Yemen's leading arms dealer, Fares Mana'a, has had his assets frozen by the UN Security Council and the US Treasury.
Mana'a served for some time as head of the committee mediating between the Yemeni government and the
Houthi
rebels, while allegedly simultaneously supplying the rebels with weapons. His brother was governor of Saada province, where the rebellion originated.
According to the US Treasury notice issued on Tuesday, Mana'a holds two Yemeni diplomatic passports and one ordinary Yemeni passport.
The international action against Mana'a is connected with his activities in Somalia rather than Yemen. The
Security Council statement says he has "has directly or indirectly supplied, sold or transferred to Somalia arms or related material in violation of the arms embargo". It adds:
"In 2004, Mana'a was involved in weapons contracts from Eastern Europe for weapons allegedly marketed to Somali fighters. Despite the Somalia UN arms embargo since 1992, Mana'a's interest in trafficking arms into Somalia can be traced back at least to 2003. Mana'a made an offer to buy thousands of arms in 2003 from Eastern Europe, and indicated that he planned to sell some of the arms in Somalia."
Al-Riyadh newspaper reports (in Arabic) on the case of a 65-year-old man
in Saudi Arabia who went for a health screening test in preparation for his marriage to an 11-year-old girl. The man was found to be infected with hepatitis B.
"The staff at the hospital were shocked not only by the shamelessness of the man but also of the eagerness of the girl’s parents to finish up the paperwork so they can go ahead with the wedding. So they are knowingly subjecting their daughter to not only a paedophile but also a disease ...
"Marriage licences are granted to hepatitis sufferers only after the healthy partner is aware and agrees but how can you expect adult consent and awareness from an 11-year-old?"
Child marriage is an increasingly controversial issue in Saudi Arabia and also in Yemen, where a 12-year-old bride
bled to death earlier this month as a result of violent sexual intercourse.
Saudi law requires pre-marital testing for sickle cell anaemia, thalassemia, hepatitis B and C, and HIV, though it appears to be ignored by some couples and marriage registrars.
In February, Health Affairs Department in Taif called for the criminalisation of marriages in which premarital medical checks are not carried out. An adviser at the royal court also called for registrars to be punished if they ignore premarital checkups.
An unnamed domestic worker died when she fell from the third floor of a residential building in Mecca. Her body was found in the street below on
Sunday, Arab News reports.
The woman, whose nationality has not been disclosed, had arrived in Saudi Arabia two months earlier.
A police spokesman said: “The maid was attempting to flee from the sponsor’s family. She sustained fatal head injuries causing her death.”
Kuwait deported four more Egyptians yesterday. Together with the 17
deported on
Saturday, this brings the total so far to 21. Around 20 others are thought to be
still under arrest in Kuwait.
Those arrested and expelled are believed to be supporters of the National Association for Change, a new Egyptian movement formed by Mohamed ElBaradei. ElBaradei – a Nobel peace prize winner and former head of the IAEA – has hinted that he may be a contender in Egypt's presidential election next year.
The movement has been establishing support groups among Egyptian communities abroad, and 379 people (out of a community of around half a million Egyptians in Kuwait) have signed up to the relevant Facebook page.
The Kuwaiti interior minister has told Human Rights Watch that those arrested and expelled broke Kuwait’s laws on public gatherings and committed slander by criticising President Hosni Mubarak. "They are visitors in Kuwait," he said. "When somebody breaks the law, he has to go back to his country ... We don’t allow demonstrations in this country."
A Kuwaiti law dating from 1979 prohibits non-citizens from taking part in processions, demonstrations, or public gatherings.
Regardless of the law (which in any case is an infringement of free speech), the authorities' behaviour has been extraordinarily heavy-handed considering the nature of the offence. Expatriate Egyptians are being deprived of their homes and livelihoods in Kuwait without a court hearing and for the most trivial of reasons.
The minister's reference to defaming Mubarak also suggests this is more about appeasing the Egyptian regime than any real concerns about public order.
Mohammad Farrag Mohammad al-Farghally, Tamar Farrag Mohammad al-Farghally, and Tariq Tharwat – Egyptian citizens detained on April 8 after they attended a small meeting of Baradei supporters at a local café – have not returned home or seen their families since late that night. Amira al-Farghally, Mohammad’s wife, told Human Rights Watch that four men in civilian clothing escorted her husband, in handcuffs, to their home around midnight on April 8. The officers stayed only a few minutes, seizing campaign t-shirts that pictured al-Baradei and the Egyptian flag with the slogan ‘Min agl it-taghyeer’ (For Change).
“When I asked them why they were arresting him, they said, ‘don’t worry yourself; we are just taking him to [the] investigations [department]; he will be back soon insha’allah,’" she said. “I am alone here in Kuwait, with just my 10-month-old son.
On the evening of April 9, a group of approximately 30 individuals met in front of the Sultan Center supermarket and restaurant in the Salmiya area to discuss a response to the first three arrests. The National Association for Change, a group formed by al-Baradei, posted the meeting and details on its website; participants had not met each other before. According to one attendee, state security officers suddenly converged upon those assembled, seizing between 15 and 20 of those present.
“They asked us why we were standing here. We said that we came here according to what we read on the internet, on Dr al-Baradei’s website,” the attendee told Human Rights Watch. He said that when those assembled told the security officers, “We are just sitting; we will go now,” they said, “It is forbidden to stand like this.” He said that then they started to take people away.
This video clip is causing a stir in Saudi Arabia. It shows Sheikh Muhammad al-Nujaimi, chairman of the interior ministry's religious advisers, laughing and joking with a woman. Not only that, but the woman – horror of horrors – isn't even wearing hijab and the neckline of her dress is alarmingly low.
As recently as last September, Nujaimi was insisting [in Arabic] that separation of the sexes in education was one of the "pillars" of the Saudi state and that female students must wear "proper" hijab and non-Muslims must observe "obligatory modesty".
Later, he supported a fatwa calling for opponents of gender segregation to be put to death if they refused to change their views.
Last month, though, Sheikh Nujaimi accepted an invitation to a conference in Kuwait marking
International Women's Day – which is where the video was recorded. A
series of photographs has also been published on the internet showing his encounters with women in Kuwait.
"After pictures and videos of his mingling made their way to the web, he first denied what the pictures and videos suggested, and said some of them were photoshopped, which is something the organisers of the event considered so insulting that they threatened to sue him.
"Today, al-Nujaimi finally admitted that he mingled, but he said he did it for
all the right
reasons: to prevent vice and help those misguided women find the righteous path."
The Nujaimi affair is the latest twist in a new – and growing – debate among Saudi religious figures on the issue of ikhtilat (gender mixing).
It was triggered by the opening last September of King Abdullah University of Science and Technology (KAUST) as the kingdom's first co-educational university. KAUST
is a pet project of KIng Abdullah and a senior cleric who dared to criticise its gender-mixing policies was
promptly
sacked. This has made other clerics wary of making similar remarks, and Nujaimi seems to be among those who have done a U-turn.
Last December, Sheikh Ahmed al-Ghamdi, head of the religious police in Mecca, gave an
astonishing interview in which he described the prohibition of gender mixing as "a recent adoption" – adding that mixing "was part of normal life" in early Muslim societies.
Ghamdi has stood by his views, despite opposition from reactionary elements, and even repeated them at the Taif Literary Club last week (as John Burgess
notes in the Crossroads Arabia blog). It is hard to believe that he would be saying these things without a green light from on high.
The authorities in Kuwait are continuing their crackdown against support for Mohamed ElBaradei among the emirate's large Egyptian community. Yesterday, 17 ElBaradei supporters were expelled.
A total of 34 Egyptians have been arrested in Kuwait, according to ElBaradei's National Association for Change – four on Thursday and 30 on Friday. Some of those arrested on Friday were attending a meeting which had been advertised on the internet.
The National Association for Change has begun establishing branches among Egyptian communities abroad. One in Britain, which held a meeting last week, is said to have
300
members.
So far, neither Egyptian nor Kuwaiti officials have had much to say about the arrests and deportations. The Egyptian foreign ministry said it was "aware" of the arrests (through the media) but it doesn't appear to have made any diplomatic representations on behalf of those involved.
While it's possible that Kuwait is simply trying to stop political activity among its expatriate workers, others suspect collusion between the Kuwaiti government and the Mubarak regime.
Yesterday, Human Rights Watch issued
a statement condemning the arrests and deportations. "Kuwait is enabling Egypt’s repression by harassing
ElBaradei supporters,” it said.
When foreign domestic workers fall out with their employers in Arab countries, it's not uncommon for the employers to falsely accuse them of crimes. It's not uncommon, either, for police to believe the employers rather than the foreign workers.
Writing about the problems of housemaids in Lebanon last month, I quoted the Ethiopian Suicides blog, which
said:
"When a maid runs away from her employer's house, the police station is unable to act because there's no law criminalising runaway maids. So the police station officer tells the Lebanese employer to say that she stole money."
Thankfully, though, there are some in the police who are prepared to give domestic workers a fair hearing. Last Friday, the Saudi newspaper, Arab News,
reported a case in Jeddah:
"Police want to find out why a Saudi man withdrew a complaint against a housemaid he earlier accused of stealing SR36,000 [$9,600] from his house in al-Shati district.
"The man withdrew the charges after the maid told police during questioning that he abused her and did not pay her wages for a long period.
"The maid also claimed that her employer ... used to threaten to hand her over to police whenever she asked for her salary."
There's now a further development, and it appears that the employer is
going to be
prosecuted.
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My attempt to compile a Middle East reading list with help from followers of this blog generated a fair amount of interest last month. The
list of 10 books was meant as a general introduction to the region but, as I recognised at the time, there are also a lot of worthwhile books dealing with specific Arab countries. So now I'm going to take a look at some of them, starting with Yemen which has recently been the focus of international attention.
Books about Yemen tend to be rather specialised, and
aimed at the small number of people who take a particular interest in the country. The British-Yemeni Society's journal is a useful source of information, having reviewed
virtually every book published about Yemen during the last few years.
For non-specialists, though, there's one very obvious choice:
Yemen: Dancing on the Heads of
Snakes, by Victoria Clark. Published earlier this year, it's a highly readable mixture of politics, history and travelogue, and it really does convey the "flavour" of Yemen. With its useful perspectives on current issues such as al-Qaeda, the Houthis and southern separatism, it ought to be required reading at Fox News and similar organisations (though I suspect it won't be).
One book that caught my attention a few years ago (though now appaarently out of print) is Timothy Morris's account of life as an aid worker in Yemen, appropriately titled
The Despairing
Developer.
Next time, I'll be looking at books about Lebanon
or Egypt, so readers are welcome to make
suggestions relating to those countries.
The authorities in Kuwait are cracking down on efforts to organise support for Mohamed ElBaradei among the emirate's large Egyptian community.
Three people were arrested
earlier this week just hours before they were due to launch the Independent Campaign for Support of ElBaradei in Kuwait.
Another report (in Arabic) says as many as 10 were arrested.
T-shirts supporting ElBaradei are also said to have been
confiscated in Kuwait.
A Kuwaiti official quoted by Alaan website cited security concerns and said: "We will not accept Kuwait being turned into an arena for external conflicts."
ElBaradei, a winner of the Nobel peace prize and former head of the International Atomic Energy Authority, is a possible contender for the Egyptian presidency in next year's election. His sceptical stance at the IAEA over Saddam Hussein's alleged weapons of mass destruction probably did nothing to win him friends among Kuwaitis.
About half a million Egyptians are thought to be living or working in Kuwait – which raises questions about their right to free expression.
Meanwhile, Egyptian writer Alaa
Al Aswany views the clampdown on pro-ElBaradei activity in Kuwait as a case of Arab regimes banding together to resist change – "brothers in repression, oppression and tyranny,"
as he puts it.
A 12-year-old girl bled to death in Yemen as a result of sexual intercourse, three days after her wedding to a man in his twenties, Gulf News
reports.
Elham Mahdi Shuee died at the hospital in Hajja. The Sisters Forum for Human Rights, an organisation which campaigns against child marriage, said medical checks had shown she suffered a ruptured womb.
Elham's marriage was an exchange between two families with no dowry involved. Her brother married a girl of the same age from her husband's family. After Elham's death, the other family came to reclaim their daughter.
The case is likely to fuel the debate in Yemen about child marriage. Last month, another 12-year-old girl was
granted a divorce from her 26-year-old husband.
A draft law has been presented to parliament which would set a minimum marriage age of 17 for females and 18 for males but is facing tough opposition from traditionalists and religious elements.
In "Million's Poet", the TV talent contest for Arab poets that has been gripping millions of viewers in the Middle East, Nasser al Ajami, a 30-year-old Kuwaiti, walked away last night with
the top prize of $1.36m.
Hissa Hilal, the controversial Saudi woman who recited her poems
covered from head to foot in black, came third out of the 48 original competitors, winning more than $800,000.
Despite coming third, Hilal stole the show earlier in the contest with
her poetic denunciations of the fatwas issued by some of Saudi Arabia's clerics, and she reportedly received death threats.
You might have thought that government ministers in Yemen had more pressing things to worry about, but yesterday's cabinet meeting
approved a new draft law concerning the
national flag:
"The law, which consists of 18 articles, defines the status and specifications of the national flag and its greeting, as well as the places and times of events to raise the national flag.
"In addition ... the law identifies the prohibitions of the national flag use and penalties for anybody [who] harms the flag in any way or violates its specifications in the manufacturing, printing, design, publication, raising, or using it as a trademark or to advertise for commercial purposes or other actions that may be meant to contempt the flag."
Presumably the aim is to criminalise separatists in the south who insist on "defacing"
the flag with a blue triangle and red
star and waving it at their demonstrations.
The suppression of protests by the 6 April
movement in Cairo yesterday has attracted a lot of media coverage, so I'll just note it here. For reports, see: AP,
BBC,
Al-Masry
al-Youm, The
Majlis, Bikya Masr and
Egyptian Chronicles (which has a collection of photos and video clips).
There were also protests in Alexandria and other cities.
Amnesty International issued
a statement condemning the "arrests, detentions and violence meted out against peaceful protesters",
and called on Egypt to honour its international human rights
commitments.
Apart from the attacks on demonstrators, there's another matter causing deep concern among the estimated 10 million Egyptians who regularly partake of hashish. It's in very short supply and prices have rocketed.
The government has even gone so far as to claim "the complete destruction of the hashish trade in Egypt".
Needless to say, conspiracy theories abound. Bikya Masr and the Saudi-owned
Asharq Alawsat have more details on the crisis.
According to reports circulating yesterday the leaders of al-Qaeda in the Arabian Peninsula (AQAP) have "temporarily" decamped from Yemen and re-established their military base across the sea in Somalia.
If true, this is a major development. The Yemen
Post, Sahwa.net, the
Saudi Gazette and
UPI give the basic outline of the story, which is attributed to unidentified Yemeni sources.
Fifteen to 20 members of AQAP, including prominent leaders, are said to have left Yemen for Somalia during the first two weeks of March via Mukalla (the port in Hadramawt province) with assistance from "foreign elements".
"Sleeper" cells are said to remain in Yemen but they have been told to freeze all activities, cut off communications and suspend all meetings until the government's offensive against them dies down.
Though the story could be pure disinformation, it does sound
plausible in the light of the US-instigated crackdown on al-Qaeda in
Yemen following the "underpants
bomber" affair.
In January last year, the Saudi and Yemeni arms of al-Qaeda
merged into AQAP and made Yemen their operational base. This was mainly a result of the Saudi authorities' campaign against them which resulted in heavy losses and made operations in the kingdom difficult.
Avoiding a similar fate in Yemen by taking refuge in the failed state of Somalia would thus be a logical step. Al-Qaeda plays a long game, so lying low for a few months in the interests of self-preservation, until the world turns its attention away from Yemen, would be no big deal.
However, it would be a mistake to imagine that al-Qaeda is abandoning
Yemen permanently. It is, after all, Bin Laden's ancestral homeland and there are plenty of other reasons (explained in Victoria Clark's recent book,
Yemen: Dancing on the Heads of
Snakes) why al-Qaeda finds the country especially attractive.
Here's an interesting example of the Mubarak propaganda machine at
work. Egyptian Chronicles notes that Mohamed ElBaradei, a possible contender in next year's presidential election, has finally made it on to the front page of the semi-official al-Ahram newspaper.
The message is subtly delivered, but from all the photos of ElBaradei that might have
been used, they just happened to choose one that shows him with Margaret Scobey, the US ambassador in Cairo. This, of course, helps to reinforce the regime's line that he's an American puppet (which
he's
not).
Contrast ElBaradei's treatment with the way al-Masa'i newspaper
hailed Mubarak's return from his recent operation in Germany.
I have received an email giving more information about the Saudi writer who is facing prosecution – and possible execution – for describing a Hadith of the Prophet as "barbaric". I reported the case
here last month, but only the scantiest details were available at the time.
The writer concerned is Yahia al-Ameer, a columnist for al-Watan newspaper, and he has been ordered to appear at a court in Jeddah on 7 June to answer a charge of apostasy.
Amazingly, the "crime" was committed five years ago – in an interview with the American-run al-Hurra TV station when Ameer allegedly criticised a statement attributed to the Prophet
Muhammad which is often regarded as misogynistic:
"After me, I have not left any affliction more harmful to men than women" (Sahih Bukhari 07:062:033).
The case appears to have been instigated by religious elements rather than directly by the Saudi authorities. However, a government-appointed cleric, Sheikh Abdulaziz Bin Abdullatif, has reportedly said that Ameer should be killed, even if he repents.
In 2006, Rebah Algwaie, a journalist and blogger, was sentenced to death for apostasy but later released on the orders of the king.
AFP is reporting that the Egyptian publisher who was arrested on Saturday – a few days after issuing a book supporting Mohamed ElBaradei, a possible candidate in next year's presidential election – has now
been
released.
The publisher, Ahmed Mahanna, was abducted during a dawn raid on his home. No official reason was given but copies of the offending book, "ElBaradei and the Dream of the Green Revolution" were also seized.
Last month, a physiotherapist who had voiced support for ElBaradei was summoned to the State Security headquarters in Fayoum and hospitalised after reportedly being
tortured.
ElBaradei himself appears to have been cold-shouldered during an Easter visit to a Coptic church at the weekend – possibly because the church did not want to risk offending the Mubarak regime.
Al-Masry al-Youm and
Egyptian Chronicles discuss what happened.
An unusual book-signing took place in Beirut at the end of last month.
"Memoirs of Randa the Trans" ( مذكرات رندا الترنس) is the
life story of an Algerian raised as a boy, who felt trapped in a male body.
Mocked and abused at school, and later threatened with death by religious extremists, Randa fled to Lebanon. She felt safer there, but finding work proved
difficult:
"When she applied for a nursing job at a hospital in Beirut, the employer hailed her resume and experience but told Randa it was against the hospital's policy to hire transsexuals.
"The only jobs she was offered sounded pretty sleazy: exotic dancer or entertainer at nightclubs. Once, someone suggested she should try prostitution – a common solution for transsexuals who are outcasts in this region, according to Randa."
Her biography, co-written with Lebanese journalist Hazem Saghyieh, is thought to be the first of its kind in Arabic.
Rather belatedly, the emo phenomenon has
reached Saudi Arabia's eastern province and come to the attention of the Committee for the Promotion of Virtue and Prevention of Vice (aka the religious police).
The authorities seem rather bemused by it – though obviously it's
the work of the devil.
Al-Watan newspaper reports (in Arabic) that a gathering of emos in Dammam a couple of weeks ago was "foiled" by the religious police. A male Asian was arrested and interrogated about this "suspicious" group.
Al-Watan helpfully explains that "emo" is abbreviated from the English word "emotion" and that emo culture is characterised by "the adoption of the colours black and pink in their organisation, lining their eyes and dyeing their hair black, while wearing tight jeans and shirts and distributing accessories on parts of their bodies".
A number of comments from disgusted readers are posted beneath the article. One describes emos as retarded and says "They are mostly queers of both sexes. This is well known."
There was a similar episode of moral panic about emos in Egypt last year, with Dream TV and
IslamOnline (among others) warning of the dangers they posed.
As Jack Shenker commented at the time, "Men with long beards and explosive belts are one thing, but teenagers who listen to My Chemical Romance and Fall Out Boy in their bedrooms while squeezing into skinny jeans are quite another."
Meanwhile, The National reports on the trials and tribulations of heavy metal
bands in Jordan.
The new Almazar shopping centre is opening
in Marrakesh today, covering 33,000 square metres on five levels, with parking for 1,200 cars, a 800-seat food court and familiar names like Carrefour and Virgin Megastore.
It's progress, I suppose, and I've nothing against
Moroccans having decent shopping facilities. But I always thought that what attracts tourists to Marrakesh is its distinctive character, its ramshackle souqs and ancient monuments, not to mention the illicit supplies of hashish. Does the Red City really need an air-conditioned "super-mall" to pull in the crowds?
Saudi Arabia's Shura Council has won some sort of award from the Arab League for having the best "parliamentary" website among the league's member countries.
The kingdom is to be "feted" at a presentation ceremony
shortly.
"The Shoura Council is currently implementing an e-governance project in line with a decision of the council of ministers to introduce e-governance in the kingdom.
"The project aims to create a standardised electronic environment inside the council that will enable its members to work in a unified environment in addition to simplify interaction between the council and the public."
All very fine – except that the Shura Council isn't an elected parliament at all. Its 150 members are all
appointed by the
king.
King Abdullah of Saudi Arabia has called on his subjects to
pray for rain on
Monday:
"All people should increase their repentance, seeking forgiveness and helping others, as well as increasing pious deeds such as giving to charities, performing prayers, remembrance of Allah and relieving the hardships of others so that Allah may relieve our hardships," a royal court spokesman told the Saudi Press Agency.
Having consulted the BBC's five-day weather forecast for the kingdom, I am confident that these prayers will indeed
be answered.
Jack Shenker's interview with Mohamed ElBaradei, possible contender for the Egyptian presidency, published
by the Guardian in three parts (here,
here and
here)
yesterday, contained a lot of interesting material.
Shenker has also posted a full transcript
of the interview on his blog.
There was a good deal of excitement in Yemen yesterday when a grenade went off at a police station in the southern city of Dali (Dhale'a) and – depending on whose accounts you choose to believe – up to 40 recently-arrested separatists
did or
didn't
escape.
Gregory Johnsen, writing for the Waq al-Waq blog, is cynical about the whole incident: "This, I believe, is big news simply because something exploded and newspapers and their reporters are enamoured of big bangs."
He points to two other, less-noticed events, which he suggests are more significant.
One refers to a group of southern soldiers returning from the Saada war who
seized a couple of trucks in protest at the ill-treatment of their comrades and the non-payment of wages.
The other is about the theft of 80 million riyals ($355,000) by gunmen who intercepted a car carrying the wages of education and health officials in Lawdar. It is suggested "that the robbers are militants and that the money will ultimately find its way to al-Qaeda".
The execution of Ali Sabat, the Lebanese TV fortune-teller who was
arrested in Saudi Arabia on charges of witchcraft is reported to be
imminent.
Mr Sabat, 46, hosted a phone-in show on the Lebanese Sheherazade channel where he gave advice and predicted the future. The Saudi religious police arrested him in Medina two years ago, while he was visiting on a pilgrimage.
Sorcery/witchcraft is a capital offence in the kingdom.
UPDATE, 2 April 2010: The BBC says
he has been given a "temporary" stay of execution. This is
an encouraging sign and it suggests the Saudi authorities may be
responding to international pressure.
Jordan: Four prominent Jordanians appeared before the state security court on Wednesday at the start of what promises to be the kingdom's biggest-ever corruption trial.
Reporters were banned from the courtroom during the two-hour hearing, which was then adjourned until April 5.
The case, which I explained here in some detail last month, involves contracts for the expansion of Jordan's only oil refinery.
According to The National,
at this week's court session lawyers for the four accused contested the charges and challenged the use of the state security court for the trial as well as the men's continued detention in custody.
A report in the Jordan Times summarises the prosecution's case, as set out on the charge sheet.
Saudi Arabia: The Saudis have also been stepping up
their anti-corruption efforts. The latest half-yearly report from the Control and Investigation Board
says that a total of 1,259 crimes involving both Saudis and foreigners were committed in various government departments, including 794 cases of bribery, during the second half of the last Hijrah year.
Algeria: Meanwhile, Britain is continuing to hesitate over the extradition of businessman Abdelmoumen Rafik Khalifa to Algeria.
A decision by the British Home Secretary had been expected on March 31
but has now been postponed until April 30.
Khalifa fled to London in 2003 in the midst of Algeria's biggest-ever financial scandal. In 2007, he was convicted in his absence by an Algerian court on charges of criminal conspiracy, robbery, embezzlement and forgery.
According to the Magharebia website, "he is also wanted in France on embezzlement charges and for alleged involvement in the collapse of Khalifa Airways, Antinéa Airlines and Khalifa Rent-a-Car. Algeria's extradition request, however, takes precedence over that of France."
