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The positive duty of prevention in the common law and the Convention

  • Achas K Burin (a1)

Abstract

Twenty years after the Human Rights Act 1998 came into force, where are we in our understanding of the relationship between tort and human rights? This paper argues that we are not as far along in our understanding as we could be. The reason for that has been the methodology we used to understand the relationship, focused as it was around remedies, limitation and causation. This paper proposes a new approach, based around the right rather than the remedy. It aims to theorise one particular cause of action – the duty in Osman v United Kingdom – to exemplify this approach. For English lawyers, who have historically used the framework of the forms of action to understand our own law, it is argued that this a good way to comprehend the European jurisprudence.

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I am very grateful to the anonymous reviewers of this journal for comments on the draft, and likewise to Miles Jackson and Leo Boonzaier. I had useful discussions about the ideas in here with Hayley Hooper and the participants of the SLS Annual Conference in 2016, and with the Oxford-Girona-Génova Conference in 2017.

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1 (2000) 29 EHRR 245.

2 [2018] UKSC 11, [2018] 2 WLR 895.

3 [2018] UKSC 4, [2018] 2 WLR 595. A later Supreme Court decision confirmed Robinson’s status as the leading tort case on public authority liability: CN and GN v Poole Borough Council [2019] UKSC 25, [2019] 2 WLR 1478 at [74].

4 This is not ultimately how the Supreme Court conceived of Robinson, but the courts below did so, and it was an issue in the case. The court said that Michael failed because it was a case of inaction, whereas the police in Robinson played an active part in the arrest of a suspect (even though it was the fleeing suspect who careened into Mrs Robinson). It is also true that DSD concerned the investigative duty, which is not the same as the Osman duty, as Lord Mance pointed out (at [151](iv)). However, the Osman duty formed a plank of Lord Hughes’ dissent, and the case is generally relevant to the relationship between tort and the HRA.

5 [1970] AC 1004.

6 Osman, above n 1, at [121].

7 Eg Mastromatteo v Italy (2002) ECHR 694 at [74], [78]; Kolyadenko v Russia (2013) 56 EHRR 2 at [216].

8 Eg Nolan, DNegligence and human rights law: the case for separate development’ (2013) 76(2) MLR 286; Woolf, LordThe Human Rights Act 1998 and remedies’ in Andenæs, M and Fairgrieve, D (eds) Judicial Review in International Perspective: Volume II (Kluwer 2000) p 432; the Privy Council in Maharaj v AG of Trinidad and Tobago (No 2) [1979] AC 385; the Court of Appeal in Dobson v Thames Water Utilities [2009] EWCA Civ 28, [2009] 3 All ER 319 at [42].

9 They include: Law Commission and Scottish Law Commission Damages under the Human Rights Act 1998 (Law Com No 266, 2000; Scottish Law Com No 180, 2000) para 4.20; Stevens, RTorts and Rights (Oxford: Oxford University Press, 2007) p 289; Cane, PTort law and public functions’ in Oberdiek, J (ed) Philosophical Foundations of the Law of Torts (Oxford: Oxford University Press, 2014) p 148 at p 163 (although Cane puts the words ‘statutory tort’ in inverted commas); Varuhas, JNEDamages and Human Rights (Oxford: Hart Publishing, 2015); Bedford v Bedfordshire County Council [2013] EWHC 1717 (QB) at [26] per Jay J.

10 Lester, A and Pannick, DThe impact of the Human Rights Act on private law’ (2000) 116 LQR 380 at 382.

11 Eg du Bois, FHuman rights and the tort liability of public authorities’ (2011) 127 LQR 589; R (Greenfield) v Secretary of State for the Home Department [2005] UKHL 14, [2005] 1 WLR 673 at [19] per Lord Bingham. I am grateful to an anonymous reviewer for pointing out that the case of Huang v Home Secretary [2007] UKHL 11, [2007] 2 AC 167 could also be said to support this view.

12 Lord Bingham in Smith/Van Colle, below n 41, and Lord Kerr in Michael, below n 39, are examples of people who hold the different-but-compatible view. Contrast N v Poole, above n 3, at [53], [62].

13 Eg Nolan, above n 8; Bagshaw, below n 50.

14 Eg Varuhas, above n 9.

15 N v Poole, above n 3, at [29].

16 Eg Stevens, above n 9.

17 DSD, above n 2, at [136].

18 Ibid, at [150].

19 Xenos, DThe Positive Obligations of the State under the European Convention of Human Rights (London: Routledge, 2012) p 3; C deThan ‘Positive obligations under the European Convention on Human Rights’ (2003) Journal of Criminal Law 165 at 178.

20 P Thielbörger ‘Positive obligations under the ECHR after the Stoicescu case’ (2012) European Yearbook on Human Rights 259 at 261.

21 VgT v Switzerland (2002) 34 EHRR 159 at [46].

22 Starmer, KEuropean Human Rights Law (London: LAG, 1999) ch 5.

23 Mowbray, AThe Development of Positive Obligations under the European Convention on Human Rights (Oxford: Hart Publishing, 2004) p 5.

24 For an overview of the types of duties said to be generated by human rights generally, see Koch, IEDichotomies, trichotomies or waves of duties?’ (2005) 5(1) HRLR 81 at 86; Fredman, SHuman Rights Transformed (Oxford: Oxford University Press, 2008).

25 R v Secretary of State for Transport, ex p Factortame (No 6) [2001] 1 WLR 942 at 965.

26 HRA 1998, s 8(3).

27 Fairgrieve, DState Liability in Tort: A Comparative Study (Oxford: Oxford University Press, 2003) p 54. See also Anufrijeva v Southwark LBC [2003] EWCA Civ 1406, [2004] QB 1124 at [50], [55].

28 Nolan, above n 8, at 296.

29 Cane, above n 9, pp 164, 165.

30 Ibid, p 163.

31 HRA 1998, s 8(1).

32 ECHR, Art 41; Storey, D and Eicke, THuman Rights Damages: Principles and Practice (London: Sweet & Maxwell, 2001) para A2-001. Though, of course, it may also offer nothing in addition to a judgment in the applicant's favour.

34 Konig v Germany 2 EHRR 469 at [15].

35 Robinson v Harman (1848) 1 Ex Rep 850 at, 855.

36 J Steele, ‘Damages in tort and under the Human Rights Act: remedial or functional separation?’ (2008) CLJ 606 at 608.

37 Anufrijeva, above n 27, at [53]. Arden makes a similar questionable presumption that ‘vindication is the very thing that the applicant wants’: M Arden ‘Human rights and civil wrongs’ [2010] PL 140 at 152.

38 Greenfield, above n 11, at [19].

39 Michael v Chief Constable of South Wales [2015] UKSC 2, [2015] AC 1732 at [125]; Greenfield, above n 11, at [19]; Watkins v Secretary of State for the Home Department [2006] UKHL 17, [2006] 2 AC 395 at [9]; Van Colle v Chief Constable of Hertfordshire [2008] UKHL 50, [2009] 1 AC 225 at [138].

40 DSD, above n 2, at [68].

41 Van Colle, above n 39, at [138]. See similarly Ashley v Chief Constable of Sussex [2008] UKHL 25, [2008] 1 AC 962, [22] where Lord Scott said that ‘Article 2 [ECHR]… incorporated into our domestic law by the Human Rights Act 1998, is at least equivalent to the constitutional rights for infringement of which vindicatory damages were awarded in [the Privy Council cases of] Ramanoop and Merson v Cartwright’.

42 Varuhas, above n 9, p 113.

43 Steele, above n 36, at 606.

44 Ibid, at 608.

45 Varuhas, above n 9, p 250.

46 Jarvis v Swan Tours [1972] 3 WLR 954.

47 Eg Van Der Leer v Netherlands (1990) 12 EHRR 567 (‘frustration’); Olson v Sweden (No 2) (1994) 17 EHRR 134 (‘inconvenience’); Lopez Ostra v Spain (1995) 20 EHRR 277 (‘anxiety’).

48 Ashley, above n 41, at [22]; Merson v Cartwright [2005] UKPC 38. See also Arden, above n 37, at 152.

49 Steele, above n 36, at 608. See also Taunoa v Attorney-General [2007] NZSC 70 at [367].

50 Bagshaw, RTort design and human rights thinking’ in Hoffman, D (ed) The Impact of the UK Human Rights Act on Private Law (Cambridge: Cambridge University Press, 2011) p 110 at p 115.

51 See eg Birks, PRights, wrongs and remedies’ (2000) 20 OJLS 1; Smith, SRights and remedies: a complex relationship’ in Roach, K and Sharpe, R (eds) Taking Remedies Seriously (Montreal: Canadian Institute for the Administration of Justice, 2010); Levinson, DRights essentialism and remedial equilibration’ (1999) 99 Columbia LR 857.

52 Eg Nolan, above n 8; Bagshaw, above n 50.

53 du Bois, above n 11, at 598.

55 Wilberg, HIn defence of the omissions rule in public authority negligence claims’ (2011) 19 Torts LJ 159.

56 Collins, HUtility and rights in common law reasoning: rebalancing private law through constitutionalization’ (2007) 30 Dalhousie Law Journal 1 at 4.

58 Robinson, above n 3, at [34], [37], [40], [50], [54], [69], [70], [83]. Contrast N v Poole, above n 3, at [28].

59 du Bois, above n 11, at 597.

60 Ibid, at 599.

61 Robinson, above n 3, at [32]; N v Poole, above n 3, at [26], [64]–[65], [75]; du Bois, above n 11, at 597.

62 Ibid, at 597.

63 Gardner, JWhat is tort law for? Part 2. The place of distributive justice’ in Oberdiek, J (ed) Philosophical Foundations of the Law of Torts (Oxford: Oxford University Press, 2014).

64 Ibid, p 341.

65 Eg Arden, above n 37, at 141; Nolan, above n 8, at 296.

66 For discussion, see H Quane ‘The Strasbourg jurisprudence and the meaning of a “public authority” under the Human Rights Act’ [2006] PL 106.

67 Costa, JThe European Court of Human Rights: consistency of its case-law and positive obligations’ (2008) 26 Netherlands Quarterly of Human Rights 449 at 453.

68 Z v UK (2002) 34 EHRR 3.

69 Chowdury v Greece App no 21884/15 (ECHR, 30 March 2017) at [88]; LE v Greece App no 71545/12 (ECHR, 21 January 2016) at [66].

70 Storck v Germany (2006) 43 EHRR 96; Jendrowski v Germany App no 30060/04 (ECHR, 14 April 2011) at [36].

71 Balmer-Schafroth v Switzerland (1998) 25 EHRR 598 at [40].

72 Osman, above n 1; Hajduova v Slovakia (2011) 53 EHRR 8 at [50].

73 Begheluri v Georgia App no 28490/02 (ECHR, 7 October 2014) at [160]; Karaahmed v Bulgaria App no 30587/13 (ECHR, 24 February 2015).

74 Özgür Gündem v Turkey (2001) 31 EHRR 49; Dink v Turkey App no 2668/07 (ECHR, 14 September 2010); Palomo Sánchez v Spain (2012) 54 EHRR 24 at [58]–[61].

75 Ouranio Toxo v Greece App no 74989/01 (ECHR, 20 October 2005) at [37], [43].

76 Rabone v Pennine Care NHS Foundation [2012] 2 AC 72; Savage v South Essex Partnership Foundation Trust [2009] 1 AC 681.

77 Webster v Ridgeway Foundation School [2010] EWHC 157 (QB).

78 Thomson v Scottish Ministers [2013] CSIH 63; Mastromatteo v Italy, above n 7.

79 Bedford, above n 9; Z v UK, above n 68; Mitchell v Glasgow City Council [2009] 1 AC 874.

80 Sarjantson v Chief Constable of Humberside [2013] EWCA Civ 1252, [2014] QB 411 at [18].

81 Robinson, above n 3, at [44].

82 Oneryildiz v Turkey [2004] ECHR 657.

83 Milanovic v Serbia (2014) 58 EHRR 33.

84 Thomson v Scottish Ministers, above n 78; Mastromatteo v Italy, above n 7; Maiorano v Italy ECtHR, 15 December 2009.

85 Dordevic v Croatia [2013] MHLR 89 at [139].

86 Hajduova v Slovakia (2011) 53 EHRR 8.

87 See eg text to n 163 below.

88 DSD, above n 2, at [112]–[114]. DSD is less relevant to my positive project than my negative project because it did not concern the Osman duty in the main. It concerned the investigatory duty, which is separate, as Lord Mance pointed out.

89 Gardner, JWrongs and faults’ in Simester, A (ed) Appraising Strict Liability (Oxford: Oxford University Press, 2005).

90 AG of Trinidad and Tobago v Ramanoop [2006] 1 AC 328 at [19].

91 Michael, above n 39, at [125].

92 Note that I am describing the structural features of the wrong. These allegations are not necessarily successful allegations. There is room for constraints upon the cause of action, such as defences and restrictions in the conditions under which the duty applies – the need for a ‘real and immediate’ risk (per Osman). I do not aim to justify the particular formulation of the Osman test here.

93 Tasioulas argues that human rights in morality have no necessary connection either with the state or with law: ‘Towards a philosophy of human rights’ (2012) 65 Current Legal Problems 1 at 2, 24. See also O'Neill, OAgents of justice’ (2001) 32 Metaphilosophy 180. Mavronicola counters that human rights are conceivably violable by non-state agents in morality, but not in law: ‘Is the prohibition against torture and cruel, inhuman, and degrading treatment absolute in human rights law? A reply to Steven Greer’ (2017) HRLR 479 at 488. The literature on the philosophical foundations of human rights in general is extensive and cannot be treated adequately here. See Cruft, R et al. (eds) Philosophical Foundations of Human Rights (Oxford: Oxford University Press, 2015) for a sample.

94 Eg Bankovic v Belgium [2001] ECHR 890 at [57]. See further, Report of the International Law Commission A/56/10 (2001) Draft Articles.

95 (2003) 37 EHRR 38.

96 Ibid, at [41]. See commentary by Quane, above n 66, at 113.

97 My account here treats the outcome as probative. There are implications to that which have not been tested in case law: what would happen if the claimant successfully warded off an attacker? Since it is the state's wrong that is at play, my view implies that the claimant need not show that she was injured or seriously injured. She would simply not recover (much) for personal injury. This is supported by cases where declarative relief is awarded when the claimant is no worse off after the violation, eg R (Wilkinson) v IRC [2005] 1 WLR 1718 at [24]–[28]; A v UK (2009) 49 EHRR 29 at [252]; Abdi v UK (2013) 57 EHRR 16 at [91]; Shahid v Scottish Ministers [2015] 3 WLR 1003 at [89]. For a similar view, see Lavrysen, LCausation and positive obligations under the ECHR’ (2018) 18 HRLR 705 at 708.

98 Mavronicola, above n 93, at 488.

99 Oneryildiz, above n 82 at [89]–[90].

100 Seibert-Fohr, AProsecuting Serious Human Rights Violations (Oxford: Oxford University Press, 2009); Tulkens, FThe paradoxical relationship between criminal law and human rights’ (2011) 9 Journal of International Criminal Law 577; Lazarus, LPositive obligations and criminal justice: duties to protect or coerce?’ in Zedner, L and Roberts, JV (eds) Principles and Values in Criminal Law and Criminal Justice (Oxford: Oxford University Press, 2012).

101 Michael, above n 39, at [112].

102 Ibid, at [113]; cf N v Poole, above n 3, at [29].

103 See eg Crawford, JState Responsibility: The General Part (New York: Cambridge University Press, 2013) p 129; Taggart, MThe nature and functions of the state’ in Cane, P and Tushnet, M (eds) The Oxford Handbook of Legal Studies (Oxford: Oxford University Press, 2003) p 105.

104 For a sample of the commentary on this question see D Oliver ‘Functions of a public nature under the Human Rights Act’ [2004] PL 329; Craig, PContracting out, the Human Rights Act and the scope of judicial review’ (2002) 118 LQR 551.

105 Eg Aston Cantlow v Wallbank [2003] UKHL 37, [2004] 1 AC 546.

106 Eg Appleby, above n 95.

107 For an account of how rights can generate ‘dynamic’ duties which may require different acts of governance depending on the situation and the type of right at issue see J Waldron ‘Rights in conflict’ (1989) Ethics 503.

108 The State represented by the Ministry of Justice and Public Security v NN (case no 2012/1900, decision of 25 April 2013).

109 Eg Bevacqua v Bulgaria App no 71127/01 (ECHR, 12 June 2008); Kalucza v Hungary App no 57693/10 (ECHR, 24 April 2012); Valiuliene v Lithuania App no 33234/07 (ECHR, 26 March 2013).

110 This argument is actually deployed in cases. It is sometimes raised explicitly in relation to liability and sometimes less explicitly in relation to causation. An example of it being raised explicitly is in Kalucza v Hungary, above n 109, where the state argued a domestic violence claim was inadmissible because the claimant had not pursued domestic remedies. It argued that although she had submitted criminal complaints, some were discontinued. The respondent attempted thereby to place the responsibility for the act of governance – prosecution – onto the claimant. An example of the point being raised less explicitly, in relation to causation, appears in Michael, see text to n 155 below.

111 Collins, above n 56, at 1.

112 N v Poole, above n 3, was less impressed with the act/omissions distinction and instead preferred the harming/benefiting distinction (see paras [28]–[29], [74], [76]). Although the discussion herein treats them as related, it does not treat them as collapsible into one another.

113 Hoffmann, LordHuman rights and the House of Lords’ (1999) 62 MLR 159 at 163, 166.

114 Robinson, above n 3, at [39] and Michael, above n 39, at [111]; both referring to Gorringe v Calderdale MBC [2004] 1 WLR 1057 at [31]–[32].

115 O'Rourke v Camden LBC [1998] AC 188 at 193. In Cowan v Chief Constable of Avon & Somerset Constabulary [2002] HLR 44 at [41], Keene LJ held police officers had no duty to prevent a (non-arrestable) offence. Compare Rice v Connolly [1996] 2 QB 414 at 419 that a police constable must ‘take all steps… necessary… for preventing crime’.

116 du Bois, above n 11, at 595. Similarly, Cane, above n 9, p 151.

117 Shue, HBasic Rights (Princeton: Princeton University Press, 1996) p 38.

118 Alexy, RA Theory of Constitutional Rights (Oxford: Oxford University Press, 2002) pp 295296.

119 Sarjantson, above n 80, at [18].

120 Michael, above n 39, at [114]. See also DSD, above n 2, at [108], Robinson, above n 3, at [83], and Stovin v Wise [1996] 3 WLR 389, but compare Arden, above n 37, at 149.

121 du Bois, above n 11, at 593.

122 R (Limbuela) v Secretary of State [2005] UKHL 66, [2006] 1 AC 396, at [92]. See also [53] and [77].

123 Robinson, above n 3, at [34]; N v Poole, above n 3, at [26], [64]–[65], [75].

124 See eg Nolan, above n 8, at 303.

125 Michael, above n 39, at [181].

126 Mowbray, above n 23, p 221.

127 van Dijk, P“Positive obligations” implied in the European Convention on Human Rights’ in Castermans-Holleman, M et al. (eds) The Role of the Nation-State in the 21st Century (London: Kluwer, 1998) p 22; Quane, above n 66, at 114.

128 Eg Z v UK, above n 68, at [73].

129 Besson, SThe bearers of human rights duties and responsibilities’ (2015) 32 Social Philosophy & Policy 244 at 253.

130 Note Art 1 is not incorporated into domestic law: HRA 1998, s 1(1)(a).

131 Shue, above n 117, p 166.

132 Eg Hatton v UK (2003) 37 EHRR 28 at [119]. For critique, see Xenos, above n 19, p 57; M Klatt ‘Positive obligations under the European Convention on Human Rights’ (2011) ZaöRV 691. But contrast Koch, above n 24.

133 For discussion of what constitutes ‘jurisdiction’ see Al-Skeini v UK [2011] ECHR 1093.

134 Glanville, LThe responsibility to protect beyond borders’ (2012) 12(1) HRLR 1 at 3.

135 The R2P, as formulated by the ICJ, closely resembles the PDP: Bosnian Genocide Case (Bosnia v Serbia) [2007] ICJ Reports 43 at [430].

136 Raz, JHuman rights without foundations’ in Besson, S and Tasioulas, J (eds) The Philosophy of International Law (Oxford: Oxford University Press, 2010) p 336. Simmons, Contrast BMobilising Human Rights (Oxford: Oxford University Press, 2010), who emphasises the role of domestic remedies in the ECHR accountability scheme. See also Nickel, JHow human rights generate duties to protect and provide’ (1993) 15 Human Rights Quarterly 77.

137 Robinson, above n 3, at [43].

138 Brown, CDo great powers have great responsibilities? Great powers and moral agency’ (2004) 18(1) Global Society 5 at 6. See further Goodin, REProtecting the Vulnerable (Chicago: University of Chicago Press, 1985) pp 117135; Pattison, JHumanitarian Intervention and the Responsibility to Protect (Oxford: Oxford University Press, 2010).

139 Greene, AConsent and political legitimacy’ in Sobel, D et al. (eds) Oxford Studies in Political Philosophy (Oxford: Oxford University Press, 2016) p 71 at p 85.

140 Williams, BIn the Beginning Was the Deed (Princeton: Princeton University Press, 2005) pp 46.

141 For the development of the concept see Farmer, PPathologies of Power (Berkeley: University of California Press, 2003).

142 Schinkel, WAspects of Violence: A Critical Theory (Basingstoke: Macmillan, 2010) p 200.

143 Ibid.

144 Ibid.

145 It does not annul individual agency, more on which below. See, relatedly, Nollkaemper, AConcurrence between individual responsibility and state responsibility in international law’ (2003) 52(3) ICLQ 615 at 618619.

146 Dekker, IReconsidering the legal relevance of structural violence’ in Denters, E and Schrijver, N (eds) Reflections on International Law from the Low Countries (London: Nijhoff, 1998).

147 Carranza, RPlunder and pain’ (2008) 2(3) International Journal of Transitional Justice 310.

148 Laplante, LAddressing the socio-economic roots of violence’ (2008) 2(3) International Journal of Transitional Justice 331; Schmid, ETaking Economic, Social and Cultural Rights Seriously in International Criminal Law (Cambridge: Cambridge University Press, 2015) p 29.

149 Ramsahai v Netherlands (2008) 46 EHRR 983 at [325].

150 Robinson, above n 3, at [80] (emphasis added).

151 Thomson, above n 78, at [60].

152 McIvor, CGetting defensive about police negligence: the Hill principle, the Human Rights Act 1998 and the House of Lords’ (2010) 69(1) CLJ 133 at 141.

153 Robinson, above n 3.

154 Reeves v Commissioner of Police of the Metropolis [2000] 1 AC 360 at 367–368. A similar point is made by former ECtHR judge Ugrekhelidze in ‘Causation: reflection in the mirror of the European Convention on Human Rights’ in Calflisch, L et al. (eds) Liber Amicorum Luzius Wildhaber (Kehl: Engel, 2007) p 476.

155 Michael, above n 39, at [138].

156 Ibid, at [181].

157 Ibid, at [197].

158 Weber, MEconomy and Society (Berkeley: University of California Press, 1978) pp 5455.

159 Van Colle, above n 39, at [138].

160 Nolan, above n 8, at 294.

161 For studies on the ECtHR's approach to causation in positive obligation cases, see Stoyanova, VCausation between state omission and harm within the framework of positive obligations’ (2018) 18 HRLR 309 and Lavrysen's response, above n 97. See also Xenos, above n 19, p 76; Conforti, BReflections on state responsibility for the breach of positive obligations’ (2003) 13 Italian Yearbook of International Law 3 at 3.

162 Kuwait Airways Corp v Iraqi Airways Co (Nos 4 and 5) [2002] 2 AC 883 at [70].

163 Smith v Ministry of Defence [2013] UKSC 41, [2014] AC 52 at [142].

164 Turpin, C and Tomkins, ABritish Government and the Constitution (Cambridge, Cambridge University Press, 7th edn, 2011) pp 1011.

165 For that see Re Officer L [2007] UKHL 36, [2007] 1 WLR 2135 at [20]; DSD, above n 2, at [109], [111], [131]–[134]; Lavrysen, above n 97, at 712; Mavronicola, above n 93, at 483; Waldron, above n 107, at 515; Stoyanova, above n 161 (on knowledge); Klatt, above n 132, amongst others.

I am very grateful to the anonymous reviewers of this journal for comments on the draft, and likewise to Miles Jackson and Leo Boonzaier. I had useful discussions about the ideas in here with Hayley Hooper and the participants of the SLS Annual Conference in 2016, and with the Oxford-Girona-Génova Conference in 2017.

Keywords

The positive duty of prevention in the common law and the Convention

  • Achas K Burin (a1)

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