the prevention of armed conflict and the protection of civilians, including gender-based and sexual violence.
33 Slim, Hugo, “Sharing a Universal Ethic: The Principle of Humanity in War”, International Journal of Human Rights, Vol. 2, No. 4, 1998CrossRefGoogle Scholar. In his more recent book Humanitarian Ethics, Slim frames his discussion of humanity in terms of ethics and the need to interpret and balance between conflicting principles. Hugo Slim, Humanitarian Ethics: A Guide to Morality of Aid in War and Disaster, Oxford University Press, Oxford, 2015, pp. 40–45.
34 R. Teitel, above note 31, p. 33.
35 Parekh, Bhikhu, “Rethinking Humanitarian Intervention”, International Political Science Review, Vol. 18, No. 1, 1997, p. 61Google Scholar.
36 For more on the distinction between biologic and biographical lives, see Fassin, Didier, “Humanitarianism as a Politics of Life”, Public Culture, Vol. 19, No. 3, 2007CrossRefGoogle Scholar; and H. Slim, Humanitarian Ethics, above note 33, p. 48.
37 Ibid., pp. 45–55.
38 The notion of “bare life” draws upon the work of Giorgio Agamben. Those cited here, including Michel Agier, Dider Fassin and Jennifer Hyndman, are scholars who draw upon Agamben in their critiques and fall within the tradition of Foucauldian critical theory. See Giogio Agamben, Homo Sacer: Sovereign Power and Bare Life, translation by Daniel Heller-Roazen, Stanford University Press, Stanford, CA, 1998.
39 C. Calhoun, above note 24.
40 Rony Brauman, “Global Media and the Myths of Humanitarian Relief: The Case of the 2004 Tsunami”, in Richard Ashby Wilson and Richard D. Brown (eds), Humanitarianism and Suffering: The Mobilization of Empathy, Cambridge University Press, Cambridge, 2009.
41 See also Malkki, Liisa, “Speechless Emissaries: Refugees, Humanitarianism, and Dehistoricization”, Cultural Anthropology, Vol. 11, No. 3, 1996CrossRefGoogle Scholar.
42 Agier, Michel, “Humanity as an Identity and Its Political Effects (A Note on Camps and Humanitarian Government)”, Humanity: An International Journal of Human Rights, Humanitarianism, and Development, Vol. 1, No. 1, 2010, p. 33Google Scholar.
43 Recognizing the fact that fundraising appeals linked to individuals, as opposed to a “mass of humanity”, are more successful, many aid agencies reference a specific individual and the ability of donations to better his or her life and community.
44 M. Agier, above note 42, p. 39.
45 D. Fassin, above note 36, p. 518.
46 Hyndman, Jennifer, “Managing Difference: Gender and Culture in Humanitarian Emergencies”, Gender, Place and Culture, Vol. 5, No. 3, 1998, p. 242CrossRefGoogle Scholar. Hyndman examines these and other issues in more depth in Managing Displacement: Refugees and the Politics of Humanitarianism, University of Minnesota Press, Minneapolis, MN, 2000. While somewhat dated, her analysis demonstrates both the long-standing tension between the universal and the particular and the still-current relevance of her critique.
47 Didier Fassin, “Inequality of Lives, Hierarchies of Humanity: Moral Commitments and Ethical Dilemmas of Humanitarianism”, in I. Feldman and M. Ticktin (eds), above note 10.
48 Ilana Feldman and Miriam Ticktin, “Introduction: Government and Humanity”, in I. Feldman and M. Ticktin (eds), above note 10, p. 4; T. W. Laqueur, above note 27; Seyla Benhabib, The Rights of Others: Aliens, Residents and Citizens, Cambridge University Press, Cambridge, 2004.
49 T. W. Laqueur, above note 27; M. Mauss, above note 11. Michael Walzer, in contrast, suggests that humanitarianism is both charity and duty, a “two-in-one” in which we as individuals “choose to do what we are bound to do”. Walzer, Michael, “On Humanitarianism: Is Helping Others Charity, or Duty, or Both?”, Foreign Affairs, Vol. 90, No. 4, 2011, p. 80Google Scholar.
50 Jeffrey Stout, Blessed Are the Organized: Grassroots Democracy in America, Princeton University Press, Princeton, NJ, 2010. I heard Stout use this phrase in a lecture on his book presented at the Kroc Institute, University of Notre Dame, on 18 October 2013.
51 See, for example, Denis Kennedy, “Selling the Distant Other: Humanitarianism and Imagery – Ethical Dilemmas of Humanitarian Action”, Journal of Humanitarian Assistance, 28 February 2009, available at: http://sites.tufts.edu/jha/archives/411.
52 This issue has received and continues to receive attention. See, for example, Alex de Waal, Famine Crimes: Politics and the Disaster Relief Industry in Africa, James Currey, Oxford, 1997. For a more recent account, see Séverine Autesserre, Peaceland: Conflict Resolution and the Everyday Politics of International Intervention, Cambridge University Press, Cambridge, 2014.
53 Didier Fassin, Humanitarian Reason: A Moral History of the Present, University of California Press, Berkeley, CA, 2012, p. 223.
54 Ibid., p. 227; D. Fassin, above note 47.
55 E.g., Convention on the Protection of UN and Associated Personnel, 9 December 1994, UNTS 2051 (entered into force 15 January 1999); Optional Protocol to the Convention on the Protection of UN and Associated Personnel, 8 December 2005, Doc. A/60/518 (entered into force 19 August 2010); UNSC Res. 1502 (2003); and Rome Statute of the International Criminal Court, 17 July 1998, 2187 UNTS 90 (entered into force 1 July 2002), Art. 8(2)b(vii).
56 For an in-depth discussion of the concept of humanitarian exceptionalism and the legal protections for aid workers, see L. Fast, above note 25, pp. 197–207. On legal protections, see also Kate Mackintosh, “Beyond the Red Cross: The Protection of Independent Humanitarian Organizations and Their Staff in International Humanitarian Law”, International Review of the Red Cross, Vol. 89, No. 865, 2007.
57 Max Ehrenfreund, “Europe Hesitates as Thousands Die Annually on Mediterranean”, Washington Post, 21 April 2015, available at: www.washingtonpost.com/blogs/wonkblog/wp/2015/04/21/wonkbook-europe-hesitates-as-thousands-die-annually-on-mediterranean/.
58 BBC News, “Nepal Earthquake: Dozens Die in New Tremor near Everest”, BBC News, 12 May 2015, available at: www.bbc.com/news/world-asia-32701385.
59 Sudarsan Raghavan, “More than 10,000 Afghan Civilians Died or Were Injured in 2014, UN Says”, Washington Post, 18 February 2015, available at: www.washingtonpost.com/world/more-than-10000-afghan-civilians-died-or-were-injured-last-year-un/2015/02/18/90aab7c6-b753-11e4-9423-f3d0a1ec335c_story.html.
60 When ten aid workers were killed in Afghanistan, stories of their work and lives appeared in multiple news stories. See CNN Wire Staff, “A Look at the 10 Aid Workers Killed in Afghanistan”, CNN, 9 August 2010, available at: www.cnn.com/2010/WORLD/asiapcf/08/09/afghanistan.victims.list/; and Shaila Dewan and Rod Nordland, “Slain Aid Workers Were Bound by Their Sacrifice”, New York Times, 9 August 2010, available at: www.nytimes.com/2010/08/10/world/asia/10aidworkers.html?_r=0.
61 Amnesty International advocates for specific victims of human rights abuses, and Human Rights Watch often employs individual stories in its reports. The Human Rights Data Analysis Group (HRDAG) triangulates lists of victims through multiple systems estimation to arrive at overall counts of human rights violations. See Megan Price, “When Data Doesn't Tell the Whole Story”, HRDAG, 7 May 2015, available at: https://hrdag.org/when-data-doesnt-tell-the-whole-story/. The use of child sponsorship and of individual representative stories to highlight the positive effects of a donation are exceptions, whereby humanitarians employ individual narratives. Yet, as Fassin points out, all of these are examples where people's biographical lives are narrated by a more powerful other. See D. Fassin, above note 36.
62 For example, in research based in East Africa (Kenya, South Sudan and Uganda), staff from different regions of a country or from neighbouring countries faced different risks based on where they were from, even though they tended to be lumped together as national staff and often received little or no customized training or benefits. See Larissa Fast, Faith Freeman, Michael O'Neill and Elizabeth Rowley, The Promise of Acceptance: Insights into Acceptance as a Security Management Approach from Field Research in Kenya, South Sudan, and Uganda, Save the Children, Washington, DC, 2011, available at: http://acceptanceresearch.org/reports/final-report/. Even though the example originates in East Africa, it is arguably relevant beyond this region and points to the importance of disaggregating risk according to multiple characteristics, including birthplace/location, ethnicity and nationality as well as job position and gender, and the subsequent complexity of risk management.
63 Sheri Fink, “Treating Those Treating Ebola in Liberia”, New York Times, 5 November 2014, available at: www.nytimes.com/2014/11/06/world/africa/treating-those-treating-ebola-in-liberia.html?emc=edit_th_20141106&nl=todaysheadlines&nlid=26958110&_r=0.
64 Paul Richards and Alfred Mokuwa, “Village Funerals and the Spread of Ebola Virus Disease”, Cultural Anthropology Online, 7 October 2014, available at: www.culanth.org/fieldsights/590-village-funerals-and-the-spread-of-ebola-virus-disease.
65 Raphael Frankfurter, “The Danger of Losing Sight of Ebola Victims' Humanity”, The Atlantic, August 2014, available at: www.theatlantic.com/health/print/2014/08/the-danger-in-losing-sight-of-ebola-victims-humanity/378945/.
66 Mary B. Anderson, Dayna Brown and Isabella Jean, Time to Listen: Hearing People on the Receiving End of International Aid, CDA Collaborative Learning Projects, Cambridge, MA, 2012.
67 International Federation of Red Cross and Red Crescent Societies, World Disasters Report, 2014: Focus on Culture and Risk, Geneva, 2014, available at: www.ifrc.org/world-disasters-report-2014.
68 World Bank Group, World Development Report, 2015: Mind, Society and Behavior, Washington, DC, 2015, available at: http://econ.worldbank.org/WBSITE/EXTERNAL/EXTDEC/EXTRESEARCH/EXTWDRS/EXTNWDR2013/0,,contentMDK:23330018~pagePK:8258258~piPK:8258412~theSitePK:8258025,00.html.
69 See, for example: www.ebola-anthropology.net and www.culanth.org/fieldsights/585-ebola-in-perspective. Many of these analyses rightly deconstructed the response, providing contextual interpretation that helped explain some of the failures of the early days of the response. Unfortunately, however, not all took the next step of suggesting practical steps for how responders could have taken account of the cultural context in their programming.
70 Anthony Banbury, “Creating UNMEER: Ebola and the UN's First Emergency Health Mission”, International Peace Institute Webcast, 3 February 2015, summary available at: www.ipinst.org/events/speakers/details/597-banbury-credits-ban-with-mobilizing-un-ebola-response.html.
71 For more on accountability in humanitarian response, see the Humanitarian Accountability Partnership website, available at: www.hapinternational.org. For academic literature, see, among others, Hilhorst, Dorothea, “Being Good at Doing Good? Quality and Accountability of Humanitarian NGOs”, Disasters, Vol. 26, No. 3, 2002CrossRefGoogle ScholarPubMed; and Kirsch, Thomas D., Perrin, Paul, Burkle, Frederick M., Canny, William, Purdin, Susan, Lin, William and Sauer, Lauren, “Requirements for Independent Community-Based Quality Assessment and Accountability Practices in Humanitarian Assistance and Disaster Relief Activities”, Prehospital and Disaster Medicine, Vol. 23, No. 3, 2012Google Scholar.
72 See L. Fast, above note 25; and Abby Stoddard, Adele Harmer and Katherine Haver, Aid Worker Security Report. Spotlight on Security for National Aid Workers: Issues and Perspectives, Humanitarian Outcomes, New York, 2011.
73 See, for example, M. Agier, above note 42; and J. Hyndman, Managing Displacement, above note 46.
74 UN OCHA, Humanitarianism in the Network Age, Policy and Studies Series, OCHA, New York, 2013, p. 56.
75 M. Agier, above note 42, p. 34.
76 Ibid., p. 42.
77 See Larissa Fast, Reginold Patterson, Alfred Amule, Simon Bonis, Lasu Joseph, Anthony Kollie, James Luer Gach Diew, Sirocco Mayom Biar Atek, Christopher Nyamandi and Jimmy Okumu, South Sudan Country Report: Key Findings from Field Research on Acceptance in South Sudan, Save the Children, Washington, DC, 2011, available at: http://acceptanceresearch.org/reports/south-sudan-country-report; Laura Hammond, “The Power of Holding Humanitarianism Hostage and the Myth of Protective Principles”, in M. Barnett and T. G. Weiss (eds), above note 24, pp. 172–195.
78 Vincent Cochetel, “Attacks on Humanitarians Are Attacks on Humanity”, TEDx, Place des Nations, Geneva, 11 December 2014, published on 8 January 2015, available at: www.youtube.com/watch?v=1F5CsD2ekSA.
79 Personal interview, South Sudan, April 2011.
80 The MSF Charter refers to “bearing witness” (www.msf.org/msf-charter-and-principles). Norwegian People's Aid refers to “solidarity in practice” (www.npaid.org/About-us), and Catholic Relief Services adopts solidarity as a guiding principle (www.crs.org/about/guiding-principles.cfm).
81 Obviously, solidarity in the sense of affirmation or endorsement of a specific group or agenda is at odds with the humanitarian principles of neutrality and, in some cases, impartiality. Solidarity-as-presence, in the sense of accompaniment for affected populations, however, might occupy a metaphorical space between neutrality and solidarity-as-endorsement.
82 See, e.g., Joe Belliveau, ‘“Remote Management’ in Somalia”, Humanitarian Exchange, No. 56, January 2013, pp. 25–27.
83 Duffield, Mark, “Risk Management and the Fortified Aid Compound: Everyday Life in Post-Interventionary Society”, Journal of Intervention and Statebuilding, Vol. 4, No. 4, 2010, pp. 453–474CrossRefGoogle Scholar.
84 L. Fast, above note 25. Chapter 6 includes an expanded critique of these approaches.
85 H. Slim, above note 33.
86 R. Coupland, above note 27.
87 C. Sommaruga, above note 3, p. 25.
88 V. Cochetel, above note 78.
89 Ibid.