TY - JOUR
AU - Storey, Hugo
AB - On refugees and climate change, that most existential of refugee law topics, the literature proceeds apace, as needs must. One of its latest additions, Matthew Scott’s book stands out for its ambition and originality. It not only sets out a new approach to climate change and disaster-related refugee claims, but seeks to propose a significant ‘recalibration’ of the refugee definition for application to all types of claim. Raising serious, well-articulated challenges on virtually every page to prevailing thinking on the definition of refugee in article 1A(2) of the 1951 Refugee Convention, it represents a signal contribution to the field. Lack of protection for victims of climate change and disasters within the existing corpus of international treaty law is well documented, both for those within States and those who involuntarily migrate. The responses of those seeking to fill this gap have taken two main forms. One response is to discard the Refugee Convention as being any sort of help and to call for new international agreements to address this gap. Those propounding this approach point out that the drafters did not intend the article 1A(2) definition to cover ‘refugees from natural disasters’. Oft-cited is the observation of Dr Jacob Robinson (Israel) during the Conference of Plenipotentiaries in November 1951 that: [t]he text of sub-paragraph (2) obviously did not refer to refugees from natural disasters, for it was difficult to imagine that fires, floods, earthquakes or volcanic eruptions, for instance, differentiated between their victims on the grounds of race, religion or political opinion. Nor did that text cover all man-made events.1 They point out that the UNHCR Handbook2 and jurisprudential guidance have confirmed that ordinarily such persons fall outside the scope of the refugee definition. They highlight the exceptional difficulty of assimilating disasters to a new form of persecution.3 The other main form of response is to adopt a complementary approach that recognizes the limits of the Refugee Convention and the need for further international measures of protection but believes that a proper approach to the article 1A(2) definition of refugee opens the way to a dynamic interpretation under which at least some new categories of person can qualify. It also sees greater scope for remedies under international human rights law, especially in the wake of the Human Rights Committee reasoning in Teitiota v New Zealand, Communication No 2728/2016, 24 October 2019, para 9.11. This latter form of response is now taken by the United Nations (UN) and United Nations High Commissioner for Refugees (UNHCR),4 and by leading proponents of the human rights approach, such as Hathaway and Foster.5 Scott’s book also places him squarely within this camp but offers an analysis which, if accepted, would require considerable reworking of prevailing approaches to the article 1A(2) refugee definition, including that of UNHCR, Hathaway and Foster, and other scholars. In an introductory chapter, Scott first identifies what he terms the ‘dominant view’ of how the Refugee Convention applies in the context of disasters and climate change, as reflected in jurisprudence and legal doctrine. According to this view, which echoes Robinson’s well-known words quoted earlier, article 1A(2) has little or no purchase. He then adumbrates a different perspective based on a ‘recalibrated interpretation’ of the Refugee Convention. In chapter 2, he presents two competing ‘disaster paradigms’, which he calls the ‘hazard’ and ‘social’ paradigms, and explains why the former is incorrect. His chapter 3 explores the existing jurisprudence on the determination of refugee status in the context of disasters and climate change. Its conclusion is that for the most part it has adopted an incorrect ‘hazard paradigm’. Based on a search of over 200 relevant cases and utilizing a helpful ‘Taxonomy’ (see especially the appendix at p 157), this chapter is an important source for existing case law on climate change in its own right. He groups cases into three categories: ‘Category 1’ cases, which frame a fear of being persecuted on return as a fear of ‘indiscriminate adversity due to the forces of nature’; ‘Category 2’ cases, which concern scenarios where identifiable actors of persecution may be expected to directly and intentionally inflict serious harm in the context of disasters and climate change; and ‘Category 3’ cases, which relate to other ex ante and ex post failures of State protection. His chapters 4–6 are devoted to diagnosing the limitations of the ‘hazard-centric’ dominant approach, looking in turn at approaches to interpreting the refugee definition (chapter 4); the temporal scope of being persecuted (chapter 5); and the personal scope of being persecuted (chapter 6). In chapter 6, Scott sets out his view that refugee law needs to give primacy to the foundational norm of non-discrimination and to understand discrimination as an inherent feature of being persecuted. Finally, in chapter 7, he examines how his interpretation, informed by the ‘social paradigm’ developed in chapter 2, should be applied to claims for refugee status in the context of disasters and climate change. ‘The result,’ he writes, ‘is a recalibrated human rights-based understanding of the refugee definition that can be applied as much to claims for recognition of refugee status in the context of disasters and climate change as to other sorts of refugee claim’ (p 1). Whilst the main focus of this review is on Scott’s analysis of the refugee definition, it bears saying that, in relation to the specific topic of climate change and disasters, his book enriches the literature in multiple ways: by providing an in-depth analysis of how these topics have been dealt with in the jurisprudence; by proposing a helpful two-stage approach in temporal terms, one considering the immediate situation (‘ongoing situations’), the other considering foreseeable future scenarios; and by examining, in chapter 7, a number of tools that refugee decision makers need to become familiar with in order to deal adequately with claims based on climate change or disasters – in particular, the ReliefWeb website (which collates a vast array of reports from UN agencies, as well as other organizations); the Integrated Phase Classification (IPC) and the Famine Early Warning Centre (FEWS-NET) (both of which focus on food insecurities); and the WorldRiskIndex, which attempts to determine the level of disaster risk facing a particular country by taking into consideration the country’s exposure to particular hazards, as well as its ability to respond to such risks. Using such tools, he points out, for example, that it is reasonably foreseeable that Somalia will continue to suffer from drought almost every year. Critique of traditional approaches Scott recognizes that for the refugee definition to better accommodate climate change cases requires considerable rethinking of traditional approaches. He tackles two objections raised by traditional approaches in particular. The first objection is that the requisite element of discrimination is lacking because the impact of climate change appears largely indiscriminate. Regarding this, he points to the growing acceptance in the literature (for example, by Hathaway and Burson, among others) that discrimination can be involved in climate change scenarios such as when marginalized groups are differentially exposed and vulnerable to disaster-related harm. The second objection tackled is that the harms involved are not ‘persecutory’ because the necessary element of human agency is missing, and, indeed, to quote from Kälin and Schrepfer in their 2012 policy paper prepared for UNHCR,6 ‘the country of origin normally does not turn against such affected people but remains willing to assist and protect them’ (p 5). Regarding this, he accepts that it remains axiomatic that to establish persecution a person must identify human agency but, building on an object and purpose approach, he argues that, applying a social paradigm, human agency, either by act or omission, can be found in many disaster and climate change scenarios. In undertaking this critique, Scott squarely identifies his approach as a human rights approach but considers that its leading proponents, such as Hathaway and Foster, still employ a ‘hazards-centric’ paradigm that focuses too heavily on events rather than processes, and have cast the temporal scope of the refugee definition too narrowly and the personal scope too widely. This series of arguments merits some elaboration. Temporal scope In Scott’s view, Hathaway and others correctly adopt an ex nunc approach in terms of reasonable foreseeability but incorrectly conceive this in an ‘events-based’ way focusing on the likelihood of persecution happening. Drawing on critiques of the event-oriented definition of disaster in the International Law Commission’s 2016 Draft Articles on the Protection of Persons in the Event of Disasters, Scott calls for an approach that focuses more on complex processes that take into account the consequences of an event combined with vulnerable social conditions. The hazard paradigm, which he sees as being in the ascendant in both international law on disasters and refugee law, prevents recognition that governance or other social factors might play a causal, as opposed to a reactive, role in the unfolding of disasters. By contrast, ‘the social paradigm sees “natural” disasters as a consequence of the interaction of natural hazards and social vulnerability’; ‘recognises that within this social context, certain individuals may be more vulnerable than others on account of pre-existing patterns of discrimination’; and thirdly, ‘understands “natural” disasters as process, in the sense that individual and societal vulnerability and exposure to natural hazard events is historically contingent and changes over time’ (p 15). In this perspective, a disaster is a phenomenon generated by weaknesses in social systems: ‘[w]ithout exposed and vulnerable human settlements, a flood will not engender disaster’ (p 15). Again, drawing on emerging trends in disaster and climate change studies, Scott notes that consensus has emerged that discrimination both engenders and exacerbates exposure and vulnerability to disaster-related harm (p 24). According to Scott, the ‘preoccupation with the moment of harm’ visible in prevailing approaches (p 100) unduly restricts the temporal scope of being persecuted because the focus of refugee status determination (RSD) is narrowed to an attempt to divine the likelihood of persecution happening. He also suggests in places that this approach goes hand in hand with recourse to an imminence criterion that limits the horizon for understanding when that event is likely to happen to the immediate context of return. For Scott, this ignores that being persecuted is a ‘condition of existence’, not simply definable in terms of acts (that is, that it has an enduring quality not delimited to acts of persecution). His ‘condition of existence’ approach has the advantage, he says, of being capable of applying not only to scenarios where individuals are exposed to specific acts of persecution, but also allowing for the inclusion within the notion of being persecuted of scenarios characterized more by the risk of harm than the instant of its accrual. He refers in this regard to what has become known via the discussion that arose in the United Kingdom Supreme Court case of HJ (Iran) v SSHD [2010] UKSC 31 as ‘the Anne Frank principle’. For Scott, assessment of risk does not form part of the ‘well-founded fear’ inquiry but is ‘part and parcel of the assessment of the claimant’s predicament in her country of nationality or former habitual residence’ (p 110). Personal scope Scott contends that the human rights approach promoted by Hathaway and others has also cast the personal scope too widely, by effectively replacing the phrase ‘being persecuted’ with that of ‘being subjected to serious human rights violations’. According to Scott, this dilutes the distinctive quality of being persecuted so that it becomes indistinguishable from being the victim of a human rights violation. Scott submits that: The result is that the category of people who can accurately be described as being persecuted becomes unduly broad, encompassing all persons who are exposed to a sustained or systemic violation of human rights demonstrative of a failure of state protection, including all victims of ‘natural’ disasters that result from failures by the state to fulfil its positive obligations to protect the right to life, health, property, and so forth from foreseeable hazards. (p 118) As an example, he cites the decision of the European Court of Human Rights in Budayeva v Russian Federation (2014) 59 EHRR 2, which held that victims of a mudslide had suffered violations of the right to life under article 2 of the European Convention on Human Rights. Such persons may, he argues, accurately be described as having suffered a sustained or systemic violation of human rights demonstrative of a failure of State protection, as there had been a systemic failure of State actors to take steps to protect victims from the known risks associated with mudslides. ‘However,’ he submits: few would contend that this clear violation of the right to life amounted to ‘persecution’. Similarly, not all persons who face serious denials of economic and social rights can accurately be described as being persecuted, even if this predicament reveals a sustained or systemic violation of human rights. The definition casts the net too widely, and in so doing fails to draw attention to the distinctive, discrimination-based nature of the experience of being persecuted. (pp 87–88) Non-discrimination as the central organizing principle around which the refugee definition is to be interpreted In Scott’s analysis, the relevant persecutory conduct is not the sustained or systemic denial of core human rights but the accumulation of direct or indirect, systemic or non-systemic forms of discrimination inherent in being persecuted. For Scott, ‘being persecuted’ is rather a ‘condition of existence in which discrimination is a contributory cause of (a real chance of being exposed to) serious denials of human rights demonstrative of state protection’ (p 129). Scott bases his argument on principles of the Vienna Convention on the Law of Treaties (VCLT). He argues that whether or not non-discrimination has attained the status of a customary norm of general international law, it is inherent in the ordinary meaning of ‘being persecuted’ ‘far more than substantive human rights norms’ (p 116); that it is clearly part of the context of the Refugee Convention by virtue of the first preambular paragraph of its preamble; and that it has firmly established itself as one to which States parties have most frequently subscribed and so a relevant rule of international law applicable between the parties, pursuant to article 31(3)(c) of the VCLT (pp 112–13). He thinks that treating non-discrimination as a foundational norm is particularly apposite to RSD because, like the concept of structural violence, the concept of systemic discrimination allows a social paradigm approach (p 115). To further support his argument that being persecuted cannot be understood in isolation from the Convention reasons and that, in fact, discrimination is a necessary condition for the phenomenon of persecution to arise, Scott particularly fastens on passages in the UK House of Lords case of Shah and Islam [1999] 2 AC 629 and in the Australian case of Applicant A [1997] HCA 4. In the latter case, McHugh J stated (at 258): Whether or not conduct constitutes persecution in the Convention sense does not depend on the nature of the conduct. It depends on whether it discriminates against a person because of race, religion, nationality, political opinion or membership of a social group. Scott’s proposed new approach to the refugee definition is set out in a coherent, well-structured, and elegant fashion. His arguments repay further study and will doubtless feature in many discussions to come. The following observations are offered by the reviewer not as a definitive critique but rather in the hope of providing further perspective on the contents of the book. Is he right about temporal scope? Scott’s approach to temporal scope harbours several difficulties. First, the wording of article 1A(2) strongly suggests that the drafters conceptualized persecution in terms of events: indeed (albeit in relation to pre-1951 circumstances), this provision twice uses the very term ‘events’. Secondly, his critique is predicated on an unduly narrow concept of ‘events’ and of ‘acts’. It reads into their definition a condition that they are confined to one moment in time (‘isolated events/acts’). That jars with the ordinary meaning of these terms. Thus, yes, an ‘event’ is sometimes just one moment in time but can sometimes be used to designate a period of time (for example, the Second World War is sometimes referred to as a major ‘event’ of the 20th century). Indeed, even before the 1967 Protocol, there was broad acceptance that the temporal restriction contained in article 1A(2) (‘events occurring before 1 January 1951’) ‘encompasses all kinds of developments, whatever their nature’.7 A third difficulty is that it conveniently ignores that it is a well-established proposition that being persecuted is a condition that can arise from the threat of persecution alone. Of course, it might be counter-argued that all that is meant here is the threat of a moment of time in the future (an act of persecution), but as the UK Supreme Court said in HJ (Iran), in order to establish a real risk of being persecuted it can suffice to establish the threat of that future event, without going on to consider whether it will eventuate. That is surely the essence of ‘the Anne Frank principle’. Put another way, contrary to Scott’s contention, the ‘dominant’ approach, by recognizing that ‘being persecuted’ can arise through a threat of persecution, is not tied to a narrow temporal scope. Further, to suggest that somehow an ‘event paradigm’ entails that the horizon for considering when that event is likely to happen is limited to the immediate context of return (that is, importation of an imminence test) is surely a step too far. Even where an event paradigm is understood strictly in terms of a (real risk of) an event happening in a moment of time in the future, why does this paradigm entail that it must be an immediate or imminent as opposed to a more distant event? (Indeed, Scott seems to recognize this (p 105) when noting acceptance in an Australian Federal Court case that the horizon for considering when that event is likely to happen can be ‘potentially distant’.8) It is also hard to reconcile Scott’s approach with another well-established feature of refugee law, namely that severe violations of human rights can arise not simply through single acts such as murder or bombing, but through an accumulation of measures (see, for example, the UNHCR Handbook and article 9(1)(b) of the Qualification Directive). Scott appears to deflect this criticism by suggesting that, when it comes to cumulative harm, ‘the focus … is on the question of when a certain threshold of severity of an accumulation of discriminatory measures will be attained’ (p 109), but it remains that the harm envisaged here is comprised of acts or measures. Further, ordinarily such measures occur over a period of time, not all at once, which is itself a recognition that the temporal scope involved can be enduring. Whilst it might sometimes be possible to portray such measures as a series of mini acts, this ignores the accepted approach to cumulative harm which is to recognize its overall effect. The above critique does not mean that Scott’s analysis lacks substance. It is a forceful reminder of the need for refugee law not to forget that temporal scope is very much a function of context and can sometimes concern a discrete moment in time but sometimes longer periods. Is he right about personal scope? As regards personal scope, Scott considers that this must largely be elicited by reference to object and purpose. However, his analysis of object and purpose at most bites only against a maverick version of the human rights approach – which he terms the ‘human rights adjudication’ approach, namely that RSD is about determining State culpability. Such an approach is scarcely applied in doctrine or jurisprudence. It is well established that RSD is not about attributing responsibility to countries of origin for human rights violations. Rather, as stated in the 1967 United Nations Declaration on Territorial Asylum, the granting of territorial asylum ‘is a peaceful and humanitarian act and …, as such, it cannot be regarded as unfriendly by any other State’. By identifying human rights violations, RSD decision makers are not establishing State culpability; they have no jurisdiction to do that in any event. Nevertheless, Scott makes a strong point regarding how the human rights approach should best formulate its reference to human rights violations. He finds it pertinent that Hathaway and Foster replace the term ‘violation’ with ‘denial’ when defining ‘being persecuted’.9 Scott states that his study ‘embraces the term “denial”, as it helps to further shift attention to the predicament of the individual rather than placing too much attention on whether the State has formally breached an obligation under IHRL’ (p 92). Is he right about non-discrimination being inherent in the notion of ‘being persecuted’? At root, Scott’s objection to the overwide personal scope afforded by the human rights approach adopted by Hathaway and others comes down to whether or not he is correct in his view that persecution must have discrimination as one of its components. He considers his view to be strongly supported by ordinary meaning, as well as context and object and purpose and other rules of international law. It is relatively clear why Scott presses for such a new approach. He is concerned about the difficulties facing people fleeing armed conflict or dangerous environments being able to establish that they are refugees, especially because it is often difficult to identify a Refugee Convention reason. If, however, persecution itself can be said to have a discriminatory element by virtue of being understood as a condition of existence, then it will be far easier to establish persecution arising from ‘structural violence’ as well as from sudden and slow-onset climate change situations which have hitherto been seen as simply ‘adversity’ due to ‘forces of nature’. For example, in this way discrimination may sometimes be seen even in a failure to maintain flood defences, failure to build accessible storm shelters, or failure to operate an early warning system. Scott is well aware that this approach to the ‘being persecuted’ element of the refugee definition has been subject to considerable criticism, in particular from Goodwin-Gill in a 1999 article.10 This reviewer is unconvinced that he has satisfactorily addressed the recognized problems with such an approach. One can readily agree that being persecuted cannot be understood in isolation from the Convention reasons: that is part of the well-accepted idea of a unified or holistic interpretation which sees the different elements of the refugee definition as interlocking and interconnected. However, to assert that persecution is not persecution unless it is discriminatory is to stretch ordinary meaning and context and objects and purposes – and also article 31(3)(c) of the VCLT – too far. As regards ordinary meaning, it is clear that the dictionary definitions of ‘to persecute’ include ones that make no use of a concept of discrimination. This is partially true even in respect of the specific definition given by the Oxford English Dictionary (OED) of ‘to persecute’ on which Scott relies, namely: ‘To seek out and subject (a person, group, organization, etc) to hostility or ill treatment, esp on grounds of religious faith, political belief, race, etc; to torment; to oppress’ (p 121). For Scott, this definition makes discrimination ‘integral to the definition’ (p 121). But first of all, this definition is not the only one given in the OED and most other dictionaries; and, secondly, even this definition prefaces reference to the discriminatory elements (the ‘grounds’) with the adverb ‘especially’, which roughly translates as ‘mainly’ or ‘mostly’, not ‘always’. Further, this definition, itself one of three, includes as distinct usages, two definitions separated by a semi-colon that refer simply to ‘to torment; to oppress’. Scott goes on to acknowledge that in the English and French dictionary definitions there are examples of both ‘discriminatory persecution’ and persecution that does not include a discriminatory element, but this is deemed not to matter since ‘it is clear that the definition that comes closest to incorporating the element of discrimination is the most relevant to an understanding of the ordinary meaning’ (p 122). This might strike the reader as somewhat à la carte reasoning. As regards context, Scott accepts that little support can be derived from the second preambular paragraph of the preamble, but considers that the reference to non-discrimination in the first preambular paragraph is enough. However, it would be strange to read the reference in that paragraph to the United Nations Charter and the Universal Declaration of Human Rights affirming ‘the principle that human beings shall enjoy fundamental rights without discrimination’ as being just about non-discrimination. As regards article 31(3)(c), the relevant rules of intentional law on discrimination are primarily to be found in international human rights law, and so this argument works as much (if at all) for the type of human rights approach advanced by Hathaway and Foster and others as for Scott’s own discrimination-centric argument. Scott suggests that one reason why such a reading of ‘being persecuted’ aligns more closely with ordinary meaning, context and object and purpose is that it would preclude the reading in of a requirement to establish intention on the part of an actor of persecution, since discrimination can be established irrespective of the intention of those responsible for discriminatory acts or omissions. But the definition of ‘being persecuted’ that underpins the predominant human rights approach does not draw on or accept that there is a requirement to establish intention, so this argument is again at best effective only against outmoded approaches. There is also a problem of self-contradiction. The main argument advanced as to why discrimination must be seen to be a necessary condition of being persecuted seems to be that to construe persecution more broadly (that is, so it is not confined to discriminatory persecution) would, as noted earlier, dilute the distinctive quality of being persecuted. It is true that if one adopts the prevailing approach, which sees the discriminatory element as confined to the nexus or Convention grounds, then some human rights approaches (for example, Hathaway and Foster’s) can have the consequence that claimants might be found to be victims of persecution, but to still not be refugees unless able to establish a Refugee Convention ground. But on Scott’s approach, it seems that even that is to be considered ‘unduly broad’ (p 118)! Thus, despite his struggle to advance a broader definition, he risks advocating a narrower one than that applied presently. If discrimination operates under the standard nexus approach as a way of delimiting the class of refugees, why is it necessary to raise the spectre of ‘unduly broad’ categories as a justification for treating discrimination as a necessary condition of being persecuted? Another problem is that Scott acknowledges that adoption of his discrimination-based notion of ‘being persecuted’ would make no difference in practice in the vast majority of cases: ‘[t]he difference,’ he writes, ‘would most likely be detectable only in complex cases relating to the kind of systemic discrimination that engenders differential exposure and vulnerability to a range of denials of human rights where a single actor of persecution is not readily identifiable’ (p 129). If that is so, given the problems identified above, is it really worth such an extensive reworking of the elements of the refugee definition? Footnotes 1 Conference of Plenipotentiaries on the Status of Refugees and Stateless Persons, ‘Summary Record of the Twenty-Second Meeting’, UN doc A/CONF.2/SR.22 (26 November 1951). 2 UNHCR, Handbook on Procedures and Criteria for Determining Refugee Status and Guidelines on International Protection under the 1951 Convention and the 1967 Protocol relating to the Status of Refugees, HCR/1P/4/ENG/REV.4 (1979, reissued 2019) para 39. ‘The expression “owing to well-founded fear of being persecuted” – for the reasons stated … rules out such persons as victims of famine or natural disaster, unless they also have well-founded fear of persecution for one of the reasons stated.’ 3 For example, Michel Prieur, ‘Draft Convention on the International Status of Environmentally-Displaced Persons’ <https://unfccc.int/files/adaptation/groups_committees/loss_and_ damage_executive_committee/application/pdf/prieur-convention_on_the_international_status_of_environmentally.pdf> accessed 3 December 2020. 4 See eg Global Compact for Safe, Orderly and Regular Migration, UN doc A/RES/73/195 (19 December 2018) para 18 (h), (i), (l); Sanjula Weerasinghe, In Harm’s Way: International Protection in the context of Nexus Dynamics between Conflict or Violence and Disaster or Climate Change (UNHCR 2018). 5 James C Hathaway and Michelle Foster, The Law of Refugee Status (2nd edn, Cambridge University Press 2014). 6 Walter Kälin and Nina Schrepfer, ‘Protecting People Crossing Borders in the Context of Climate Change: Normative Gaps and Possible Approaches’, UNHCR Legal and Protection Policy Research Series, PPLA/2012//01 (2012). 7 Andreas Zimmermann and Claudia Mahler, ‘Article 1A, Paragraph 2’ in Andreas Zimmermann (ed), The 1951 Convention Relating to the Status of Refugees and Its 1967 Protocol: A Commentary (Oxford University Press 2011) 323. 8 NAGT of 2002 v Minister for Immigration and Multicultural and Indigenous Affairs [2002] FCAFC 319, para 22, cited in Hathaway and Foster (n 5). 9 Hathaway and Foster (n 5). 10 Guy S Goodwin-Gill, ‘Judicial Reasoning and “Social Group” after Islam and Shah’ (1999) 11 International Journal of Refugee Law 537. Goodwin-Gill’s objections were that: (i) the reference to non-discrimination in the second preambular para of the preamble concerns the rights of refugees in the host State, after recognition; (ii) the purpose of the Convention is not to promote non-discrimination of those who might become refugees; (iii) the lack of reference to discriminatory denial of human rights in the travaux préparatoires; (iv) such a focus risks a failure ‘to reflect the social reality of oppression’; and (v) ‘[a] person who is persecuted by reason of a political opinion wrongly imputed in no way suffers discrimination by reason of some innate, unchangeable or otherwise fundamentally important characteristic’ (at 539). Author notes The views expressed here are the author’s own. © The Author(s) (2021). Published by Oxford University Press. All rights reserved. For Permissions please email: journals.permissions@oup.com This article is published and distributed under the terms of the Oxford University Press, Standard Journals Publication Model (https://academic.oup.com/journals/pages/open_access/funder_policies/chorus/standard_publication_model)
TI - Climate Change, Disasters, and the Refugee Convention
JF - International Journal of Refugee Law
DO - 10.1093/ijrl/eeab028
DA - 2021-10-27
UR - https://www.deepdyve.com/lp/oxford-university-press/climate-change-disasters-and-the-refugee-convention-DO3iGw42ts
SP - 170
EP - 179
VL - 33
IS - 1
DP - DeepDyve
ER -