Obiter最新文献

{"title":"DO MUNICIPALITIES HAVE THE POWER TO REGULATE THE KEEPING OF “DANGEROUS” DOGS?","authors":"Hendrik J van As","doi":"10.17159/obiter.v44i4.17594","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17594","url":null,"abstract":"Dog attacks and resultant deaths are frequent occurrences in South Africa. Pit bulls are responsible in many of these cases and there are calls for them to be banned. Dogs, however, are the property of their owners, and forcing people to give them up will amount to a deprivation of property and an infringement of a dog owner’s right to property, which is protected by section 25 of the Constitution. Dogfighting is rife in South Africa and the conduct of dog owners contributes to dogs being aggressive and leads to dog attacks. In terms of the Constitution, animal control is a functional area of concurrent national and provincial legislative competence; on a strict interpretation, this means that municipalities do not have the power to legislate on the function. However, everyone is guaranteed the right to freedom and security of the person, which includes the right to be free from all forms of violence from either public or private sources. As such, the municipality (as part of the State) must respect, protect, promote and fulfil the right. Municipalities also have a duty to promote a safe and healthy environment, and the power to make by-laws on matters they may administer. They may also exercise powers that are reasonable and incidental to the effective performance of municipal functions, which is supported by the principle of subsidiarity, the fulfilment of the duties arising from section 12 of the Constitution, and the objective to promote a safe and healthy environment. A municipality that has the necessary resources can legislate and enforce by-laws on matters listed in Schedule 4A and 5A of the Constitution, provided that such action seeks to further the objectives of Chapter 2 of the Constitution and is not in conflict with measures adopted by the national and provincial spheres. The National Society for the Prevention of Cruelty to Animals (NSPCA) is responsible for animal welfare, but the responsibilities of animal welfare organisations are becoming greater as urbanisation in South Africa accelerates and animals in many disadvantaged communities are in dire need of basic animal care. The suite of local government law is geared towards the social and economic upliftment of communities, and there is legislative justification for interventions by municipalities to address matters such as the control of public nuisances, dog licensing, the operation of pounds, and the conduct of community members that can alleviate the pressure on those organisations tasked with animal care. There are a number of legislative instruments that apply to animals. A consolidation of the provisions of the various pieces of legislation into a single by-law aimed at regulating the keeping and treatment of dogs, may result in increased law enforcement and (it is hoped) increased sentences as a result of amplified enforcement, as well as improved deterrence.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"54 17","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139533257","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}

{"title":"AN EXAMINATION OF POLICIES REGULATING THE PARTICIPATION OF TRANSGENDER LEARNERS IN SOUTH AFRICAN HIGH SCHOOL SPORTS","authors":"Muyenga Mugerwa-Sekawabe","doi":"10.17159/obiter.v44i4.17595","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17595","url":null,"abstract":"South African high schools typically adopt a sex-segregated approach to sports teams and, therefore, have “boys” sports teams and “girls” sports teams. This approach is complicated by the increasing number of high school learners who identify openly as transgender. Transgender learners experience the sports policies that South African high schools choose to adopt as falling into one of three broad categories. These categories are: the restrictive approach, the partially inclusive approach and the fully inclusive approach. These approaches vary in terms of what steps they require trans learners to take in order to participate in sports teams that are consistent with their gender identity. School policies must be consistent with the Promotion of Equality and Prevention of Unfair Discrimination Act (PEPUDA) in order to be legally compliant. It is argued that the restrictive approach is inconsistent with PEPUDA, and, therefore, unlawful, as no legitimate purpose underlies it. As legitimate reasons exist for the implementation of partially and fully inclusive policies, it is argued that they are lawful. As both such policies are lawful, policymakers will have a choice regarding which set of policies to adopt. When making this choice, a school must consider which values it seeks to promote. On the one hand, there is the imperative to acknowledge the well-being and dignity of trans learners while, on the other hand, there are legitimate concerns about the fairness of competition. As dignity is both a right that is granted to everyone by the Constitution, and one of its founding values, it is argued that fully inclusive policies should be favoured as they result in the validation of trans learners’ dignity. Furthermore, it is argued that high school sports should serve broader educational goals, such as teaching high school learners that their trans peers deserve the chance to live their truth in full.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"52 24","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139531848","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}

{"title":"THE INTRODUCTION OF “FREE, PRIOR AND INFORMED CONSENT” TO THE LAND REFORM LEGAL LEXICON Baleni v Minister of Mineral Resources 2019 (2) SA 453 (GP)","authors":"George Barrie","doi":"10.17159/obiter.v44i4.17596","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17596","url":null,"abstract":"Although decided four years ago, Baleni v Minister of Mineral Resources (2019 (2) SA 453 (GP) (Baleni)) stands out regarding four significant features and it remains surprising that the decision has not attracted more attention in connection with the land-reform programme. The first feature was the interpretation of the Interim Protection of Informal Land Rights Act 31 of 1996 (IPILRA). The second feature was the emphasis on customary law in the interpretation of IPILRA. The third feature was the application of multiple international-law instruments in the interpretation of IPILRA. The fourth feature was the court’s conclusion that these international-law instruments determine that no decisions may be taken regarding the lands of indigenous peoples without the latter’s “free, prior and informed consent” (FPIC). This conclusion has far-reaching implications for the South African land-reform process introduced by section 25 of the Constitution of the Republic of South Africa, 1996 (the Constitution).","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"44 20","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139533368","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}

{"title":"PUTATIVE PRIVATE DEFENCE IN CRIMINAL LAW Tuta v The State 2023 (2) BCLR 179 (CC)","authors":"Jolandi Le Roux-Bouwer","doi":"10.17159/obiter.v44i4.17598","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17598","url":null,"abstract":"In a country like South Africa, plagued as it is by violent contact crime, it is not surprising that the defences of private defence and putative private defence are often raised by accused in criminal trials. It is trite that, for a conviction in a criminal court, the prosecution is tasked with proving the accused’s liability beyond reasonable doubt. As an element of a crime, unlawfulness does not simply lie in fulfilment of the definitional elements of a crime. There are instances where, notwithstanding fulfilment of the definitional elements of a crime, the conduct is justified or legally regarded as objectively reasonable. These instances are known as grounds of justification and technically serve to exclude unlawfulness. A ground of justification, if successfully raised, is therefore a complete defence to any criminal charge. There is not a numerus clausus of valid grounds of justification in South African criminal law; the test remains whether the accused’s conduct was objectively reasonable in the particular situation. One such ground of justification is private defence. A person acts in private defence, and therefore lawfully, if they use the minimum force necessary to ward off an unlawful human attack that has commenced, or is imminently threatening, upon their or somebody else’s protected legal interests such as life, physical integrity, property, reputation or dignity. The defensive act in private defence must be: necessary to protect the threatened interest; directed at the attacker; reasonably proportionate to the attack; and perpetrated with the knowledge that it is performed in private defence. Unlike private defence, putative private defence is not a ground of justification that excludes unlawfulness. Putative private defence exists where an accused is under the mistaken belief that they are conducting themselves in private defence whereas there is no such ground of justification in the circumstances. If an accused labours under the genuine but erroneous belief in the existence of a ground of justification, their conduct remains unlawful. The accused lacks the knowledge that they are, in reality, acting unlawfully. While the accused’s conduct remains unlawful, the absence of knowledge of unlawfulness results in a lack of intention, since knowledge of unlawfulness is an integral part of intention. The accused’s mistaken belief that they are acting lawfully in private defence must be honest and genuine but need not be rational or reasonable. If, on the facts, there could be no honest and genuine belief on the accused’s part in the lawfulness of their defensive act, putative private defence cannot exist.  \u0000It is trite that, for private defence to succeed as a ground of justification, the test is objective in the sense that the attack and the defensive action must meet certain objective requirements. The accused’s subjective belief, whatever it may be, has no impact on the validity of private defence as a ground of justification. The ","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"13 3","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139532786","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}

{"title":"DISTINGUISHING THE FORMS OF COMMON PURPOSE LIABILITY S v Govender 2023 (2) SACR 137 (SCA)","authors":"Shannon Hoctor","doi":"10.17159/obiter.v44i4.17597","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17597","url":null,"abstract":"In the case of S v Govender (2023 (2) SACR 137 (SCA)), the Supreme Court of Appeal (SCA) was required once again to examine the common purpose doctrine, which although it has been in use in South African law for the past century, has in recent years seen significant development, in its expansion from being applied solely to a prior agreement, to also being applied in the case of an active association between two or more persons. The importance of distinguishing between these different forms of the common purpose doctrine has concomitantly also become increasingly important.As the court points out in S v Mzwempi (2011 (2) SACR 237 (ECM) par 56), prior-agreement common purpose encompasses “any conduct which falls within the wide and general common design”, whereas active-association common purpose is “restricted to particular conduct”. Thus, in active-association common purpose, the association is with a “specific act” by which the crime was committed by another participant in the common purpose. It follows that, given the “marked differences” between the two forms of common purpose:“in a case where the state seeks to place reliance on the doctrine of common purpose, the trier of fact will be required to determine the nature of the common purpose relied upon, what the scope of that common purpose happened to be, and whether the accused was a participant, and remained a participant, in the common purpose.”The discussion examines the significance of the distinction between the different forms of common purpose doctrine, in light of the SCA judgment in the case of Govender.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"47 24","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139531998","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}

{"title":"THE PLIGHT OF SOUTH AFRICAN WHISTLE-BLOWERS: SEARCHING FOR EFFECTIVE PROTECTION","authors":"Karin Calitz","doi":"10.17159/obiter.v44i4.17592","DOIUrl":"https://doi.org/10.17159/obiter.v44i4.17592","url":null,"abstract":"Daily reports in the media about the extent of corruption in South Africa and the plight of whistle-blowers who dare to report it demonstrates the inadequacy of protective measures in South Africa. The murder of whistle-blower Babita Deokaran saw other whistle-blowers go into hiding, fearing for their own safety, and calls for urgent measures to be implemented to ensure the physical safety of whistle-blowers. The United Nations Convention Against Corruption (UNCAC) contains measures that could be implemented to protect the physical safety of whistle-blowers. Currently, the only legislation specifically protecting whistle-blowers in South Africa is the Protected Disclosures Act (PDA), which only protects against detriment in the workplace. A number of other statutes provide a measure of protection, but they are fragmented and by no means adequate. A legal comparison with the United Kingdom (UK), Ireland and the United States of America (US) may provide guidelines for reform in South Africa. The UK is currently debating the Protection for Whistleblowing Bill (Bill 27) in the House of Lords to improve protection for whistle-blowers. This Bill proposes to sever the required link to employment so that any person reporting wrongdoing will be protected if certain requirements are met. Bill 27 also establishes the Office of the Whistleblower, which has wide-ranging powers to protect whistle-blowers. The Irish Protected Disclosures (Amendment) Act 2022 was amended to broaden the definition of “worker” to include persons not previously protected and to establish an Office of the Commissioner similar to the Office of the Whistleblower in Bill 27, although with limited power. Neither the UK nor Ireland requires whistle-blowers to report in good faith; the focus is on the message instead of the messenger. Financial rewards for whistle-blowers in the US have proved to be highly successful and could be implemented in South Africa. It is recommended that physical protection of whistleblowers be prioritised, that a Whistle-Blowers’ Office with wide-ranging powers be established, that protection be extended to persons outside the employment relationship, that whistle-blowers be rewarded for reporting on wrongdoing in prescribed circumstances, that the burden of proof be reversed and that the good faith requirement for protection be dropped.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"8 1","pages":""},"PeriodicalIF":0.0,"publicationDate":"2024-01-12","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"139532508","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}

{"title":"RACIAL CONSIDERATIONS ARE A PREREQUISITE AND NOT AN AFTERTHOUGHT: A DISCUSSION OF Kroukamp v The Minister of Justice and Constitutional Development [2021] ZAGPPHC 526 and Magistrates Commission v Lawrence 2022 1 All SA 321 (SCA)","authors":"Fanele Mabaso","doi":"10.17159/obiter.v44i3.14166","DOIUrl":"https://doi.org/10.17159/obiter.v44i3.14166","url":null,"abstract":"This case note engages in a critical examination of two recent cases concerning the issue of race-based appointments, or rather the lack thereof, in the judiciary. The crux of this case note concerns the appointment of judicial officers as regulated by section 174 of the Constitution of the Republic of South Africa, 1996 (Constitution). In particular, the case note is driven by subsection 2 of section 174, which provides:“The need for the judiciary to reflect broadly the racial and gender composition of South Africa must be considered when judicial officers are appointed.”In essence, this case note is an advocate for the argument that the South African judiciary must reflect the demographics of the country. That is to say, racial considerations are a prerequisite in judicial appointments, and not an afterthought. The case note starts with a discussion of the matter that was before the Gauteng High Court, sitting as the Equality Court, in Kroukamp v The Minister of Justice and Constitutional Development ([2021] ZAGPPHC 526). The case note then discusses the later decision of the Supreme Court of Appeal in Magistrates Commission v Lawrence (2022 1 All SA 321 (SCA)).","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"32 10","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-26","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135017583","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}

{"title":"THE INFUSION OF AFRICAN JURISPRUDENCE ON LEGAL DEFENCES INTO JUDICIAL DELIBERATIONS Bulelwa Ndamase v Development Bank of Southern Africa Limited D 8073/2020 [2022] (ZAKZDHC) (30 May 2022)","authors":"None Aubrey Manthwa","doi":"10.17159/obiter.v44i3.17052","DOIUrl":"https://doi.org/10.17159/obiter.v44i3.17052","url":null,"abstract":"It is often said that customary law is unwritten, as its knowledge system is not recorded in statutes and codifications. Tracing its earliest origins can prove difficult, largely because African communities have historically lived independently of one another, observing norms and practices that differ from one community to another. In previous eras, Africans lived according to values such as a sense of communal belonging, collective ownership of assets and the communal life that characterised the African tradition. All these elements developed into an African normative system that catered for justice and human rights. The fortunes of customary law, however, changed after contact with colonialism. Section 11(1) of the Black Administration Act (BAA) 38 of 1927, for example, afforded courts the discretion to apply customary law in all disputes concerning African people as disputants, provided that customary law was not against public policy and natural justice. This repugnancy proviso therefore limited the application of customary law. Section 11(1) of the BAA was repealed in 1988 by the Law of Evidence Amendment Act 45 of 1988, which was framed in similar terms to the BAA, and in terms of which courts could take judicial notice of customary law if it could be readily ascertainable. As a result, courts could merely strike down any African practice or norm that they deemed to be inconsistent with principles of public policy and natural justice. The interim Constitution contained a specific provision speaking to the cardinal African concept of ubuntu. However, this concept did not find space in the 1996 Constitution. Yet, ubuntu had already informed the basis for the abolition of the death penalty in one of South Africa’s most seminal judgments in a first case that came before a full panel of the Constitutional Court. The Constitutional Court stressed the importance of infusing African jurisprudence or indigenous knowledge systems into judicial pronouncements. This had become apparent in the wake of the ill-treatment of customary law as a subordinate legal system vis-à-vis common law. Other courts have subsequently made commitments that customary law and its value systems would be afforded space as an independent legal system away from the prowling eye of the common law. Also, in Gumede v President of the Republic of South Africa (2009 (3) SA 152 (CC) par 22), the Constitutional Court confirmed that customary law “lives side by side with the common law and legislation”. Notwithstanding these assertions, courts have not given effect or found an avenue to allow customary law to be integrated in decision-making. It must be stated that customary law differs from indigenous law as customary law emerges from the latter. Customary law is people’s adaptation of indigenous law to socio-economic changes. This gives effect to the value of indigenisation that scholars have written about and has also become a value that institutions of higher learning have embrace","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"71 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"135889132","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}

{"title":"ALTERNATIVE ACCOMMODATION OF AN UNLAWFUL OCCUPIER’S CHOOSING: SOME REFLECTIONS ON Grobler v Phillips [2022] ZACC 32","authors":"None Lerato Rudolph Ngwenyama","doi":"10.17159/obiter.v44i3.17034","DOIUrl":"https://doi.org/10.17159/obiter.v44i3.17034","url":null,"abstract":"An abundance of case law dealing with eviction has emerged. Clear rules for evictions exist in the eviction context and a solid body of law is being developed in this regard. For many years, little attention was given to the issue of unlawful occupiers refusing to be evicted based on preferences or wishes to remain in the same house or land under the Prevention of Illegal Eviction From and Unlawful Occupation of Land Act 19 of 1998 (PIE). However, in recent years disputes around the choice of alternative accommodation in terms of the Extension of Security of Tenure Act 62 of 1997 (ESTA) have increased significantly.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"1 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136142506","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}

{"title":"THE NATURE AND AMBIT OF THE INTIMIDATION OFFENCE S v White 2022 (2) SACR 511 (FB)","authors":"None Shannon Hoctor","doi":"10.17159/obiter.v44i3.17001","DOIUrl":"https://doi.org/10.17159/obiter.v44i3.17001","url":null,"abstract":"The offence of intimidation has been associated with controversy, particularly because of the historical link between the Intimidation Act (72 of 1982) and the legislative machinations of the apartheid regime. In the words of Gamble J, the Act may be regarded as “a piece of apartheid order legislation introduced at a time of increasingly repressive internal security legislation designed to criminalise conduct, largely in the field of resistance politics” (Sandlana v Minister of Police 2023 (2) SACR 84 (WCC) par 34). The nature and ambit of the intimidation offence has once again come under scrutiny in the recent case of S v White (2022 (2) SACR 511 (FB)). The decision in this case is examined here in the context of a general assessment of the offence. The offence can now only be committed by contravening section 1(1)(a) of the Act, as the Constitutional Court has struck down the section 1(1)(b) provision (as well as section 1(2)) as unconstitutional in Moyo v Minister of Police (2020 (1) SACR 373 (CC)), a development confirmed by the amendment of the Act by the Protection of Constitutional Democracy Against Terrorist and Related Activities Amendment Act (23 of 2022). (Some are of the view that the Constitutional Court could have gone further (Burchell Principles of Criminal Law 5ed (2016) 593–594).) However, for the purposes of the discussion that follows, it is useful to cite the full section 1(1) provision prior to amendment.","PeriodicalId":485606,"journal":{"name":"Obiter","volume":"147 1","pages":"0"},"PeriodicalIF":0.0,"publicationDate":"2023-10-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"136356699","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}