Comparative and International Law Journal of Southern Africa-CILSA最新文献_第5页

The Canadian Courts’ Approach to the ‘Duty to Consult’ Indigenous Peoples: A Comparative Overview 加拿大法院对土著人民“咨询义务”的态度:比较综述

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-04-21 DOI: 10.25159/2522-3062/5307

G. Barrie

{"title":"The Canadian Courts’ Approach to the ‘Duty to Consult’ Indigenous Peoples: A Comparative Overview","authors":"G. Barrie","doi":"10.25159/2522-3062/5307","DOIUrl":"https://doi.org/10.25159/2522-3062/5307","url":null,"abstract":"Articles 18, 19 and 23 of the United Nations Declaration on the Rights of Indigenous Peoples 2008 and Articles 6 and 15 of the ILO Convention Concerning Indigenous and Tribal People No 169 of 1989, generated a concept of the ‘duty to consult’ indigenous peoples in matters that adversely affect their interests. The question as to whether this ‘duty to consult’ had not developed into a rule of customary international law, was raised at the International Law Association’s meeting in Sofia in 2012. To answer this question a survey of state practice needs to be undertaken. This article focusses on the state practice of Canada regarding the ‘duty to consult’ as illustrated by decisions of that country’s courts. It can be implied that Canadian courts see the ‘duty to consult’ as an obligation which must be adhered to. Canadian courts have recognised the ‘duty to consult’ since the judgment in R v Sparrow in 1990, but the elaboration of the concept came strongly to the fore in a trilogy of cases in 2004 and 2005 in the Haida Nation, Taku River Tlingit First Nation and Mikisew Cree First Nation cases. Since then, the concept has been incisively discussed and applied in the Canadian Supreme Court in the Rio Tinto, Little Salmon, Moses and the Behn/Moulton Contracting cases from 2010 to 2013. The above developments are encapsulated in the 2017 Ontario Superior Court case of Saugeen First Nation. The example of Canadian courts accepting ‘the duty to consult’ its indigenous peoples has manifested itself in other jurisdictions, particularly in Australia and recently in South Africa; and indicates an evolving international customary law norm.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41594696","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Hmong ‘Marriage by Capture’ in the United States of America and Ukuthwala in South Africa: Unfolding Discussions 美利坚合众国的苗族“捕获婚姻”和南非的乌库特瓦拉：展开讨论

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-04-21 DOI: 10.25159/2522-3062/5981

L. Mwambene

{"title":"Hmong ‘Marriage by Capture’ in the United States of America and Ukuthwala in South Africa: Unfolding Discussions","authors":"L. Mwambene","doi":"10.25159/2522-3062/5981","DOIUrl":"https://doi.org/10.25159/2522-3062/5981","url":null,"abstract":"‘Marriage by capture’ among the Hmong people in the United States of America and ukuthwala in South Africa both take the form of the mock abduction of a young woman for the purpose of a customary marriage. The noteworthy point about these two customary marriage practices is that, although Hmong marriage by capture takes place in the context of a minority community in a liberal state, and ukuthwala occurs in a postcolonial state, courts in these jurisdictions convert these marriage practices to the common law offences of rape, assault, and abduction. This article reflects on the accused-centred approach in the case of People v Moua, in which the court invoked the cultural defence, and the victim-centred approach in Jezile v S, which severed cultural values from the rights of the woman. It questions whether the two communities in question, in their respective liberal and postcolonial settings, influence the attitudes of the courts in cases involving rape, assault, and abduction charges. The main argument proffered is that both approaches may encourage communities to continue marriage abduction practices without bringing them to the attention of investigative organs, with adverse human rights implications for the women and girls affected. The ultimate purpose of this conversation, therefore, is to show how the approaches of the courts to the recognition or non-recognition of these customary practices affect the rights of girls and women who encounter institutions of law that alienate people belonging to minority cultural groups, and often perpetuate injustice.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-04-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"49321322","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

The European Union’s General Data Protection Regulation (GDPR) and its Implications for South African Data Privacy Law: An Evaluation of Selected ‘Content Principles’ 欧盟的通用数据保护条例(GDPR)及其对南非数据隐私法的影响:对选定的“内容原则”的评估

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-03-08 DOI: 10.25159/2522-3062/7985

Anneliese Roos

{"title":"The European Union’s General Data Protection Regulation (GDPR) and its Implications for South African Data Privacy Law: An Evaluation of Selected ‘Content Principles’","authors":"Anneliese Roos","doi":"10.25159/2522-3062/7985","DOIUrl":"https://doi.org/10.25159/2522-3062/7985","url":null,"abstract":"After a lengthy legislative process, South Africa implemented the Protection of Personal Information Act 4 of 2013 (POPI Act) on 1 July 2020. The POPI Act is an omnibus data-protection Act that conforms to the former benchmark for data-protection laws worldwide, namely, the 1995 EU Data Protection Directive. At the time of drafting the proposed Bill that would later become the Act, the South African Law Reform Commission emphasised the importance of a South African data-protection Act that complies with international standards on data protection, especially with the EU’s Directive. The Directive, in Article 25, imposed a prohibition on the transfer of personal data to non-member countries that do not ensure an adequate level of protection when personal data of their citizens are processed. South Africa’s Act needed to comply with the standard set in the Directive for the protection of personal information if South Africa wanted to remain part of the international information technology market. In 2016, the EU adopted the General Data Protection Regulation (GDPR) that replaced the 1995 Directive with effect from May 2018. The question now arises whether the South African Act still meets the minimum standards for data protection set out by this Regulation and whether amendments to the Act are needed. This article compares certain provisions of the GDPR with similar provisions of the POPI Act in order to establish whether the South African Act meets the standard set in the GDPR.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-03-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"49230594","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 5

Emergence of Illegality in the Underlying Contract as an Exception to the Independence Principle of Demand Guarantees 见索即付保函独立性原则的例外——基础合同非法性的出现

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-03-08 DOI: 10.25159/2522-3062/8077

M. Kelly-Louw, C. Lupton

{"title":"Emergence of Illegality in the Underlying Contract as an Exception to the Independence Principle of Demand Guarantees","authors":"M. Kelly-Louw, C. Lupton","doi":"10.25159/2522-3062/8077","DOIUrl":"https://doi.org/10.25159/2522-3062/8077","url":null,"abstract":"It is questionable whether illegality in the underlying contract of a demand guarantee can or should constitute a valid exception to this instrument’s independence (autonomy) principle. From earlier English case law and scholarly discussions it appears that the acceptance of such an exception is contentious and, even if it is recognised, its extent remains uncertain. The English courts have previously indicated that they are open to accepting illegality in the underlying contract as an exception to the principle of independence of demand guarantees, but have not developed the exact parameters of such an exception. In the past, there were no South African court cases where illegality in the underlying contract was accepted, or even considered, as a possible exception to the independence principle of a demand guarantee. In a recent South African case, Mattress House (Proprietary) Ltd v Investec Property Fund Ltd, we find the first evidence of a South African High Court’s willingness to accept the possibility of illegality in the underlying contract as constituting a valid exception. In this article we discuss this South African case, which provides general guidance on the possibility of accepting such an exception under the South African law. South Africa is always persuasively influenced by English law in relation to demand guarantees. Therefore, we also discuss the English law.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-03-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47006030","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 2

International Human Rights Law and the Access of Children of Asylum Seekers to Social Assistance in South Africa 国际人权法和寻求庇护者儿童在南非获得社会援助的机会

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-03-08 DOI: 10.25159/2522-3062/8060

A. O. Jegede, P. Letuka, Tivoneleni Edmund Lubisi

{"title":"International Human Rights Law and the Access of Children of Asylum Seekers to Social Assistance in South Africa","authors":"A. O. Jegede, P. Letuka, Tivoneleni Edmund Lubisi","doi":"10.25159/2522-3062/8060","DOIUrl":"https://doi.org/10.25159/2522-3062/8060","url":null,"abstract":"There is a massive presence of asylum seekers in South Africa. Amongst this population are children who need social assistance from the state distributed as ‘grants’, due to their dependence, vulnerability and developmental requirements. South Africa is a state party to international instruments on human rights and has a regulatory framework including the Constitution which allows for the application of these instruments and guarantees the right to social security for everyone. This article focuses on whether the existing corpus of international instruments on human rights and relevant domestic regulatory frameworks may allow children of asylum seekers the access to social assistance in South Africa. While demonstrating that the access to social assistance for children of asylum seekers is implied under international human rights instruments, the article establishes that this has not found expression in the application of existing legislation on social assistance in South Africa. By deploying an appropriate interpretive approach, courts may respond to this normative gap and thereby assist in guaranteeing the access of these children to social assistance in South Africa.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-03-08","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46589862","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

The Indian Approach to Criminal Justice: The Role of Traditional Courts as Alternative Dispute Resolution Mechanisms 印度的刑事司法方法：传统法院作为替代争端解决机制的作用

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-01-26 DOI: 10.25159/2522-3062/7636

Christa Rautenbach, Navilla Somaru

{"title":"The Indian Approach to Criminal Justice: The Role of Traditional Courts as Alternative Dispute Resolution Mechanisms","authors":"Christa Rautenbach, Navilla Somaru","doi":"10.25159/2522-3062/7636","DOIUrl":"https://doi.org/10.25159/2522-3062/7636","url":null,"abstract":"South Africa and India both struggle with a high crime rate and case backlogs in the mainstream courts. Both countries have a pluralistic system where state law consists of formal law and customary law. Both have mainstream and traditional courts following dispute resolution based on traditional values and principles. The panchayat system in India is comparable to traditional authorities in South Africa. The panchayat system performs judicial-like functions, and traditional courts operate at informal (nyaya panchayat) and formal (gram nyayalayas) levels in the rural areas. The lok adalat system is an alternative dispute resolution mechanism employed by the Indian government to address the high crime rate and court backlogs. Statistics reveal that these alternative justice mechanisms based on traditional values and principles have successfully cleared some backlogs. South Africa is in the process of adopting legislation on traditional courts, and it is envisaged that the Traditional Courts Bill [B1-2017] will soon be transformed into law. In reconsidering traditional courts’ role in the South African criminal justice system, it is worthwhile to explore what the Indian government has been doing in this regard. The main aim is to analyse the Indian approach to criminal justice regarding dispute resolution examples based on traditional laws, namely the panchayat system (nyaya panchayats and gram nyayalayas) and also lok adalats in a comparative context.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-01-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"41256144","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

A Gain-based Remedy for Breach of Contract in English Law: Some Lessons for South African Law 英国法中基于利益的违约救济:对南非法的启示

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2021-01-26 DOI: 10.25159/2522-3062/7742

Kwena Seanego

{"title":"A Gain-based Remedy for Breach of Contract in English Law: Some Lessons for South African Law","authors":"Kwena Seanego","doi":"10.25159/2522-3062/7742","DOIUrl":"https://doi.org/10.25159/2522-3062/7742","url":null,"abstract":"A gain-based remedy for breach of contract is aimed at taking away the profits acquired through breach of contract. Traditionally, contractual damages can be claimed only if the breach caused the plaintiff patrimonial loss. There is an assumption that breach of contract causes a loss to the plaintiff, and as a result the defendant should compensate the plaintiff. However, in the past, courts have been confronted with cases where the opposite of this assumption is true. This is in instances where a defendant breaches a contract and gains profit as a result of that breach, whereas the plaintiff suffers little or no patrimonial loss. Unfortunately, in these circumstances the plaintiff may be left with no remedy or legal recourse for the breach, while the defendant may keep the profits generated as a result of the breach. However, in English law the courts have recognised a gain-based remedy in the circumstances outlined above, allowing the disgorgement of such ill-gotten profits. But a similar remedy has not yet gained recognition in the South African law of contract. The purpose of this article is to explore how South African law can draw some valuable lessons from English law in developing and recognising a gain-based remedy for breach of contract in order to deal with the profits generated through breach of contract.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2021-01-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48882615","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Namibia and Blanket Amnesties: Challenging the Namibian Blanket Amnesties on the basis of International Law in the Namibian Courts 纳米比亚和全面大赦:在纳米比亚法院根据国际法对纳米比亚的全面大赦提出质疑

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2020-12-22 DOI: 10.25159/2522-3062/7317

Atilla Kisla

{"title":"Namibia and Blanket Amnesties: Challenging the Namibian Blanket Amnesties on the basis of International Law in the Namibian Courts","authors":"Atilla Kisla","doi":"10.25159/2522-3062/7317","DOIUrl":"https://doi.org/10.25159/2522-3062/7317","url":null,"abstract":"Amnesty laws issued by Administrator General Pienaar in 1989 and 1990 still show their effect by preventing prosecutions and investigations of situations that occurred before Namibia’s independence. Unlike South Africa, Namibia did not establish a truth-finding body such as the Truth and Reconciliation Commission. The result is a situation of silence, oblivion and impunity without any kind of accountability. On this basis, crimes such as international crimes or serious human rights violations have never been prosecuted or even investigated. As this article argues, the amnesty laws from 1989 and 1990 qualify as blanket amnesties. Up until today, Namibians as well as the members of the South African Defence Force benefit from those amnesties. Against this backdrop, the question of whether the Namibian blanket amnesties apply in relation to international crimes and grave human rights violations will be addressed. This article argues that based on international law, the application of the Namibian blanket amnesties can be challenged in a potential criminal case that deals with international crimes or grave human rights violations in the Namibian courts. Therefore, this article illustrates how international law applies in the Namibian legal system. In this context, Namibia follows a monist approach which makes it quite receptive of international law and international standards. On this basis, this article points out binding international law at the time before and after Namibia’s independence as well as examining Namibia’s binding treaty obligations which arise under the Geneva Conventions, Torture Convention and the International Covenant on Civil and Political Rights. In the next section, an examination of domestic and international jurisprudence lays the foundation for the argument that the Namibian blanket amnesties can be challenged in a Namibian court when the crimes in question constitute international crimes, such as crimes against humanity or war crimes.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2020-12-22","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"46916749","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Disparaging Language (ex curia) as a Barrier in Individual Complaints before the European Court of Human Rights (Zhdanov v Russia)—Lessons for the African System? 在欧洲人权法院（日丹诺夫诉俄罗斯）的个人申诉中，语言差异（法庭外）是一个障碍——非洲制度的教训？

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2020-12-22 DOI: 10.25159/2522-3062/7728

Angelo Dube

{"title":"Disparaging Language (ex curia) as a Barrier in Individual Complaints before the European Court of Human Rights (Zhdanov v Russia)—Lessons for the African System?","authors":"Angelo Dube","doi":"10.25159/2522-3062/7728","DOIUrl":"https://doi.org/10.25159/2522-3062/7728","url":null,"abstract":"On 16 July 2019, the European Court of Human Rights (ECtHR) rejected an application by Russian human rights activist, Nikolay Alekseyev, on the basis that he had published personally offensive and threatening material online, directed towards the ECtHR. This was in the matter of Zhdanov and Others v Russia Applications Nos 12200/08, 35949/11 and 58282/12. Even though the published material fell afoul of the European Convention in that it amounted to an abuse of the court process, nothing offensive was contained in the applicant’s own submissions before the court. In like fashion to the ECtHR’s admissibility requirements, the African Charter contains a much more pointed exclusionary clause which renders inadmissible any communication that contains disparaging or insulting language. The difference between the two systems is that the European system relies on an open-ended concept of ‘abuse of the right of individual petition’, whilst the African system specifically proscribes insulting language. In this article, I analyse the approach of the ECtHR in the Zhdanov matter, and contrast it with the approach of the African Commission on Human and Peoples’ Rights (the African Commission) under Article 56(3) of the African Charter on Human and Peoples’ Rights. I further interrogate whether there were any instances where, in similar fashion to the Zhdanov matter, the African Commission declared a communication inadmissible on account of insulting language occurring externally, and not contained within the submission itself. Alive to the fact that the concept of ‘abuse’ in the European system is wide, the article is limited to cases in which the abuse of the right of individual petition under the European Convention manifests in disparaging or insulting language.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2020-12-22","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"48966387","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0

Legally Pluralist and Rights-based Approaches to South African and English Muslim Personal Law—A Comparative Analysis 南非和英国穆斯林属人法的法律多元化与权利本位——比较分析

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Comparative and International Law Journal of Southern Africa-CILSA Pub Date : 2020-11-21 DOI: 10.25159/2522-3062/7232

B. Clark

{"title":"Legally Pluralist and Rights-based Approaches to South African and English Muslim Personal Law—A Comparative Analysis","authors":"B. Clark","doi":"10.25159/2522-3062/7232","DOIUrl":"https://doi.org/10.25159/2522-3062/7232","url":null,"abstract":"This article examines the right to the free exercise of religion from a comparative perspective in the context of Islamic marriage and divorce in England and South Africa. In particular, the article considers how Islamic marriage may be interpreted and recognised in a coherent manner in rights-based systems of law and how these two legal systems ensure that the rights of religious women are fully respected and acknowledged. The similarity in the growth of non-legal, quasi-judicial bodies (sharia councils in England and ulama in South Africa) is analysed, along with their effect on rulings on Islamic divorces and other matters. The article suggests that both legal systems may learn from the other and suggests ways in which this comparative method of legal analysis can be employed to achieve legal reform and the legal recognition of these marriages. In this regard, the article deals with various models, based on either the assimilation and unification of marriage laws (as proposed in South Africa) or integration and pluralism. The article examines these models not only from a pragmatic perspective, but also from a rights perspective. It suggests that the assimilation model, based on a Western, Judeo-Christian paradigm of marriage, would not only be inconsistent with the ethos of legal pluralism promoted by the South African Constitution and the English Human Rights Act, but, more importantly, would not protect the rights of Muslim women adequately. Therefore, the article concludes that, in line with recent South African High Court jurisprudence, the legislative recognition of Muslim marriage and divorce law is urgently required in both jurisdictions.","PeriodicalId":29899,"journal":{"name":"Comparative and International Law Journal of Southern Africa-CILSA","volume":null,"pages":null},"PeriodicalIF":0.1,"publicationDate":"2020-11-21","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"47287719","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 0