March 26
YEMEN:
Rebel court sentences Yemen president to death
A rebel court in Yemen's insurgent-held capital has sentenced President
Abedrabbo Mansour Hadi to death for high treason in absentia, the rebel news
agency has said.
Yemen on Sunday marked the 2nd anniversary of a Saudi-led coalition starting
air strikes against the Huthi rebels in support of Hadi's government, after the
insurgents overran the capital Sanaa.
The court found Hadi guilty of "usurping the title of president after the end
of his term in office" in February 2014, "instigating attacks by Saudi Arabia"
and "undermining the independence and integrity of the Republic of Yemen", the
rebel-controlled Saba agency said late Saturday.
Six members of Hadi's government were also sentenced to death for treason, it
said.
On Sunday, hundreds of thousands of Huthi supporters flooded the streets of
Sanaa for a mass rally against Saudi Arabia's role in the war, an AFP reporter
at the site said.
That came a day after former president Ali Abdullah Saleh, who is allied to the
Huthis, slammed Riyadh in a speech marking two years since the coalition's
military intervention.
"Free Yemenis will continue to choose resistance, as long as the coalition led
by Saudi Arabia continues to choose war," Saba quoted Saleh as saying.
Rebel leader Abdul Mali k al-Huthi said the Saudi-led coalition had been
"living under the illusion that they can take Yemen in a week or a month... but
have sunk into the mud," it said.
Hadi's forces have gained ground in southern Yemen since the coalition's
intervention in March 2015, but the Huthis still control the capital and
strategic ports on the Red Sea coastline.
More than 7,700 people have been killed and over 40,000 injured over the past
two years, the United Nations says.
3 million people have been displaced and the country faces a serious threat of
famine, it says.
al-monitor.com)
INDIA:
The death penalty is required to be retained in our book with certain
amendments.
The proposed recommendation of the National Law Commission for abolition of
death penalty, prima facie, appears to be based on three facts. First, most of
the advanced countries in the world have abolished the death penalty being a
cruel and inhuman sentence. Secondly, there is no rational foundation for
awarding death penalty and the discretion of the judge varies from person to
person. Thirdly, in our country the death penalty has not served as a deterrent
measure as the heinous crime falling in the category of "rarest of rare" cases
are committed frequently.
However, I am of the candid opinion that the death penalty is required to be
retained in our book with certain amendments for 2 reasons. Firstly, it is not
just a punishment given to the criminal concerned, but it also gives a strong
signal to other like-minded people. Secondly, it works as a deterrent measure
against such criminals who are the menace to society.
I have come across the cases wherein the death penalty by sessions judge was
confirmed by the High Court and even the SC upheld it. However, even after the
rejection of the mercy petition by the President, the High Court again
entertained a petition of death convicts challenging the capital punishment and
stayed the death penalty. Naturally, the death convicts are interested in
prolonging petitions hoping that courts would turn the death penalty into life
imprisonment on the account of delay. This results in sending a message to the
people at large that death penalty has no useful purpose.
I would have been happy if the Law Commission would have considered as to how
the execution of death penalty can be expedited or how delay can be avoided. I
will not say that once the sessions court has imposed death then it should
expeditiously be executed. But certain time limit is required to be prescribed
while deciding petitions challenging the death penalty. And there should be
provision that if such appeals or mercy petitions are not decided in a
stipulated time period then death penalty should stand rejected. But, it should
not be taken out of the book.
(source: Advocate Ujjwal Nikam is a famous special public prosecutor who has
represented the state or the CBI in cases such as 1993 Bombay bomb blasts,
26/11 terror attacks in Mumbai and Gateway of India twin blasts. He has the
record of securing maximum death penalties in Maharashtra----Asian Age)
*********************
The legitimacy of Capital punishment
Law Commission felt time has come for India to move towards abolition of the
death penalty. It hoped the movement towards absolute abolition will be swift.
But it is difficult to agree with the Commission's majority opinion.
To be or not to be, is the question. To live, or to extinguish life? William
Shakespeare's question posed in Hamlet in 1602 haunts policymakers across the
world still: whether or not to award capital punishment.
The terms "capital" is derived from the Latin capitalis, "of the head",
referring to execution by beheading. Beheading is barbaric. Although most
nations (more than 100) have abolished capital punishment, many countries have
retained it. Over 60 % of world's population live in countries where execution
takes place, such as in India, the United States, China, Indonesia etc.
Historically, execution of criminals and political opponents has been used by
nearly all societies both to punish crime and to suppress political dissent.
Normally capital punishment is reserved for murder, terrorism, war crimes,
reason, espionage etc. In some countries rape, adultery, incest carry death
penalty. In many countries drug trafficking is also a capital offence. In
China, human trafficking and serious cases of corruption are punished by death
penalty still.
In India, recent terrifying rape-and-murders gave rise to calls for death to
rapist-murderer. So, will Law Panel's recommendation of death for terrorists
give a leeway for a demand for the inclusion of rapists-murderers? Where do the
demands stop? And are these demands justified?
Although several members of the Constituent Assembly were opposed to death
penalty, yet founding fathers of India's Constitution retained capital
punishment. Parliament, through law, prescribed death penalty in many
situations such as murder, mutiny by a member of armed forces, waging a war
against the government etc. First fetter was imposed in 1973 when Section 354
(3) of the Code of Civil Procedure, 1973 impelled the judiciary to give special
reasons for capital punishment.
Then, on May 9, 1980, came the landmark verdict of a Constitution Bench of the
Supreme Court in Bachan Singh vs State of Punjab [1980 (2) SCC 684], in which
the constitutional validity of death penalty for murder provided in Section 302
of the Indian Penal Code (IPC), and the sentencing procedure stipulated in
Section 354 (3) was impugned. The Supreme Court by a split verdict of 3 to 2
rejected the challenge to the constitutionality of Section 302 of the IPC and
Section 354 (3) of the CrPC (Justices Chandrachud, Gupta and Untwalia). The
minority view (Justices Bhagwati and Sarkaria) struck down Section 302 of IPC
as unconstitutional and void in so far as it provides for imposition of death
penalty as an alternative to imprisonment for life.
The Bachan Singh judgement propounded "rarest of rare" doctrine. It is now well
settled that life sentence is the rule and death sentence an exception. This is
also buttressed from the fact that in several important judgments involving
serious crimes, the Supreme Court declined to award death penalty to convicts.
Judgements pertaining to Graham Staines, Jessica Lall, Priyadarshini Mattoo
etc., bear testimony to this jurisprudential trend.
But then Bachan Singh case also opened up a challenge to the judiciary: What
constitutes "rarest of rare"? There is no statutory definition. It is entirely
in the realm of judicial discretion without any legislative yardstick. Of
course, who else, but only a Judge, can award a death sentence. An element of
discretion/conscience is always ingrained in every judicial function. And, as
American Chief Justice Earl Warren [1891-1974] said, in civilised life, the law
floats in a sea of ethics.
Law Commission of India took note of above situation and, in its 262nd report
recommended that death penalty be abolished for all crimes other than terrorist
related offences and waging war against the Government of India. The Commission
felt that time has come for India to move towards abolition of the death
penalty. The Commission further hoped that the movement towards absolute
abolition will be swift and irreversible. With respect, it is difficult to
agree with Law Commission's majority opinion. The line of demarcation between
terrorist related offences and other heinous offences is blurred. Criminals
must face punishment. Greater the ferocity of offence, higher should be the
penalty. India is a vast country with multi-faceted strife in every field. It
is premature to abolish death penalty now or swiftly in future. Time is not
ripe yet. Existence of death penalty acts as a deterrence, and awarding death
sentence must continue to remain in the realm of judicial discretion/wisdom.
Also, under Articles 72 and 161 of the Constitution, the President and
Governors, respectively are powered to grant pardons, reprieves, respites or
remissions of punishment or to suspend, remit or commute the sentence of any
person convicted of any offence.
Although death sentence may be retained, but procedure to execute must improve.
Beheading or hanging till death is barbaric, uncivilised and epitomises state
cruelty. Penalty of death sentence can surely be executed in a more civilised
manner; for example, extinguishing life by injecting painless medicine. Article
21 of India's Constitution sanctifies extinguishing (depriving) life by
"procedure established law". Extant established procedure of hanging till death
is most cruel. Indian civilisation in 21st century cannot afford to remain so
insensitive. The State must invent a better procedure to extinguish life.
Cruelties committed by criminals can, by no means, justify contra procedural
cruelty committed by the State. Death penalty may thus be retained in rarest of
rare cases, but the State may extinguish life in a civilised and less cruel
manner.
(source: Opinion; Bishwajit Bhattacharyya----The writer is Senior Advocate,
Supreme Court of India and former Additional Solicitor General of India----The
Asian Age)
*******************
Emotions and word of law
Wobbly and inconsistent standards could dilute or confuse India???s legal
process.
Judges should never be bloodthirsty - a real concern for the dignity of human
life postulates resistance to taking a life through law's instrumentality. That
ought not to be done save in the rarest of rare cases when the alternative
option is unquestionably foreclosed." The Supreme Court spoke thus in the
Bachan Singh case. Judiciary has invariably stuck to the 'rarest of rare' rule
to pick convicts to send to the gallows.
The death penalty has been on the statute book for long and passed
constitutional muster too. In its 35th report in December 1967, the Law
Commission, which began its deliberations after a Parliament resolution in
1962, rejected the abolition of capital punishment linking it to "conditions in
India, to the variety of social upbringing, to disparity in morality and
education in the country."
But in August of 2015, the Commission, a proactive body with retired Chief
Justice A.P. Shah as its helmsman, recommended the "abolition of death penalty
except for terrorism and waging war-related crimes". Now, it is this report
that has been referred to all States by the Centre as Criminal Law and
Procedure are in the concurrent list of the Seventh Schedule of the
Constitution, and the entities need to be in the loop.
The Commission's deliberations were born out of a judgement of the SC in the
Sankar Kisanrao Kade case where the top court was concerned with differing
standards in adoption by the Judiciary and the Executive in considering crimes
fit for gallows or clemency. While the judiciary stuck to the "rarest of rare"
doctrine, the standards of the Executive were wobbly and were called into
question for "selectivity". The power of pardon with the President did not
always disclose good and valid reasons and therefore judicial intervention
became somewhat routine.
While the State Governments deliberate on their responses, emotions ought not
to hold sway as they may in Tamil Nadu as so many Rajiv Gandhi case death row
convicts are involved. The primary concern of SC is that the dispensation ought
to rid the inconsistency in treating prisoners fit for gallows and clemency and
not whether times have changed in 2017 from 1967 so much that India can afford
to get rid of the death penalty, even as ghastly crimes have shown no
noticeable abatement.
(source: Opinion; Narasimhan Vijayaraghavan----The writer is an advocate in the
Madras high court----The Asian Age)
MALAYSIA:
Be bold and abolish death penalty, government told----Human rights advocates
urge that capital punishment be removed not just for drug trafficking offences,
but for all crimes currently punishable by death.
Human rights groups have urged the government to be bold and abolish the
mandatory death penalty in its entirety.
In applauding the Cabinet decision to amend Section 39(B) of the Dangerous
Drugs Act 1952 to include a clause providing discretionary powers to the courts
in sentencing drug traffickers, they said capital punishment was not right.
Amnesty International, Lawyers for Liberty and Suara Rakyat Malaysia all agreed
that there was no evidence to show the death penalty reduced crime.
They called on the government to make the anticipated removal of the mandatory
death penalty for drug offences the first step towards complete abolition of
that particular form of punishment.
"Malaysia is 1 of some 30 countries that still use the death penalty, including
mandatory death penalty, which remains one of the most abhorrent methods of
punishing crime," said Amnesty International Malaysia executive director
Shamini Darshini.
"Death penalty robs lives, has no impact on crime rate, and gives Malaysia a
black mark where its human rights record is concerned."
She said there was concern about the fate of current death row prisoners should
the 1952 Act be amended to allow discretionary sentencing by judges on certain
death penalty cases.
Prison Department statistics show there are almost 800 prisoners, both
Malaysians and foreigners, currently on death row for drug trafficking
offences.
On March 23, Minister in the Prime Minister's Department Azalina Othman Said
told the Dewan Rakyat that a review of the Act would enable judges to mete out
suitable jail sentences instead of the mandatory death penalty, especially in
marginal cases.
Lawyers for Liberty executive director Eric Paulsen echoed Shamini's call for
the government to extend the review to all death penalty offences.
"The judges are in the best position to decide on the appropriate sentence for
each individual case, whether it is for murder, kidnapping, waging war, or
firearms offences."
He said contrary to popular belief, there was no "cogent empirical evidence" to
show the death penalty was a more effective deterrent of crime than long-term
imprisonment.
"The death penalty disproportionately affects the poorer and lower classes, and
the risks of wrongful convictions cannot be excluded."
Paulsen also urged the government to impose a moratorium on all death penalties
pending the review and amendments.
Suara Rakyat Malaysia executive director Sevan Doraisamy said the "long-awaited
baby move" - it was promised to be tabled in Parliament last year - was a
positive 1st step towards abolition of the death penalty.
"Everyone deserves a 2nd chance. The death penalty is not a solution; it is a
violation of human rights and should be abolished.
"We are aiming to become a developed nation, and one of its important elements
is human rights.
"Many countries have abolished the death penalty and we should aim for the
same," he said.
(source: freemalaysia.com)
**************************
Ex-judges want review of mandatory death penalty
The proposed amendments to review the mandatory death sentence for drug
trafficking will give judges wider discretion when deciding if a person is to
hang, says former chief justice Tun Ahmad Fairuz Sheikh Abdul Halim.
He said giving judges leeway for discretion would be a positive move in some
circumstances.
"There are some situations where a crime might not warrant the death penalty.
If this amendment is allowed, judges would be able to use their own
discretion," he said when met after a legal lecture he delivered yesterday.
He was responding to the Cabinet's agreement to review the Dange???rous Drugs
Act 1952 to allow judges to use their discretion in sentencing offenders
instead of impo???sing the mandatory death sentence.
Minister in the Prime Minister's Department Datuk Seri Azalina Othman Said, who
made the announcement last week, said the review would enable judges to mete
out suitable sentences in marginal cases where offenders could be jailed
instead.
She said the review was presented to the Cabinet on March 1 by Attorney-General
Tan Sri Mohamed Apandi Ali.
Ahmad Fairuz said during his time on the Federal Court bench, the duty of
having to sentence a man to death weighed on the conscience.
Datuk Seri Nazri Aziz, who was a former minister in charge of law, said judges
would have the option to mete out suitable senten???ces on a case-by-case
basis.
"We always worry that judges do not have other options than the man???datory
death sentence. In some cases, there is not much evidence, but the judges have
no other options but to give the death penalty," he said.
Nazri said the move to give judges more discretion over the death penalty in
drug trafficking cases was long overdue.
He said the proposed amendments to provide such discretionary powers to judges
had come during his tenure when he was in charge of the law portfolio.
"When I was the minister, there were about 240 Malaysians who are suspected to
be drug mules all over the world. Some of their family members came to see me
personally and pleaded for leniency.
"We also can use this to negotiate with other governments who have arrested
Malaysians suspected to be drug mules," he added.
Nazri said another factor that was considered was that there were cases that
judges who do not wish to mete out death sentences in drug trafficking cases.
"Some judges do not believe in the death penalty. So when the case comes before
them, although there was enough evidence to impose a conviction, they will find
some technicality to acquit the person," he said.
Former court of appeal judge Datuk Mah Weng Kwai, who is also Suhakam
commissioner, is in favour of abolishing the death penalty.
"As for sentencing in cases of Section 39(B) of the Dangerous Drugs Act 1952, I
believe that the grant of judicial discretion to judges is a step forward," he
said.
Senior criminal law practitioner Kitson Foong said the move would address cases
of drug mules where the offender might be an innocent carrier.
"This will be a good opportunity for the court to spare the life of an
individual who has been used by drug cartels," he said.
(source: thestar.com.my)
UNITED ARAB EMIRATES:
Son's killers: Pakistani man pardons 10 Indians
A Pakistani has decided to forgive the murderers of his son, which could save
the lives of 10 Indian men.
A court in United Arab Emirates' city of Abu Dhabi has approved to pay blood
money in exchange of acquitting the Indian youngsters sentenced to death for
murder, BBC Urdu reported.
The youngsters, who came to work in Abu Dhabi from Indian Punjab, were
convicted in October last year for killing a Pakistani following an argument in
2015.
'Blood money' explained
As per Shariah law in the UAE, an appeal against death penalty can be filed in
court if the family of the victim and the convict reconcile, and the affected
family pardons the offender.
Mohammad Riaz, who originally belongs to Peshawar, has decided to pardon the
killers of his son, Mohammad Farhan.
Although the final decision will be taken by the court, the appeal has given
the convicts a new ray of hope, and a possibility to go free.
The blood money is being arranged by an Indian businessman SP Singh Oberoi, who
is based in Dubai. He's a president of the NGO, Sarbat Da Bhala Charitable
Trust, which works for people convicted and arrested for such matters.
"We have succeeded in forging the reconciliation," said Oberoi.
Pakistani citizen Farhan had breathed his last following the brawl. His father,
along with family and friends, is now in Abu Dhabi for exonerating the 10
Indians. He submitted the agreement in court, and has been given time until
April 12, 2017 for further action into the matter.
"It was unfortunate that I lost my son. I appeal the young generation not to
indulge in such fights and mind their own business," said Riaz. "I have
forgiven these 10 individuals. It's my name only...Allah has saved their lives.
Lives of at least 10 people, including wife and children, are attached
[financially] to one person [who comes to work in UAE]."
Riaz, Oberoi said, has assured he [on behalf of his family] will ask the judge
to pardon all the 10 convicts.
The Indian businessman said Riaz was invited from Pakistan 3 days ago, with all
arrangements, including visa and accommodation being made by his trust. "We
somehow made him agree... and as per Sharia law, have submitted Dhs200,000 as
blood money in court," he added.
Detailing the work of his NGO, Oberoi said that between 2006 and 2010, about
123 youngsters were sentenced to death and in prison for up to 40 years in the
UAE. His non-for-profit saved the lives of 88 such men, who have now returned
home. These men belonged to Punjab, Haryana, Maharashtra and Hyderabad. 5 such
youths were also from Pakistan, and 5 from Bangladesh.
(source: Express Tribune)
IRAN:
Young Man Facing Death for Insulting Islam Online Tricked into Signing
Confession
Sina Dehghan, sentenced to death for "insulting the prophet" of Islam when he
was 19-years-old, was tricked into signing his confession, an informed source
told the Center for Human Rights in Iran (CHRI).
Despite the severity of the charge, a court-appointed attorney who failed to
defend him properly represented him during his trial, added the source, who
requested anonymity for security reasons.
"During his interrogation, Sina was told that if he signed a confession and
repented, he would be pardoned and let go," said the source in an interview
with CHRI on March 21, 2017. "Unfortunately, he made a childish decision and
accepted the charges. Then they sentenced him to death."
"Later he admitted that he signed the confession hoping to get freed," said the
source. "Apparently the authorities also got him to confess in front of a
camera as well."
"Security and judicial authorities promised Sina???s family that if they didn't
make any noise about his case, he would have a better chance of being freed,
and that talking about it to the media would work against him," added the
source. "Unfortunately, the family believed those words and stopped sharing
information about his case and discouraged others from sharing it as well."
"Sina is not feeling well," continued the source. "He's depressed and cries
constantly. He's being held in a ward with drug convicts and murderers who
broke his jaw a while ago."
"He was a 19-year-old boy at the time (of his arrest) and had never done
anything wrong in his life," added the source.
The Islamic Revolutionary Guard Corps (IRGC) arrested Dehghan on October 21,
2015 at a military barracks in Tehran after he made comments against Islam and
the Quran on the LINE instant messaging application. He has been imprisoned in
Arak Prison ever since.
Initially, Branch 1 of the Criminal Court in Arak sentenced Dehghan to death
for "insulting the prophet" and 16 months in prison for "insulting the supreme
leader." The Supreme Court confirmed his death sentence in late January,
according to the source.
Deghan's co-defendants, Sahar Eliasi and Mohammad Nouri, were also convicted of
posting anti-Islamic content on social media.
Nouri was issued the death sentence, which was upheld by the Appeals Court, but
it is not known if the Supreme Court has issued a final ruling.
Eliasi was initially issued a 7-year prison sentence, which was later reduced
to 3 years upon appeal.
According to article 262 of Iran's Islamic Penal Code, insulting the prophet is
punishable by death. However, Article 263 states that if the accused tells the
court that his insults were the result of anger or a mistake, the sentence
could be reduced to 74 lashings.
"Sina is allowed to contact his family by phone and receive visits," the source
told CHRI. "During the past year, his family has come from Tehran to visit him
every week."
(source: iranhumanrights.org)
***************
Death Penalty Focus of Human Rights Report on Iran
The Secretary General released its report on the situation of human rights in
Iran at the 34th session of the Human Rights Council, being held in March in
Geneva. The 1st point of the report focused on the death penalty. Although
there has been a decrease in the number of executions in 2016 compared to 2015,
there are still a large number of individuals being executed or sentenced to
death in Iran.
At least 530 people, including 9 women, have been documented as being executed
in 2016. Non-governmental sources believe that this figure is actually much
higher. Many these executions are related to drug offences. On November 23,
2016, Hassan Nourozi, a member of the Iranian Parliament, indicated that there
were about 5,000 prisoners between 20 and 30 years old on death row in Iran.
Most of these individuals were 1st-time drug offenders.
Even though the death penalty has not been shown to be an effective deterrent
for drug-related offences, there has been no progress toward the adoption of a
bill to amend mandatory death penalty sentences for these crimes and no
moratorium against the execution of drug offenders.
Additionally, the trials for these individuals show that due process guarantees
were often violated in proceedings that fell short of international fair trial
standards. United Nations human rights mechanisms have repeatedly and
consistently expressed their great concern at this persistent trend, along with
urging the Iranian government to end executions and institute a moratorium on
the death penalty altogether.
There are also individuals in the Iranian parliament that continue to support
the death penalty for drug offenses, which is a concern as discussions of
changes to the penal code continue. Those who support an anti-death penalty
campaign can find themselves arrested. Atena Daemi, an anti-death penalty
campaigner, was reportedly taken away from her parents' home to begin serving a
7-year prison sentence for her activities against the death penalty. The
Iranian government has noted that her sentence has now been reduced to 5 years.
2 mass executions were conducted in 2016. On August 5, 20 people belonging to
the Kurdish minority were executed for terrorism-related offences. Concerns
were expressed by the Special Rapporteur and the UN High Commissioner for Human
Rights regarding the fairness of the these trials. On August 27, 12 individuals
were hanged for drug related offences. Basic international human rights fair
trial standards and due process guarantees were also reportedly disregarded in
their trials as well.
There is also the issue of individuals who have been sentenced to death row
remaining there for lengthy periods, in some cases over 15 years. Those who
have been executed are often put to death in public executions. Despite a 2008
circular banning this practice, the government continues to justify its use,
including as a deterrent for drug-related offenses. In July, a public execution
took place in front of a crowd of people including children. In September, a
prisoner was hanged in public at a sports stadium with at least one child
watching the execution. The UN Committee on the Rights of the Child expressed
concern about the continued practice of public executions and their impact on
children.
Politics also play a role in a number of death penalty cases. Several
individuals were reportedly executed in political cases and non-violent
economic crimes, again with issues regarding their trials. Iran is a party to
the International Covenant on Civil and Political Rights, but the trials for
political prisoners often ignore the international norms for due process as
defined in Article 14.
In August, Mohammad Abdollahi, an alleged Kurdish militant, was executed at
Darya. His charges were based solely on an accusation that he was a supporter
of a Kurdish opposition group and was sentenced to death for Moharebeh (enmity
against God), although he reportedly never committed any armed or violent acts.
Another key issue with the death penalty in Iran is the execution of juvenile
offenders. International human rights instruments, ratified by Iran, impose an
absolute bank on the execution of any persons who were under 18 at the time of
their offense, regardless of the nature or circumstances of the crime itself.
However, the Iranian penal code still allows for sentencing of children to
death and no progress to change this has been made, despite repeated
recommendations from the High Commissioner for Human Rights, Special Procedures
mandate holders and Committee on the Rights of the Child.
Despite assurances by the Iranian authorities that the judiciary was working to
prevent juvenile executions, at least five young individuals who were below the
age of 18 at the time of their offense in 2016. Between 80 to 160 individuals
convicted as children were reportedly on death row as of December 2016.
Additionally, the Secretary-General's predecessor noted that up to 60% of the
executions in Iran were taking place without prior notice and without informing
the family. Same-sex relations was also being punished with the death penalty,
partners being reportedly forced to describe their consensual sex acts as rape
to avoid a death sentence.
As a result of multiple issues regarding the use of the death penalty, the
international community continues to encourage the Iranian government to
suspend the use of the death penalty, particularly in regards to cases with a
juvenile offender or drug-related offenses.
(source: themediaexpress.com)
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