Home Editor's Picks Complaint to the United Nations Regarding the Disastrous Impacts of Water Crisis in Northeast Syria

Complaint to the United Nations Regarding the Disastrous Impacts of Water Crisis in Northeast Syria

Synergy Association for Victims and Malva for Culture, Art and Learning call to take the necessary measures to find an urgent and sustainable solution to the water crisis in northeast Syria, as it has catastrophic impacts on local communities, the ecosystem, biodiversity, and cultural identity

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Complaint to the attention of mandate holders:

  1. Special Rapporteur on the rights to water and sanitation;
  2. Special Rapporteur on the human rights of internally displaced persons;
  3. Special Rapporteur on human rights and the environment;
  4. Special Rapporteur on the right to health;
  5. Special Rapporteur on the right to food;
  6. Special Rapporteur in the field of cultural rights.

Summary:

We are writing to you in your capacities as relevant mandate holders to draw your attention to the exacerbating and chronic water crisis in northeast Syria and its disastrous impacts on the lives of more than four million people, including about one million Internally Displaced Persons (IDPs), and on local communities, the ecosystem, biodiversity, and cultural identity due to weaponizing water by the Turkish government and other parties to the conflict.

 Synergy Association for Victims and Malva for Culture, Art and Learning, the joint organizations submitting this complaint, reached that the exacerbating water crisis in northeast Syria is one of the main causes for food insecurity, undermining livelihood, and immigration seeking resources. Let alone that water scarcity and its poor quality, poor sanitation and inadequate hygiene, notably in IDPs makeshift camps, cause serious water-borne diseases.

The main challenge lies in the fact that Syria’s water resources are greatly entangled in the ongoing conflict in the country. Water resources are not run by single unified management but are rather managed according to the policies of the party in control. Meanwhile, parties such as the Syrian and Turkish governments and the groups affiliated with them are accused of committing water-related human rights violations.

The notification is based on extensive research on the historical and legal context of the crisis and on 20 direct testimonies/interviews collected during July and August 2023. The interviewees included water crisis-directly affected victims, residents or IDPs, and craftsmen. In addition to analyzing outcomes of an opinion poll which targeted 201 persons from different social components with a view to a broader understanding the seriousness of water crisis in northeast Syria and explore its multi-faceted impacts on local communities.

The signatories call on the UN to take the necessary procedures to find an urgent and sustainable solution for the water crisis in northeast Syria, taking into consideration the facts included in the complaint and the attached joint recommendations.

 

Disastrous Impacts of Water Crisis:

The ongoing Syrian conflict for more than twelve years has affected all joints of life in the country. Parties to the conflict have varied and Syria’s geography has been divided into different areas of influence/control between them. Regional and international parties got involved in the Syrian conflict to further complicate the situation, destroy the infrastructure and deteriorate social services leaving massive humanitarian needs.

Denying civilians to access safe and sufficient water, and weaponizing it by the Turkish government as well as other parties to the conflict, exacerbates the existing humanitarian crisis and leaves disastrous impacts on local communities and on the ecosystem, biodiversity, and cultural identity in northeast Syria.

For several years, the Turkish authorities have been decreasing Syria’s portion of water from the Euphrates River, an essential source for drinking water for more than five million people in Syria, according to the UN estimates. The agreement pertaining to organizing the Euphrates River water flow between Syria and Turkey says the Turkish side undertakes to release 500 M³/Sec to go through Syria. However, since 2019, the most dwindling levels of water flow, amounted to 200 M /Sec, have been recorded many times and at intermittent periods, causing damages to the ecosystem and biodiversity in northeast Syria.

Turkey’s breaches and deliberate reduction of Syria and Iraq’s share of the Euphrates River water are not recent developments, but rather a practice which Turkey has followed for decades, especially during years of drought. These actions have escalated following Turkey’s incursion into Syria in 2016 and its occupation of vast areas northern the country.

Airborne imagery exclusive to “Synergy” and “Malva” taken on August 23, 2023, showing the low level and water pollution of the Euphrates River near the historic Qal’at Ja’bar [Ja’bar Castle] in Tabqa City in Raqqa countryside.

Since the Euphrates River has been historically considered sources for agriculture creating a greenbelt along the river, hence, restricting water of the Euphrates River behind Turkish dams has seriously curtailed the water level, reduced irrigation-dependent crop production on the Euphrates, and substantially affected the yields.

Ahmed al-Khalid, a farmer from Raqqa, said water scarcity damaged his crops.  Once, agriculture production was his sufficient main source of income, but now he works in other freelance jobs, which are hardly enough for his daily living.

Water scarcity led to disputes among the locals, particularly farmers, in a region always characterized by civil peace and coexistence, al-Khalid confirmed. The priority to draw water and irrigate farmlands were the causes of disputes, which he himself witnessed many, and in some incidents there was shooting in the air.

Since the Turkish occupation of Ras al-Ayn/Serê Kaniyê region in October 2019 as a result of a military operation dubbed “Peace Spring” by Ankara, the communities of northeast Syria, deliberately and discriminatorily, have been denied their right to access sufficient and safe water by the Turkish government and by Turkish-backed factions of the opposition Syrian National Army (SNA) due to repeated interruptions in pumping drinking water from Allouk Water Station in Ras al-Ayn countryside.

Allouk Water Station, which experienced numerous disruptions, is the only source for drinking water for approximately 800,000 people in northeast Syria, particularly the residents of al-Hasakah City, Tall Tamr Town and the adjacent countryside, in addition to being the main source for water trucking for al-Hol, al-Areesha/al-Sed and al-Twinah/Washokani, and Serê Kaniyê camps (which include tens of thousands of IDPs from different provinces and parts of Syria, as well as thousands of Iraqis and foreigners who used to live in areas formerly held by the Islamic State, known as ISIS), according to the International Committee of the Red Cross (ICRC).

Repercussions of water crisis exacerbate in summer and appears distinctively amongst the vulnerable categories, especially children and people with special needs, like in the case of Mohammed Rahim, who is unable to stand up. He feels the consequences of water crisis more watching efforts of all members of his family to secure water, fill in tanks and call on water tanks to come. Rahim says people like him can only watch the news about water which is an important part of the crisis that has cast its shed on all joints of life.

Rahim said he heard that some children escaped from their homes located in the security square (where the Syrian Government Forces are in control in al-Hasakah) because private water cisterns do not enter that area making it more difficult to secure water. Therefore, the children fled because their parents do not respond to their demands to move to other places of residence as they are forced to carry jerry cans filled with water to distant areas beyond their capacity.

Image exclusive to “Synergy” and “Malva” showing a woman and two little girls filling buckets and jerry cans with water from an NGOs-supported makeshift tank to take them to their houses in a neighborhood in al-Hasakah on July 4, 2023 due to the worsening and ongoing water crisis in northeast Syria.

Dilawar Mohammed Ali, Director of the Health Office in Serê Kaniyê Camp, pointed out that the camp that accommodates 15,540 individuals, among them 8,000 children, suffer from water crisis. One NGO provides water through cisterns that are periodically checked to make sure their water is consumable and potable. However, each individual has a portion of only 50 L of water daily for all uses which is simply not sufficient. He said:

 “Boreholes from which cisterns are filled are considered to be hotspot for water-borne diseases. First, offices of the Autonomous Administration check these boreholes and authorizes them. However, over time, and due to their deficiency, the contamination rate in some of them increases to the point where the water becomes unfit for consumption. This leads to many diseases, the most common of which are enteritis, diarrhea, dehydration, renal insufficiency, skin lesions, and gum infections.”

The consequences of the water crisis are particularly evident among children. The teacher Mohammed Hajo, an education official in Serê Kaniyê Camp, said that 3,230 students attend school for the three educational stages; 60 cases of scabies amongst the children were recorded this year, in addition to cases of the spread of lice particularly amongst the students in the primary stages. These are all results of poor hygiene, which in turn is linked to water shortage.

In 2021, Turkish-backed factions of the SNA built three earth dams on the Khabur River interrupting water flow to the Syrian Democratic Forces (SDF)-held areas and causing critical damages to agriculture and food security. This interruption coincided with a period when the region was witnessing severe drought and hikes in fuel prices, preventing many farmers from operating their water pumps and rendering them unable to irrigate their farmlands. Consequently, vast areas of farmlands were left fallow (uncultivated).

As different water resources represented in rivers, most importantly the Euphrates River, and groundwater supplied by seasonal precipitation cover needs of approximately 4,800,000 beneficiaries in northeast Syria, among them more than one million IDPs, the crisis directly affects no less than the half and threatens civil peace as well. Scarcity in water resources creates disputes among the civilians on water resources and priority to access them.

An opinion poll conducted by Synergy Association for Victims and Malva for Culture, Art and Learning, which targeted 201 local persons and IDPs, reflects the existing humanitarian crisis due to the water crisis in northeast Syria. The poll’s results were: 49% considered changing their original place of residence and move to areas less affected by water crisis, while 11% have already changed their place of residence, and 72% illustrated that water crisis this year have significantly worsened compared to last year.

One of the lesser-explored aspects of water crisis is its threat on the cultural identity of the regions in northeastern Syria, where water has long been a fundamental component of their heritage. Archeological sites and mythologies as well as the written and oral heritage, all attest to the fact that water has been the backbone of life since ancient times and the main reason for establishing different civilizations alongside rivers, particularly the Euphrates and the Khabur rivers. Songs, poems, stories and epics have been composed, such as Moolaya songs [traditional kind of songs] and others that glorify or lament the Euphrates and the Khabur rivers and addressing them as great rivers.  Some argue that if Egypt is “The Gift of the Nile”, so the Mesopotamia is “The Gift of the Khabur and the Euphrates”, let alone folk tales and poems.

The exacerbated water crisis recalls years of drought and hunger which historically led to massive human movements and also threatens many water resources-relevant crafts, such as fishing, pottery, cane, bamboo among others which entirely, greatly or partially depend on water.

Water resources crisis impacts simple manufacturing industries that express the societal culture, particularly home catering and household economy.

Rojin Ahmed, an engineer who has worked for years in rural women’s units of agriculture offices, said scarcity of water resources has had an impact on women’s jobs. Water-related manufacturing and creative industries retreated.

Examples of these industries are: converting tomatoes into tomato paste, drying vegetables, supplies and preserves. They were damaged significantly as productivity declined directly affecting the economy, contributing to soaring prices and resorting to imported products with high prices, hence affecting the population’s livelihood.

Water resources-dependent local production quantities, directly or indirectly, affect the revitalizing factories, workshops and plants, and even affect the livestock-based industries which were also severely impacted by water crisis, such as textile and cheese plants and leather tanning. Consequently, all these industries retreated in the region.

The worsening water crisis in northeast Syria has exacerbated the already existing disastrous humanitarian crisis. Water shortage, its poor quality, poor sanitation and inadequate hygiene, notably in IDPs camps, have caused serious water-borne diseases, such as cholera, acute Diarrhea as well as skin diseases like Scabies and contributed to the outbreak of Covid-19 in its peak.

 

Background:

The northeast Syria residents rely on three water sources, whether for drinking, domestic, agricultural, industry or other purposes. In addition to rains and groundwater, rivers have long been regarded as the region’s lifeline. These water sources serve local and IDP communities, covering the needs of an estimated 4,800,000 beneficiaries[1], including more than one million IDPs.

In 2023, precipitation levels in al-Hasakah Governorate have seen 60% less than over the past documented three years[2] to correspond with the drought alarm issued by the Global Drought Observatory (GDO) with respect to eastern Syria in April 2021. At that time, al-Hasakah Governorate recorded a clearly sharp precipitation decline compared to the long-term monthly average (80 mm), calculated between 1981 and 2010.[3]

These levels alarm increase in drought waves and severity bringing more challenges to the residents and to the agrarian sector, especially that rains are responsible for supplying groundwater and main/seasonal rivers. A decade of hostilities has produced many activities that help deepen climate change. The increase in the emission of greenhouse gases caused local warming and the entrapment of rain in the clouds.[4]

The residents turned to digging artisan wells to fill the demand gap generated by low river levels and the cutting off of water from the Allouk Water Station in the Ras al-Ayn/Serê Kaniyê. In late 2022, local authorities in the region prohibited residents from digging wells to save groundwater without providing a viable alternative other than tank water, which beneficiaries claim is distributed unfairly.[5]

These natural drivers and the resulting water shortages negatively affect the lives of the region’s residents. The absence or lack of water services has turned the region into a hotspot for epidemics due to the dearth of required support and the willingness of some parties to the conflict to weaponize water at the most critical times, such as during the COVID-19 pandemic.

 

Legal Liability:

Under International Humanitarian Law (IHL), included in the Geneva Conventions Additional Protocol I (Protection of Victims of International Armed Conflicts), attacks on ‘objects indispensable to the survival of the civilian population’, (including water infrastructure), is prohibited.

Turkey’s limited flow of the Euphrates River will have serious consequences for the population downstream [northeast Syria]. Taking into account both climatic conditions and further limitations of water coming in from the shutdown of Allouk Water Station, let alone the blockade of the Khabur River’s water flow. These water resources are indispensable for the survival of the civilian population.

Thousands of households are struggling with water access caused by the violation of Turkey and Turkish-backed SNA to have their right access potable water, household, agricultural and industry use. Thus, the blockade is an extreme measure that resulted in denying the civilian population of their sustenance.[6]

Multi-layered violations and their effects on the rights and cultural identity of residents of northeast Syria will have dire, long-term consequences and post-conflict sustainable impacts due to not considering their rights enough.

It is worth mentioning that Turkey is an occupying power in northern Syria and collaborates with the SNA and this would invoke Turkey’s obligation to ensure respect for human rights and IHL, including respect the rights of the all Syrians to access potable and usable water. Thus, Turkey must exert its influence, to the degree possible, to stop such violations by the SNA and any armed group with which it collaborates.

Moreover, this case also raises issues related to the violation of fundamental human rights, such as the right to water, the right to food and the right to life. The blockade of the Khabur River, limited flow of the Euphrates River and the repeated interruption of Allouk Water Station all have extensive and negative impacts on the human rights of the civilian population of northeast Syria.

  • Turkey’s Responsibility as an Occupying Power:

IHL states that when a state exercises effective control over part of another state’s territory, it is subject to the laws of occupation, including the obligation to secure the basic needs of the population, among them water. Whether a State is practicing such control is a matter of fact and is not determined by the opinions of the parties involved.[7]

According to the international law governing occupation, an occupying power may not arbitrarily use the natural resources of the occupied territories for its own ends, but may use them to the extent necessary for the current administration of the occupied territories and to meet the basic needs of the population.[8] Under no circumstances shall the occupying Power be entitled to exploit the population, resources, or other assets in the areas under its control for the benefit of its territory or population.[9]

Accordingly, in addition to the above-mentioned International Water Law, Turkey’s exploitation of the occupation and effective control over Syria’s territory, including its water resources and certain vital water facilities, to serve the goals and objectives of its territories and water resources on the one hand or other political ends, including bargaining with other parties to the armed conflict such as the Syrian Government or the Autonomous Administration on the other hand, is a clear violation of this principle.

  • Weaponizing Water During the Conflict:

All parties involved in armed conflict must mitigate the negative impact on the right of civilians to water, even if water infrastructure is not a target of deliberate attack.[10] In addition to the negative obligations on the parties to the conflict, such as not to target water as a civilian object indispensable to the survival of the population, international law prohibits the use of water and its infrastructure as a weapon, including the diversion or blocking of access to water for purposes of coercion or political pressure.

Some practices, such as intentional cutting of water supplies, are considered to be a form of diversion prohibited under international law, especially when linked to specific contexts, such as the fact that the population is entirely dependent on the source of water that has been diverted or blocked, as is the case with, for example, the practice to which the Allouk Water Station has been subjected to.

These provisions apply to all parties to the conflict, including non-state armed groups, the occupying power and government actors. The duty to respond and secure the needs of the civilian population also imposes positive obligations on the parties to the conflict to undertake actions and measures that would ensure a more effective management of water resources and infrastructure.

  • Enforcement of International Human Rights Law Continues:

In international law and practice, it is well established that the provisions of International Human Rights Law (IHRL) remain in force during armed conflict, and, in some situations, may have priority, particularly when other articles of IHL fail to provide comprehensive protection.

In the Syrian context, the Syrian State remains primarily responsible for safeguarding the population’s access to water and must take all possible measures and procedures to ensure that they enjoy that right, which is enshrined in numerous IHRL instruments. Turkey, as an occupying Power, also bears the same responsibility in the areas under its control. It is also recognized that the provisions of IHRL apply to non-state armed groups exercising de facto authority or effective control over territories and population.[11]

In addition to the duty of states to respect the right to water, appropriate measures must be taken to ensure that this right is protected from interference by other parties and is fulfilled. The practices or negligence in Syria’s water situation may amount to a clear violation of the three types of obligations: respect, protection and fulfilment.[12]

  • Relevant Basic Principles and Rules in International Water Law:

The 1997 Convention on the Law of Non-Navigational Uses of International Watercourses is the only international treaty that establishes the principles and rules of cooperation between states on the management, use, distribution, and protection of international watercourses. Unfortunately, Turkey did not accede to this agreement—which entered into force in 2014—and instead raised several objections and voted against it in the UN General Assembly.

Nonetheless, there are various other international legal instruments, including those regarded as a reflection of customary international law, that govern international relations involving international water-courses. Furthermore, the state of armed conflict in Syria since 2012 and Turkey’s involvement in it, necessitate the implementation of the relevant provisions of IHL, in addition to the provisions of IHRL.

The principle of equitable and reasonable utilization is one of the most important international norms regarding the management of international watercourses. Even though the principle of state sovereignty gives states the right to use shared freshwater within their territories, they are required to do so in an equitable and reasonable manner towards other states.[13]

Accordingly, no riparian state can exploit a fait accompli to acquire the right to international watercourses. Involved states must instead continue to enforce the principle of equitable and reasonable utilization through constant review and evaluation because changing conditions require adjustments in use.[14]  The armed conflict in Syria, and the various dynamics of control in the country, as well as the challenges brought about by climate change, may be some of the clearest examples that compel Turkey to conduct such assessments and evaluations.

The principle of no-harm is one of the provisions of customary international law that applies to IWL, in addition to being applicable to all aspects of international law and international relations.[15] This principle can be interpreted as states can utilize what they own without causing harm to what other states own. This principle is closely linked to the principles of good neighborhood[16] and prohibition of abuse of rights.[17] On the basis of this principle, states have an obligation of conduct rather than an obligation of result, which means they must take all reasonable measures not to cause significant harm. To do so, states must take into account the facts and circumstances in each case in accordance with the principle of due diligence. This principle applies to both upstream and other riparian states.

Moreover, riparian states must follow a set of procedures that, on the one hand, ensure the implementation of their other duties and lead to evasion of conflicts between states on the other. The most essential of these obligations are the duty to notify, the duty to exchange information and data, the duty to consult with potentially affected states, the duty to conduct an environmental impact assessment, and the duty to cooperate.[18]

The environmental consequences of the measures taken by riparian states should not be limited to assessing the environmental impact on the other states involved but should go beyond that to take into account environmental considerations in general. The Syrian case, such considerations include the impact on groundwater, soil pollution, and desertification, among others.

Eventually, it should not be assumed that the texts regulating IWL do not literally address individual rights as a justification for the negligence of these rights. The rationale behind the principle of equitable and reasonable utilization in itself and the provisions of IWL, which regulate the management and distribution of water between states, is that both this principle and the provisions aim to meet vital human needs and therefore should be prioritized over any other uses.[19]

 

Recommendations:

  1. Establish an impartial and independent monitoring mechanism for the Euphrates River and all transboundary water resources shared by Syria, Turkey, and Iraq. Its mission should be to oversee compliance with signed agreements and the provisions of international law, as well as to facilitate dialogue between key stakeholders to reach a sustainable settlement that ensures equitable and reasonable water usage.
  2. Call on the Turkish government and other parties to the conflict to abide by their duties towards human rights and respect the right of all Syrians to access drinking and usable water, as well as neutralize water resources from political rivalries.
  3. Reinforce monitoring and oversight of violations of the right to water and seek justice for victims: international organizations and donors must support efforts of documenting and archiving water rights-related violations, meaning efforts conducted by victims’ groups and civil society organizations. Also, the Human Rights Council and the Independent International Commission of Inquiry on the Syrian Arab Republic must systematically include the issue of interruption of rivers water-related violations in their reports and raise this issue with the relevant authorities.
  4. Develop a strategy for the region on transboundary water challenges: The UN must take the necessary measures to ensure the right of the civilians in northeast Syria to access safe and sufficient water, and address the conflict challenges influencing surface water, groundwater, soils and vegetation cover.
  5. Ensure inclusive participation in water resources management, access to information and transparency measures: platforms must be established to involve key stakeholders, including local communities and civil society bodies, in consultations or policies about water resources and transboundary water, while increasing the platforms’ transparency in reporting on water resources management issues.
  6. Prioritize the conservation and prevention of depletion of existing water resources, in addition to the rehabilitation of their infrastructure, and initiate the clean-up and treatment of all contaminated water resources and rivers.
  7. Pressure all parties, including the Syrian Government and the Autonomous Administration, to assume their responsibilities in providing the interventions necessary in northeast Syria to avoid the resurgence of epidemics, such as cholera, including the increase of the number of water stations.
  8. support efforts of preserving the collective memory and cultural identity of people of northeast Syria, particularly in the region between the Euphrates and the Tigris rivers, and plan for interventions and projects aiming to protect crafts, livelihood and industries at risk of extinction due to water resources crisis as a part of seeking a sustainable and comprehensive peace in Syria.

 

———–

[1]Population Estimation of AANES”, HDC.

[2]Current Situation of the Water Crisis in Northeast Syria and its Humanitarian Impacts”, REACH, 26 June 2023

[3]Drought in Syria and Iraq – April 2021”, GDO, 22 April 2021.

[4] Climate Change its Causes & Consequences”, HDC.

[5]The AANES Bans Digging Artisan Wells”, North Press, 22 October 2022 (Last visited: 7 July 2023).

[6] For more, read the report: Killing the Khabur: How Turkish-backed armed groups blocked northeast Syria’s water lifeline. Pax Organization. Publish date: November 3, 2021, (last accessed: June 12, 2023).

[7] For an overview of state practice and judicial decisions confirming that occupation is a question of fact, see: Tristan Ferraro ‘Determining the Beginning and End of Occupation under International Humanitarian Law’, International Review of the Red Cross, pp 132-138.

[8] See, for example: James Crawford, ‘Opinion: Third Party Obligations with respect to Israeli Settlements in the Occupied Palestinian Territories’ (24 January 2012 ) (Available at: https://www.tuc.org.uk/sites/default/files/tucfiles/LegalOpinionIsraeliSettlements.pdf).

[9] Antonio Cassese, ‘Powers and Duties of an Occupant in Relation to Land and Natural Resources’ in E Playfair, (ed.) International Law and the Administration of Occupied Territories – Two Decades of Israeli Occupation of the West Bank and Gaza Strip (Clarendon Press: Oxford, 1992), 420-1.

[10] See in general: Diakonia International Humanitarian Law Centre, ‘Protection of Water in Non-International Armed Conflicts’ (May 2023) (Available at: https://www.diakonia.se/ihl/news/protection-of-water-in-non-international-armed-conflicts/).

[11] UNOHCHR, Joint Statement by independent United Nations human rights experts on human rights responsibilities of armed non-State actors (25 February 2021), (Available at: https://www.ohchr.org/en/press-releases/2021/02/joint-statement-independent-united-nations-human-rights-experts-human-rights).

[12] See, for example: UNOHCHR, The Right to Water, Fact Sheet No. 35 (August 2010) (Available at: https://www.ohchr.org/sites/default/files/Documents/Publications/FactSheet35en.pdf).

[13] See in general, Stephen McCaffrey (ed.), ‘The Law of International Watercourses’, Oxford University Press, Third Edition (2019).

[14] Mohamed S. Helal, ‘Sharing Blue Gold: The UN Convention on the Law of the Non-Navigational Uses of International Watercourses Ten Years On’, Colorado Journal of International Environmental Law and Policy, Vol. 18, No. 2. (2007), p. 345.

[15] See, for example: Corfu Channel (United Kingdom of Great Britain and Northern Ireland v. Albania) (Merits), I.C.J. reports 1949, p. 4, para. 22

[16] UN General Assembly, Declaration on Principles of International Law concerning Friendly Relations and Cooperation among States in accordance with the Charter of the United Nations (A/8082), Resolution No. 2625 (XXV), 24 October 1970.

[17] See: PCIJ, Germany v. Poland (1926), P.C.I.J. (Ser. A No. 7 at 30).

[18] B. Baker Röben, ‘International Freshwaters’, in F.L. Morrison and R. Wolfrum (eds.), International, Regional and National Environmental Law (2000), pp. 303-304.

[19] K. Bourquain, ‘Freshwater Access from a Human Rights Perspective: A Challenge to International Water and Human Rights Law’, Brill-Nijhoff (2008), p. 43.

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