Female Participation in Terrorism

12600 words (50 pages) Dissertation

9th Dec 2019 Dissertation Reference this

Tags: CriminologyExtremismTerrorism

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  1. Introduction

Around the world, topics of political violence, ‘jihad’, and terrorism dominate todays media, public and political discourses. Jihad is commonly understood as the core of modern radical Islamist[1] ideology, with these groups often referring to themselves as ‘jihadi’. Frequently portrayed by Western media, jihad is often conflated with terrorism and broadcast as a ‘holy war’ conducting God’s will and punishing the ‘non-believers’, depicting Islam as religiously intolerant.[2] This portrayal is commonly exploited by radical Islamist groups associating jihad with a resistance to globalization and the West. Alternatively, some scholars have argued jihad as a defensive principle to be directed inward, and therefore having nothing to do with external violence. Not surprisingly, these divergent interpretations of jihad are found among Muslims across the world. Michael Bonner suggests the various understandings of jihad exist on a spectrum: Islam, as represented through jihad is equivalent to violence and war on one end, or to peace on the other.[3]

Historically, women in patriarchal societies have been denied positions of power and access to civil rights such as education, healthcare, and voting. This conservative patriarchal tradition has further limited women’s freedom of movement and expression; women have been relegated to the domestic private sphere to raise the next generation of jihadis. Accordingly, their participation in active jihad has been largely denied by contemporary jihadi groups on the basis of their conservative, gender-biased ideologies. However, as this essay will explain, the denial of women’s participation in defensive jihad risks the credibility of jihadi groups legal rationalization of their ideology, based on defensive jihad. As a result, jihadi groups have managed to continue to deny women a role in militant jihad by reforming classical perspectives on female martyrdom to their advantage, all while maintaining the patriarchal order of traditionally conservative societies and the oppression of women. Consequently, these jihadi groups have strategically exploited gender stereotypes, making women the “ultimate stealth weapon.”[4]

Farahnaz Ispahani, suggests if women were integrated through equal opportunities by way of participation in social, political, and economic life, they could positively confront violent extremist ideology, and alter the future of the Muslim world.[5] However, because of the traditionally conservative, patriarchal societies of most Muslim-majority countries, women’s rights are currently exploited by Islamist groups, who reject the notion women have equal rights to men. This inequality coupled with personal, cultural and societal influences, has contributed to an increase in women who support or join Islamist extremist groups.[6]

Accordingly, by comparing contemporary interpretations of women’s role in jihad to classical Muslim legal literature, this essay will explore two related questions: Why do Muslim women desire an active role in jihad? And does women’s involvement in jihad improve the rights and standing of women within Islamic society; in other words, is taking up jihad effective for improving gender equality?

Beginning with an overview of jihad, this essay will first review the classical doctrine to provide a historical context, then analyse the contemporary readings on the doctrine. It will then briefly examine the status of women in Islam before reviewing their role in jihad, focusing on classical interpretations and the contemporary applications of the doctrine, specifically highlighting their exclusion from defensive jihad. Following, the inclusion of women in martyrdom operations will further demonstrate the contradictory nature of modern jihadis position on women’s role in jihad. Subsequently, this paper will explore women’s agency and motivations in pursuing an active role in jihad. Lastly, this essay will conclude with a contextual review of the concepts regarding women’s agency in taking up jihad, their role in jihad and their role in martyrdom operations, within Daesh.

  1. Jihad

Because the historical context is important in understanding the social & political misuse of the principle of jihad today. Accordingly, this section is divided into two parts: first, a review of the classical doctrine of jihad, based on the preaching and practices of the Prophet Muhammad and his companions, followed by the modern contemporary readings applied by jihadi groups today.

  1. Classical Doctrine

Throughout the ages, Muslims have deliberated and disagreed about the meaning of jihad, contributing to a divided understanding and practice. There is no universally accepted doctrine of jihad, however, the principal is central to Islamic theology and is rooted within the Quran.[7] While the Quran provides the origin for jihad doctrine, it is the tradition literature of Islam, or the hadith,[8] that provides Muslims with an interpretation.[9] Nevertheless, because the principal is a product of its interpretation, there remains no agreed upon understanding on the practice of jihad.[10]

Literally interpreted, ‘jihad’ means “to strive, to apply oneself, to struggle, to persevere.”[11] The Quran refers to jihad as striving to serve God’s purpose on earth, and obliges Muslims “to lead a virtuous life, to fight injustice and oppression, reform and create a just society and, if necessary, engage in armed struggle to defend one’s community and religion.”[12] In regards to this last obligation, to strive or engage in armed struggle or war, the conflict must be considered ‘just and good’[13] to be jihad. In other words, if the purpose of the war is just and good, the struggle to attain it, is jihad. Khaled Abou El Fadl, emphasizes that in accordance with the Quran, while war might be necessary, it is either justified or it is not.[14] When justified, individuals killed in war are considered martyrs, though, ultimately only God can deliver this status.[15] Abou El Fadl goes on to stress that while the Quran recognizes a justified war’s necessity, war remains neither morally nor ethically good.[16]

While the Quran leaves the principle of jihad open to interpretation, two specific types have emerged over time: the greater jihad (internal or jihad al-kabir), the struggle from within oneself to be a more virtuous human being; and the lesser jihad (external or jihad al-saqhir), the defense of Islam through fighting its enemies.[17] The lesser jihad originates from the Prophet Muhammad’s defensive military struggle against the Meccan pagans, to protect Islam and the global Muslim community.[18] As such, the lesser jihad is often interpreted as a defensive principle, even though the Prophet was engaged in combat. Nevertheless, it is important to note that the distinction between a defensive action and an offensive action may not always be so great, as defensive objectives against an enemy may require offensive actions.[19]

Another main issue in the classical doctrine of jihad is the subject of collective versus individual. In an effort to control the conduct of warfare and assist in regulating peace, Muslim jurists developed a legal doctrine of warfare, differentiating between offensive and defensive jihad. Offensive jihad was established to allow for a strong Islamic state to wage war externally, whereas the defensive was established to assist those Muslim communities who were left militarily and politically powerless, following an invasion.[20] Accordingly, offensive jihad was heavily regulated requiring a legitimate ruler’s command and for Muslim fighters to consider their physical, financial and family circumstances, prior to engaging in battle.[21] As such, offensive jihad was regarded as a collective duty (fard kifaya), while defensive jihad was seen as an individual duty (fard ‘ayn) as Muslims were not required to seek permission to defend their territory when under attack.[22]

This legal distinction between collective and individual obligations, was established to differentiate between duties Muslims are required to undertake universally, and duties that some Muslims can undertake on behalf of others.[23]  Because individual obligations,[24] as established by law, do not require supervision or permission to be carried out as they can be fulfilled by oneself. While collective obligations,[25] also established by law, are undertaken as a communal action, meaning these duties cease to be mandatory once they have been carried out by a sufficient number of Muslims.[26] Nelly Lahoud suggests this distinction indicates that jihad is not a universal obligation, under normal circumstances. However, when Islamic territory is being attacked and authority structures are destroyed, jihad becomes a universal obligation to be fulfilled by each Muslim, without the need to seek permission.[27]

In situations of warfare with an external enemy, the collective Muslim community is involved, as such a war cannot be fought without state resources and organization.[28] Michael Bonner suggests this type of warfare may be considered ‘holy’, as it achieves religious objectives by protecting and expanding the Muslim community.[29] Alternatively, the individual who voluntarily participates in this warfare is also fulfilling religious objectives; however, they are ultimately concerned with achieving a personal religious reward, rather than protecting or expanding the Islamic territory.[30] Bonner proposes these two components represent the “holy war” and the “holy struggle”, both of which he argues are embodied in jihad.[31]

The Quran neither recommends nor condones illegitimate violence, and while early Quranic passages did assert a right to respond to aggression and counter persecution, verses also indicated that if attackers proposed peace, then peace must be made as God does not like aggressors.[32] However, jihad become a core element of Islam emerging as a result of conquests.[33] Although conquests are attributed with the spread of Islam, it was not “by the sword” or forced upon the inhabitants of conquered territories, instead these invasions established necessary preconditions for the expansion of the religion. Because Islam became the majority faith in most territories by force, conquests and the doctrine of jihad are regarded as crucial to the development of Islam.[34]

Correspondingly, the “Verse on the Sword,” is often considered as being the most important regarding jihad:

Then, when the sacred months are over, kill the idolaters wherever you find them, take them [captive], besiege them, and lie in wait for them at every point of observation. If they repent afterwards, perform the prayer and pay the alms, then release them. Allah is truly All-Forgiving, Merciful. (Q. 9:5)[35]

The verse is neither found in the Quran nor the Hadith, as it represents a later interpretation of the Quran by eighth to ninth century religious scholars (ulema). These scholars replaced the original Meccan Quranic verses with more militant verses which were subsequently implemented into Islamic law and utilized by rulers to justify their militant jihad for conquest and imperial expansion against all non-Muslims, as it was the name of defending and spreading Islam.[36] Esposito acknowledges the significant distortion of this verse today, by both critics of Islam and Muslim terrorists. While the critics suggest this verse is demonstrative of the religion’s violent nature, Muslim extremists have used it as a justification for unconditional warfare against all unbelievers and non-Muslims.[37] Yet not surprisingly, both groups fail to acknowledge the second half of the verse, commanding followers to stop fighting if their attackers propose peace.[38]

  1. Modern Readings

In the last half of the 20th century, global jihadist movements have been gaining widespread publicity. Essentially, this globalization has been split into two distinct realms: religious thought and armed struggle. First, the primary greater jihad, remains essential today to Muslim spirituality, emphasizing the ‘struggle’ to lead a good life. Second and more publicized, the principle had been used and exploited by both resistance and liberation movements, and extremist and terrorist organizations, as a recruitment and motivational tool.[39] Accordingly, the traditionally territorial jihadist agenda, has evolved into a widespread global agenda.

Many scholars suggest the 1979-1989 Soviet-Afghan war, marked the turning point in the expansion of a global jihad. Specifically, John L. Espositio, notes that in addition to Muslim nations fear of Communism, Iran’s Ayatollah Khomeini’s dissemination of its Islamic revolution created further apprehension.[40] He goes further to argue that as a result of the Afghan war, a global jihad ideology and movement developed targeting un-Islamic Muslim governments and the West.[41] Consequently, the policies of the emerging authoritarian Muslim regimes facilitated radicalization, violence, and terrorism, both nationally and globally.

Muhammad ‘Abd al-Salam Faraj founded the contemporary revolutionary appeal of defensive jihad in his 1986 book “The Neglected Duty” (al-Farida al-Gha’iba).[42] Subsequently, this same doctrine was popularized for global purposes by the Palestinian radical ‘Abadallah ‘Azzam,[43]  who was influential in assembling Arab Muslims to volunteer for jihad against the Soviets in Afghanistan. While these volunteers ultimately played a very small role in the eventual withdrawal of Soviet forces from Afghanistan, the campaign represented the first time in centuries Muslims joined together to fight for the sake of Islam.[44] However, this battlefield was regarded as a “religious and social incubator for globalist radical Islam,” as it effectively established contacts among various radicals.[45]

Consequently, this global ideology and movement utilizing violence and terror in the name of Islam, was heralded by Osama Bin Laden and al-Qaida in the September 11, 2001 attacks on the United States.[46] As a result, this global jihad as exploited by al-Qaida against both Muslim and Western governments, predicated a model for other groups such as the Islamic State in Iraq and Syria (ISIS), or Daesh. These groups were representative of a new form of international terrorism, exemplified by their global ideologies, strategies, targets, economic transactions, and network of organizations.[47] As such, these militant groups extend beyond the classical doctrine of jihad, discussed in the previous section, rejecting any regulations set by Islamic law such as the proportional use of violence, not targeting civilians, and that jihad must be declared by a legitimate ruler. They legitimize their forbidden acts as required and necessary based on a war between good and evil, or against the unbelievers.[48]

As previously discussed, the Quran refers to jihad in regards to an armed struggle or war in two categories: defensive, stressing the fight against aggression, and offensive or expansionist, regarding a broader command to fight against all unbelievers spreading the message of Islam. Modern radicaljihadisagree their struggle is based on the former defensive jihad, arguing their actions are justified and lawful based on the political conditions governing the Muslim world today.[49] However, this rationale begs the question, if defensive jihad is an individual obligation incumbent on all Muslims, and the current situation is so extreme as to constitute this universal obligation for all Muslims to take up jihad, why is it not all Muslims are being called upon? More specifically, why and how is it these jihadi leadersexclude women from the military domain when rallying Muslims to take up jihad? The next section will examine these questions further.

  1. Women in Islam

Before analysing women’s role in jihad and its impact, if any, on their status within Islamic society, a brief overview of women’s position in Islam is first required. It is important to note the significant diversity of views and interpretive possibilities on women’s status within Islam. A variety of factors influence these interpretations based on the unique conditions and circumstances of different societies and countries.[50] As such, many of these factors have little to do with Islam and more to do with the political regime in place. In particular, totalitarianism coupled with patriarchy creates a barrier preventing any advancement of women’s rights, even if motivated by religious factors.[51]

The patriarchal components of Arab societies emphasise the preservation of customs and traditions.[52] One of these traditions relevant to this essay’s topic, is the limitation of women’s freedom of movement. As required by classical legal tradition, women are to travel with their husbands or a mahram – a male relative. This requirement is necessary when a woman travels on her own under normal circumstances, however as will be expanded on below, it does not apply under the extraordinary circumstances of defensive jihad.[53] Nevertheless, contemporary jihadis maintain women cannot participate in combat as they would inevitably come in the company of non-relative males, thus breaking the law.

Additional social restrictions limiting a woman’s freedom and maintaining the patriarchal social order include their segregation from the public sphere, and an emphasis on “traditional ideals of femininity, motherhood and wifehood.”[54] Moreover, women’s identity and overall worth is shaped based on their obedience, seclusion and ability to produce male children. Ultimately, these oppressive restrictions serve as a control over Muslim women, and perpetuate male domination over them.[55]

Further exhibiting the patriarchal, gender-biased oppression within Islamic societies is the pressure placed upon women to uphold family ‘honour.’ This honour is predominately connected to a woman’s sexual behaviour, specifically her chastity, modesty and sexuality.[56] Accordingly, if a woman portrays immodest behaviour or inappropriate sexual conduct, she brings shame and dishonour upon her entire family. Whereas as woman’s family honour is characterised through her pure reputation, a man’s honour is represented through his courage, religiosity and hospitality. In other words, women’s honour can be seen as passive and can only be lost, whereas men’s honour is active and can only be reclaimed or expanded.[57] The issue of a woman’s honour, as will be discussed below, has been a significant motivation for women joining jihad, and in some cases, may be one of the only viable options to regain lost honour.

  1. Women’s Role in Jihad

What then, is a woman’s role in jihad? The debate on women’s participation and role in jihad has been ongoing since the early years of Islam. While some Islamists argue for women’s participation to be indirect or passive, such as providing support to malejihadis and producing the next generation, others have argued for a more active role including women’s participation in combat.[58] Not surprisingly, classical Muslim legal literature on jihad contains very little regarding women’s participation. The common historical understanding indicated women’s jihad was the pilgrimage to Mecca (hajj), rather than a right to fight.[59] However, information concerning the historical nature of women’s role in jihad, is limited.[60]

As some women were aware of the high spiritual merit bestowed upon the jihad (male) fighter, attempts by women to participate in fighting were made during the classical period of Islam. However, the Prophet responded to such attempts by indicating the reward given to men in jihad would ultimately be afforded to women if they obeyed their husbands and kept to their houses.[61]  Early jihad literature reasoned, women were denied participation on the battlefield because of the belief that ‘earthly women’ of this world bound men to it, while jihad’s focuswas instead to be on the next world and thus ‘women of paradise’ were supposed to be a major incentive for male fighters. Accordingly, jihad fighters were to actively reject elements of civilization and society, such as having a wife and family.[62] Another reason women were excluded from the battlefield was to preserve the traditional principles of modesty and the patriarchal social order, maintaining the separation of gender roles and statuses.[63]

Nevertheless, women did participate in some great conquests, including those who were companions of the Prophet Muhammad.[64] These women took up arms and participated in battle, such as Um ‘Umara, who was said to have fought alongside men taking on many wounds, and Safiya, the Prophet’s aunt who beheaded an attacker, successfully fending off an assault from the Jews on the Muslim’s stronghold of Medina.[65] From the ninth to eleventh centuries, the Mutarajjulat, a category of women who acted and dressed like men are also thought to have fought alongside them in battles; though, these women were said to be cursed by the Prophet Muhammad.[66] Nevertheless, it becomes clear that many of the women participating in battles, did so in a supporting role either by providing medical care, or as encouragement alongside male fighters. In addition, there is no record of women having made significant military contributions, crucial to the expansion of Islam.[67] Moreover, much like the Judeo-Christian traditions, Islam eventually developed into a patriarchal domain where the role of women became limited to the private sphere.

However, beyond the classical conservative and patriarchal considerations, women’s role in jihad may have been limited for additional reasons. In particular, Muslim jurists considered the financial aspects of jihad, specifically asking whether a woman’s contribution to jihad entitled her to a share in the profits. Ultimately, the majority of jurists concluded that “a woman is not entitled to a share, but to a gift.”[68] Conversely, the jurists did agree that women are permitted to participate in war, and therefore those who held them in similar regard to men could grant them a share in the profit, while those who found women to be less effective in combat, could choose to grant them less of a share as a gift, or nothing at all.[69] Perhaps more importantly stemming from this decision, is the acknowledgement that women can legally take part in jihad. While the Prophet Muhammad did not command women to take a combative role in jihad, He did praise those who decided to take an active role and sacrificed in battles crucial for the survival of Muslims. Accordingly, because the classical jurists based their legal theories on the believed experiences during the prophetic era, women’s participation in battle was seen to be justified in such extraordinary circumstances.[70]

The classical era suggests that women involved in battle alongside the Prophet were the exception rather than the norm, as women were not expected to fight save for exceptional circumstances when the survival of Islam was at stake. In other words, based on the classical readings of jihad, women’s participation in battle is seen as lawful under extraordinary circumstances of defensive warfare. Moreover, as previously discussed, a Muslim does not need to seek permission to carry out fard ‘ayn, as it is an individual obligation, correspondingly, the classical jurists did not require a woman to have a mahram to participate in defensive jihad.[71]

Women’s role in jihad began to emerge more significantly in the 1990s. In particular, Islamic Scholar Muhammad Khayr Haykal was prominent in his consideration on the issue of women’s role in combative jihad, departing significantly from the classical literature.[72] He argued jihad was divided into two categories, as discussed above: fard kifaya, as a collective obligation and fard ‘ayn,as an individual obligation. Accordingly, Haykal suggested there is no obligation for women to fight when jihad is fard kifaya, however, in instances of fard ‘ayn women would be obligated to fight.[73] Going further, he argued training women on the use of arms and methods of fighting was necessary, because as long as it was possible that jihad could become fard ‘ayn a woman should be prepared to fulfil this obligation.[74]

Neither contemporary nor classical jihadileaders are dismissive of women’s non-militant role in jihad, and in fact often believe the success of jihad is dependent on their supportive role.[75] Women are relied on to promote jihad in the domestic sphere, specifically through raising money, and spreading the value of jihad to others in mosques, print and online.[76] Yet as touched upon in the previous section, while these leaders are committed to the individual obligation of jihad or fard ‘ayn, rallying Muslims globally, they refrain from calling upon women or exclude them from having a militant role. This exclusion contradicts the classical jurists’ interpretation that all Muslims should have a role in fighting, if the situation is of extraordinary defensive circumstances.

‘Azzam, the radical Palestinian jihadi and ideological father of al-Qaida previously discussed, recognized that while women participating in jihad is lawful as prescribed by Sharia, the practice nevertheless amounts to “great evil” as it requires the mixing of sexes on the battlefield, causing temptation.[77] Referring to the legal requirement of a woman to be accompanied by a mahram, ‘Azzam, as well as other jihadi groups, suggests this as an additional reason why women cannot participate in jihad.[78] However, as previously noted, the classical jurists did not require this as a condition of the legal doctrine of defensive jihad, as has been adopted by these radical jihadi groups. Because these organizations rationalize their jihad as the defensive doctrine, they therefore recognize the jurists condition that no Muslim is required to seek permission to defend themselves. As such, their requirement for women to be accompanied by a mahram on the battlefield, thus seeking permission, is contradictory to their rationale.

Because of the potential consequences of mixing the sexes in combat ‘Azzam stresses that women should serve behind the lines of battle as nurses, and cooks and carry out additional “womanly activities.”[79]  He acknowledges the participation of women in jihad during the prophetic era, however, he indicates their involvement was rare and undertaken by older unappealing women.[80] Remaining consistent with the classical readings on women’s role in jihad, the majority of women’s contributions have indeed been in less visible roles, including:

Raising their children in the path of jihad, managing the finances and the logistics of the operations, recruiting new fighters and female companions, collecting and disseminating intelligence, providing medical care, glorifying the struggle and spreading the jihadist ideology through Internet traditional contacts.[81]

Moreover, women are described as playing a significant role in convincing their male relatives to fight. In many cases, it is a woman, who is behind a male relative’s decision to fight, particularly convincing sons to become jihadists or martyrs.[82]

Interestingly, women’s participation in militant jihad and martyrdom operations have occurred on a larger scale in Palestine and Chechnya, two of the more secularized and well-educated areas in the Muslim world.[83] It should also be noted that as a result of years under Soviet rule, Chechen Muslims knew very little about their faith, perhaps making these women more vulnerable to militant religious ideologies.[84] Moreover, the Chechen conflict represented a unique situation where women’s role in jihad actually involved fighting, establishing a precedent for other Islamic women’s engagement in  jihad.[85] However, examples of women fighting in jihad are limited to these nationalist Islamic resistance movements in Palestine and Chechnya, and have not yet been utilised in global jihadist movements. If in the future jihadi groups do permit women a more active role in jihad, they would likely follow the attempts made by Chechen and Palestinian Muslims.[86]

Ultimately, the inclusion of women in defensive jihad presents a problem for modern jihadis:if they call upon women to take up arms they risk empowering women and threatening culturally conservative traditions, but if they continue to insist on the exclusion of women from the battlefield, they will lose the legal basis of their defensive jihad stance. While maintaining their cultural conservatism, it is clear that modern Islamic terrorist groups have taken an increasingly liberal position on the involvement of women in jihad against the ‘enemy’, straying from the classical literature. However as will be made more apparent from the analysis below, rather than being liberal in the sense of parting with traditional patriarchal control or gender-oppression, these groups are instead manipulating classical concepts to utilize women for strategic purposes in martyrdom operations, in an effort to advance their agendas.

  1. Female Martyrdom: Suicide Attacks

Martyrdom,[87] distinct from suicide which is strictly forbidden in the Quran and Islamic doctrine, refers to the idea that self-sacrificing acts on the battlefield will be met with divine reward, and is praised and encouraged. However as previously noted, only God can know the full intention of a fighter and if their sacrifice is not true, they will be deprived of their martyred status in the afterlife. [88] Nevertheless, because humanity cannot know this intention, those fighters slain in battle still receive a special burial and obtain martyr status in life. Because of the inability to understand intentions and the increasing frequency of these acts, the doctrine of martyrdom has received much controversy in recent times.[89]

Today, while jihadi leaders may refrain from permitting women a military role in jihad, they do support and bless those women who choose to carry out martyrdom operations as these, according to their theories, do not require a woman to be in the company of a mahram.[90] Historically however, acts of martyrdom by women were not encouraged nor were they met with approval.[91] Because the underlying purity of society within fundamentalist frameworks is reliant on female sexual purity, women were widely considered to not be pure enough for martyrdom in the name of Islam. Accordingly, based on the traditional patriarchal society’s emphasis on gender roles and the public-private divide, women’s participation in violence represented cultural fragmentation.[92] Nevertheless, increasing actions by female martyrs began to shift perceptions whereby Islamic clerics, despite earlier beliefs, began to proclaim that women much like men, would also be guaranteed entry into paradise.

Subsequently, several fatwa’s[93] were issued approving women’s participation in martyrdom operations, further legitimising women’s participation in jihad. Beginning in Chechnya after Hawa Barayev’s suicide and subsequent fatwa supporting her action, a precedent and model emerged for female participation in martyrdom and religious terrorism.[94] Rather than being met with disapproval by traditional Islamic societies, the incident spurred acceptance of the idea, and was subsequently utilized by the High Islamic Council in Saudi Arabia to encourage Palestinian women to also become suicide bombers.[95] Consequently, female terrorist attacks have increased significantly since 1976 with over 230 suicide attacks committed by women in jihadi groups, between 1985 and 2010.[96] One argument for the increase in female suicide attacks is because of women’s desire to engage in political violence, and as these organizations do not permit them a role in active jihad, women are turning to martyrdom.[97]

Lahoud suggests the exclusion of women in combat provides these groups with a tactical advantage, benefiting their overall agenda: women can lawfully carryout martyrdom operations contributing significantly to the cause, while the jihadis do not have to compromise their conservative stance toward women.[98] In other words, the use of women as suicide bombers provides an escape for jihadi groups from the undesirable female empowerment that may result from their role in combat.[99] In addition, the inclusion of women as suicide bombers is advantageous as it provides for a “stealthier attack, an element of surprise, [and] a hesitancy to search for women,” due to the perception of females as non-violent.[100] Because of the stereotypes such as pacifism, femininity, and maternity associated with women, they are considered to be less suspicious than men and can therefore conceal explosives and avoid security checks better than their male counterparts. These same stereotypes are ultimately why female terrorist attacks have such a profound psychological impact, are more effective,[101] and may appeal to other women.[102]  Additionally, women’s participation in both suicide missions and jihad may spur an increase in male fighters conscripting, as a result of the humiliation they face from women’s enrolment.[103]

The inclusion of women in martyrdom attacks presents a complicated analysis on women’s equality within Islam. While maintaining the patriarchal order of traditionally conservative societies and the oppression of women, jihadi groups have managed to continue to deny women a role in militant jihad while reshaping historical perspectives on female martyrdom to their advantage. Traditionally, women were confined to the domestic domain and not accepted as martyrs based on their perceived lack of purity; whereas today their participation as suicide bombers has been approved and encouraged by jihadi groups. However, this support and recruitment of female martyrs is not based on extremists’ sudden recognition of female equality, but instead on the exploitation of women as a tactical advantage for their cause.

  1. Women’s Agency in Jihad

Perhaps the next question that needs to be addressed, is why are women taking up violent jihad? Despite the stereotypes and passivity often associated with women, they are driven to engage in jihad for many of the same reasons as men: political motives, and personal reasons such as revenge for the death of a relative or a violation of their honour.[104] Mia Bloom has developed the “Four R Plus One” framework, to explain why women engage in terrorism.[105] These motivations also correspond with women’s motivation to take up jihad. The Four R’s include: revenge, for the death of a relative; redemption, the need to avenge a personal or family shame; relationships, in joining relatives involved in jihad; and rape, or sexual exploitation by jihadis.[106] Additional motivations may involve feelings of contributing to a cause, being part of a community and sisterhood, gaining an identity as a member of a jihadi group, personal incentives such as marriage, and the perception of Islam as being under attack globally, and thus the call to defensive jihad.[107]

Some women may choose jihad as a personal decision to avoid discrimination and abuse, and as an alternative to Western feminism which they regard as unfulfilling or disappointing. Accordingly, in such circumstances women’s roles are perceived as complementary rather than equal to men’s.[108] Chechen female terrorists, also commonly known as the ‘Black Widows,’ were labelled as such based on their call to arms to avenge the death of their male loved ones killed at the hands of Russian soldiers. Chechen female militants’ participation in jihad has largely been characterized based on their grief and revenge, rather than political motivations.[109] These women were driven to acts of martyrdom to regain a personal or familial honour, lost from the routine rape they endured by Russian soldiers. As highlighted in the previous section, the traditional patriarchal societies these women originate from govern women based on a strict set of social, cultural, and religious rules, so when a woman breaks these rules, they and their families are overwhelmed with shame and become ostracized by the community.[110] Because of this marginalization, women may turn to jihadi groups as a means of regaining their honour through committing a suicide act. In other words, these women gain the dignity they lost in life, through their death.[111]

While studies have shown, female terrorists are largely motivated by the same reasons as men, gender-based oppression may establish an additional motivational element for women.[112] As agents of violence, women are participating in the public domain and may no longer feel confined by their gender roles in the private sphere. Accordingly, women may become compelled to join jihad as a result of gendered oppression, violated rights and stifled freedoms. Female Palestinian suicide bombers, provide an excellent example of this resistance to gendered oppression.

Although women have been no stranger to the Palestinian national struggle, it wasn’t until 2002 during the second Intifada[113] that their role became violent. During the first Intifada women had participated in demonstrations, on committees and even in the production of terrorist attacks.[114] However, it wasn’t until January 27th 2002 that women’s participation began to include acts of violent resistance, namely suicide bombings. On this day, Wafa Idris, a young Palestinian woman detonated a bomb in Jerusalem killing herself and one other, initiating a movement of Palestinian female suicide bombers.[115] Yasser Arafat furthered this movement by inviting women to actively participate in the resistance against Israel, referring to them as his “Army of Roses.”[116] While it is without a doubt that Palestinian women have been motivated to take up an active role in violent jihad for political and nationalist reasons, the resistance against gender oppression and the traditional patriarchal society can also be seen as contributing to their participation. Because of the restrictive Muslim-Palestinian society, young women are denied freedoms and are heavily controlled through gender-based oppression. By becoming suicide bombers Palestinian women are taking control of their bodies, expressing their objections to the restrictive, patriarchal, gender-biased society. As Anat Berko and Edna Erez remark: “by becoming a suicide bomber, Palestinian women are as likely to make a statement about the colonization of their land as they are about the colonization of their female body by Palestinian patriarchal hegemony.”[117]

Based on this motivation against the oppressive patriarchal society, the question emerges: have Palestinian women gained an increase in equal rights and freedoms, through their death? Put differently, has this ‘strategy’ been successful for Palestinian women’s liberation? Indicating it has not, is the amount of money a family receives for their martyred relative: a female martyr’s family receives substantially less money compared to that of a male martyr.[118] Moreover, regardless of a woman’s motive to commit a suicide attack, when they are not successful in their attempt (they do not die) they are met with little approval by both their family and the community. In addition, they may become further marginalized as society perceives these women as stepping outside of their traditional female role. Essentially, when “female suicide bombers die, they are praised – but not if they live.”[119] Arguably, this indicates that through their death, Palestinian women’s attempt to challenge the narrative on oppression and inequality through martyrdom, has been unsuccessful in improving the situation for the women left behind.

Today, female actors in jihad and martyrdom operations are losing their agency as a result of the media’s representation contributing to the public and political discourse defining their actions, and bolstering gender oppression against them. Western media defines female terrorists based on personal characteristics focusing on appearance, family status, social status, and biographical details with their behaviour being attributed to external factors, rather than personal motivations.[120] Studies suggest the media’s portrayal of women terrorists focuses more heavily on personal information than when covering a male terrorist.[121] Accordingly, the media’s portrayal of women committing political crimes or participating in jihad, undermines their agency and is in accordance with gender stereotypes. This narrative minimizes the gender politics present in a women’s agency, reinforcing the controlling patriarchal aspects of these Islamic societies.

  1. The Case of Women in Daesh

In an effort to contextualize the above discussions on women’s agency in taking up jihad, and their role in jihad and martyrdom operations, a breakdown of Daesh’s (ISIS), current stance on these topics will follow. First however, a brief note on Daesh’s ideology is required. The group’s founder Abu Bakr al-Baghdadi’s declaration of a caliphate[122] and a violent jihad against all those opposed to his extremely conservative and militant version of Islam, has been widely disowned and rejected by a vast majority of Muslims and Islamic authorities.[123] The group utilizes a unique Salafi ideology to rationalize, recruit, motivate and legitimate its cause. More specifically, al-Baghdadi has combined politics and religion creating his own version of Islam for a “military ideological movement.”[124] Nevertheless, the group has been hugely successful in manipulating and exploiting Islamic doctrines to rally Muslims and establish an actionable jihad. Moreover, despite its patriarchal and brutal ideologies Daesh has recruited a considerable number of Muslim women and girls, to engage in its jihad.

  1. Women’s Agency

Daesh is notorious for its barbarity, abuse and subjugation toward women. Repeatedly exhibiting misogynistic behaviour towards women’s rights, the group do not offer any freedoms nor liberties to them: so why are women joining their ranks? Muslim women and youth in diaspora communities throughout the Western world have been continually ignored, hated, and separated from the broader public. In particular, Muslim women and girls have become an easy and obvious target because of the hijab and burka, as seen with backlash by governments such as France.[125] Consequently, ten percent of Daesh’s Western recruits have been women lured over social media platforms, with European recruits acknowledging that alienation and restrictions on religious practices, such as head scarf bans, have pushed them to join the group.[126] In Muslim-majority countries, issues such as unemployment, forced secularity by regimes, and the inability of democracy to deliver have contributed to increased Daesh recruits. Specifically, Tunisian women and youth make up Daesh’s most recruited members, with the percentage of Tunisians joining the group, higher than citizens from any other country.[127] Moreover, Daesh has succeeded with recruiting women from around the globe based on underlying causes within Muslim communities: specifically, the continuance of patriarchy and paternalism defining gender roles, allowing them to exploit women’s understanding of their role in society.[128]

In addition, Western women may be motivated by the idea of adventure or seek an alternative to their mundane life. While some women may join Daesh with the intention of becoming a ‘jihadi bride’ undertaking a traditional domestic role in jihad, others expect to become jihadis fighting in combat having an equal role as men.[129] However, the latter expectation of women desiring a more militant role in Daesh, does not coincide with the group’s current ideologies of women’s participation in jihad.


  1. Women’s in Jihad

As a result of their extremely conservative stance, especially towards women, it is perhaps no surprise Daesh has been reluctant to allow women to participate in fighting. Distinct from other jihadi groups prioritizing the fight against the West and its systems, Daesh also aims to create a transnational caliphate. Accordingly, many other roles are required for state and society building besides fighters, in order to establish conditions for the growth and sustainability of the caliphate. As such, Daesh has recruited women for traditional roles such as producing the next generation of jihadis, supporting their fighting husbands, and undertaking duties such as cooking or providing medical attention to soldiers.[130]

Daesh is distinguished from other modern radical jihadi groups based on the scale, organization and roles of females within the group. Exemplary of this distinction, is tasking female recruits with positions of enforcement such as the all-female Al-Khanssaa brigade. Regarded as the “morality police” the unit is armed and trained in weapon use, and is responsible for patrolling the streets and controlling checkpoints to ensure that all women comply with Daesh’s strict dress and conduct laws.[131] Those women caught violating the laws are subject to punishment, through reportedly cruel and barbaric methods as seen when fifteen women were disfigured by acid for not wearing a niqab.[132] In July 2015, the brigade published a document outlining Daesh’s position on women’s participation in jihad entitled, “Women in the Islamic State: Manifesto and Case Study.”[133] The document endorses women’s participation in jihad, in both active and passive capacities, calling on women to partake in both a domestic role and in active combat.[134] However, the Manifesto limits the combative role of females to situations of extreme enemy attack, insufficient numbers of men, and upon the issuance of a fatwa by an imam advocating for women’s participation.

Increasingly, Daesh’s women are indicating their support and desire for a more militant role in jihad.[135] Accordingly, the armed all-female Al-Khanssaa brigade is perhaps representative of a step in the direction of women’s participation in combat. However, as Alberto Cervone and Anita Peresin point out, it must be questioned if this unit represents the starting point in achieving a more combative role for women, or perhaps the limit.[136] Based on the restrictive and conservative nature of Daesh, it is unlikely the group would provide any opportunity for women to have a significant role in fighting, potentially opening the door to female empowerment. More specifically, Cervone and Peresin suggest Daesh is hesitant to include women in an active militant role for fear it could result in a “sexual revolution” undermining the patriarchal society and the jihadi ideology all together.[137]

  1. Female Martyrs

According to Daesh’s ideologies on jihad, suicide bombings are not only permitted, but are also an important instrument for the group’s jihad against the enemy.[138] Accordingly, Daesh has actively recruited and deployed female suicide bombers in Syria and Iraq, as well as indirectly in other states though its affiliates. More recently however, the group has expanded their reach with the November 14th 2015 Paris attacks, where Hasna Aitboulahcen became Western Europe’s first suicide bomber.[139] However, the use of women in these operations is regarded as a move of desperation and a choice of last resort.[140] Accordingly, should the situation for Daesh worsen, women may become increasingly used in suicide operations prior to being given more militant roles. Moreover, as previously discussed, the use of women in suicide operations provides Daesh with another opportunity to advance their agenda, without opening the door to female empowerment which they fear would result from women’s involvement in combat.

  1. Conclusion

Because of either a lack of understanding or the deliberate exploitation of the doctrine, jihad today is commonly viewed from the lesser jihad perspective, by both Westerners and Muslims.[141] Moreover, radical Islamist figures have utilized this perspective and declared combative jihad to rally Muslims behind their cause. Moreover, while modern radical jihadi groups legitimize their struggle based on the defensive individual obligation of jihad or fard ‘ayn, they refrain from calling upon women or exclude them from having a militant role. This exclusion contradicts the classical jurists’ interpretation that all Muslims should have a role in fighting if the situation is of extraordinary defensive circumstances. And while there is no consensus on women’s participation in active jihad, there is no religious order banning it either. Today’s jihadis’ wish to restore the “man of the past, the man who amounted offensive not defensive jihad… [who] was always triumphant and without women’s help.”[142] Accordingly, jihadi groups have managed to continue to deny women a role in militant jihad while adapting historical perspectives on female martyrdom to their advantage.

Women may be compelled to join jihad based on many of the same political and personal motivations as men. However, additional gender-related motives such as societal oppression, violated rights, and limited freedoms, may also influence women’s decision to take up violent jihad. To suggest in all cases women are being exploited and manipulated to participate in jihad, removes a woman from her agency. In fact, many women make the personal choice to join jihad and well aware of its potential consequences on their rights and freedoms. Moreover, the generalization of female martyrs and jihadis based on stereotypes connected to pacifism, femininity, and maternity, perpetuate this gender inequality and minimize a women’s own political agency.

Are jihadis today excluding women from active jihad, on the basis of their social conservatism? The participation of women in battle is unlikely to persuade religiously conservative Muslims who are representative of a traditional patriarchal order. Because these conservatives are to who radical jihadi ideologies appeal, jihadi groups maintain women’s importance to jihad in a strictly passive role in the private sphere. Accordingly, the exclusion of women from the battlefield is arguably done so to maintain the repressive patriarchal hegemony. In other words, jihadi groups fear that permitting women a militant role will result in female empowerment where these women, now playing a role in the public sphere, will revolutionize and demand more rights and freedoms – disrupting the oppressive gender status quo. Nevertheless, as demonstrated by Daesh’s all-female Al-Khanssaa brigade, jihadi groups are becoming more liberal in permitting female participation in militant jihad; however this development is unlikely to significantly and positively affect women and girls’ rights and status within Islamic societies.

Even though women have been effective in achieving a more active role in jihad, forcing Islamist groups to amend their approach, this role has mainly involved martyrdom operations helping advance jihadi agendas, begging the question: are women slowly gaining a more militant role in jihad as a result of jihadi groups sudden recognition of women’s desire to participate, or are jihadi groups realizing the strategic advantage of female fighters? Will more women take the initiative to fight in defensive jihad and declare their ‘right’ to participate or will they continue to wait for jihadi leader’s approval? Moreover, based on the legal doctrine of defensive jihad being incumbent on all Muslims, it is difficult to determine how long these groups can continue to exclude women from the battlefield, and if women do become more active will they indeed revolutionize and demand even more freedoms?

More broadly, this essay highlights the response to violent Islamist groups must include a focus on women’s rights, and the gender gap in the Muslim world. Traditionalist conservative Muslims, dictators, jihadis and even Western governments continue to define Muslim women’s rights and freedoms, however, it is Muslim women themselves who should be defining their own rights. In turn, with a focus on women’s rights and empowerment, Muslim women would be less motivated to turn to violent jihad.

[1] Because there is much confusion among the general public in the differences between Islam and Islamism, a brief word on their terminology is useful. The essential difference between these terms, is that Islamism is about politics rather than faith, and can be regarded as “religionized politics”. Islamism is not Islam, rather, it developed out of a specific interpretation of Islam based on a political ideology distinct from the religious teachings of Islam. Further, Islamism is not a revival of Islam, but instead an “invention of tradition”, calling for a return to an Islamist utopia which has never existed (Bassam Tibi, Islamism and Islam, (New Haven: Yale University Press, 2012), 1).

[2] Khaled Abou El Fadl, The Great Theft: Wrestling Islam From the Extremists (New York: HarperCollins, 2007), 220.

[3] Michael Bonner, Jihad in Islamic History, (Princeton: Princeton University Press, 2006), 1-2.

[4] Mia Bloom, “Death Becomes Her: The Changing Nature of Women’s Role in Terror,” Georgetown Journal of International Affairs 11, no. 1 (2010), 95.

[5] Farahnaz Ispahani, “Women and Islamist Extremism: Gender Rights Under the Shadow of Jihad,” The Review of Faith & International Affairs 14, no. 2 (2016), 102.

[6] Ibid.

[7] John L. Esposito, “Islam & Political Violence,” Religions 6 (2015), 1069.

[8] The hadith or the tradition literature of Islam, accounts for the preaching and events of the Prophet Muhammad’s life, as recounted by his close companions (David Cook, Understanding Jihad, (Los Angeles: University of California Press, 2005), 13).

[9] Cook, “Understanding Jihad,” supra note 8, at 13.

[10] Esposito, supra note 7, at 1069.

[11] Abou El Fadl, supra note 2, at 221.

[12] Esposito, supra note 7, at 1069.

[13] Abou El Fadl, supra note 2, at 221.

[14] Ibid., 222

[15] Ibid.

[16] It should be noted that ‘jihad’ as used in the Quran, does not refer to acts of warfare, these acts are known as ‘qital’, or the military action of jihad (Abou El Fadl, supra note 2, at 223).

[17] Amin Saikal, “Women and Jihad: Combating Violent Extremism and Developing New Approaches to Conflict Resolution in the Greater Middle East,” Journal of Muslim Minority Affairs 36, no. 3 (2016), 314.

[18] Ibid.

[19] Ibid.

[20] Nelly Lahoud, “The Neglected Sex: The Jihadis’ Exclusion of Women from Jihad,” Terrorism and Political Violence 26, no. 5 (2014), 781.

[21] Ibid.

[22] Ibid.

[23] Ibid., 782.

[24] Individual duties may include ritual prayer and fasting (Lahoud, supra note 20, at 782).

[25] Collective duties may include funeral prayer and offensive jihad (Lahoud, supra note 20, at 782).

[26] Lahoud, supra note 20, at 782.

[27] Ibid.

[28] Bonner, supra note 3, at 4

[29] Ibid.

[30] Ibid.

[31] Ibid.

[32] Esposito, supra note 7, at 1070.

[33] Cook, “Understanding Jihad,” supra note 8, at 13

[34] Ibid.

[35] Ibid., 10.

[36] Esposito, supra note 7, at 1070.

[37] Ibid.

[38] Ibid.

[39] Ibid., 1072.

[40] Ibid.

[41] Ibid.

[42] Lahoud, supra note 20, at 782.

[43] Although ‘Azzam’s writings have been widely published, they are banned today in most Arabic speaking countries (Cook, “Understanding Jihad,” supra note 8, at 128).

[44] Cook, “Understanding Jihad,” supra note 8, at 128.

[45] Esposito, supra note 7, at 1072.

[46] Ibid.

[47] Ibid.

[48] Ibid.

[49] Lahoud, supra note 20, at 783.

[50] Ekaterina Yahyaoui Krivenko, “Islamic View of Women’s Rights: An International Lawyer’s Perspective,” Journal of East Asia and International Law 2, no. 1 (2009), 127.

[51] Ibid.

[52] Anat Berko and Edna Erez, “Martyrs or Murderers? Victims or Victimizers? The Voices of Would-Be Palestinian Female Suicide Bombers,” in Female Terrorism and Militancy: Agency, Utility, And Organization, ed. Cindy D. Ness (New York: Routledge, 2008), 148-49

[53] Lahoud, supra note 20, at 783.

[54] Berko and Erez, supra note 52, at 149.

[55] Ibid.

[56] Ibid.

[57] Ibid.

[58] Saikal, supra note 17, at 316.

[59] Lahoud, supra note 20, at 792.

[60] David Cook, “Women Fighting in Jihad?”, Studies in Conflict and Terrorism 28, no. 5 (2005), 376.

[61] Ibid., 377.

[62] Ibid. 377-378.

[63] Alberto Cervone and Anita Peresin “The Western Muhajirat of ISIS,” Studies in Conflict & Terrorism 38, no. 7 (2015), 497.

[64] Cook, “Women Fighting in Jihad?”, supra note 60, at 376.

[65] Ibid.

[66] Ibid., 376-377.

[67] Lahoud, supra note 20, at 792.

[68] Ibid.

[69] Ibid.

[70] Ibid., 793.

[71] Ibid., 795.

[72] Cook, “Women Fighting in Jihad?”, supra note 60, at 378.

[73] Ibid., 379.

[74] Ibid.

[75] Lahoud, supra note 20, at 783.

[76] Ibid.

[77] Ibid., 785

[78] Ibid.

[79] Ibid.

[80] Ibid.

[81] Cervone and Peresin, supra note 63, at 497.

[82] Ibid.

[83] Katharina Von Knop, “The Female Jihad: Al Qaeda’s Women,” Studies in Conflict & Terrorism 30, no. 5 (2007), 399.

[84] Khapta Akhmedova and Anne Speckhard, “Black Widows and Beyond: Understanding the Motivations and Life Trajectories of Chechen Female Terrorists,” in Female Terrorism and Militancy: Agency, Utility, and Organization, ed. Cindy D. Ness (New York: Routledge, 2008), 111.

[85] Cook, “Women Fighting in Jihad?”, supra note 60, at 383.

[86] Ibid., 379.

[87] It should be noted that several categories of non-combatant martyrs also exist including: women who die in childbirth, those who die of accident or of disease, and those who die of natural causes while engaged in meritorious acts such as pilgrimage (Bonner, supra note 3, at 78).

[88] Bonner, supra note 3, at 77.

[89] Ibid.

[90] Lahoud, supra note 20, at 783.

[91] Cindy D. Ness, “In the Name of the Cause: Women’s Work in Secular and Religious Terrorism,” in Female Terrorism and Militancy: Agency, Utility, and Organization, ed. Cindy D. Ness (New York: Routledge, 2008), 19.

[92] Ibid.

[93] A legal ruling on a question by a recognized authority – recognized as an authoritative statement of law.

[94] Cindy D. Ness, supra note 91, at 20.

[95] Ibid.

[96] Ispahani, supra note 5, at 102.

[97] Von Knop, supra note 83, at 399.

[98] Lahoud, supra note 20, at 795.

[99] Cervone and Peresin, supra note 63, at 498.

[100] Von Knop, supra note 83, at 401.

[101] Female terrorists are said to be four times deadlier on average than their male counterparts, partly because of these stereotypes and ability to get closer to a target (Bloom, “Death Becomes Her,” supra note 4, at 93).

[102] Cervone and Peresin, supra note 63, at 497.

[103] Ibid., 497-498.

[104] Ibid., 498.

[105] Mia Bloom, Bombshell: Women and Terrorists, (London: Hurst, 2011), 234.

[106] Ibid.

[107] Cervone and Peresin, supra note 63, at 497.

[108] Ispahani, supra note 5, at 102.

[109] Cindy D. Ness, supra note 91, at 19.

[110] Von Knop, supra note 83, at 400.

[111] Ibid.

[112] Von Knop, supra note 83, at 399.

[113] “Uprising”, in this case Intifada is referring to the Palestinian resistance against Israeli occupation.

[114] Berko and Erez, supra note 52, at 146.

[115] Moran Yarchi, “The Effect of Female Suicide Attacks on Foreign Media Framing of Conflicts: The Case of the Palestinian–Israeli Conflict,” Studies in Conflict & Terrorism 37, no. 8 (2014), 676.

[116] Ibid.

[117] Berko and Erez, supra note 52, at 160.

[118] Ibid.

[119] Ibid.

[120] Yarchi, supra note 115, at 677.

[121] Ibid.

[122] A caliph refers to the title given to those succeeding the Prophet Muhammad’s societal leadership, becoming the leader of all Muslims. This title does not imply prophecy as Muhammad is God’s last prophet, according to Islamic doctrine (Saikal, supra note 17, at 316).

[123] Saikal, supra note 17, at 316.

[124] Esposito, supra note 7, at 1075.

[125] Ispahani, supra note 5, at 103.

[126] Jayne Huckerby, “When Women Become Terrorists,” New York Times, January 21, 2015,accessed April 28, 2017, https://www.nytimes.com/2015/01/22/opinion/when-women-become-terrorists.html?_r=0.

[127] Ispahani, supra note 5, at 103.

[128] Ibid.

[129] Cervone and Peresin, supra note 63, at 501.

[130] Ibid., 499.

[131] Saikal, supra note 17, at 318

[132] Cervone and Peresin, supra note 63, at 502.

[133] Ibid., 501.

[134] Saikal, supra note 17, at 318

[135] Cervone and Peresin, supra note 63, at 502.

[136] Ibid.

[137] Ibid., 503.

[138] Saikal, supra note 17, at 318.

[139] Ibid., 318-19.

[140] Cervone and Peresin, supra note 63, at 498.

[141] Ibid., 315.

[142] Lahoud, supra note 20, at 798.

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