Abstract
The transformation of Organisation of African Unity (OAU) to the African Union (AU) in 2002, revealed a determination for African States to control their own affairs and resources from peace, security, economy, trade, governance and upholding and strengthening their democracies. Although AU has made a number of strides in that expedition, it has faced a number of challenges in so many areas including enhancing peace and security. The contemporary security challenges facing Africa include extremism, conflicts, political violence, climate change, natural and man-made disasters, flawed electoral processes, unemployment, cybercrime, human trafficking and diseases. These issues have had a bearing on Africa’s economic development which in turn have suffocated efforts to have a peaceful and secure Africa. Economic destitutions, desecration and manipulation of constitution, violation of human rights, disparities and ostracism have made peace, security and stability in Africa a mindboggling reverie. In that regard, in 2002 the AU launched a continental framework with the aim of promoting peace and stability in the region termed African Peace and Security Architecture (APSA). The assessment of the APSA reveals that it is a ‘two-legged tripod’ in as much as it constitutes early warning mechanisms and corresponding early response mechanisms, but it lacks formidable preventive mechanisms. Considering the shift from state security to human security, the AU ought to have not clearly accommodated the AU human rights and governance mechanisms in the APSA. In addition, mainstreaming of human rights into the organs of the AU can strengthen the African Court of Justice and Human Rights as a mechanism for the enforcement of the human rights commitments by AU Member States. The AU should focus more on addressing structural causes of atrocities than on the costly intervention after the fact. Thus, the APSA should clearly incorporate the human rights and governance institutions to effectively focus on timely and adequate prevention.
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Notes
- 1.
Practical Steps to Silence the Guns in Africa by the Year 2020—A Speech by Mr. Osman Keh Kamara to African Union Peace and Security Council, 6 December 2016 available at https://apctimes.com/practical-steps-to-silence-the-guns-in-africa-by-the-year-2020/ (accessed on 20 August 2020).
- 2.
As above.
- 3.
S/RES/2320 (2016), Resolution 2320, adopted by the Security Council at its 7816th meeting on 18 November 2016.
- 4.
Kamara 2016.
- 5.
THE AFRICAN UNION AND COUNTER-TERRORISM article available at https://nesa-center.org/the-african-union-and-counter-terrorism/ (accessed on 23 November 2020).
- 6.
Andrew Harding, Mozambique President visits region beset by Islamists, 2020 BBC News, 14 August 2020.
- 7.
The Africa Center for Strategic Studies, Myths about Human Trafficking in Africa July 26, 2019 available at https://africacenter.org/spotlight/myths-about-human-trafficking-in-africa (accessed on 19 November 2020).
- 8.
Jamille Bigio and Rachel Vogelstein, The Security Implications of Human Trafficking, Discussion paper, Council on Foreign Relations (2019).
- 9.
Ibid.
- 10.
Jeffrey Kurebwa and Jaquiline Tanhara, Cybercrime as a Threat to Zimbabwe’s Peace and Security, 2020. 10.4018/978-1-7998-2466-4.ch066 available at www.researchgate.net/publications (accessed on 15 September 2020).
- 11.
AU Convention on Cybersecurity and personal data protection by the 23rd ordinary session of the Assembly, held in Malabo, Equatorial Guinea on 27 June 2014. This convention has of late become to be known as the Malabo Convention.
- 12.
United Nations, Climate Security Mechanism, Briefing Note, New York, 2020.
- 13.
As above.
- 14.
Yayew Genet Chekol, ‘Major Successes and Challenges of African Peace and Security Architecture,’ 5(2) International Journal of Political Science (2019), pp. 1–8 available at www.arcjournals.org (accessed on 18 February 2021).
- 15.
As above.
- 16.
See also Kioko, supra footnote 9, pp. 822–824.
- 17.
The AU Assembly gives directives to the Executive Council (of Ministers of Foreign Affairs), the PSCor the Commission on the management of conflicts, wars, acts of terrorism, emergency situations and the restoration of peace, but it may delegate to any other AU organ. Cf. The Constitutive Act of the African Union, 2000 [‘AU Act’]; Arts. 7 of the Act and Art. 9(g); and Rules 4(1) (d) and 4(2) 6 and 18 of the Rules of Procedure of the AU Assembly; see also Kioko, supra footnote 9, p. 816.
- 18.
The fourth recital of the Preamble of the PSC Protocol states that pursuant to a decision of the 37th Ordinary Session of the OAU Assembly of Heads of State and Government in Lusaka, Zambia in July 2001, the Assembly ‘decided to incorporate the Central Organ of the AOU Mechanism for Conflict, Prevention, Management, and Resolution as one of the organs of the Union’.
- 19.
The PSC Protocol was endorsed on 9 July 2002 at the First Ordinary Session of the Assembly of the AU in Durban, South Africa. It was adopted pursuant to Art. 5(2) of the AU Act, which empowers the AU to establish other ‘organs that the Assembly may decide to establish’.
- 20.
Levitt, supra footnote 5, p. 110.
- 21.
G. Puley, The Responsibility to Protect: East, West, and Southern African Perspectives on Preventing and Responding to Humanitarian Crises, Working Paper, Project Ploughshares 05–5, 2005.
- 22.
Levitt, supra footnote 5, p. 116.
- 23.
G. Alemu, available at: www.ossrea.net/publications/newsletter/oct05/article8.htm (10 May 2008).
- 24.
Quoted by C. Van der Westhuizen, ‘The AU’s Peace and Security Council: On a Tightrope Between Sovereignty and Human Rights?’ 42 Global Insight (2005), p. 6.
- 25.
Cf. A. Abass, ‘The Darfur Crisis: The Role of the African Union in Darfur,’ 24(65) Utrecht Journal of International and European Law (2007), pp. 47–57, p. 49.
- 26.
Levitt, supra footnote 5, p. 116.
- 27.
For more details see J. Cilliers & K. Sturman, ‘The Right of Intervention: Enforcement Challenges for the African Union,’ 11(3) African Security Review (2002), pp. 101–102.
- 28.
See B.A. Kiplagat, ‘Regional Co-operation in Africa,’ in Conflict Prevention and Peace-building in Africa, Report from the Maputo Conference, 28–29 June 2001, Danish Ministry of Foreign Affairs, Danida, 2001, p. 20.
- 29.
The Panel builds on a longstanding African tradition of mediation by African ‘elder statesmen’ to help bring an end to armed conflicts and is seemingly a derivative of the ‘Council of Elders’ of the ECOWAS peace and security structure.
- 30.
See also Samkange, supra footnote 30, p. 83.
- 31.
See ‘The World Summit Outcome,’ supra footnote 8, paras. 149–151.
- 32.
For details on this point see J. Cilliers, ‘The African Standby Force: An Update on Progress,’ ISS Paper 160, Pretoria: Institute of Security Studies, March 2008, p. 4.
- 33.
The ASF will consist of a system of five regionally managed multidisciplinary contingents comprising 3000–4000 troops, between 300 and 500 military observers, police units and civilian specialists on standby in their countries of origin. See also Powell, supra footnote 3.
- 34.
PSC Protocol 13, African Standby Force.
- 35.
Puley, supra footnote 25, pp. 3–4.
- 36.
PSC Protocol, Article 15.
- 37.
D.C. Peifer (ed.), Stopping Mass Killings in Africa; Genocide, Airpower and Intervention, Alabama: Air University Press, 2008, pp. 6, 44.
- 38.
See Report of the 4th Meeting of African Chiefs of Defence Staff and Experts on the Establishment of the African Standby Force and the Common African Defence and Security Policy, EXP/Def&SecRpt (IV), January 2004.
- 39.
See ICISS Report, supra footnote 6, see also G. Däniker, The Nature and the Use of Armed Forces, Geneva: United Nations Institute for Disarmament Research, 1999.
- 40.
For more details see Mepham & Ramsbotham, supra footnote 10, p. xiii, see also Dr. Mohamed Bin Chambas, Executive Secretary, ECOWAS, 25 May 2005, ‘Forward I’ in Aboagye and Bah (eds.), supra footnote 13, p. xviii, pp. xv–xix; see The Brahimi Report, supra footnote 51, p. xi; cf. Bah, supra footnote 13, pp. 45–46; see F.B. Aboagye & A.M.S. Bah, ‘Synergies of Regional and UN Interventions The Contribution of the UN Mission in Liberia to Civilian Protection,’ in F.B. Aboagye & A.M.S. Bah (eds), A Tortuous Road to Peace: The Dynamics of Regional, UN and International Humanitarian Intervention in Liberia, Pretoria: ISS, 2005, pp. 99–126, p. 123; see also Powell, supra footnote 3, pp. 23–24.
- 41.
L. Feinstein, ‘Darfur and Beyond: What Is Needed to Prevent Mass Atrocities’. 22 Council Special Report, New York: Council on Foreign Relations, 2007, p. 20; see also ‘The Responsibility to Protect: Moving the Agenda Forward,’ Ottawa: United Nations Association in Canada, 2007, p. 29.
- 42.
At that time very few African States (i.e., Gambia, Senegal, and Botswana), could vaunt of a democratic regime respectful of at least the fundamental human rights. See Project on International Courts and Tribunals, African Court of Human and Peoples’ Rights, available at: www.pict-pcti.org/courts/ACHPR.html (12 December 2007).
- 43.
Levitt, as above footnote 5, p. 124.
- 44.
As above.
- 45.
K. van Walraven, Dreams of Power: The Role of the Organisation of African Unity in the Politics of Africa (1963–1993), Ridderkerk: Ridderprint, 1996, p. 295.
- 46.
R. Murray, Human Rights in Africa–From the OAU to the African Union, Cambridge: Cambridge University Press, 2004, pp. 59–60.
- 47.
Cf. Assembly/AU/Dec.6 (II), Draft Decision on 60th Annual Activity Report on the African Commission on Human and Peoples’ Rights-Doc. Assembly/AU/7(II).
- 48.
Murphy, supra footnote 36, p. 351.
- 49.
It took six years to be ratified by just 15 Member States. Although the African Court on Human and Peoples’ Rights is operational, the Court of Justice is yet to be ratified; cf. Assembly/AU/Dec.45, (III).
- 50.
See Cilliers & Sturman, supra footnote 37, p. 105; but see the Protocol on the Statute of the African Court of Justice and Human Rights [the ‘Single Protocol’], available at: www.africa-union.org/root/au/Documents/Treaties/treaties.htm (12 December 2008), Art. 2 of the Single Protocol.
- 51.
Cilliers & Sturman, supra footnote 37, p. 104; see also D. Geldenhuys, ‘Brothers as Keepers: Africa’s New Sovereignty Regime,’ in 28(2) Strategic Review for Southern Africa (2006), p. 19.
- 52.
The decision was made in June 2004. According to Art. 7 of the ‘Single Protocol,’ the old ACtHPR Protocol shall remain in force for a transitional period of one year to enable the African Court on the Human and Peoples’ Rights to implement measures necessary. The single Protocol replaces the Protocol to the African Charter on Human and Peoples’ Rights on the Establishment of an African Court on Human and Peoples’ Rights adopted in 1998 (the ACtHPR Protocol), and the Protocol for the transfer of its prerogatives, assets, rights, and obligations to the ACtJHR. See the Single Protocol, supra footnote 73.
- 53.
A staff member of the AU on appeal, in a dispute and within the limits and under the terms and conditions laid down in the Staff Rules and Regulations of the AU; obviously, the Court shall not be open to States, which are not members of the AU. The Court shall also have no jurisdiction to deal with a dispute involving a Member State that has not ratified the Protocol. see the Statute of the African Court of Justice and Human Rights [the ‘ACtJHR Statute’] attached to the Single Protocol, available at: www.africa-union.org/root/au/Documents/Treaties/treaties.htm (12 December 2008), Art. 29(1)(c) and 29(2) of the ACtJHR Statute.
- 54.
The International Centre for the Legal Protection of Human Rights, available at: www.interights.org/AfricanSingleProtocolAdopted/index.htm (29 July 2008).
- 55.
Mepham & Ramsbotham, supra footnote 10, p. 33.
- 56.
Cf. A. de Hoogh, Obligations Erga Omnes and International Crimes: A Theoretical Inquiry into the Implementation and Enforcement of the International Responsibility of States, The Hague: Kluwer Law International, 1996, p. 404.
- 57.
Puley, supra footnote 25, pp. 22–23.
- 58.
Project on International Courts and Tribunals, supra footnote 65.
- 59.
W.A. Schabas, ‘Genocide Convention at Fifty,’ Special Report, Washington, DC: United States Institute of Peace, 1999, p. 4.
- 60.
S.R. Ratner & J.S. Abrams, Accountability for Human Righhts Atrocities in International Law: Beyond the Nuremberg Legacy, 2nd edn, Oxford: Oxford University Press, 2001, pp. 225–227.
- 61.
Ibid.
- 62.
The original draft by experts in 1995 gave access to individual victims and enabled NGOs to represent them. This was watered down in the final version adopted by the OAU Heads of State in 1998; cf. Art. 5 of the Single Protocol, supra footnote 73.
- 63.
Cilliers & Sturman, supra footnote 37, p. 104.
- 64.
Out of the 280 cases brought before the African Commission over the years, 279 were made by individuals and NGOs, and only one by a State Party against another State Party. Ibid., pp. 103–104.
- 65.
See The Kampala Document, supra footnote 57.
- 66.
Cf. the PSC Protocol, Arts 8, 11, 12(3), 13(3) and 20, supra footnote 21; see also Resolution on the Co-operation between the African Commission on Human and Peoples’ Rights and NGOs Having Observer Status with the Commission 1998.
- 67.
Mepham & Ramsbotham, supra footnote 10, p. 33.
- 68.
See Article 8 of the ‘Single Protocol,’ supra footnote 73; see also Artilce 30 (f) of the ‘ACtJHR Statute,’ supra footnote 76; see also the International Centre for the Legal Protection of Human Rights, supra footnote 77.
- 69.
Art. 11, Protocol to the Treaty Establishing the African Economic Community Relating to the Pan-African Parliament, CM/2198(LXXII), Annex I.
- 70.
Levitt, supra footnote 5, p. 124.
- 71.
G. Hugo, ‘The Pan-African Parliament: Is the Glass Half-Full or Half-Empty?’ ISS Paper 168, Pretoria: Institute of Security Studies, 2008, 1.
- 72.
P. van Dijk, ‘The Law of Human Rights in Europe—Instruments and Procedures for a Uniform Implementation,’ 6(2) AEL (1997), pp. 22–50.
- 73.
See also Geldenhuys, supra footnote 74, pp. 18–19.
- 74.
Hugo, supra footnote 94, p. 5.
- 75.
Ibid.
- 76.
Ibid., pp. 5–9.
- 77.
Cilliers & Sturman, supra footnote 37, p. 103.
- 78.
See Institute of Security Studies, Operationalising the African Peace and Security Architecture: Challenges and Opportunities, Report of the ISS Seminar 20 March 2009, p. 4 [ISS Report on APSA].
see also Bah, supra footnote 13, pp. 45–46.
- 79.
See generally J. Cilliers, ‘Regional African Peacekeeping Capacity—Mythical Construct or Essential Tool?’ in From Peacekeeping to Complex Emergencies: Peace Support Missions in Africa, Johannesburg: South African Institute for International Affairs and ISS, 1999, supra footnote 377.
- 80.
As of 19 March 2021, the Members are: Algeria, Angola, Benin, Burkina Faso, Cameroon, Chad, Côte d’Ivoire, Djibouti, Egypt, Equatorial Guinea, Ethiopia, Gambia, Gabon, Ghana, Kenya, Lesotho, Liberia, Malawi, Mali, Mauritania, Mauritius, Mozambique, Republic of Niger, Namibia, Nigeria, Republic of Congo, Rwanda, São Tomé and Príncipe, Senegal, Sierra Leone, South Africa, Sudan, Tanzania, Togo, Tunisia, Uganda and Zambia. See African Union, African Peer Review Mechanism (APRM), available at: https://au.nt/en/organs/aprm (accessed 18 March 2021). See Geldenhuys, supra footnote 74, pp. 21–22.
- 81.
Although the NEPAD is focused on economic development, it explicitly recognises that ‘peace, security, democracy, good governance, human rights and sound economic management are conditions for sustainable development’. NEPAD proposes systems for monitoring adherence to the rule of law that can promote respect for human rights, in addition to serving as a check to prevent conditions in a given country from deteriorating to the point of insurgency or conflict. NEPAD sets out a series of peace and security priorities to respond to different stages of conflict that correspond with the report’s prevention-reaction-rebuilding framework. In parenthesis, NEPAD has been given global legitimacy with the UN General Assembly’s unanimous adoption of the ‘Declaration on the New Partnership for Africa’s Development’ in September 2002. See also United Nations, Declaration on the New Partnership for Africa’s Development, UN Doc.GA/57/L.2/Rev.1 (16 September 2002).
- 82.
J. Busumtwi-Sam, ‘Architects of Peace—The African Union and NEPAD,’ 7 Georgetown Journal of International Affairs (2006), pp. 71–81, pp. 76–77.
- 83.
However, in the worst case, it could result in weakening of those standards by those AU States with little interest in subscribing to a process of peer review. Ibid., p. 78.
- 84.
Ibid.
- 85.
See Background Research: International Commission on Interventional and State Sovereignty, the Responsibility to Protect, available at: www.iciss.ca/01_Section_A-en.asp (2 May 2008); see also Report on the Implementation of the CSSDCA, supra footnote 57.
- 86.
For example, Human Rights Committee concluding observations: Argentina, CCPR/CO/70/ARG, para. 9 (2000), in which the HRC recommended that Argentina take measures ‘to ensure that persons involved in gross human rights violations are removed from military or public service’ after noting its concern ‘that many persons whose actions were covered by [amnesty] laws continue to serve in the military or in public office, with some having enjoyed promotions in the ensuing years’ and ‘at the atmosphere of impunity for those responsible for gross human rights violations under military rule’.
- 87.
Geldenhuys, supra footnote 74, pp. 15–17.
- 88.
A. Abass, ‘Consent Precluding State Responsibility: A Critical Analysis,’ 53 International & Comparative Law Quarterly (2004), pp. 211–225, p. 51.
- 89.
See R. Gossen & S. Sharma, ‘Advancing NEPAD through The Responsibility to Protect,’ Policy Brief, The Liu Institute for Global Issues, July 2003; see also Powell, supra footnote 3, pp. 14–15.
- 90.
See Centre For Conflict Resolution, Building An African Union For The 21st Century: Relations With Regional Economic Communities (RECs), NEPAD and Civil Society, Policy Seminar Report The Vineyard Hotel, Cape Town, 20–22 August 2005, Cape Town, 2005, p. 11.
- 91.
See OAU, Resolution CM/Res464 (XXVI), Twenty-Sixth Ordinary Session of the Council of Ministers, Addis Ababa, 23 February–1 March 1976.
- 92.
The Common Market for Eastern and Southern Africa (COMESA) too has not adopted a formal protocol on peace and security although it has formally endorsed a number of State-centric guiding principles, including non-aggression between Member States and the peaceful resolution of disputes between Member States. The Eastern African Community (EAC) has developed a Memorandum of Cooperation in Defence and has held joint meetings on small arms and light weapons, joint exercises for peace operations training, counter-terrorism and disaster management. Cf. Powell, supra footnote 3.
- 93.
See M. Mwanasali, ‘From the Organization of African Unity to the African Union,’ in M. Baregu & C. Landsberg (eds.), From Cape to Congo: Southern Africa’s Evolving Security Challenges, London: Boulder Lynne Rienner Publishers, 2003.
- 94.
For views on ECOWAS see Ambassador Jacques Paul Klein, Special Representative of the Secretary General, United Nations Mission in Liberia (UNMIL) and Coordinator of the UN Operations in Liberia, 25 May 2005, ‘Forward II,’ in Aboagye & Bah (eds.), supra footnote 13, p. xxii, pp. xxi–xxiv, pp. 1–2; see also Aboagye & Bah, supra footnote 63, pp. 73–98, p. 122; Bah, supra footnote 13, p. 30; see also G.J. Yoroms, ‘Mechanism for Conflict Management in ECOWAS,’ Accord Occasional Paper, No. 8. 1999, pp. 3–4; cf. Proposed concept of ECOWAS Standby Brigade, May 2004; see also ECOMIL After-Action Review, Final Report, Abuja, August 2004.
- 95.
In contrast to ECOWAS and SADC, IGAD does not possess the operational infrastructure to respond militarily to conflict. Instead, it has focused its efforts on ‘conflict prevention’ through the on-going formation of a continental early warning system, and ‘conflict resolution’ by mediating the peace processes in Sudan and offering critical support to the Somalia–Djibouti-led peace process. In March 2005 member states of IGAD revised its Charter in order to authorise the deployment of a peacekeeping mission to support the Somalia peace process; cf. Centre for Conflict Resolution, A More Secure Continent: African Perspectives on the UN High-Level Panel Report, A More Secure World: Our Shared Responsibility, Seminar Report, Somerset West, Cape Town, 23–24 April 2005, p. 25.
- 96.
See M. Juma & A. Mengistu, ‘The Infrastructure of Peace in Africa: Assessing the Peace-building Capacity of African Institutions,’ New York: International Peace Academy, September 2002.
- 97.
Ibok (2004), supra footnote 4, pp. 7–9.
- 98.
International Peace Academy, Refashioning the Dialogue: Regional Perspectives on the Brahimi Report on UN Operations, New York, 2001.
- 99.
See Powell, supra footnote 3, p. 69.
- 100.
See EXP/AU-Recs/ASF/Comm (I) At an Experts’ Meeting in Addis Ababa in March 2005, the AU and the RECs (ECOWAS, ECCAS, IGAD, COMESA, EAC and SADC) agreed to consider a draft Memorandum of Understanding on conflict prevention, resolution and management but were not able to come to a final agreement on modalities. This is due to a resistance on the part of Member States to confer greater decision-making authority to the AU in some cases, in part because regional organisations provide an alternative forum to exercise influence and leverage greater institutional support for specific political agendas than might be possible in organisations with a larger and more diverse membership. Moreover, ECOWAS and SADC actually have more experience in executing military responses to conflict than the AU, which—with the exception of AMIB and AMIS—has only undertaken observer missions; see Powell, supra footnote 3, p. 69.
- 101.
More so, while the AU has the right to intervene under Article 4(h) and 4(j) of the Act and Article 7(e) of the Protocol of the PSC compels the AU to intervene whereas Article 11 of the SADC Organ on Politics, Defence and Security Cooperation Protocol (PPDSC) does not firmly provide for such intervention. In addition, SADC will only respond to a heavy, forceful and well-informed sub-regional bottom-up approach. In relation to internal and external threats the CADSP deals with both simultaneously while in the SADC provisions, these matters are dealt with separately both in the PPDSC and the Mutual Defence Pact (MDP). Furthermore, decision-making processes between the two also differ. Whereas AU decisions are by consensus and voting in the event of a deadlock, decision-making in SADC is based invariably on consensus. Ibid.
- 102.
The CSSDCA, which is loosely modelled on the Organization for Security and Cooperation in Europe (OSCE), also has a peer review implementation similar to the APRM. The CSSDCA process has also developed a framework of activity that would serve the monitoring and evaluation goals of the AU Assembly as prescribed in Art. 9(e) of the AU Act. The obligations and frameworks of behaviour set for values, commitments and actions to be taken, and key performance indicators enunciated in the Memorandum of Understanding on the Security, Stability, Development and Cooperation Calabashes under the CSSDCA meet the highest comparable regional and international standards. It is also remarkable that the Member States in consensus agreed and committed themselves in clear and unequivocal terms on standards to stand by them and to respect and implement all this undertakings in the conformity with Arts 9(e) and 23(2) of the AU Act; see the Report on the implementation of the CSSDCA, supra footnote 57.
- 103.
The CSSDCA is one of the two special programmes of the AU, the other being NEPAD. Initially, the CSSDCA was a framework for the adoption of common values for the AU as well as benchmarks against which successes could be measured, while NEPAD was an action programme for achieving the objectives of the AU and the continent as a whole. One of the main characteristics of the CSSDCA initiative was its provision of a mechanism for monitoring and facilitating the implementation of OAU/AU decisions. Although there is convergence and complementarity between the objectives of the CSSDCA and NEPAD in the context of the AU, there are areas of overlap and possible duplication that need to be addressed; cf. Report on the implementation of the CSSDCA, supra footnote 57.
- 104.
See also Bah, supra footnote 13, pp. 35–36.
- 105.
See also United Nations, Report of the Secretary-General to the Security Council on the Protection of Civilians in Armed Conflict, S/1999/957, 8 September 1999, para. 36.
- 106.
Ibid., para. 38(4).
- 107.
Ibid., para. 45.
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Kuwali, D. (2022). The African Union Agenda for Sustainable Peace and Security. In: Kuwali, D. (eds) The Palgrave Handbook of Sustainable Peace and Security in Africa. Palgrave Macmillan, Cham. https://doi.org/10.1007/978-3-030-82020-6_4
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