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OpenAI, Modern Slavery in Global Supply Chains: The situation of Tea Workers in Bangladesh and Cocoa Farmers in Ivory Coast, Digital image Introduction:   How many times have we casually drank our morning tea or bitten into a piece of chocolate after unwrapping it without wondering about the farmers who produced it? Probably more frequently than we would like to think. Unfortunately, while tea and chocolate appear to be benign commodities intended for public consumption, the reality is far from perfect. There are untold tales of injustice and exploitation concealed behind these everyday indulgences. The production of tea and cocoa is supported by modern-day slavery as they involved child labour, wage inequities, and systematic human rights abuses in countries like Bangladesh and Ivory Coast. These industries, which are frequently idealised or taken for granted, are tightly regulated by a small number of strong businesses that make enormous profits, while the workers at the bottom of the supply chain continue to be ensnared in cycles of contemporary slavery. To combat the crisis faced by these two industries, government, international corporations and other non-state actors should step up and take initiative to address this global injustice.   The Plight of Tea Workers in Bangladesh:   Tea workers represent one of the most marginalized and vulnerable populations, possessing minimal access to the rights provided by the state. According to the latest gazette published by the Bangladeshi government, tea workers earn 170 taka per day, which is slightly more than $1. For category B and category C garden, the wage is 169 taka and 168 taka respectively. Workers on tea plantations are more vulnerable since they sometimes have to depend on their employers for housing, food, and education. Additionally, they face more difficult working conditions than in the past because of the rising temperatures and heavy rains, which make it harder for them to reach the daily quota. In August 2022, tea workers went on strike , demanding Tk300 per day. In response to the tea workers' movement, the wage was increased by Tk50, to Tk168-170. But is 170 taka enough to support life in a country with a per capita income of $2784?   In an interview with Drik News , Khairun Akhter, a young woman who was at the center of the protest, described the problems experienced by tea workers due to low wages. They can only afford to eat rice and lentils once a day; the rest of their meals are dry items such as puffed rice or chira. They cannot afford nutritional foods and can only eat meat once or twice a year due to the expensive cost.   With the economy of Bangladesh experiencing steadily rising inflation, the initial demand of 300 taka is not met, hence the agreed upon amount of 170 taka is insufficient for the tea workers.   Ivory Coast’s Cocoa Industry - A Sweet Product with a Bitter Origin:   The biggest cocoa producer in the world, Ivory Coast's cocoa bean industry has a darker side that is not concealed by the shiny chocolate wrappers. When consumers eat chocolate, they often associate it with European premium goods from Belgium or Switzerland. However, the dreadful story of how cocoa beans are made is forgotten, despite the fact that the raw material is sourced from small, hard-working farms, many of which employ children.   The majority of the 2.1 million children who work on cocoa farms in Ghana and Ivory Coast are most likely exposed to the most extreme forms of child labour. Most of the youngsters that labour on cocoa fields are between the ages of twelve and sixteen, however some might be as young as five. Additionally, 40% of these children are girls who go on to work on cocoa plantations as adults. Shifting demand and downward pressure on prices put cocoa growers at peril of an uncertain income. In the 1970s, cocoa producers received half of the value of a chocolate bar. That percentage has since decreased to just 6%, though. In contrast, chocolate prices increased by 14% in 2023 reflecting a system where profits bypass the producers. The Supply Chain Bottleneck: While Bangladesh's middle-class and upper-middle-class citizens are able to share their workload over a hot cup of tea, the labourers who cultivate it rarely get to enjoy such comforts. Similar circumstances apply to cocoa farmers, the great majority of whom work their entire lives growing cocoa yet have never had a chocolate bar. This disparity raises critical questions about the ethical limitations of global supply chains in these industries, where structural inequalities make it nearly impossible for the producers to access the very products they help create. In the Ivory Coast alone, there are about half a million tiny, family-run farms that are the starting point for the production of cocoa . Because things like breaking pods and fermenting beans are done by hand, the process is very labour-intensive. The story of chocolate resembles an hourglass: at the beginning, there are millions of small-scale farmers producing cocoa, and at the end, there are millions of consumers enjoying chocolate. But at the centre of this hourglass lies a bottleneck controlled by a handful of powerful corporations. Cargill, Barry Callebaut, and Ofi — these three companies dominate the industry, collectively purchasing and processing nearly 60% of the world’s cocoa. These companies then supply chocolate to major brands like MARS, Mondelez, Ferrero, Hershey, and Nestlé, which account for nearly half of global chocolate sales. The story of Bangladesh's tea business is similar. For more than 180 years, tea has been grown throughout the nation as the second most important cash crop after jute. With 167 tea estates spanning roughly 279,507 acres, Bangladesh currently produces 67,400 tonnes of tea annually on average. Approximately 1.5 million people are actively employed in this sector, and many more are indirectly connected. Alongside an increase in imports, domestic tea consumption has skyrocketed, rising from 18,190 tonnes in 1990 to 67,031 tonnes in 2016. Tea makes up 1.89% of global production and contributes 1% to the GDP. However, the industry's success obscures the difficult conditions that tea workers must endure. Despite promises of benefits such as medical funds and retirement allowances, workers often live in dire conditions , receiving only 3 kilograms of rations per week, which leaves many perpetually undernourished. Additionally, 46% of adolescents in tea-growing communities face child marriage, and 15% of women suffer from cervical cancer. In Bangladesh, well-known tea brands including James Finlay, Duncan Brothers, and Ispahani Mirzapore have a significant amount of market power . Only Ispahani controls 50% of the market for nationally branded tea and 80% of the branded tea bag market. The Ispahani Group, which has a 202-year history, has diversified into textiles, IT, and agricultural, bringing in Tk 20 billion annually. The enormous revenues have not been able to improve the lives of the tea workers who make this success possible, despite significant investments of Tk 1.3 billion in a state-of-the-art tea factory in Gazipur and Tk 2.5 billion in textile expansion in Chattogram. Structural Similarities and Intergenerational Injustice: The similarities between the exploitation of labour in the Ivory Coast’s cocoa plantations and Bangladesh’s tea plantations are stark. Both systems rely on systemic controls that strip workers of their agency, perpetuate economic dependency, and deny future generations the opportunity for upward mobility. In the Ivory Coast, farmers are trapped by global market structures that favour exporters and middlemen, while in Bangladesh, workers are confined by the plantation system’s rigid hierarchies . In both cases, child labour emerges as a tragic consequence of systemic exploitation, with families prioritizing immediate survival over long-term prospects. These practices not only sustain economic inequality but also reinforce the generational cycles of poverty and marginalization that characterize modern slavery. Conclusion:   As supply chains are based on structural inequality and labour exploitation, the tea and cocoa industries serve as a stark reminder of the negative aspects of globalisation Addressing these issues requires dismantling the structural inequalities that underpin these exploitative systems and providing workers with fair wages, access to education, and alternative opportunities for livelihood than merely making token gestures of corporate responsibility. To live with the respect, rights, and financial stability they deserve, governments must enforce stronger labour laws, companies must ensure fair pricing and wage structures, and international institutions must hold supply chains accountable.

OpenAI,  Illustration of Ecotourism in Bangladesh: Sustainability and Implications ( ChatGPT, 26 May 2025) Introduction: Ecotourism is a sustainable form of natural resources-based tourism that focuses primarily on experiencing and learning about nature. It ethically manages to be low-impact, non-consumptive, and locally oriented while contributing to conserving or preserving such areas . It is more of a purposeful event in the natural areas, which creates an understanding of the cultural and natural history of the environment, safeguarding the integrity of the ecosystem while producing economic opportunities to make the conversion of natural resources beneficial to local people. Bangladesh boasts unparalleled ecological diversity, featuring the breathtaking Sundarbans mangrove forest, a UNESCO World Heritage Site , the world’s longest uninterrupted beach of Cox’s Bazar, and the serene hills of Bandarban and Rangamati, making it a promising destination for Ecotourism. Ecotourism offers a chance to balance environmental conservation with community empowerment as the country struggles with poverty, degraded rural economies, and ecological deterioration. The author has explored Bangladesh's potential for Ecotourism, outlined the country's current legal and regulatory environment, and evaluated the obstacles to sustainable Ecotourism in Bangladesh in this blog. The author goes on to describe global Ecotourism best practices as well as strategies for developing sustainable Ecotourism in Bangladesh. Bangladesh’s Ecotourism Potential: The potential and sustainability issues of ecotourism must be taken into account in order to determine whether Bangladesh is making sustainable use of its natural beauty. These challenges can be improved through strategic measures such as strict regulations on waste management, promoting community-based tourism, and investing in eco-friendly infrastructure. Currently, tourism contributes only 4% to our GDP . Bangladesh provides a distinctive fusion of biodiversity and natural beauty, demonstrating the potential for growth through sustainable ecotourism. The country is home to various wildlife because of its verdant forests, picturesque river sceneries, and sun-drenched beaches along the Bay of Bengal. Monkeys, langurs, gibbons, otters, mongooses, Asiatic elephants, leopards, and the Royal Bengal Tiger are among the famous animals that call this place home. With more than 600 bird species and a wide range of reptiles, Bangladesh is a unique location for the growth of ecotourism, which is based on respect for the environment and culture. However, according to the Bangladesh Tourism Board (BTB), Bangladesh hosted around only 650000 foreign tourists last year. At the same time, our neighbouring countries, India, Nepal, and Sri Lanka, attracted 9.24 million, 1.0 million, and 1.5 million foreign tourists, respectively. This number is disheartening, as the tourism sector has failed to reach its potential compared to other regional countries. Ecotourism is significant because it promotes nature conservation, community participation, profitability, environmental sustainability, social and cultural integrity, and economic well-being by preserving the natural environment and promoting sustainable tourism. If managed sustainably, it can uplift rural economies by creating jobs in guiding, hospitality, and handicrafts while balancing the preservation of ecosystems with community benefits. Bangladesh has taken specific initiatives for sustainable Ecotourism, such as community-based tourism in Bandarban, which could empower indigenous groups like the Chakma and Marma tribes, who currently see limited financial benefits, but this sector still needs more exploration. Existing Legal and Regulatory Framework: Ecotourism and its potential are governed by a number of laws and regulations, but their effective use is hampered by significant barriers. The Constitution of Bangladesh emphasizes the state's responsibility to protect and improve the environment, biodiversity, wetlands, forests, and wildlife for current and future generations. Among the key policy documents the National Tourism Policy (NTP) 2010 plays a pivotal role tourism sector by focusing on sustainable development, community participation, and environmental protection. The Environmental Conservation Act 1995 is essential for environmental protection and sustainable resource management, particularly relevant to ecotourism development as its directly aligning with ecotourism goals. The Bangladesh Wildlife (Preservation) Act 1974 protects wildlife and their habitats, regulating hunting, poaching, and wildlife trade. Additionally, the Forest Act of 1927 governs the management and use of forest resources, including those within protected areas. The Protection and Conservation of the Environment Ordinance, 1990 addresses various environmental concerns by addressing a broader range of environmental issues. The National Tourism Policy 2010 which includes several key activities, such as renovating and developing airports for both domestic and international flights, ensuring traveller safety, and identifying and maintaining tourist spots nationwide. They aim to expand ecotourism destinations while preserving resources, raise public awareness through community activities, and involve local government in promoting Ecotourism. The plans also focus on improving tourism infrastructure through partnerships, monitoring industry performance, building economic sector capacity, and establishing tourism training centres. Complementing these efforts, the Bangladesh National Conservation Strategy also provides a comprehensive framework for environmental conservation and sustainable development, including Ecotourism. It identifies gaps in existing policies and recommends reform. Challenges to Sustainable Ecotourism in Bangladesh: Implementation and enforcement of these regulations remain a challenge despite having laws and a regulatory framework due to factors like – the lack of enforceable sustainability certification for resorts, insufficient monitoring of eco-friendly practices and disrupted coordination between government agencies and private operators. There is not enough visibility into capacity building among stakeholders, including local communities, tour operators, and government agencies. Poor tourist experiences and irresponsible behaviour can lead to environmental pollution and degradation. For instance, the Sundarbans and Cox’s Bazar suffer from plastic waste, untreated sewage discharge, and noise pollution from tourists, which disrupt wildlife habitats and crucially degrade the environment in tourist areas. According to Landsat Normalized Difference Vegetation Index (NDVI) analysis , unplanned urbanization caused 33.4% of vegetation loss from 2000 to 2015. The principles of Ecotourism are also disregarded due to a lack of local participation and awareness of the concept, hindering the success of ecotourism initiatives. A high count of visitors beyond the carrying capacity hampers the sustainability of the resources. Not only that, but Ecotourism in Bangladesh faces several constraints, too. The concept of Ecotourism focuses on natural habitats, local cultures, and serene sites, with local or indigenous people influencing tourists positively. However, the absence of help from indigenous people and local riots can cause fear and negativity in the minds of tourists. There are many government and private tour operators in Bangladesh, but the majority only offer traditional package trips instead of encouraging genuine ecological experiences. Many tour guides, transportation companies, and support personnel are not properly trained or knowledgeable about ecotourism concepts. Poor service quality and perhaps unfavourable social contacts with local populations are common complaints from tourists. The safety and appeal of ecotourism destinations are diminished by the frequent inaction of law enforcement agencies. Although hotels, motels, resorts, and private guesthouses engage in ecotourism-related activities, the entire ecotourism experience is undermined by their frequent lack of uniform pricing, consistent service quality, and appropriate visitor advice.   International Best Practices in Ecotourism: While maintaining sustainability in Ecotourism is challenging, Bangladesh can take inspiration from several countries like Costa Rica, Bhutan, Norway, and Nepal. For example, Costa Rica generates 5% of its GDP revenue powered by strict certifications like Certification for Sustainable Tourism (CST), which ensures environmentally responsible practices. Bhutan mandates a daily tourist fee (USD 200-250) to fund conservation and community projects. Norway involves local communities in managing fjord tourism to ensure adherence to emission standards and equitable profit-sharing. The introduction of the buffer zones program , due to significant investment in plantation and forest-management initiatives, became a promising factor for forest conservation and ecotourism, as seen in Chitwan National Park in Nepal. Buffer zones in Nepal were established to provide forest resources that had not been plundered from national parks/ wildlife reserves. Nepal’s Buffer Zone Management Regulation 1996 granted rights to local people for community development, forest management, and buffer zone utilization to stimulate public involvement to conserve resources and reduce park-people conflict. Local People also obtained various social and economic benefits from protected areas, and such areas raised income via tourism-related employment or affiliated markets, which could be spent on household assets. Bangladesh can use such strategies in environmentally delicate areas to improve community well-being and environmental preservation. Implementing balanced pricing structures, incorporating local or tribal councils in governance, and introducing certification systems could all be useful and reasonably priced ways to encourage sustainable ecotourism in the nation. Approaches for Achieving Sustainable Ecotourism in Bangladesh: Achieving sustainable Ecotourism requires a multifaceted approach to environmental conservation, community involvement, and responsible tourism practices. This includes minimizing the environmental impact of tourism, empowering local communities, educating visitors about conservation, and ensuring long-term ecological and socio-economic benefits. To revolutionize the whole ecotourism industry for sustainability and proper implementation of the legal framework, Bangladesh can take several steps , including educating locals about Ecotourism, implementing law enforcement measures for site safety, providing adequate restrooms and refreshment zones, implementing proper waste management system, energy efficiency, and habitat restoration to mitigate the adverse environmental effects of tourism. Addressing unauthorized construction, training tour operators and service providers, implementing punitive actions for eco-tourist violations, the establishment of visitor limits in sensitive areas to prevent ecological degradation and ensuring economic benefits for local/Indigenous people etc. Collectively, these measures aim to preserve the integrity of ecotourism destinations while promoting responsible practices that protect Bangladesh’s natural heritage for future generations. Conclusion: Ecotourism in Bangladesh has enormous potential as a sustainable tourism model. Still, its success depends on striking a balance that gives equal weight to environmental protection, community well-being, and financial sustainability. Although it can be an effective means of creating employment, its real value is cultivating a profound love and respect for the natural world and enabling rural and indigenous communities to take charge of their own ecological and cultural legacy. Despite Bangladesh's abundant natural beauty, from the Sundarbans to the hill tracts, there are still many obstacles to genuinely sustainable Ecotourism, such as a lack of awareness, policy flaws, and infrastructure deficiencies. A thorough and inclusive strategy backed by effective governance and community involvement is necessary to make Ecotourism a long-term, sustainable activity.

1. INTRODUCTION The majority of war reports focus on infrastructure loss, displacement, and casualties. But in the midst of Gaza's destruction, another silent crisis unfolds: the suffering of stray animals. Israeli bombardment, blockades, and the absence of basic necessities have put innocent animals like cats, dogs, donkeys, and birds who were already at risk before the war—at risk of malnutrition, trauma, and death. Their plight is not just a humanitarian footnote but a notable indicator of systemic legal neglect and societal breakdown.    This blog uses a socio-legal lens to analyses how the war has affected Gaza's stray animals. In addition to highlighting the extent of the destruction and the lack of accountability in Gaza, it argues that recognising animal suffering is not only a matter of compassion but also reveals violations of international humanitarian law, reflects the larger collapse of protective institutions, and demands interdisciplinary legal reforms and immediate humanitarian support.     2. STRAY ANIMALS: THE OVERLOOKED VICTIMS  Stray animals are commonly exposed to violence and deprivation, victims of starvation and disease, suffering from trauma, with mass death in captivity as a result of a collapsed protection system. 2.1 Exposure to Violence and Deprivation, Starvation and Disease: Stray animals in Gaza face the same horrors as humans: bombings, starvation, and forced displacement. The Israeli military’s destruction of infrastructure has left animals without food, water, or medical care. Veterinary clinics have been bombed , and rescue efforts are nearly impossible due to siege conditions.  The war has made Gaza into a humanitarian catastrophe and animals are suffering just as severely as humans. With nearly 90% of the population struggling to find food, pets and strays are left to scavenge through rubble or slowly starve. Sulala Animal Rescue , the only organization dedicated to animal welfare in Gaza, has reported heartbreaking scenes such as dogs and cats collapsing from malnutrition, untreated wounds festering, and countless animals dying in silence. Without access to basic supplies like food and medicine, even the most resilient creatures are succumbing to the harsh conditions.    2.2 Trauma: The constant roar of explosions and gunfire hasn’t just shattered buildings, it has broken the spirits of Gaza’s animals. Veterinarians and rescuers describe dogs shouting violently, paralyzed by fear, while cats cling to the ruins of homes where their families once lived. These animals aren’t just physically injured, they are traumatized , displaying behaviours akin to PTSD (Post-Traumatic Stress Disorder). Many refuse to leave the debris, as if waiting for owners who will never return. The psychological toll of war is often overlooked, but for creatures with no understanding of conflict, the terror is relentless and inescapable.   2.3 Mass Deaths in Captivity:  Even animals that once had shelter haven’t been spared. Gaza’s zoos, farms, and equestrian centers have been destroyed. At Gaza City’s Zoo, 90% of the animals vanished , some in bombings, others from starvation as keepers fled or were killed. Horses, once symbols of pride and livelihood, now lie dead in their stables or in the streets, their bodies too often left where they fell.   2.4 A Collapsed Protection System: The plight of Gaza's stray animals is not a singular tragedy; rather, it is a reflection of the complete social breakdown of the region. Bombs have destroyed the urban and natural settings that formerly supported life, turning neighborhoods into wasteland. Raw sewage can flood streets and seep into the ground since water treatment facilities are in ruins. Desperate to stay hydrated, strays unintentionally poison themselves by licking at tainted puddles. The same toxic water that sickens children also kills animals slowly, linking their fates in a vicious cycle of neglect.   This ecological breakdown goes beyond immediate hunger or thirst. With no functioning waste management, mountains of garbage rot in the open, attracting rodents and spreading disease among both humans and animals. Strays weakened by malnutrition now face outbreaks of parvovirus, mange, and respiratory infections, ailments that would be treatable under normal conditions. But "normal" no longer exists in Gaza. The few remaining veterinarians work in makeshift clinics, lacking even basic antibiotics, while rescuers plead for international aid that rarely comes.   Gaza's animals perish due to the same structural flaws that cause its human population to struggle for survival without access to clean water, electricity, or hospitals. Once dependent on market scraps or the generosity of people, strays now roam a landscape devoid of even those bare lifelines. Their misery is a clear sign that the infrastructure has been overburdened and serves as a living example of how war kills not only with guns and bombs but also with the wilful destruction of all that supports life. In the meantime, strays will have less scraps to live on due to the nearly complete loss of cropland (80% of tree cover lost). 3. LEGAL BLIND SPOTS Even though it's absurd to ask for legal protection for stray animals where the lives of human beings do not matter to the world, we can still find some legal blind spots below.   3.1 International Law’s Failure to Protect Animals in War and the Absence of Direct Legal Status for Animals: International law has systematically failed to adequately protect animals during armed conflicts, particularly unowned or stray animals, due to the anthropocentric design of International Humanitarian Law (IHL) and the absence of direct legal status for animals. Even though the Geneva Conventions and the Universal Declaration on Animal Welfare (UDAW) nominally acknowledge animal protection, however, implementation remains largely nonexistent, especially for animals not classified as “property” or "civilian objects" such as livestock .   The Geneva Conventions primarily focus on minimizing harm to civilians, with animals only receiving incidental protection when categorized as objects either as “military targets”, “components of the environment”, or “cultural property” rather than as sentient beings deserving intrinsic consideration. This legal framework leaves stray animals in a particularly vulnerable position, as they fall into a jurisdictional void , lacking both ownership-based protections and recognition under IHL’s limited environmental provisions. The current system’s deficiencies stem from its failure to account for animal sentience, its reliance on outdated property classifications, and its high thresholds for environmental damage , which rarely trigger meaningful safeguards.   Consequently, animals continue to suffer mass casualties, exploitation as military tools, and ecological devastation during conflicts, underscoring the urgent need for legal reforms that either reinterpret existing norms to include animal welfare or establish new, direct protections under international law.   3.2 Ecocide and Environmental Law: The Rome Statute recognizes "widespread, long-term environmental damage" as a war crime , yet no legal action has been taken despite Gaza’s ecological devastation, which directly affects animals. Al Mezan , an independent, non-partisan, non-governmental human rights organization based in the occupied Gaza Strip began recording and reporting on the terrible environmental effects of Israel's settler-colonial and apartheid government in Gaza well before October 2023. This encompasses the consequences of frequent, extensive military operations as well as the de-development measures put in place by Israel's 17-year-old siege and embargo of Gaza.  Their sufferings have been overlooked as stray animals are not covered by international humanitarian law or environmental law.   3.3 Accountability Gaps: Israel’s blockade on Gaza has created severe accountability gaps in the delivery of animal food and veterinary supplies, violating fundamental principles of International Humanitarian Law (IHL) that prohibit the starvation of civilians and their livestock as a method of warfare. The blockade's restrictions on animal feed which forcing Palestinians to repurpose it for human consumption, and denial of veterinary medicines have led to mass livestock deaths, exacerbating food insecurity and disregarding humane treatment obligations under the Article 55 of the Fourth Geneva Convention and the Universal Declaration on Animal Welfare. Despite the International Court of Justice’s (ICJ) rulings on mandating humanitarian access, Israel continues to obstruct aid convoys carrying animal-related supplies, with no meaningful enforcement from the international community.   This systemic obstruction may constitute a war crime under the Rome Statute and a breach of the Genocide Convention , given the deliberate infliction of conditions leading to mass animal and human suffering. The lack of legal recourse for aid groups and the destruction of agricultural infrastructure underscores the urgent need for accountability, including pressure to lift restrictions, enforcement of the ICJ rulings, and investigations into potential IHL violations.   3.3 Why Legal Recognition Matters: The absence of legal protections for animals reflects a broader failure to hold war perpetrators accountable. If even human rights violations go unchecked, animal suffering remains invisible. Legal scholar Sophia Stamatopoulou-Robbins argues that dehumanizing rhetoric (e.g., Israeli officials calling Palestinians "animals") reinforces this exclusion, justifying indiscriminate violence against all life in Gaza.    Filling in the legal void for crimes against animals and the ecocide could close accountability gaps. supports stricter international legislation pertaining to animal welfare and urges governments to reconsider their military and environmental strategies from a more responsible perspective.  This would provide protections for all sentient life affected by war.   4. CALL TO ACTION To safeguard animals impacted by the violence in Gaza and throughout Palestine, we urgently need both interdisciplinary legal reforms and immediate humanitarian assistance.   4.1 Interdisciplinary Legal Reform: Bridges between international humanitarian law, environmental law, and animal law are desperately needed in order to: Acknowledge stray animals as sentient, vulnerable beings. Provide them with fundamental protections in the event of armed conflict or environmental damage. Incorporate their well-being into evaluations of ecological effect, environmental damage, and moral warfare tactics. A strong basis for international legal reform is provided by Islamic law, which places a strong focus on kindness, self-control, and ethical warfare. The mistreatment of animals and destruction of the environment during war are not only ethical concerns but also violations of divine law. Islamic teachings emphasize compassion and accountability toward all living beings. The Prophet Muhammad (peace be upon him) prohibited the killing of animals without cause, even during armed conflict, and condemned the destruction of trees and natural resources. These principles establish a moral and religious duty to protect life, aligning with calls for legal reforms. Integrating such religious ethics into international discourse can strengthen the moral imperative behind legal accountability for wartime ecocide and animal suffering. Specifically, animal protection during wartime in Islamic law emphasize the humane treatment of animals even in times of war, with specific prohibitions and guidelines reflecting compassion and ethical responsibility:   The Geneva Conventions need to be changed to specifically protect animals in conflict areas. Whether they are wildlife, livestock, or companion animals, these helpless creatures are all too frequently overlooked victims of human conflict. They experience intentional cruelty, famine, displacement, and bombings, and there is no legal system in place to bring those responsible for these crimes accountable. Why do we overlook the same misery imposed on animals if we acknowledge the atrocities of war on humans? The rules of war need to change. By advocating for these reforms, we can guarantee that compassion transcends species boundaries and that conflict-related violence against animals is regarded as a grave transgression. How well the world protects its most vulnerable citizens is a good indicator of its moral development. This isn’t just policy, it’s justice.    4.2 Aid for Animals: Animals in Gaza are starving, wounded, abandoned and cut off from even the most basic medical care at this very moment. While human suffering rightly dominates headlines, these voiceless victims of war endure the same bombs, the same siege, and the same collapse of infrastructure. But Israeli invaders are blocking veterinary aid. Medicines, vaccines, and emergency supplies sit stalled at borders while animals die in agony. This isn’t just about compassion, it’s about persistency. If we accept that all life has value, then aid shouldn’t stop at species lines. Field hospitals for humans exist; why not for the animals caught in the crossfire? Pressure them now: Lift restrictions on veterinary aid entering Gaza. Fund mobile clinics to treat injuries, disease, and malnutrition. Include animals in ceasefire negotiations and humanitarian corridors.   5. CONCLUSION: JUSTICE BEYOND THE HUMAN The suffering of Gaza’s stray animals is not a secondary issue, it is a lens through which we see the war’s full brutality. Their neglect in international law reflects a hierarchy of compassion that devalues non-human life, reinforcing cycles of violence.   Recognizing animal suffering does not diminish human tragedy; it expands our understanding of justice. If even the most vulnerable beings are acknowledged, perhaps accountability for all war crimes human and environmental will follow. As Neha Vora writes , " Palestine’s trauma is a multispecies trauma. To ignore it is to accept a world where destruction knows no limits .”

This picture is taken from Doctors Without Borders/Médecins Sans Frontières (MSF) 1.   Introduction   The refugee crisis is one of the most talked-about issues in the modern world. The main topic of controversy in Bangladesh is the intricacy between the country's domestic legislation and the international law governing refugees. Despite having a customary international law obligation , Bangladesh does not have a comprehensive refugee law and is not a signatory to either the 1951 Refugee Convention or its 1967 Protocol. Consequently, issues such as the lack of legal duties to refugees, the uncertainty surrounding the duration of their stay, and national security concerns remain unresolved.    The crisis started in August 2017 when the Rohingya were forced to evacuate the Rakhine (formerly Arakan) state due to a crackdown by the Myanmar military. Despite Bangladesh's admirable humanitarian efforts, national security issues are becoming more and more prominent.   In order to manage the Rohingya crisis in a way that upholds both national interests and human dignity, this blog explores how the convergence of international and national legal standards, changing geopolitical dynamics, and growing security concerns demand for a thorough and organised approach for policy development.   2.   Gaps in Legal Protection and Emerging Security Concerns: The Rohingya Challenge in Bangladesh   Bangladesh recently extended its hand to the Rohingya following the 2017 military crackdown in Myanmar's Arkane state; yet, the country's national security is at risk due to the Rohingya refugees' unlawful activities and a legal responsibility and protection vacuum.   2.1 International Legal Framework :   Internationally, refugee protections are governed primarily by the 1951 Refugee Convention , the 1967 Protocol , and the United Nations High Commissioner for Refugees (UNHCR). The 1951 Convention defines the term “refugee” (Article 1) and outlines a series of rights, including:   • Freedom of religion (Article 4) • Access to courts (Article 16) • Right to work (Articles 17–19) • Housing (Article 21) • Education (Article 22) • Public relief and assistance (Article 23) • Freedom of movement (Article 26) • Identity and travel documents (Articles 27–28) • Protection from penalties for illegal entry (Article 31) • Protection from expulsion (Article 32) • Protection from refoulement (Article 33)   The 1967 Protocol removed the Convention’s original temporal and geographic limitations, thereby broadening its applicability. However, obligations for refugees are comparatively minimal. While refugees must respect the laws and regulations of the host country, there is little clarity on enforcement mechanisms or consequences for violations that do not qualify as international crimes. This raises critical questions like What happens when refugee actions threaten national security but don’t constitute crimes under their own national laws? How long can, or should refugees be allowed to stay in a host country?   2.2 National Legal Framework:   Bangladesh lacks a specific legal framework to address refugee matters. Though several laws touch upon immigration and foreign nationals, such as the Passports Act, 1920, Foreigners Act, 1946, and the Citizenship Order, 1972, but none provide a comprehensive policy for refugee protection or obligations. Bangladesh is also not a party to the 1951 Convention or the 1967 Protocol. As a result, Rohingyas are not formally recognized as refugees under domestic law. Additionally, the fundamental rights enshrined in Articles 26 to 47A of the Constitution of Bangladesh are not explicitly extended to non-citizens.   A growing number of crimes involving some refugees, such as drug trafficking, violence, and people smuggling, are a result of this legal void. Such problems can exacerbate tensions and threats to internal stability if there are no legal time limits or geographic restrictions for settlement. Other urgent questions are brought up by this situation, such as, If a refugee risks national security, what legal requirements are applicable? Under Bangladeshi law, what are their rights? How should Bangladesh react if a refugee's actions endanger security but are not prohibited by the laws of their home country?     3.     Current Developments in the Rohingya Refugee   Despite some encouraging diplomatic developments between Bangladesh and Myanmar, obstacles still stand in the way of voluntary repatriation, particularly with regard to the safety, citizenship, and dignity of returning refugees. Security issues are being raised for both the host and refugee populations at the same time by the rise in illicit activities in the camps, such as drug trafficking, human smuggling, and the growing influence of insurgent organisations like ARSA.   3.1 Repatriation Efforts:   According to a list provided by Bangladesh, Myanmar confirmed in April 2025 that 180,000 Rohingya refugees are eligible for repatriation. A list of 800,000 refugees from 2018 to 2020 was already submitted by Bangladesh . Additionally, Myanmar stated that final verification is still pending for an additional 70,000 people and promised to speed the review of the remaining 550,000. Many Rohingya demands that all refugees should be permitted to return with full citizenship and privileges, notwithstanding these declarations, and they remain sceptical due to concerns of persecution, previous attempts at repatriation in 2018 and 2019 were unsuccessful. Representatives of refugees have voiced their dissatisfaction , arguing that the scant confirmation is insufficient and calling for a thorough and sincere resolution to restore their legal status and dignity in Myanmar.   3.2 Security Concerns:   Security officials in Bangladesh have arrested Ataullah Abu Ammar Jununi, the commander of the Arakan Rohingya Salvation Army (ARSA), on charges of illegal entry, sabotage, and terrorist activities. ARSA is a Rohingya insurgent group involved in a conflict with Myanmar's military regime to protect Rohingya rights. The arrest occurred in Narayanganj near Dhaka, where security forces also seized items such as cash, a knife, and wristwatches. Additionally, 10 other ARSA members, including children and women, were detained in separate raids. Armed militant groups , primarily consisting of Rohingya individuals, have been abducting, torturing, and killing fellow refugees.   4.     Toward a Structured Response: The Need for Policy Development   As the saying goes, if you can't solve a problem, you must learn how to manage it. That means we need practical steps. Under international law , it is important to set clear rules on how long refugees can stay, where they can live, and what their responsibilities are. This would help protect Bangladesh’s national security while also ensuring refugees are treated fairly. Bangladesh should also consider joining international agreements on refugee rights. This would allow it to receive more support from other countries and improve its own laws with global guidance.   To address these issues, global organisations like UNHCR, IOM, Amnesty International, and local groups like RRRC and CPJ have suggested creating a special refugee law for Bangladesh. This law should reflect the real challenges on the ground and involve input from refugee communities. With such a law, Bangladesh can move beyond temporary solutions and set up clear rules and protections that balance both human rights and national security. Programs like the World Bank’s Private Sector for Refugees (PS4R) also show that giving refugees work opportunities can boost the economy and reduce crime. Allowing refugees to earn a living could help ease tensions and improve security within the country.   In short, establishing a clear refugee policy is not only the right choice, but also a timely and necessary step for ensuring Bangladesh’s long-term stability and progress.     5.   Conclusions   “Refugees didn’t just escape a place. They had to escape a thousand memories until they’d put enough time and distance between them and their misery to wake up to a better day.” – Nadia Hashimi , an Afghan-American novelist, captures the struggles of refugees in her quote , which highlights that they are people, have feelings, sorrow, and aspire to live like us and the fact that people do not choose to become refugees willingly.   Like all human beings, they are also subject to fundamental human rights. While it is the duty of a nation to prevent internal unrest and safeguard its national security, Bangladesh, as a country that promotes peace, must find a balance between these priorities to ensure both security and the humane treatment of refugees.

By Barrister Shahriar Yeasin Khan, Executive Editor, Map of Justice The image was created using AI   via Dall-E 2 . Autonomous Weapon Systems based on Artificial Intelligence As humankind continues to make unprecedented strides in technology in the 21st century, and with the growing proliferation of Artificial Intelligence (AI) in armed conflict situations, International Humanitarian Law (IHL) faces an urgent need to grapple with the applicability of the rules of warfare in relation to the use of Autonomous Weapon Systems (AWS) based on AI. Before delving further, some definitional aspects need to be clarified. AI refers to machines which are designed with specific algorithms that give them the capability to collect information, analyse them and to make decisions without requiring human intervention. In a way, AI seeks to mimic human intelligence through a complex process which includes machine learning and deep learning . There are various definitions as to what AWS are, and as of yet there is no globally agreed consensus on it. In simple terms, AWS are machines that can, once deployed, operate on its own through the use of AI without the need for further human supervision, and can thereafter collect data, analyse them, choose targets and apply force, lethal or otherwise. Land-mines and defensive missile systems also operate with some degree of autonomy. However, they should not be labelled as AWS because they require very specific and exacting trigger-situations within which they must operate; they do not have absolute autonomy in choosing a target; and they are not based on AI. Machines including drones that only use AI to collect and relay information, but are not able to deploy weapons on its own should also not be labelled as AWS. There are multiple terms used globally for AWS in various contexts such as ‘ killer robots ’, ‘ fully autonomous weapons ’, ‘ lethal autonomous weapon systems ’, ‘ lethal autonomous robotics ’, etc. Arguably a streamlined and consistent terminology is more helpful for the global community to relate to as it helps in creating momentum in international advocacy. It is hoped that a consensus can be reached in that regard amongst academics and relevant stakeholders. Issues with using AWS in armed conflicts The deployment of AWS is a very concerning matter, not least because there is a distinct possibility that the decision making of algorithm based machines may simply be incorrect because various nuances of a particular situation may need to be taken into account which a human may be better placed to do rather than machines. For example: a drone equipped with explosive munitions is deployed in a conflict zone to destroy an enemy military installation situated directly adjacent to a residential building occupied by civilians. In this case, dropping a bomb on the military installation runs the risk of killing civilians. If the drone is operated by AI, the concern is how will AI decide whether the bomb should be dropped or not?  Can the AI algorithm be designed in such a way whereby it can strike a delicate balance upon the principles of proportionality and military necessity in relation to the military advantage sought? Will there be a risk percentage within which the AWS can operate? Or for incidental loss of life to be considered excessive will there be a mathematical threshold based on rudimentary consequentialist moral reasoning? Furthermore, how much can AWS be relied upon to even distinguish civilians from combatants? In some situations combatants may disguise themselves in civilian clothes. Children growing up in various conflict zones are sometimes seen playing with toy guns. A machine may fail to uphold the principle of distinction in these scenarios. In an article at Just Security it was acknowledged that “the mere existence of the guidance, processes, and technologies to avoid civilian harm […] does not, in itself, solve the tragedy of collateral damage. They have to be employed in good faith […].” It is doubtful that there can be a mathematical algorithm for good faith. Eventually, if there is a ‘mistake’ by the AWS, and there was no possibility for a human operator to intervene and suspend the attack, in that case the machine itself cannot be held accountable for individual criminal responsibility under International Criminal Law. These are some of the many compelling issues about AWS that are yet to be resolved. The inevitability of the deployment of AWS In its June 2019 report on AI the ICRC stated that it is “not opposed to new technologies of warfare per se” provided that as a minimum requirement it “must be used, and must be capable of being used, in compliance with existing rules” of IHL and that it is “essential to preserve human control over tasks and human judgement in decisions that may have serious consequences for people’s lives in armed conflict”. In relation to AWS however, the ICRC has expressed serious concerns . In addition, the UN Secretary General on March 2019 stated that AWS are “politically unacceptable, morally repugnant and should be prohibited by international law”. Regardless of such concerns and opposition, arguments in favour of AI and AWS are also being proffered. Some claim that AWS may lend greater precision to attacks, minimise collateral damage, increase efficiency and save costs. In September 2019 the Director of the US Joint Artificial Intelligence Center expressed that AI will give them battlefield advantages and they will begin rolling out the technology in warzones. Militaries of other countries such as Israel , Russia and China are also developing their AI and AWS capabilities. In the 2019 report on AI the ICRC stated that “military applications of new and emerging technologies are not inevitable”, but they are “choices made by States”. It is submitted that it is inevitable that in the near future advanced military States will continue to develop the technology at an even greater pace and begin testing the use of AI and AWS in conflict situations, and it is unlikely that the deployment of AWS can be stopped. The immediate need for regulating the use of AWS Advanced military systems across the world are rapidly developing their AI and AWS capabilities without internationally agreed safeguards. On the other hand, although research is being done in relation to how IHL can be potentially updated and new rules promulgated to reflect the challenges posed by AWS, the progress has been relatively slow.  We do not yet know how exactly AWS may impact the on-ground situation in armed conflicts, given the paucity of empirical evidence at hand. The UN reported in 2021 , citing a confidential source that the Turkish manufactured STM Kargu-2, which the manufacturer itself considers a form of AWS, were deployed in Libya, but the UN report unfortunately lacks detailed information. It has also been reported that Azerbaijan have used AWS in its conflict with Armenia in the Nagorno-Karabakh region, but factual details are very scarce. Under the circumstances, the international community will not benefit from a reactive approach by waiting to see evidence of the implications of AWS before seeking to regulate it further. A more proactive approach is required. It should be noted that militaries across the world do not expressly deny that the use of AWS must be in conformity with IHL. However, despite their best efforts, and even best intentions, AWS which are able to learn by itself and change over time, may act in ways that may violate existing rules of IHL in the battlefield. Furthermore, there are massive risks that AWS may end up in the hands of non-state actors. Absent adequate safeguards, the risks are far too much. Therefore it is prudent that concerned organisations including the UN and the global civil society step up immediately and with greater fervour to ensure that whilst AI and AWS are still in this relatively nascent state of development, the international community agrees to a set of rules within which AWS can be developed and implemented. Otherwise the technology will jump ahead whilst the law remains lagging, and once a dangerous uncontrollable weapon is developed, the situation may very well be irreversible. When nuclear weapons were first developed, the world failed to completely stop its proliferation . We should not make the same mistake again. Enforcing human control in the deployment of AWS The final decision as to whether or not a human should be attacked in an armed conflict should lie on another human, and should not be delegated to a machine. Indeed it is an affront to human dignity that a human being is killed by the decision of a machine which “raises fundamental ethical concerns” as expressed by the ICRC in its May 2021 position paper on AWS. The ICRC also asserts that “ human control ” is essential for AWS to be compliant with IHL. The US Department of Defense’s Directive on AWS also states that AWS shall be designed to ensure “appropriate levels of human judgment over the use of force”. Apart from the ethical dimension, human control is also required to ensure accountability for any potential violations of IHL. Therefore it is imperative that an AWS should never be fully autonomous and human control must be ensured. Notably, there are strong arguments that AI cannot necessarily be designed with such an algorithm which can take into account cultural sensitivities and on ground realities to make context-based decisions and to reliably identify who is a civilian and who is not. Consequently, Article 51.4 of Additional Protocol I can be interpreted to suggest that since an AWS without human control has the potential to strike military objectives and civilians or civilian objects without distinction, it is inherently an indiscriminate weapon. Thus, arguably such a means or method of combat can be prohibited under IHL. Furthermore, the Convention on Certain Conventional Weapons already restricts the use of certain weapons. Considering the growing use of AWS, it can be potentially updated or an additional Protocol can be negotiated and adopted to contain express provisions that AWS always require human supervision before it can attack another human. A challenge to humanity and the need for global consensus At this juncture of human civilisation, human-made machines may soon reach a level of autonomy whereby they cannot even be controlled by humans anymore. AI is a very powerful tool and the technology is already at a very advanced stage. AI can process humongous amounts of data, can teach itself to do extremely complex analyses in milliseconds to a very high level of accuracy. A quick look at OpenAI’s ChatGPT and Dall-E 2 will inform the reader how advanced and potentially even scary current AI technology is. Therefore, as explained above, it is imperative that globally agreed standards are put in place for the development and use of AWS. Whilst a complete ban on AWS is perhaps ideal, it is acknowledged that the reality is that they are here to stay. Nonetheless, in developing AWS we must ensure, at the very least, that human supervision and control supersedes the autonomy of such machines. Consequently, any AWS should only have limited autonomy, and a fully autonomous weapon that can operate without human control should be declared illegal under International Law. If the term ‘AWS’ in that case seems impractical because the presence of human control entails that it can no longer remain truly autonomous, it is suggested that it can be called ‘Controlled-AWS’ (CAWS). The CAWS can therefore, in practice, identify targets and make suggestions, and humans can make the final decision whether to launch an attack or not. In the end, it is hoped that a fine balance between dogmatism and pragmatism can be reached by the global community, and concrete measures are put in place so that humans remain at the helm of civilisation, and not machines. P.S. This article was originally published by the International Law Blog   Link to the original article: https://internationallaw.blog/2023/01/16/autonomous-weapon-systems-and-the-changing-face-of-international-humanitarian-law/

Introduction: The beginning of forest laws in Bangladesh can be traced back to the 18th– 19th century when​ the entire Indian subcontinent was controlled by British colonialism. Over time, these laws have been reformed, and repealed, as per the demands of time and environment, albeit, both effectively and ineffectively. Forests play a central role in the history of many civilizations as places, as renewable resources, and as symbols of nature to which humans belong and have migrated from. The impact of human activities on forests has been a common topic of discussion and research. However, it is quite rare to find existing literature on how the degrading health of the forest in turn affects human lives and health. Over the last couple of decades, a direct link between the health of the forest and human have seldom been threaded out. This interdisciplinary and interconnected issue between the social and natural sciences evinces how the most vulnerable and socially and economically backward communities and people suffer the first, the most, and the worst consequences of environmental degradation. This blog overlooks the laws and policies crucial in regulating and maintaining forests in Bangladesh and further explores the impact on human health of the implementation, or lack thereof, of these laws and policies. Connecting Forests, Laws, State, and Human: Bangladesh has numerous laws and policies regulating the forest and environment, incorporating the principles of multiple international conventions and protocols in order to safeguard forests and wildlife. Some of the provisions in the existing laws and policies below highlight the evolution and importance of forest protection. In 1894, the colonial British government announced the first official forest strategy for the Indo-Pak region, which provided the basis for creating laws and regulations for forest management and exploitation during this time. Even the rate of forest exploitation increased their authority, with little significance given to resource conservation or preservation. This strategy primarily prioritised crop production, and encouraged the quick conversion of forest areas to agricultural use, and served as the foundation for the legal classification of key forest-related regulations, and the first Forest Act of 1927. While these regulations assisted in bringing forest management under government oversight, their primary goal was to increase forest revenue by appointing feudal lords to manage various forest zones. Unfortunately, despite the advent of institutional management, the state’s economic interests continued to dominate its activities; the overall forest health was not enhanced. This foundation of economic exploitation was grounded deeply within the minds of the people. Thus, the aim of this law, which was to codify the laws ‘relating to forests, the transit of forest produce and the duty leviable on timber and other forest produce, was achieved. In 1950, the State Acquisition and Tenancy Act, 1950 (East Bengal Act) was enacted with the objective of putting tenants under the direct supervision of the government and destroying landlord power of private individuals over their tenants. The Act allowed tenants to keep homesteads and agricultural areas, but not forested lands. Many private holdings, including forestland, were deemed not retainable as a result of these stipulations. Under this law, the tenants were not permitted to keep forested lands. In order to avoid government claims over their private forested lands, the villagers cut down their forests to build villages, resulting in losing forest land. This law, while effective in fulfilling its objective, was not a necessary law on forestation and conservation. On the other hand, the Acquisition of Waste Land Act, 1950 (East Bengal Act), allows the government to acquire uncultivated private land for public use, including afforestation. In 1955, Pakistan published its first national forest policy, under which Bangladesh's (at the time, East Pakistan) woods were managed. This policy successfully introduced several formal forest management plans, followed by an inventory of various forest zones. This policy was overtaken by political-economic interests, leading to minimal improvements in the condition and sustainability of the forests. In 1979, the newly independent Bangladesh drafted its first national forest policy. Unfortunately, the wordings and language of the policy were ambiguous and conflicting in nature which made it impossible to properly follow the recommendations; thus, indirectly encouraging actions that were eventually harmful to the health of the forests. The 1994 Forest Policy, however, placed a strong emphasis on the preservation and management of trees outside of designated forests through a participatory approach with residents. It encouraged the planting of trees by local groups and communities alongside roads, stream banks, and marginal lands, and the State supports all types of local forestry and forestry-related companies. The next year, the Forestry Sector Master Plan (1995–2015) was strategised, and much later, through the Forest Act of 2000 (Amendment), institutional restructuring (1998–2000), and social forestry rules (2004) were developed. Following these laws, the Environmental Courts Act, 2010 was enacted in 2010 to establish courts to deal with legal concerns and crimes related to forest issues. Under this law, only special Magistrates have the power to hear complaints, and the courts must conclude the case within 180 days. In addition, the Saw-mill (Licence) Rules, 2012 provides that no saw-mills should be built within 10 kilometres of a ‘protected forest’, as defined by the Forest Act of 1927. The saw-milling process of the trees includes removing the outer bark of the logs and cutting them into sections, which are then finally sawn into timber boards. This process impacts the environment by rising particulate matter from debarking and sawing, as well as kiln draws. The particulate environmental matter arises from log debarking, sawing into boards, wood residues and kiln drying as these processing stages create environmental hazards on the land. With regard to protecting forests, the Brick Manufactures and Kiln Establishment (Control) Act, 2013 prohibits brick fields to operate without the Deputy Commissioner’s approval. Although the law also prohibits cutting hills and the usage of forest wood for brick-making, fuel wood is still used to make bricks since it is the owners’ only available energy source for brick-making now. Both the National Forestry Policy 2016 and the Wildlife (Conservation and Security) Act, 2012 are against any form of industrial activity within 2 km of sanctuaries. These laws bring to light how far the operation of the Rampal Power plant project conflicts with the legal framework of Bangladesh. The Bangladesh Forestry Master Plan (2017–2036) is intended to enhance the Protected Area network by 30% and safeguard wildlife from poaching. Bangladesh currently comprises of 45 protected areas; most of which lack funds and well-trained staff, with high levels of conflicts between ministries and agencies over implementing laws and regulations. Lastly, with the latest amendment of the Forest Act in 2020, the Act legalised social forestry; a practice of planting trees in an area in association with the local population in order to influence their economic, ecological, and social growth. Given the importance, as well as shortage, of forest land, these provisions can be essential in human and forest sustenance. These provisions also allow those who plant the trees to support themselves until the trees’ fruits are reaped. In order to handle the wildlife and forest-related issues and offences, the Ministry of Environment, Forest, and Climate Change is responsible. Under this Ministry, the Wildlife Crime Control Unit (WCCU) of the Department of Forest (DoF) has been mandated to identify environmentally critical zones, including the forest lands in the country and to draft regulations that improve these forest lands. And under the Environment Court Act 2010, every district has been mandated to have an environmental court, if required. Under this Act, the Magistrate Court will be provided with the power to dispose of complaints and finish proceedings within 180 days. This Act's distinctive feature shows that it can speed up environmental lawsuits and proceedings, resulting in the protection of Bangladesh's forests and other vital resources if properly applied. Besides its national measures, Bangladesh has signed or ratified significant international forest conventions such as the Convention on Biological Diversity, UN Framework Convention on Climate Change, and its Kyoto Protocol. Apart from these, the Convention on Wetlands of International Importance (“Ramsar” Convention) and The Convention on the Protection of the World Cultural and Natural Heritage were also signed. Regardless, while on paper and official records the state seems to take a stand or draft laws in line with the international principles regarding the protection, conservation and safeguarding of the forests, in practice, the reality is quite the opposite. Forest’s Impact on Human Health: The Food and Agricultural Organization (FAO) estimated that between 2015 and 2020, almost 10 million hectares (2.5 million acres) of forest were lost globally each year. As a result of not conserving the forests, an adverse effect on human health has been evinced. Deforestation: Deforestation has been demonstrated to fragment forest ecosystems, increasing the concentration of infectious diseases and non-infectious illnesses like diabetes, typhoid, and lung disease. Following deforestation, as forest species, that cause allergies or irritants, move into new habitats or areas, human health problems will continue to rise. Climate Change: Climate change has a significant impact on human lives. Following deforestation, one such challenge of climate change is the transboundary movement/migration of pests, and thus, diseases. Similarly, the distribution of a species in a certain area may change, which could increase pollen production negatively affecting human health. Scientists fear that climate change could possibly charge the next pandemic, which have been made worse by human-induced landscape transformation. Removing the trees, the natural protector against climate change, invites frequent heat waves, rising the temperature of the earth, depleting the ozone layer, increasing the level of CO2 in the air, and increases global warning; which all in turn impacts the human body negatively. Deforestation also leads to loosening the soil, catalyses soil erosion, increases the salinity of the groundwater, and increases the sea levels. This groundwater, when consumed by human, raises the blood pressure due to the high salt matter. Hill Cutting: While the Brick Burning Control (Amendment) Act, 2013 prohibits cutting hills and using forest wood for brickmaking, hill cutting is a common practice in Bangladesh. The main reasons for hill cutting, as evinced through the survey conducted in the Chittagong City Corporation, include higher prices for newly developed plain land, population growth, the apartment and hotel industry, political influence and a lack of hill management policy, soil for brick fields, inadequate monitoring of hill land infrastructure development, and filling in of low areas. Locals from the Chittagong district claim that the hilly areas are rich in forest resources, including food in the form of a variety of fruits, and woody plants and trees with medicinal properties, which are lost as a result of the loss of dense forest areas via hill cutting. Wood burning and Brick kilns: In Bangladesh, unregulated brick kilns burns an enormous amount of fuel wood each year, which is equal to 2.4 crore standing trees and around 96,000 acres of forested land. The country has between 6,000 and 8,000 brick kilns, which burn primarily coal to generate about 1,200 crore bricks annually. Yet, because most of these kilns are either poorly managed or not inspected at all, many of the uncontrolled brick kilns burn firewood partially or exclusively. Most of the fuel used in these brick kilns is coal, which produces SO2 and particulate matter (PM) emissions, which result in poor air quality, and causes respiratory related diseases. Power Plant near Forest: One of the basic preconditions for a power plant project must be that it is outside a 25km radius from the outer periphery of an ecologically sensitive area in Bangladesh. Unfortunately, the Rampal Power Plant is situated a mere 14km north of the world’s largest mangrove forest Sundarbans which is a UNESCO world heritage site, and has already gone on commercial operation. It is estimated that around 4.75 million tons of coal would be burned annually at this power plant, and emit 14 million tons of CO2, linking to the increase in global warming. The power plant’s SO2, NOx, and PM emissions would have an impact on the air quality over a sizable region. All these pollutants are toxic when inhaled, causing short-term respiratory and other symptoms. Moreover, exposure to PM2.5 and NO2 has been related to serious long-term health effects, most notably an increase in the chance of developing chronic diseases. In the case of PM2.5, these impacts include stroke, lung cancer, heart diseases, and chronic respiratory diseases. Besides these pollutants, the plant could emit high levels of mercury, which when deposited, ‘could be sufficient to render fish unsafe to eat over an area of approximately 70 km2 around the power plant’. Mercury is a neurotoxin that damages children’s brains and nervous systems once consumed. While there exists no direct connection between the forest laws and their impact on human health, it can be inferred that implementing forest policies that centre on conserving forests will decidedly improve the health of both the forest and human, as doing the opposite adversely affects human health as well. While still archaic in nature, laws and policies are important tools that must be utilised effectively and properly to ensure the sustenance of forests and human health. Conclusion: From the existing legal overview, it can be inferred that the foundation of the colonial forest laws in Bangladesh, especially the Forest Act of 1927, was drafted primarily to make commercial use of the forest resources and generate revenue. Bangladesh’s degrading forests demonstrate the ineffectiveness of the current laws, institutions, and methods that collectively fail to safeguard the forest ecosystem. With time, more forest lands are being denuded, historical forest custodians are being alienated, and the forest administration is becoming draconian with its anti-forest and hence anti-people policies and practices. It is quite clear that the existing regulations are archaic, colonial, and unappreciative of modern administration. As a result, not only is the forest's health suffering, but so is human life. It is high time to make practical use of the existing legislation in order to protect forest lands. The state officials should also consider a step forward to collectively work with the communities and all relevant stakeholders to adopt and catalyse a pro-forest and pro-people practice regarding the forest ecosystem, which should extend above and beyond the legal conversation in ensuring the health of the forests, and thus, human.

The introduction of ADR was necessitated by the need to provide access to justice for all, through facilitating speedy disposal of disputes and inexpensive procedures. The success of ADR around the world has encouraged both the Courts and litigants to resort to different forms of ADR to resolve disputes. Though ADR saves time and money and helps the litigants to resolve a dispute in the manner best suited to their desire, such considerations cannot always be the driving criterion for justice. Interests of justice sometimes may require confrontational and lengthier process. Thus, ADR has not become a replacement but rather a necessary complement to the traditional justice system. Interests of justice must also account for the grievances and wishes of the litigants. Litigants come to the Courts with certain expectations, which aside from quick and inexpensive disposal of the case also include availing the remedies of their choice, a certain quality of adjudications, a fair trial etc. The recent evolving practices of mandatory ADR are said to be disruptive in the realization of such expectations. There have been growing sentiments that compulsory ADR requirements are a barrier towards access to courts. The England and Wales Court of Appeal in the Halsey v. Milton Keynes Gen. Hospital held that compulsory mediation violated Article 6 of the European Convention of Human Rights, which provides for the right to a fair and public trial. Such a strict interpretation of the right to a fair trial is indeed faulty. The failure of a State to allow access to a Court or Tribunal does amount to a violation of human rights unless such limitations are based on domestic legislation, are necessary to pursue a legitimate aim such as the proper administration of justice, [1] and doesn’t impair the essence of the right.[2] Thus, a state providing for mandatory ADR to resolve a dispute is not in violation of human rights. Governments have the authority to impose conditions on bringing cases before the Court for the greater interests of justice, which may include providing for inexpensive and speedy pre-trial ADR procedures which don’t prejudice any rights of the parties. Some disputes are inherently of such nature that the inordinate length and excessive cost of the legal procedure are out of proportion to the financial value of the case, thus necessitating ADR. Therefore, mandatory ADR provisions do not restrict the access to courts, rather works as a qualifying stage, for the greater interests of justice. On the other hand, some courts, being ‘over-enthusiastic’ about the ADR mechanisms, have tried to force it upon the litigants. For example, the Code of Civil Procedure, 1908 makes it mandatory for the Courts to refer the dispute to mediation after the issues are framed for settlement of disputes. This view is in resonance with the attitude of different courts in various jurisdictions surrounding the ADR. The U.S. Court of Appeals, in re Atlantic Pipe Corp., held that a federal trial Court has the inherent authority to order mandatory mediation if it deems such as appropriate. Similarly, the England and Wales Court of Appeal in Pauline Lomax vs. Stuart Lomax, held that a judge-led early neutral evaluation under the Civil Procedure Rules didn’t require the consent of the parties. The Court was of the opinion that due to ehethe the absenthe absence of an express requirement for consent in the rules, the concerns of cost efficiency and speedy disposal are to be prioritized. In Dunnett vs. Railtrack Plc, the Court went as far as to hold that a winning party will lose its right to costs against the losing party due to its reluctance to participate in pre-trial ADR. While courts can force parties into mandatory ADR, if such discretion is conferred to them by the law, such an approach may not always be justified. One of the key factors behind favouring ADR mechanisms over the traditional justice system is that such process allows the litigants, to reach an outcome, which is favourable to both the sides. But, if the party themselves are reluctant to participate in such process, forcing them into such, can hardly spawn an outcome that is preferable to both sides. Besides, party autonomy and empowerment, which are also considered as some of the primary benefits of ADR, [3] are diminished if the parties are forced into the process. The Court, during its deliberation in the Milton Keynes Gen. Hospital case, stated that compelling parties to enter into a mandatory mediation process, that they objected, may result in added costs, additional time and may damage the perceived effectiveness of the ADR process. Thus, forcing ADR to reluctant parties may undo all the positives that are usually achieved from ADR. An adjudicatory process may leave both parties unhappy at its conclusion, but in ADR, where the parties are unwilling, the beginning of the process itself is unsatisfactory, thus moving towards a dissatisfactory end. Traditional Courts often leave the parties unsatisfied, because of the rigid remedies provided by such. But if the parties themselves want such remedies, then forcing them to find alternative remedies can hardly bring any benefit. Therefore, though it is an exaggeration to identify mandatory ADR as a human rights violation, indiscriminate use of such may undermine justice and the process itself. Both governments and courts shouldn’t consider ADR as a ‘silver bullet’ for all cases. Such one size fits all approach may prove to be an impediment towards ensuring justice. Instead of forcing the parties to resort to ADR, the judges should rather explore the reasons for parties’ resistance towards ADR. [1] UN Human Rights Committee (HRC), General comment no. 32, Article 14, Right to equality before courts and tribunals and to fair trial, CCPR/C/GC/32, 23 August 2007, para 18. [2] See for e.g. Ashingdane v United Kingdom, Judgment (Merits), Case No 14/1983/70/106, App No 8225/78 (A/93); Benthem v Netherlands, Merits and just satisfaction, App No 8848/80, A/97. ; [3] See Robert A. Baruch Bush, 'Efficiency and Protection, or Empowerment and Recognition? The Mediator's Role and Ethical Standards in Mediation' [1989] 41 University of Florida Law Review 253.

Experiencing an unsafe, unsecured, and rowdy public space has become a quotidian life for people living in Dhaka City. Daily, we encounter acts interfering with the public's comfort, health or safety in the way of Noise, Vibration, Heat, Smoke, Smell, Sewer Obstructions etc., which are nothing but offences of public nuisance. Due to the lack of rule of law and awareness among the citizens about the law of public nuisance, we not only commit the offence of public nuisance but also choose to remain inactive when we come across such offences on regular basis. In pursuit of public safety, health and convenience, we need to be aware of public nuisance crimes that occur every day in Dhaka city. What is Public Nuisance? When a person does any act or omits to discharge any legal duties which – endanger the life, health, safety, property, and morals of the public or the comfort of the public, or obstruct the public in exercising or enjoying the rights common to all, is responsible for public nuisance whether such person is an ordinary citizen or a government official under section 268 of the Penal Code, 1860 (hereinafter referred to as the Code). The purpose of addressing public nuisance is to secure the public's life, health, property, morals, or comfort and to exercise or enjoy the rights common to the public without any obstruction. Public Nuisance – The Most Committed Crime in Dhaka City In Dhaka City, it is impossible to find a day without having news either on the Adulteration of Food, Drink, Drugs, or Air Pollution, Noise Pollution, Rash Driving, and Obstruction in Public Ways, which are offences of Public Nuisances. Similarly, we experience all these offences regularly. Why? Because either this way or another, we all, are committing a public nuisance. Either we are the dishonest traders, importers and manufacturers, cultivators and processing agencies responsible for the adulteration of food, drink, and drugs, or we are the unskilled, drunken, and reckless drivers who do not obey the traffic law and regulations responsible for rash driving, or the creator of obstruction in a public way by putting dirt, gravel, soil, rubbish, junk vehicle, etc. to obstruct traffic, drainage, pedestrians or otherwise safe and open access to such right-of-way. If not these, we are responsible for activities like spitting, smoking in public areas, urinating on footpaths, parking a car in non-parking public areas, etc. Therefore, either one way or another, each one of us comes under the fold of public nuisance offences. Offences of Public Nuisance Affecting Public Health, Safety, and Convenience: To give an overview of how activities of ​Public Nuisance are​ damaging public health, safety, and convenience; the following illustrates​ ​crimes mentioned in Chapter 14 of the Code and are discussed briefly. Adulteration of Food and Drink: On daily basis, some people sell basic food items like rice, pulses, spices, fish, oil, vegetables and sweetmeats which contain toxic chemicals and other harmful additives. According to a survey, the markets in Dhaka and other parts of the country now sell more than 75% of all foods that are adulterated. In addition, more than 80% of fruits, 60% of vegetables, 70% of rice, and 60% of both branded and open edible oil are dangerously adulterated now. Food adulteration has been marked as one of the main reasons for the rise of cancer, and damaging vital human organs like the liver, kidney, and heart as per the research conducted by the Ministry of Health. It is also affecting children's mental and physical growth. Transparency International Bangladesh (TIB) disclosed that more than 4.5 million people in the country are at health risk from consuming adulterated and contaminated food every year, and due to this, 16% of the population are kidney patients, according to the Health Directorate of Bangladesh. Food adulteration is an offence of public nuisance as per Sections 272 and 273 of the Code, which is damaging the fate of present and future generations. Dishonest traders, importers and manufacturers, cultivators and processing agencies are involved in these unethical practices. Adulteration of Drug: Whoever adulterates (lessens the efficacy or changes the operation of such drug or medical preparation, or makes it harmful) any drug or medical preparation for the purpose of selling or knowing it to be likely that it will be sold or used for, any medicinal purpose and whoever knowingly sells, or offers or exposes for sale, or issues from a dispensary for medicinal purposes is guilty of public nuisance under Sections 274 and 275 of the Code. Pharmaceutical drug adulteration is widespread in Bangladesh, which is not only injurious to health but also pushes millions of people to death slowly. It compromises the treatment of chronic and infectious diseases, causing disease progression, drug resistance, and death [1]. Making Atmosphere Noxious to Health: Whoever willingly impairs the atmosphere of any place to make it harmful to the health of people who live there or carry on business in the neighbourhood or pass along the public way is guilty of public nuisance under Section 278 of the Code. The following activities that cause to debase the atmosphere of any public places are the offences of public nuisance. Air Pollution Due to Brick kilns, Surface Dust and Sand, Vehicle Emission - 85% of Dhaka’s air pollution is caused by brick kilns, surface dust and sand, and vehicle emissions. Exposure to high levels of air pollution is causing breathing difficulties, cough, lower respiratory tract infections, depression, and other health conditions as per the report of the World Bank. The air quality of Dhaka City is hazardous according to the Air Quality Index (AQI). In Ram Raj Singh v. Babulal, the accused carried on a trade that involved crushing bricks through a brick crusher machinery, which resulted in the emission of a large quantity of dust in the surrounding areas. The victim, a medical practitioner, lived neighbouring the accused’s premises. The victim complained that the dust emitted as a result of the accused’s trade was detrimental to his and his patient’s health. In this case, since numerous people were involved, the accused’s act constituted a public nuisance and the court issued an injunction order against the defendant and granted special damages to the victim. Smoking in Public Place - Air pollution from cigarettes is 10 times the emissions from diesel car exhaust. Tobacco smoke produces fine particulate matter, which is the most dangerous element of air pollution for health. “Cigarette filters pollute our oceans, rivers, city sidewalks, parks, soil and beaches every year,” said Dr Ruediger Krech, Director of Health Promotion at WHO. Smoking in “public places and public transport” is a regular thing in Dhaka City despite the fact that smoking in public places and public transport is a punishable offence under the Smoking and Tobacco Products Usage (Control) Act 2005. In K Ramakrishnan v. State of Kerala (1999), the Court declared that smoking in any form in public is a public nuisance. Smoking is harmful to the public at large and is, thereby, fulfilling the requisites of public nuisance. Honking Beyond Prescribed Limit – It is definitive for the residents of Dhaka city to experience horns in their everyday lives. Horn causes deafness, anxiety, and high blood pressure. Honking horns beyond the prescribed limit causing injury, and disturbance to the public, is a punishable offence under section 290 of the Code. In Ramlal v. Mustafabad Oil and Oil Ginning Factory, the Court observed that once it is determined that the noise exceeds the threshold required to be responsible for public nuisance, it is not a valid defence to argue that the noise originated from lawful activity. Dhaka is the most noise pollution city in the world as per the United Nations Environment Programme. Rash driving or riding on a public way: According to the Bangladesh Road Safety Foundation’s (RSF) annual report, at least 6,284 people died, and 7,468 others were injured in road accidents between January and December 2021, compared to 5,431 people dead and 7,379 injured in road collisions in 2020. Reasons for the increase in traffic accidents include: Reckless driving, excessive speed, forced overtaking, violation of traffic rules, illegal and dangerous competition, long hours of non-stop driving, driving under the influence of drugs or alcohol, driver incompetence, dangerous roads, careless bike riding, ineffective traffic control system [2]. Rash driving or riding on a public way creates criminal damage to roads, other vehicles and surrounding property, and injury and death to the public, which is an offence of public nuisance according to Section 279 of the Code. In the State By J.C. Nagar P.S. v Santanam, 1997, the accused, a military personnel, drove a military truck in a zigzag manner and struck and killed a moped driver then hit an auto-rickshaw​ ​causing damage to it. The autorickshaw driver chased the truck in another auto-rickshaw and saw him hitting a compound wall and a grille. The High Court of Karnataka held that the truck driver was guilty of public nuisance. Danger or obstruction in public way: An analysis of five years (2011-2015) of crash data showed that unpredictable pedestrian crossings, violations of traffic signs, exceeding speed limits, fast traffic at intersections, overtaking on curves, etc., reflect highway vulnerabilities that are the causes of danger, obstruction or, injury in any public way or line of navigation, which is an offence of public nuisance as per Section 283 of the Code. Statistics showed that Bangladesh has the highest road fatality rate, with over 50 fatalities per 10,000 road vehicles. Conclusion: Knowingly or unknowingly, we all are guilty of public nuisance. Ignorance of the law is not a valid ground for the defence of a case in our legal system. Neither the concerned authority nor the people can give any dispensation for not obeying the law. Tolerance is an important concept that helps people to live together peacefully, however, our tolerant attitude towards public nuisance is making our life miserable as well as harmfully affecting our life, health, and property as a whole. To enjoy a clean, healthy and disturb-free public life and environment, we must act as responsible citizens and do our part in keeping the environment clean and peaceful. [1] Ak Mohiuddin. The Mysterious Domination of Food Contaminants and Adulterants in Bangladesh. Int J Environ Sci Nat Res. 2019; 16(3): 555941. [2] SABIHA AKTER SEEMA, 'Road Accident: A Major Concern of Bangladesh' Centre for Governance Study, 18 May 2022.