Emalus Library Online Documents Collection - Customary Law



THE CUSTOMARY LAW QUESTION IN THE SOUTH AFRICAN CONSTITUTION

HON. YVONNE MOKGORO*



Source: Saint Louis University Law Journal, Fall 1997; 41 St. Louis L.J. 1279


 
* Justice of the Constitutional Court of South Africa. B. Juris., LL.B., LL.M. University of the Northwest (South Africa). LL.M., University of Pennsylvania. Justice Mokgoro has served as a lecturer and Associate Professor at the University of the Northwest, the University of the Western Cape and the University of Pretoria. She also served as Specialist Researcher in Human Rights at the Centre for Constitutional Analysis at the Human Sciences Research Council, until her appointment to the Constitutional Court. This article is a revised version of a paper delivered at the Saint Louis University School of Law on October 7, 1997.

SUMMARY:
  ... When the Constitution of South Africa, Act 200 of 1993, called the interim Constitution, was adopted, it was a historical milestone of unprecedented significance. ... The Nature of African Customary Law and its Constitutional Recognition ... This piece of legislation, in a way, provided a false celebration of cultural diversity in that it made customary law applicable to certain "classes" of Africans who were said to live according to African tradition or custom. ... During the Multi-Party Negotiations process which forged the interim Constitution there was strong lobbying by traditionalists on the one hand and what seemed an equally strong and highly motivated feminist lobby on the other, for the place of customary law and traditional authority in a new dispensation. ... It was the view of the traditionalist lobby, however, that the systems of customary law and traditional leadership ought to be accorded more respect and dignity in a new dispensation. ... At the same time, sub-section 3 insists that the entrenchment of a fundamental right shall not be construed to be denying a right conferred by customary law if it is not inconsistent with that fundamental right. ... In Mthembu v Letsela and Another, there was an application for an order declaring the rule in African customary law which excluded women from intestate succession to be inconsistent with the provisions of the equality clause. ...  

TEXT:
 [*1279]  



I. Background
 
Constitutions are not written everyday. They are historical milestones. When the Constitution of South Africa, Act 200 of 1993, called the interim Constitution, was adopted, it was a historical milestone of unprecedented significance. Like most constitutions, it was also a reflection of the history, the fears and aspirations of the nation it was meant to serve, stating in its preamble:


 
... there is a need to create a new order in which all South Africans will be entitled to a common South African citizenship in a sovereign and democratic constitutional state in which there is equality between men and women and people of all races so that all citizens shall be able to enjoy and exercise their fundamental rights and freedoms.... 1
 
Unlike most constitutions, however, the interim Constitution has been widely described as a product of political negotiation and compromise. Many of the contradictions and difficulties in interpreting its provisions have been attributed to this characteristic feature.

During the multi-party negotiations process which took place at Kempton Park, Johannesburg, in 1993, a two stage process of constitution-writing was agreed to by all political parties participating in the process. First, an interim Constitution would govern from the date of the completion of the first democratic election until a new Constitution had been drafted and adopted by Parliament. Second, introducing another special feature of this interim Constitution, participating political parties had negotiated and concluded that thirty-  [*1280]  four constitutional principles within the bounds of which the new Constitution would be drafted, would form part of the interim Constitution. 2 It was further agreed that before the new text would be adopted, the newly created Constitutional Court would have to certify that all of the provisions of the new text complied with the constitutional principles. The Court duly certified the new constitution only after a second submission by the Constitutional Assembly, after the first submission had not borne the required result. 3

South Africa functioned under the interim Constitution for almost three years after it was adopted. The new constitution is now in operation, having been signed into law on February 4, 1997. 4

Not unlike its predecessor, the new Constitution is the supreme law of the land and contains a chapter which guarantees fundamental human rights. 5 This chapter of the Constitution, described as "the cornerstone of democracy in South Africa," 6 is founded on values of freedom, equality and human dignity. 7

In full realization of the potentially competing demands that a drastically changing society of diverse values and equally diverse historical experiences may place on scarce resources, the new Constitution contains a fully fledged limitations clause in the Bill of Rights, which provides courts with sets of criteria to be applied when competing rights and interests have to be balanced. 8

Much as there is a need to develop a new South African constitutional ethos, there is also acknowledgement that the rich diversity of indigenous values need to be nurtured with pride, for it is that rich diversity which will give birth to and shape a new South African constitutional value system. Of course the new Constitution reminds us that South Africa is now back in the global fold. So that while we continue to shape our own constitutional values, we are enjoined at the same time, to promote the values that underlie an open and democratic society, based on human dignity, equality and freedom. We are to consider international law and are encouraged to take into account constitutional values developed in foreign jurisdictions in similar situations. However, this does not imply wholesale importation.

It is in the context of this background that the apparent tensions between  [*1281]   the recognition of African customary law in the Bill of Rights of the Constitution and the guarantee of fundamental human rights in the same Bill of Rights should be viewed.



II. The Nature of African Customary Law and its Constitutional Recognition
 
In South African jurisprudence, there is no single interpretation of the concept Customary Law. It is however generally understood as the cumulative of all legislative enactments and judicial pronouncements on African social tradition and custom. Because it is based on African traditions and customs, if it is not legislated upon, it should continuously respond to society's contemporary values, needs and practices. If it is sufficiently responsive to social reality, its contemporary value would be measured in terms of its compatibility with the contemporary values, needs and practises of its jural communities. For reasons now well-documented in the colonial history of South Africa, which include self-serving political ideals of successive colonial governments, traditional institutions were largely formalized through legislation and infused with the typical conservatism of positive law, thus substantially reducing their inherent responsive potential.

In ordinary circumstances, because social tradition and custom are so closely connected to social lifestyles, custom should reflect society's stage of social development. In the case of African traditional social institutions which form part of the corpus of "positive" customary law, however, the place and extent of evolution was the prerogative of political and legal authorities. The denial of participation of blacks in the political and judicial processes generally precluded Africans themselves from having a direct influence on the development of customary law. Moreover, the significant failure on the part of legal policy to keep customary law abreast with social reality resulted in a sharp dichotomy between custom as law and custom as social practice. In a rather silent and invisible revolution, women, particularly in the rural sectors, have largely overturned the central principles which have ordered society for centuries. They have disrupted social relations and unsettled social identities. In real terms, women have long been challenging power relations and demanded participation in decision making, but legal policy has been unresponsive. Judicial administration in this respect fell within the jurisdiction of the Commissioners Courts and other specialized customary law courts where the response was equally inadequate. The power of traditional Chief's Courts, the only courts conducted by jural communities themselves, lacked the capacity to have any significant impact on the evolution of the system because of their limited jurisdiction. There is also the general tendency to romanticize African custom or tradition as an expression of African social values, pure and unchanged by colonial influence. The truth of the matter is that much of the social tradition and custom has evolved with the development of traditional  [*1282]  communities over time. Whatever developments have been effected by successive colonial administrations to certain customary law institutions, the system still lags behind contemporary social values, needs and practices. In a number of situations, this dichotomy between customary law and social reality causes serious hardships for jural communities in general and for women in particular. For example, in contemporary traditional families, women make significant contributions to the accumulation of communal family property and transact frequently in connection therewith. In the officially developed customary law, however, a woman has no legal capacity to act whether on her own behalf or on behalf of her own children, or on behalf of any other. She has been understood to be a perpetual minor with no capacity to own or transact property or even to act as guardian of her own children. She herself is regarded as a ward of the nearest surviving male relative even if it is her own married son. Some of these misconstrued patriarchal institutions, accorded senior male persons, as heads of households, superior status in the private and public sphere, enthroning them as the only true persons in law and the sole holders of family property, whereas in pre-colonial custom and tradition, the head of the household was but only the "administrator" or "fiduciary" of family communal property. This general misconstruction places women and unmarried children outside of the law rendering them legally invisible. Originally, the institution of succession to communal family property was compatible with the unity of the extended family. Today, despite the erosion of that family unity senior male relatives, at times remotely related, are still enabled by customary law to succeed to communal family estates and more often than not, leave widows and children destitute. 9

Unlike South African common law, customary law, like religious law, has not featured prominently in the mainstream of South African jurisprudence. A separate court structure was created to administer customary law, and to apply it in terms of the then Black Administration Act. 10 This piece of legislation, in a way, provided a false celebration of cultural diversity in that it made customary law applicable to certain "classes" of Africans who were said to live according to African tradition or custom. Those who were sufficiently "westernized" were exempted from the application of what had become a more restrictive system of law for women and unmarried family members, mostly in the area of family relations. The latter would, alongside their white counterparts be subject to the application of Roman Dutch (Common) Law. 11  [*1283]   This marginalization of customary law vis a vis the common law has thus contributed largely to its skewed development. That has resulted in much scepticism and mistrust, for the application of customary law. The attitude is quite naturally most prevalent among women who seem to bear the brunt of this skewed legal development. At the same time, however, South Africans are now faced with what seems an essentialized system of law, which in reality affects thousands of particularly rural African lives in areas where decades of apartheid neglect have resulted in widespread illiteracy. Some institutions within this system of law are still cherished, particularly by traditionalists, and those who seemingly derive from it a power base, whether it be in the public or private sphere. It is for this reason too that the need for the harmonization of customary law with the fundamental values of a new legal orderCas opposed to abolitionChas become important.



III. The Customary Law Question in the Interim Constitution
 
During the Multi-Party Negotiations process which forged the interim Constitution there was strong lobbying by traditionalists on the one hand and what seemed an equally strong and highly motivated feminist lobby on the other, for the place of customary law and traditional authority in a new dispensation.

The feminist lobby aimed to vigorously expose the weaknesses of the system of customary law in general and traditional leadership, challenging the practices which have come to discriminate severely against women and unmarried persons. 12 They set out to weaken the legitimacy of the systems and their role in a new dispensation by presenting the envisaged Fundamental Bill of Rights and Freedoms as a counter balance to the demands of traditionalists. In particular, they underscored what was viewed as the undemocratic and discriminatory aspects of the system of traditional authority and leadership. Not only was the traditional authority insulated from the electoral process, the lobby argued, it was also hereditary, where the hereditary process was significantly male primogeniture and by its nature excluded women. As a result, it precluded women from ever presiding over customary law and bring it in line with their contemporary needs. Considering that a majority of the nearly forty percent of rural South Africans are women, it was difficult to justify the continued recognition and enhanced protection of a system of rural local governance which was fundamentally male in character, governing predominantly female communities and excluding women. This seemingly unrepresentative and discriminatory nature of traditional leadership could not be ignored. It had outlived its legitimacy. It is offensive to the principles of participatory development and government accountability. It violates the values of equality, dig-  [*1284]  nity and freedom, so basic in the envisaged interim Constitution. Fighting this rearguard battle, the feminist lobby aimed to prevent an outright traditionalists victory.

It was the view of the traditionalist lobby, however, that the systems of customary law and traditional leadership ought to be accorded more respect and dignity in a new dispensation. The lobby thus demanded not only continued recognition of the systems, but their entrenched protection after decades of operating in a political system notorious for its suppression, manipulation and exploitation of African national symbols. Again, considering that forty percent of South Africans are currently permanently rural, they argued, and a significant number commute between town and country, where such communities are essentially traditional, there is a need for greater recognition and protection of traditional leadership and the system of law over which the lobby presides. In circumstances where South Africans were now turning their back on apartheid and all that it stood for, the call was widely considered not to be unreasonable.

The view was that a call for enhanced and maximized power for traditional leadership, despite the system's notorious history, forms part of the argument that colonialism, apartheid and racism in South Africa made Africanism an integral part of the history of the national liberation struggle. 13 Achieving national liberation should naturally include the restoration and revival of institutions symbolic of African pride, dignity and other forms of assertion. In a post-apartheid democracy, they argued further, there was a need to structure an all inclusive constitution and Africanise government structures and legal institutions. Besides, traditional authorities, particularly in the former homelands, constituted the local government of the day. Despite the controversy around them, the system is firmly in place and cannot disappear by the stroke of a pen. Rural communities identify with it and view it as their own. Whether it is appreciated or not goes the argument, traditional leadership exercises substantial power and authority over their jural communities. The effect these strongly opposed demands placed on the democratization process during the Multi-Party negotiations are evident in the provisions of the interim Constitution.

There are a number of references to customary law in the interim Constitution which seemed to give it some elevated recognition and status. 14 It has been argued that previously, on its face, the choice of law principle in South African jurisprudence provided a person with the freedom to participate in his  [*1285]   or her cultural life, but did not provide that as of right. Section 31 of the interim Constitution, however, introduced the idea of that choice as of right. It has been argued that this right does not nullify the previous freedom. A person only had an additional right to insist on the application of customary law in appropriate legal proceedings. The freedom, it is further argued, comprehends the generality of social life while the right requires a special act of recognition by courts or authorities.

Significant in the newly acquired status of customary law is the notion that once its application is considered as a right in particular circumstances, it is placed on a constant collision course with other relevant fundamental rights in Chapter 3. 15 This is the case particularly between the equality clause in section 8 16 and a number of customary law principles and institutions which were understood to subject the fundamental rights and freedoms of women and children to that of senior male persons within the family structure.

However, there seemed to be no hierarchy of rights in Chapter 3 of the interim Constitution. When those rights were in conflict with customary law principles, as it was bound to happen, it was left to judicial interpretation to balance opposing interests. The limitations clause contained in section 33 as a whole, provided some guidance by laying down the criteria or factors which had to be considered in the balancing exercise. 17 Sub-sections 2 and 3 clearly establish the relationship between the chapter on Fundamental Rights and Freedoms 18 on the one hand and customary law on the other. Section 3(2) provides that a law of general application, which includes a provision of customary law may not limit a fundamental right. At the same time, sub-section 3 insists that the entrenchment of a fundamental right shall not be construed to be denying a right conferred by customary law if it is not inconsistent with that fundamental right. 19

The interpretation clause (which is contained in section 33) 20 further subjects the development of customary law to the fundamental rights and the basic values of freedom, equality, the purport and objectives of the Bill of Rights, where the right to participate in the cultural life of one's choice was part of the same Bill of Rights.

The interim Constitution has come and gone. In its short life-span, no challenge to any aspect of customary law was brought before the Constitutional Court in its ordinary proceedings. The meaning and effect of these seemingly contradictory provisions within the interim Constitution have there-  [*1286]  fore not had occasion to be settled by the Court.

Some of the High Courts have however had the occasion to test the extent of protection provided by the Interim Constitution for customary law: In Congress of Traditional Leaders of South Africa v Minister for Local Government, Eastern Cape, 21 applicants challenged the constitutionality of a proclamation and regulations which they alleged, if applied in the rural villages of the Eastern Cape Province, had the effect of depriving traditional leaders of their powers which were entrenched in the interim Constitution. The application, however, failed on the basis that the proclamations and regulations did not have the effect alleged by the applicants. The Court was of the view that there was not a single function of local government which was vested in the applicants who were a group of traditional leaders. There was no appeal against this decision.

In Mthembu v Letsela and Another, 22 there was an application for an order declaring the rule in African customary law which excluded women from intestate succession to be inconsistent with the provisions of the equality clause. The rule was upheld. The Court was of the view that if the injunction in section 33 is applied the differentiation between men and women here, did not amount to unfair discrimination in that the rights conferred by customary law should not be construed to be inconsistent with the fundamental rights in the Constitution. Similarly, no appeal was lodged against the decision.



IV. The Customary Law Question in the New Constitution
 
Constitutional Principle XIII in Schedule 4 of the interim Constitution, 23 when read with section 71(1) of that Constitution, committed the new Constitution to continue to recognize and protect the role and functions of traditional leaders, and for the courts to apply Customary Law as provided for in the new Constitution and relevant legislation. Constitutional Principle XI, read with section 71(1)(a) of the interim Constitution, required the new Constitution to promote and protect cultural diversity. Thus, it seems a positive duty on the part of the State to do so. It is the extent to which this recognition applies vis a vis other relevant provisions of the new Constitution which is still questioned. Other than the occasion of the first and subsequent certification of the new Constitution, and the certification of the constitution of the province of KwaZulu-Natal, the Constitutional Court has unfortunately still not had an opportunity to interpret these pertinent provisions. However, there are some academic opinions in this regard. 24

 [*1287]  

V. Future Prospects for the Development of Customary Law
 
Viewed from the outcome of the two certification judgments of the Constitutional Court, it seems the constitutional tensions between customary law and the Fundamental Rights, reflected in the interim Constitution have been eased. To what extent this is in fact so, would be difficult to assess since there has not been much interpretation by our courts during the interim phase of the constitution to compare. The Bill of Rights, which is contained in Chapter 2 of the new Constitution is also applicable to all law, including customary law. It now binds not only the legislature and executive as was the case in the interim Constitution, but its binding force has been extended to the judiciary as well. 25 Moreover, it is now also binding on natural persons and juristic persons. There is a view that it introduces a clear yet limited horizontal effect. To what extent this is indeed so and how this will affect power and privilege in customary law personal relationships will optimistically soon be interpreted by South Africa's courts. Nothing, however, stops academics and others from speculating through academic analysis.

Section 39 seems to provide much room for harmonizing customary law with the rights protected in the Constitution. This section requires courts to promote the spirit, purport and objects of the Bill of Rights when they develop the law, including customary law. The section, like its predecessor also recognizes the rights conferred under customary law, protects their continuous application but also expressly requires that such recognition shall be given only if customary law is consistent with the Bill of Rights, reinforcing the same apparently circular argument. What the effect of the relationship between these and other relevant sections of the new Constitution have, on the status of customary law in South Africa, still needs to be interpreted and settled by the courts.

There are also a number of other provisions in the new Constitution which may affect the development of customary law one way or another. The South African Law Commission is currently embarking on a major customary law reform project, with a view to harmonize the system of customary law with the ConstitutionCa rather daunting task which requires substantial human and financial resources. 26 However, in the Commission's view, the task is nevertheless achievable.

The judiciary, notably the Constitutional Court and the High Courts in South Africa, have the primary duty to resolve existing constitutional tensions through interpretation. 27 The opportunity, however, can only arise through  [*1288]  vigorous constitutional litigation, but South Africans are only as litigious as they are rights-conscious. This is still a serious short-coming due to widespread illiteracy, particularly in the deep rural areas of South Africa where the need is so great.

There are new constitutional structures specifically created to support constitutional democracy, and to create and nurture a human rights culture in South Africa. These structures have started to do sterling work in this regard. Of particular significance for the customary law question are the Commission on Gender Equality 28 and the Commission for the Promotion and Protection of the Rights of Cultural, Religious and Linguistic Communities. 29 The former has the duty to promote and protect gender equality. Its powers include to: educate, lobby, advise, research and report on issues of gender equality. The latter has the primary duty to promote respect for the rights of cultural, religious and linguistic communities. Like the former, it also has the power to research, educate, lobby, advise and report, on issues of cultural, religious and linguistic communities. There is particular curiosity about how these two bodies will relate to each other in their function and practical operation.

Traditional leaders, who still enjoy recognition in the new Constitution have been provided with a Council of Traditional Leaders at a national level and houses of traditional leaders at the level of provinces. 30 Their role will be set out in national and or provincial legislation. In terms of the Interim Constitution these structures had been entitled to advise and make proposals to legislatures or to government on matters relating to traditional authorities, indigenous law or the traditions and customs of traditional communities. However, whether this recognition is only symbolic or whether a real governmental function has been carved out for traditional leaders in the new Constitution still has to be fully interpreted by the courts. Concerning the creation of public awareness around the Constitution, for purposes of litigation, and in the context of the socio-economic history of South Africa, it is acknowledged that the new government cannot do all at once. For this reason, civil society through non-governmental structures still has an important role to play in popular education around the Constitution and in the creation and promotion of a human rights culture in South Africa. Much of the constitutional litigation brought before the Constitutional Court has been a direct result of the efforts of such nongovernmental organizations and structures, providing legal aid and or representing parties and or acting as amicus curiae.



VI. Conclusion
 
During the Multi-Party Negotiations Process which ushered in the new le-  [*1289]   gal order, many in South Africa argued against the recognition of customary law. Many in the women's movement particularly expected the Bill of Fundamental Rights and Freedoms to purge customary law of all provisions which have a discriminatory effect on women and unmarried persons. Today, however, the demands for the restoration and revival of African symbols of respect, pride and dignity as part of the widespread call for an African renaissance has infused a new level of realism in the customary law question.

To an extent it is accepted that customary law is a living law which affects millions of South Africans. It can therefore not be wished away. Nhlapo has indeed observed that it is not so much the recognition of the system which is the source of tension, but the technical difficulties that arise from such recognition. 31 Precedents in neighbouring jurisdictions like Zimbabwe, Botswana, Zambia and Swaziland are not always helpful in this regard. Their constitutions have clearly insulated customary law from the application of the norms of equality. Indeed, though this may not be desirable as Bennett opines, 32 it is at least helpful for purposes of interpretation. The prospects for the harmonization of customary law with fundamental rights in the South African context awaits to be seen. In conclusion, it is my view that if customary law can survive the harmonization process, then all skepticism about its continued existence in a human rights legal order should become unnecessary.
 
 

FOOTNOTES:
Click here to return to the footnote reference.n1. S. Afr. Const. (Act 200 of 1993), preamble.

Click here to return to the footnote reference.n2. S. Afr. Const. (Act 200 of 1993), sched. 4. For the full text of schedule 4, see Appendix A, at 41 St. Louis U. L.J. 1319 (1997).

Click here to return to the footnote reference.n3. See Ex Parte Chairperson of the Constitutional Assembly: In re Certification of the Amended Text of the Constitution of the Republic of South Africa 1996, 1997 (1) BCLR 1 (CC) (second certification). For the result of the first submission, see Ex Parte Chairperson of the Constitutional Assembly; In re Certification of the Constitution of the Republic of South Africa, 1996 (4) SA 744 (CC) (first certification).

Click here to return to the footnote reference.n4. S. Afr. Const.

Click here to return to the footnote reference.n5. S. Afr. Const. ch. 2. See also 7-39.

Click here to return to the footnote reference.n6. Id. at 7(1).

Click here to return to the footnote reference.n7. Id. at 7(3).

Click here to return to the footnote reference.n8. Id. at 36.

Click here to return to the footnote reference.n9. The South African Law Commission is currently embarking on an ambitious program of harmonizing customary law with Roman-Dutch Common Law. The goal of the program is to bring the two systems in line with the new Constitution. Papers dealing with the position of children under customary law and marriage under customary law have already been released by the Commission for public comment.

Click here to return to the footnote reference.n10. Act 38 of 1927.

Click here to return to the footnote reference.n11. 31 of Act 38 of 1927.

Click here to return to the footnote reference.n12. See Yvonne Mokgoro, Traditional Authority and Democracy in the Interim Constitution, 3 Rev. of Const. Stud. 60 (1996).

Click here to return to the footnote reference.n13. See generally, M. Van Diepen, The National Question in South Africa (1989).

Click here to return to the footnote reference.n14. There were major provisions which seem to result in its elevated status in the interim Constitution, such as 181 which explicitly recognizes traditional authorities and customary law and 31 which formed part of Chapter 3 provided: "Every person shall have the right to use the language and participate in the cultural life of his/her choice." See also 33(2), 33(3), 35(3) and 182.

Click here to return to the footnote reference.n15. Id.

Click here to return to the footnote reference.n16. Id. at 8.

Click here to return to the footnote reference.n17. Id. at 33.

Click here to return to the footnote reference.n18. S. Afr. Const. (Act 200 of 1993) ch.3, 7-35.

Click here to return to the footnote reference.n19. Id. at 3(3).

Click here to return to the footnote reference.n20. S. Afr. Const., ' 35.

Click here to return to the footnote reference.n21. 1996 (2) SA 898 (CC).

Click here to return to the footnote reference.n22. 1997 (2) SA 936 (CC).

Click here to return to the footnote reference.n23. S. Afr. Const. (Act 200 of 1993), sched. 4. For the text of schedule 4, see Appendix A, 41 St. Louis U. L.J. 1319 (1997).

Click here to return to the footnote reference.n24. See, e.g., T. Nhlapo, African Customary Law in the Interim Constitution, in The Constitution of South Africa from a Gender Perspective 156-66 (Sandra Liebenberg ed., 1995).

Click here to return to the footnote reference.n25. S. Afr. Const., 8.

Click here to return to the footnote reference.n26. The South African Law Commission's Project 90, Discussion Paper, The Harmonisation of the Common Law and Indigenous Law 74 (1997).

Click here to return to the footnote reference.n27. S. Afr. Const., 167.

Click here to return to the footnote reference.n28. Id. at 181(1)(d).

Click here to return to the footnote reference.n29. Id. at 181(1)(c).

Click here to return to the footnote reference.n30. Id. at 12; S. Afr. Const. (Act 200 of 1993), 182.

Click here to return to the footnote reference.n31. Nhlapo, supra note 24.

Click here to return to the footnote reference.n32. T.W. Bennett, Contemporary African Customary Law in Southern Africa 26 (1985).

 

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