My Vagina is not a Cosmetic Affair!

Thoughts on Female Genital Mutilation in Europe

Brenda I. Piñero Carrasquillo

“People are embarrassed, so you can see why people can get away with it because nobody talks about vaginas. People can’t even say the proper word for genitals.”

– Nimco Ali[1]

Female genital mutilation (hereinafter FGM) is a non-medical practice which Poses serious health issues, and potential life risks, to girls and women worldwide. It is estimated that every year three million girls and women are subjected to FGM practices. This total translates into 8,000 victims per day.[2] Of these, it is likely that 180,000 girls in Europe alone are at risk.[3] Indeed, the European Parliament estimates that there are currently half a million women and girls living in Europe suffering from the consequences of FGM.[4] Moreover, although it constitutes a widespread practice in countries of the African continent, there has been an increase in cases reported at the European level.

Dr. Pierre Foldès works as a surgeon in France. He has successfully performed reconstructive surgery on 2,938 victims of FGM.[5] Of these, 564 had undergone FGM in France.[6] Although Foldès’ approach has been quite successful, women who would like to undergo this surgical procedure face many obstacles. I will discuss some of these challenges and obstacles and engage with a broader debate on whether this type of reconstructive surgery is a medical or a plastic procedure. FGM is a grave issue that changes girls and women’s lives permanently. Its physiological and psychological effects burden its victims with every day challenges. For these and other reasons, which I elaborate upon below, my contention is that reconstructive surgery for FGM survivors cannot be considered a cosmetic procedure but rather a necessary medical one.

First I will provide a brief introduction on the different types of FGM and its accompanying health risks. Next, I will identify which human rights these procedures violate, and discuss why there have not been any prosecutions in this matter. In order to address the topic from a health perspective, I will then discuss the role of practitioners and medical personnel regarding FGM. In this context I will provide information on an alternative available to victims of FGM: reconstructive surgery. Finally, I will provide some recommendations on how to best tackle this issue along with some thoughts on why society must, in particular, overcome the prevalence of taboos that undermine frank discussions on the prevalence and effects of FGM.

Female Genital Mutilation: Health Risks and Human Rights

According to the World Health Organization (hereinafter WHO), the term FGM refers to a set of procedures which may include the partial or complete removal of the external female genitalia.[7] In addition, FGM may also include injuries to female genital organs for reasons other than medical ones.[8] FGM can be divided into 4 types: (1) clitoridectomy; (2) excision; (3) infibulation; and, (4) other types.[9] Very often, FGM is performed in unsanitary conditions, which increases the health risks and complications that this practice can have on girls or young women. Its effects can be classified as both short- and long-term. Among these, there is the risk of suffering a hemorrhage, of developing infections like tetanus, of shock, and of injury and trauma to the genital area and body.[10] In the long run, FGM victims suffer from chronic pain, very painful menstrual periods, pain during sexual intercourse, pelvic and urinary tract infections, cysts, abscesses, infertility, and even a “higher susceptibility to HIV and other sexually transmitted infections.”[11] Furthermore, there is also the possibility that the victim might die as a result of complications from the mutilation performance itself.

From a human rights perspective, FGM violates a vast set of fundamental rights. Among these, FGM represents a violation to the right to life, to human dignity, to be free from discrimination (on the basis of sex), and to children’s rights.[12] Of particular importance from a health perspective, FGM also violates the right to the highest attainable standard of health.[13] Thus, such practices contravene numerous articles incorporated as part of the following set of international instruments: (1) the Universal Declaration of Human Rights;[14] (2) the International Covenant on Civil and Political Rights;[15] (3) the International Covenant on Economic, Social and Cultural Rights;[16] (4) the Convention on the Rights of the Child;[17] and, (5) the Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment.[18] Moreover, FGM violates all articles of the Convention on the Elimination of all forms of Discrimination against Women.[19]  In 2012 the United Nations General Assembly also passed a resolution banning FGM.[20] Although not legally binding, the General Assembly’s adoption of the resolution reflects the increased attention that that FGM has garnered over the last several years, as well as widespread condemnation of the practice. Indeed, later that same year the Parliament of the European Union adopted a resolution on ending this practice.[21]

Fortunately, in certain countries FGM is also tackled at a national level. The UK stands as an example of a country with national statutes that establish a clear prohibition of FGM. In 1985, the UK introduced the Female Circumcision Act, and in 2003, the Female Genital Mutilation Act, which included the principle of extraterritoriality.[22] However, although nine countries in the European Union (hereinafter EU) have specific legislation against FGM, no prosecutions have yet been made.[23] Within the next lines, I will discuss some of the reasons why FGM prosecutions represent a challenge.

For the past years, FGM has become much more relevant in Europe, as many victims live in European countries.[24] More importantly, there are a vast number of females, living in the European Union, which are at risk of suffering FGM.[25] Even though there is an official EU Report on the subject matter that establishes that “[n]o hard evidence was identified on FGM being practiced within the EU,”[26] there are in fact testimonies of victims and doctors that state the opposite. For example, according to an article published in 2010 by the BBC, the Metropolitan Police Service of London (the MET) had intervened in FGM cases. It states: “[t]he Met said it was aware that FGM was taking place in London and had intervened in 122 cases since 2008, including 25 times this year. But it said that as it was a “taboo” subject there had been no prosecutions.”[27] In addition, Dr. Comfort Momah, a practitioner in London, reported at the time that she provided medical assistance, during 2010, to approximately 350 females who had suffered FGM at some point in their lives.[28]

Certainly, FGM remains a difficult crime to tackle, in part because most of the victims are girls or young females who are very reluctant to press charges. The latter is mainly due to the sad fact that it is often the victims’ parents’ decision to subject their daughters to this practice. Thus, by the time the victim acquires greater knowledge and understanding of the legal consequences of what she was subjected to, it is difficult for her to file a police report against her loved ones. This family element is also present in other ways. In most cases, it is women that perform FGM procedures with the assistance of the victim’s mother. Indeed, the risk of being subjected to any of these procedures increases if the potential victim has a mother that suffered FGM as well. To these factors we must add that there are many religious, social, and cultural “justifications” for the prevalence of the practice. Ultimately, these trace their roots to the gender inequalities of patriarchal systems.

FGM and Health

From a medical perspective, FGM brings many challenges to the table. For practitioners, it might be difficult to address patients in order to determine if they have been subjected to FGM procedures. Medical professionals must make sure to create an adequate environment in which patients will feel safe and comfortable to discuss the topic. The presence of female medical personnel, for example, is strongly advised when dealing with FGM victims.[29] Also, patients should be treated with respect and should not be judged or unnecessarily questioned by the practitioner.[30] Doctors, especially pediatricians, should pay special attention to clues which might indicate that a patient could be subjected to FGM. Among these, are: the presence of relatives who are victims of FGM (especially patient’s mothers), as well as “reports of extended holidays, preparations for special ceremonies, and requests for travel vaccinations or antimalarials.”[31] In the same line of thinking, education professionals should also have a keen eye for situations like prolonged visits to the restroom, neglect of participation in sport activities and abrupt behavioral changes after holidays.[32]

However, the fight against FGM does not end with an orientation at the doctor’s office or with the school counselor. Educational campaigns are needed that target the population at risk. For maximum efficacy, these should be carried out by the government at schools and neighborhoods. The fact is that the grave responsibility to counteract the prevalence of FGM cannot be left only to non-governmental organizations, seeing as the latter have access to limited resources and funding relative to the State. In this sense, the UK has proven to be proactive when it comes to FGM prevention and orientation. For example, in London there are African Well Women Clinics that provide health assistance to FGM victims.[33] Also, the London Safeguarding Children Board launched the London FGM Resource Pack, which provides a compiling tool for professionals and community groups.[34] More recently, in November 2013, The Royal College of Midwives launched a report on Tackling FGM in the UK: Intercollegiate Recommendations, which provides information and assistance on the subject.[35]

In addition to these preventive measures, strategies must be put in place to help those women who unfortunately have already suffered through FGM. Perhaps most importantly, victims and relatives should be oriented about available reconstructive procedures. Such orientation must include information on when and where they can undergo this surgery. Although a reconstructive procedure is available, it is not widely performed.[36] There are only a few doctors that perform it, among them Drs. Momah and Foldès, and these are certainly not enough to adequately deal with the total number of victims. Therefore, EU initiatives must include medical training for doctors and health professionals not only on such procedures as defibulation[37]–which refers to a process in which type 3 FGM is reversed by making a bigger vaginal opening–but also on the reconstructive surgery procedure.

 Any Alternatives? The Surgical v. Plastic Debate

Unfortunately, there are still many people who share the view that reconstructive surgery for FGM victims is a cosmetic instead of a medical procedure. As a consequence of this:

[W]omen with genital mutilation are not usually informed about the possibility of specific health care to address the consequences of mutilation. In some countries, the health insurance or national health-care systems do not recognize defibulation and clitoral reconstruction as therapeutic procedures, classing them as cosmetic surgery.[38]

Despite the fact that Foldès insists on the medical nature of the procedure, not everyone shares his view. There are instances in which a national health insurance program will not cover the procedure because it is considered to be an aesthetic intervention. Fortunately, this is not the case for patients attended by Dr. Foldès, as:

In France, reconstructive surgery has been available on the French National Health Service since 2004. Surgery was initially offered to women with pain sequelae, but has since been extended to women wishing to improve their sex lives or their physical appearance.[39]

Foldès has performed reconstructive surgery on more than 2,938 victims, of which 2,933 stated that their main reason for undergoing the surgery was to recover their female identity.[40] In addition to these numbers, a total of 847 women reported pain reduction, 239 reported a ‘normal clitoris,’ and 815 reported clitoral pleasure.[41]

It is my view that FGM reconstructive surgery distinguishes itself from cosmetic surgery. The reconstructive surgery is performed on women to alleviate pain, avoid or eliminate serious health complications, and even to allow childbirth. I have discussed some of the health risks that FGM victims are subjected to. To these victims, reconstructive surgery is not a matter of big or small, tight or loose, or pretty or ugly; as could be argued regarding certain cosmetic surgeries. To FGM victims, a surgical procedure to reconstruct their clitoris and vulva is a matter of health, as well as of human dignity. It is part of their right to the highest attainable standard of health. I agree with Dr. Foldès that the kind of reconstructive surgery that he performs is in no way a cosmetic procedure. Therefore, I unequivocally subscribe to his contention that:  “…what we are doing can in no way be described as ‘cosmetic.’ Instead, what we are trying to do is to restore the dignity and wellbeing of women who have experienced violence—and who very much welcome our initiative.”[42]

There is a big difference between a reconstructive surgery and a cosmetic surgery. Although one might say the latter seeks to improve the aesthetic appearance of a body part, the former seeks to correct health problems that can be burdensome and even life threatening. Reconstructive surgery presents itself as an effective vehicle to improve the quality of life of women who were brutally victimized during their childhood. This surgery also includes processes such as the previously mentioned defibulation,[43] especially in pregnant women before delivery. However, the fact that FGM also affects the sexual life of women seems to be regarded as a less important aspect, which in turn hinders the importance of providing the option of, and healthcare coverage for, reconstructive surgery for FGM victims.

Reconstructive surgery is not only a matter of improving sexual life. The experience of  Dr. Foldès indicates that this surgery not only improved the sexual life of women, but also eased their process of recognizing themselves as human beings filled with dignity and pride; thereby, improving their psychological state of being as well. There are some women, especially those who have undergone infibulation, which have reported other positive effects, such as improved body self-image and stronger female identity associated with their mutilated genital area.[44] With respect to this, it is my contention that reconstructive surgery is not a mere cosmetic procedure but a much-needed intervention to facilitate natural processes of a woman’s body such as menstrual periods and childbirth. It must be noted that female identity is not circumscribed to cosmetic matters; it is much more complex. Identity is shaped by social, historic, religious, and economic notions. Therefore, the terms body self-image and female identity are not universal for women and men; just like the term women itself, which is not monolithic and homogeneous. If these two terms are construed from an androcentric point of view, then the exercise of defining image, beauty and identity imposes male conceptions and standards, which in turn disregards dissimilarities between men and women, as well as differences among women as a social group. To disregard a medical procedure as merely cosmetic, just because women think it will improve their image and identity, represents not only a narrow way of thinking but is also uninformed and deceptive. The problem may lie on how society insists upon teaching and learning disciplines–such as social and natural sciences, for example–as if they represent different and independent universes without common intersections and study subjects. It might also be that, for some people, psychological and identity factors are less important. Or maybe it is that, the indifference shown to the medical aspect of this issue is due to the fact that FGM occurs among a small population–mostly immigrants–in comparison to the population of European women who have been born and raised in Europe.

In times of economic crisis, money is always a key factor and the argument that this type of reconstructive procedure might represent an economic burden to the economy, and to the national health system of countries in Europe in general, might be a valid one. Although further research must be conducted in order to quantify the amount required to effectively address the problem, it seems to me that money will not be a burden since the population in need of this procedure comprises a fraction of the total female European population. Race and skin color play a huge role on how much importance European politicians and leaders give to the discussion of FGM as part of their political agenda. The lack of an intersectional approach is one of the main arguments that have been stressed by feminists in developing countries regarding matters of human and women’s rights.

According to Pamela Scully, the invisibility of cultural, racial and economic factors has played a huge role in the preponderant feminist discourse. For her, colonial states sought ways to inculcate European femininity and the rhetoric of anti-slave trade depicted women of African descent as “vulnerable subjects” in need of protection granted within the private sphere of family and marriage.[45] Confining violence against women to the private sphere has obstructed the path for education and has slowed legal reforms on women’s rights. The international feminist agenda, proposed by women from northern countries, in many ways does not fit within the daily life of women in the developing world. We must not forget that many feminist in developed countries are white and enjoy a better economic position. Therefore, it comes as no surprise when the third world feminist approach strongly critiques the paternalism of first world countries as a vehicle to grant and recognize human rights, and then its use of human rights violations as a basis for military and political intervention in developing countries. Unfortunately, as Sally Engle Merry portrays, the response at some international forums has been juxtaposing culture to law and perceiving the latter to be within the minorities. According to the anthropology professor, what has been produced at international legal settings, in the midst of modernity, has been “a culture that relegates culture to the margins.”[46]

Ignoring a situation does not make it disappear. Rather, open discussion on these topics is essential for understanding the nature of the problem and finding proper ways to address it. Silence leads to ignorance, indifference and political inaction. The less we are willing and able to discuss matters regarding FGM the less we actually talk about the need for reconstructive surgery, let alone train professionals on how to perform it. There are many studies that show the importance and benefits of educating girls and women. As a society, we must work to educate girls on how to value themselves as human beings filled with pride and dignity. It is important that girls understand that FGM is not their fault and that it does not represent an act of protection or love. Accordingly, women must be empowered in order to believe and understand that FGM is a violation to their human rights and that they also have a right to health, which includes this reconstructive procedure. It is utterly important to unveil the fact that patriarchy, dominance, violence, and subordination are present in FGM, in order to educate people on women and children rights.

Under no circumstance is it my intention to suggest that the responsibility for eradicating FGM lies solely on women’s shoulders. To do this will perpetuate stereotypes and will also replicate violence against women. There must be a multi-agency approach to tackle FGM. This includes educating health professionals, but also personnel on agencies responsible for protection–such as the Police–and those departments or agencies that provide assistance to women and girls in areas like education, health, and safety. Also, efforts and initiatives must be taken in areas regarding research, data and statistics.[47] In addition, women who were subjected to FGM should be granted health coverage for reconstructive procedures. FGM must be treated as a form of child abuse and indications that a girl may be subject to it should be reported. Furthermore, particular importance must be paid to monitoring the progress of these initiatives and periodical reports must be published so that recommendations can be implemented.[48] Lastly, the law must not only take an active role in preventing FGM but also in prosecuting those who commit it.

As a final point, I must address the silence and the shame that some people feel when talking about sexual and reproductive issues. Our inability to name female body parts, as stressed by Nimco Ali in the foreword quote, is only the tip of the iceberg. We must discuss how politicians continue to legislate using the female body as political arena. Women, and men, must have access to education on sexual and reproductive rights. And talk of FGM and Human Rights cannot remain merely a topic of academics or among privileged groups.

This article is an extract of a written piece that I presented as the final assessment of an International and European Health Law Class. During my evaluation, the Professor inquired why I chose FGM as a topic. In addition, he requested that no pictures be shown during the class presentation. Certainly, such attitudes do little to further the cause on women’s rights. This happened at the post-graduate university level and in Belgium, a country home to such international political fora as the Parliament of the European Union. As a graduate student, I expected that a final class presentation would be an exercise in promoting questioning and progressive thinking, an opportunity to present challenges and address potential solutions. The blatant interference with my methodology of presentation, as well as the Professor’s questioning on why I chose an ugly and not so friendly topic, exemplifies censorship and an attempt to undermine the importance and severity of FGM as a human rights issue. Is there such thing as a perfect and ideal time to discuss why governments within the European Union must address and discuss women and children rights? Should students be led to believe that only pleasant and trendy topics are worthy of discussion? Was I supposed to discuss cosmetic health procedures instead of talking about reconstructive surgery for FGM survivors?

It is surprising how easy people can talk about penises and vaginas when it comes to sex, pornography or to make a joke, but how stressed and shameful some feel when discussing topics such as FGM. My academic experience is only one example of how issues of women’s rights remain hidden, invisible, and silenced. Also, it represented an attempt to undermine the urgency to eradicate violence against women and girls. From an academic perspective, my Professor’s attitude was not only disrespectful to me as a woman but also as a law student.  His comments and viewpoint in effect contribute to the prevalence and reproduction of stereotypes within society and among future legal professionals. And even worse, it almost precluded students from learning about FGM as a human rights violation that happens very often and on European soil.

There are many challenges that need to be discussed within the human rights spectrum. The fact that FGM happens to women and girls, particularly to those that are African descent, should not make the discussion less important. Violence against women and children happens every day; it waits for no one and certainly it is not a matter that happens under perfect circumstances. We must empower ourselves to speak and demand; to remain silent is not an option. Education is a powerful tool against human rights infringements and an essential component to progress in a society which values life and human dignity. Regardless of what many people may think, any time is the perfect time to talk about vaginas and FGM.

[1] Anna Davis, We’re too British to talk about this outrage, says female genital mutilation survivor, STANDARD (30 April  2013), (last visit 1 December 2013). Nimco Ali is a FGM survivor who, alongside 2 other FGM survivors, started Daughters of Eve, a campaign group in the United Kingdom that promotes education awareness in schools.

[2] END FGM European Campaign, ENDFGM, (last visit 22 January 2014).

[3] Id.

[4] Id.

[5] Pierra Foldés, Béatrice Cuzin, & Armelle Andro, Reconstructive surgery after female genital: a prospective cohort study, TheLancet  (12 June 2012), (last visit 22 January 2014).

[6] Id.

[7] Media Centre, Female Genital Mutilation, Fact Sheet No°241, World Health Organization (February 2013), (last visit 22 January 2014).

[8] Id.

[9] Id. The World Health Organization (WHO) defines clitoridectomy as a procedure that consists in the “partial or total removal of the clitoris” and, in rare cases, such procedure may be done only to the prepuce. As for excision, the international organization defines it as “partial or total removal of the clitoris and the labia minora, with or without excision of the labia majora.” Infibulation consists on “narrowing of the vaginal opening through the creation of a covering seal.” This third type of FGM is done by “cutting and repositioning the inner, or outer, labia, with or without removal of the clitoris.” In addition to these three procedures, the WHO considers that those done for other purposes–besides medical reasons–are also considered as FGM. Within these non-medical actions, the WHO mentions: “pricking, piercing, incising, scraping and cauterizing the genital area.”

[10] Report: Female Genital Mutilation in the European Union and Croatia, European Institute for Gender Equality (6 March 2013), (last visit 22 January 2014).

[11] Id.

[12] Universal Declaration of Human Rights, G.A. res. 217A (III), U.N. Doc A/810 at 71 (1948), at art. 2., art. 3, art. 5, art. 25 (under the Universal Declaration of Human Rights, the following articles are breached when FGM takes place: Art. 2, Right to be free from discrimination (on the basis of sex); Art. 3, Right to life, Art. 5, Right to be free from cruel, inhumane and degrading treatment, and Art. 25, Right to the highest attainable standard of health).

[13] Universal Declaration of Human Rights, G.A. res. 217A (III), U.N. Doc A/810 at 71 (1948), art. 25; International Covenant on Economic, Social and Cultural Rights, G.A. res. 2200A (XXI), 21 U.N. GAOR Supp. (No. 16) at 49, U.N. Doc. A/6316 (1966), 993 U.N.T.S. 3, entered into force Jan. 3, 1976, at art. 12; Convention on Elimination of all Forms of Discrimination against Women, G.A. res. 34/180, 34 U.N. GAOR Supp. (No. 46) at 193, U.N. Doc. A/34/46, entered into force Sept. 3, 1981, at art. 12 (the right to the highest attainable standard of health is covered in: Art. 25 of the Universal Declaration of Human Rights; Art. 12 of the International Covenant on Economic, Social and Cultural Rights, and Art. 12 of the Convention on Elimination of all Forms of Discrimination against Women).

[14] Universal Declaration of Human Rights, supra note 14.

[15] International Covenant on Civil and Political Rights, G.A. res. 2200A (XXI), 21 U.N. GAOR Supp. (No. 16) at 52, U.N. Doc. A/6316 (1966), 999 U.N.T.S. 171, entered into force Mar. 23, 1976.

[16] International Covenant on Economic, Social and Cultural Rights, supra note 14.

[17] Convention on Rights of the Child, G.A. res. 44/25, annex, 44 U.N. GAOR Supp. (No. 49) at 167, U.N. Doc. A/44/49 (1989), entered into force Sept. 2, 1990.

[18] G.A. res. 39/46, annex, 39 U.N. GAOR Supp. (No. 51) at 197, U.N. Doc. A/39/51 (1984), entered into force June 26, 1987.

[19] Convention on Elimination of all Forms of Discrimination against Women, supra note 15.

[20] United Nations Bans Female Genital Mutilation, United Nations Entity for Gender Equality and the Empowerment of Women (20 December  2012), (last visit 22 January 2014).

[21]Resolution of 14 June 2012 on Ending Female Genital Mutilation, EUR. PARL. DOC. PV 18 (2012). Also available at

(last visit 22 January 2014).

[22] Report, supra note 12 at 44.

[23] Id. at 43 (These countries are: Austria, Belgium, Cyprus, Denmark, Ireland, Italy, Spain and Sweden).

[24] Id. at 26 (It is estimated that there are 65,790 FGM victims in the UK. Following on the list there is France with 61,000; Italy with 35,000; Germany with 19,000 and, Belgium with 6,260).

[25] Id. (There are 30,000 girls at risk in the UK; 4,000 in Germany; 1,975 in Belgium and 1,000 in Italy).

[26] Id. at 13.

[27] Rise in female genital mutilation in London, BBC News (22 August 2010), (last visit 22 January 2014).

[28] Id.

[29] Jane Simpson, Female Genital Mutilation: The Role of Health Professionals in Prevention, Assessment, and Management, BMJ (14 March 2012), (last visit 22 January 2014).

[30] Id.

[31] Id.

[32] Id.

[33] See Hospitals and Clinics in the UK offering Specialist FGM (Female Genital Mutilation) Services, Forward, (last visit 22 January 2014).

[34]See London FGM Resource Pack, London Safeguarding Children Board (last visit  22 January 2014).

[35] RCM, RCN, RCOG, Equality Now, UNITE, Tackling FGM in the UK: Intercollegiate recommendations for identifying, recording and reporting, Royal College of Obstetricians and Gyneacologists (1 November 2013), (last visit 22 January 2014).

[36] Deni Kirkova, Girls ask me if I can put their clitoris back: Midwife behind UK’s only female genital mutilation clinic recounts harrowing stories, Mail Online (11 March 2013), (last visit 22 January 2014).

[37] “Defibulation,” or “Deinfibulation,” is the surgical procedure to open up the closed vagina of FGM type III and is often performed multiple times such as, on the wedding night, when the husband goes away for any significant period of time and returns, and prior to childbirth. See Deinfibulation, AboutFGM (2011), (last visit 22 January 2014).

[38]  Jasmine Abdulcadir et al., Reconstructive surgery for female genital mutilation, 380 The Lancet 90, (2012). Also available at (last visit 22 January 2014).

[39] Foldès, supra note 5 at 134.

[40] Id. at 134.

[41] Id. at 134.

[42] Pierre Foldès, Correspondence: Author’s reply to Guo-You Zhang and colleagues, 380 THE LANCET 1469-1470 (2012). Also available at (last visit 22 January 2014).

[43]  Foldès, supra note 5 at 134.

[44] Abdulcadir, supra note 40 at 91

[45] Pamela Scully, Gender, History and Human Rights, in Gender and Culture at the Limit of Rights 17, 26-29 (Dorothy Hodgson ed., 2011).

[46] Sally Engle Merry, Constructing a Global Law-Violence against Women and the Human Rights System, 28 Law and Social Inquiry 941 (2003).  Also available at (last visit 22 January 2014).

[47] RCM, supra note at 37.

[48] Id. at 12.


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