Human Rights Watch acknowledges at the outset the difficult role UNHCR must often play in refugee crises, seeking to protect refugees in the face of frequently hostile governments of receiving countries as well as countries of origin. For the most part, refugee protection remains the responsibility of States-not only receiving countries and countries of origin, but donor countries as well. The success of UNHCR's activities hinges largely on the adherence of States to their obligations under international human rights and humanitarian law, as well as the 1951 Convention for those States that are signatories. Nevertheless, UNHCR has an express mandate to protect refugees, which includes a significant role in the coordination and organization of voluntary repatriation operations and in monitoring the consequences of return.6 As a practical matter, UNHCR also serves as one of the few voices that can effectively influence States' behavior toward refugees. UNHCR remains the preeminent entity entrusted with the protection and assistance of refugees.
While it is well recognized that UNHCR plays a central role in voluntary repatriation programs, the contours of that role have not always been well defined.7 However, the basic principles of protection in voluntary repatriation were stressed by Executive Committee conclusions and other public statements of UNHCR. As the Executive Committee emphasized in 1980, "The essentially voluntary character of repatriation should always be respected."8
The Handbook on Voluntary Repatriation reiterates this fundamental link between international protection of refugees and voluntariness in refugee repatriation.
The principle of voluntariness is the cornerstone of international protection with respect to the return of refugees. While the issue of voluntary repatriation as such is not addressed in the 1951 Refugee Convention, it follows directly from the principle of non-refoulement: the involuntary return of refugees would in practice amount to refoulement.9
The Handbook on Voluntary Repatriation also recognizes that establishing a truly voluntary repatriation program is not only consonant with international law but is also the most pragmatic approach to repatriation: "Repatriation which is voluntary is far more likely to be lasting and sustainable."10
The essence of repatriation is voluntariness. Yet, UNHCR has in several instances transgressed this axiom of refugee repatriation, violating the very standards its Executive Committee had promulgated.
"Push" Factors
UNHCR recognizes that "push" factors-those that compel refugees to repatriate because conditions are worse in the country of refuge than in the country of origin-seriously compromise the voluntariness of a repatriation. This principle is implicit in UNHCR's view of voluntary repatriation at least since 1980.11 Yet Human Rights Watch has researched several instances since the early 1990s in which UNHCR itself has either undertaken or acquiesced to precisely such coercive measures, including the reduction of food assistance. Such practices not only risk the safety of returnees, but also undermine UNHCR's credibility and arguably constitute a violation of its mandate.
For example, Human Rights Watch found in researching the plight of Tajik refugees in northern Afghanistan that UNHCR's Afghanistan office used the reduction of rations to "push out" Tajik refugees from a refugee camp in Balkh province of northwestern Afghanistan. Human Rights Watch addressed the situation of Tajik refugees camps in northern Afghanistan in two reports. In a May 1995 report, "Return to Tajikistan," Human Rights Watch/Helsinki examined the repatriation of Tajik refugees from northern Afghanistan.12 Several returning refugees from Camp Sakhi in Balkh province, Afghanistan, told Human Rights Watch/Helsinki that the Afghanistan office based in Mazar-i-Sharif, which administers Camp Sakhi, had pressured them into returning to Tajikistan by, among other things, reducing rations.13 According to UNHCR, however, food distribution was not halted or reduced, but was instead adjusted downward to reflect earlier inflated population figures.14
Yet, as described in a second report, the May 1996 "Tajik Refugees in Northern Afghanistan: Obstacles to Repatriation," when Human Rights Watch/Helsinki returned in December 1995 to update its investigation, we found that there were again numerous reports that UNHCR's Afghanistan office was reducing rations in Camp Sakhi in order to pressure Tajik refugees there to repatriate.15 Again, UNHCR's initial response to queries regarding these ration cuts suggested that they were meant to be adjustments to earlier incorrect population figures. However, an officer for the Afghanistan office later told Human Rights Watch/Helsinki that while earlier ration reductions hadindeed been implemented to reflect what UNHCR felt was the true population figure in the camps, reductions that had been planned for late 1995 and early 1996 (including at least one that had already been implemented by October 1995) were intended to pressure the Tajiks to enter UNHCR's voluntary repatriation program.16 Returning refugees also told Human Rights Watch/Helsinki that UNHCR had expressly linked the reduction of rations to the need for the Tajik refugees to return to Tajikistan in refugee camp announcements during the fall of 1995.17
The situation of Tajik refugees in northern Afghanistan also points to practical benefits for establishing a truly voluntary repatriation. Among other things, by compelling "voluntary" repatriation, UNHCR risks harm to its reputation and ability to function effectively. At the same time that UNHCR was seeking to compel Tajik refugees to repatriate from the camp near Mazar-i-Sharif, it was seeking to gain access to three other Tajik refugee camps, administered by the United Tajik Opposition, in Konduz and Takhar provinces. Many Tajik refugees in northern Afghanistan have come to doubt UNHCR's integrity as news and rumors of the measures undertaken in Camp Sakhi spread to the refugee camps in Konduz and Takhar provinces. It did not help that UNHCR failed to state clearly in seeking to gain access to the Konduz and Takhar refugee camps whether it believed that those camps should be set on the same repatriation schedule as the camp near Mazar-i-Sharif. As a result, the organization's ability to obtain access to Tajik refugees in other refugee camps in northern Afghanistan has arguably been diminished.18
Suspicion directed at UNHCR may also have affected the efficacy of some other elements of the voluntary repatriation program in the Konduz and Takhar camps. In particular, refugees in those other camps have come to distrust UNHCR's attempts to provide information about conditions in Tajikistan-information which is critical to the ability to make a sound decision regarding whether or not to return. For example, Tajik opposition leaders and several refugees told Human Rights Watch/Helsinki that they suspected that UNHCR was deliberately suppressing letters from Tajikistan that detailed the difficulties of life there, and was instead only delivering the more optimistic letters.19 That such wildly implausible stories should have gained currency among Tajik refugees reflects the extent to which UNHCR's practices in Mazar-i-Sharif have provided the refugees with putative reasons to question UNHCR's commitment to its protection role.
Human Rights Watch encountered a related problem in early 1996 when researching the plight of a new wave of Burmese Muslims seeking refuge in Bangladesh. The Bangladesh government severely restricted access by UNHCR and other NGOs, thereby denying new arrivals the right to seek asylum and their ability to receive any kind of food or medical assistance. Furthermore, the government arrested some 250 Rohingyas. In the face of such pressure directed at the new asylum seekers, U.N. agencies including UNHCR, raised objections to the denial of access, yet at the same time publicly demonstrated reluctance to criticize other harsh measures such as the refusal to provide food assistance. For example, UNHCR treated the distribution of food as a "pull-factor" for new arrivals, with the UNHCR resident representative in Dhaka publicly stating, "If we give food to this group, we'll attract50,000 more the next day."20 The Bangladesh government had tried a similar strategy after the cyclone of May 1994 devastated refugee camps, by delaying the provision of bamboo and other housing materials. UNHCR at that time failed to protest vigorously the deliberate delay. Nor was the limitation of food as a push factor the first time in the history of Rohingya flight that food had been used to apply pressure in favor of repatriation. In the 1978 repatriation of Burmese refugees from Bangladesh too, the Bangladesh government had reduced rations in order to force refugees to return to Burma. A UNHCR officer reported then that, "[n]one of the U.N. agency heads raised any objections to using food as a political weapon."21
According to UNHCR's Handbook on Voluntary Repatriation, an important prerequisite to ensuring that a decision to repatriate is voluntary is "the absence of measures which push the refugee to repatriate."22
Refugee repatriation is not voluntary when host country authorities deprive refugees of any real freedom of choice through outright coercion or measures such as, for example, reducing essential services . . . .23
This point is reinforced elsewhere in the Handbook on Voluntary Repatriation: "There must be no threat to phase down basic refugee assistance programmes in connection with registration" for repatriation.24 Although such measures clearly offend the fundamental element of voluntariness in return, in light of these past experiences Human Rights Watch especially welcomes the new guidelines' clear stance against the use of push factors.
Neutral, Accurate and Objective Information
The Executive Committee in 1980 recognized that truly voluntary repatriation requires that "refugees be provided with the necessary information regarding the conditions in their country of origin in order to facilitate their decision to repatriate."25 Nevertheless, in certain instances, UNHCR has failed to provide such information.
In the case of Rohingya refugees from Burma who fled to Bangladesh, testimony from refugees and NGO workers26 indicates that UNHCR practices in the field fell significantly short of these protection standards. Nevertheless, the return of over 200,000 Burmese Muslim refugees from 1992 to 1996, from Bangladesh to their home state of Arakan in western Burma, is being held up as a success story by UNHCR in speeches of senior officials as well as in publications, including its 1995 biennial report, State of the World's Refugees.27 While that repatriationwas still under way, in early 1996, a new refugee outflow began, with some 10,000 new asylum seekers entering Bangladesh from Arakan between the end of February 1996 and the end of May 1996. The Bangladesh government has been intent on repatriating them. The new arrivals came to Bangladesh at a time when UNHCR was attempting to complete the repatriation of the Rohingya who had fled violent abuse by the Burmese military in 1991 and 1992. It is perhaps for that reason that, in contravention of UNHCR policy, the representative in Dhaka publicly stated that all the new arrivals were "economic migrants," who were escaping poverty not persecution, and stepped up efforts inside Arakan state to ensure that those planning to leave would not do so.28
In Arakan state, only UNHCR has had free access to the returnees' home villages, and then only since February 1994; free access to all areas in Arakan state was not achieved until the end of 1994. Despite this relative lack of access in the country of origin, UNHCR's position when it began the promotion of repatriation in June 1994 was that while the fundamental situation in Burma had not changed, the violent abuses which led the Rohingyas to flee had come to an end, so that the abuses to which the Rohingyas were now subject were no different from abuses experienced by all people in Burma.29 On that basis, UNHCR concluded that the conditions in the country of origin were conducive to return and that its presence in Burma would reassure refugees and encourage them to return. Nevertheless, there has been evidence of ongoing abuse directed in a discriminatory manner against the Rohingyas in Burma, including the disappearances and arrests of Rohingya returnees from the 1992 to 1996 repatriation, as well as forced labor, forced relocations and arbitrary taxation.30 Despite such evidence, UNHCR failed to include these facts in their repatriation information, meanwhile continuing repatriation of the older asylum-seeker population and taking measures to prevent new arrivals. Given its exclusive access, UNHCR was in a strong position to dismiss as mere rumors reports of severe abuses from refugees, NGOs and, at times, new arrivals.31
While it was failing to provide Rohingya refugees with sufficient or accurate information with which to make a decision on voluntary repatriation, UNHCR was at the same time distributing information in Arakan state, telling Rohingya there that if they left to seek asylum, they would face arrest in Bangladesh. While such information may have constituted an accurate reflection of the Bangladesh government's treatment of the new arrivals, UNHCR would have better directed its efforts to seeking protection for newly arrived Rohingya who sought to exercise their fundamental right to seek asylum.
Thus, UNHCR's response to the more recent influx arguably has been to facilitate the Bangladesh government's decision to return the Rohingya refugees, rather than protest violations by a receiving government determined to force refugees back to their country of origin. This approach stands in contrast to UNHCR's response in Bangladesh in December 1992, when the organization withdrew from all camps entirely and made vociferous public complaints against the Bangladesh authorities until it was able to win agreements which enabled UNHCR protection officers to interview individual refugees in confidence. The more recent approach stretches to the point of meaninglessness the principle of voluntary return which UNHCR always seeks to uphold and puts at risk the fundamental principle of protection from refoulement. In the case of the Rohingyas, UNHCR's tentative statementthat the refugees "appear to have recognized that it is better to go home now"32 and were thus making a voluntary decision to return, remains a point of contention.
The importance to a successful voluntary repatriation operation of the exchange and dissemination of neutral and objective information on conditions in the country of origin is reiterated in UNHCR's Handbook on Voluntary Repatriation: "Only an informed decision can be a voluntary decision."33 The Handbook on Voluntary Repatriation states further: "Information campaigns are UNHCR's core responsibility and principal mechanism to promote voluntary repatriation and to ensure that refugees' decisions are taken in full knowledge of the facts."34 The Handbook on Voluntary Repatriation further specifies that
The information campaign must be objective, accurate and neutral. It is not propaganda, and care must be taken not to paint an overly rosy picture of the return . . . . Finally, [refugees] need to know about what will happen in the event they decide not to volunteer for repatriation.35
Access to Refugees: In the Country of Asylum
UNHCR access to refugees is an implicit precondition to several of the voluntary repatriation guidelines set forth in Executive Committee conclusions. Among other things, such access is fundamental to the core protection responsibility of providing refugees with objective and neutral information on the relevant current conditions in the country of origin. Yet, UNHCR has taken part in several supposedly voluntary repatriation programs where it has had little or no access at all to the refugees in the receiving country prior to repatriation. In the 1993 report "Halt Repatriation of Sri Lankan Tamils," Human Rights Watch/Asia investigated the repatriation of Tamil refugees to Sri Lanka.36 Neither NGOs nor UNHCR had access to the Tamil refugee camps located in southern India where registration for repatriation took place. As a result, UNHCR had no meaningful opportunity to establish the elements of a voluntary repatriation or to examine the claims of the Indian government that the repatriation was voluntary.
Access to refugees is an obvious link to another key element of voluntary repatriation-the dissemination of information upon which refugees may base a decision to repatriate. Without access to UNHCR, the Tamil refugees lost an important avenue for obtaining information about the situation in Sri Lanka, upon which to base a decision on repatriation. The basis for the repatriation was a bilateral agreement between the Indian and Sri Lankan governments. Despite its longstanding practice of negotiating tripartite agreements, UNHCR was excluded from the repatriation agreement, and repatriation proceeded without its involvement. There was widespread evidence that the repatriation was anything but voluntary. Indian officials used various tactics to pressure Tamils into repatriating, including arbitrary arrests and the withdrawal of stipends and food rations. In some instances, Indian authorities pressured refugees into signing "voluntary" repatriation agreements (many of which were only in English) through the destruction of their huts.
In the face of such circumstances, UNHCR negotiated a restricted role in the repatriations after the High Commissioner wrote to the Indian prime minister and raised specific questions about security conditions in Sri Lanka. The negotiations increased NGO concerns that the agency's acceptance of its restricted role with the SriLankan refugees would "lend legitimacy to the repatriations, while allowing the Indian government to bar UNHCR from fulfilling its protection mandate."37
The Handbook on Voluntary Repatriation reiterates the importance of free access for UNHCR to refugees:
For UNHCR to ensure and to satisfy itself that repatriation is voluntary, free and unhindered access to the refugees is necessary. In turn, refugees have to have free access to UNHCR without fear of disadvantages or reprisals resulting from such contacts.38
The importance of access to refugees is further stressed by the emphasis it is given in the handbook's discussion of critical ingredients of the tripartite repatriation agreement, where the first among the "core protection" elements is "[g]uarantees of UNHCR's free and unhindered access to all refugees and returnees and free access of all refugees and returnees to UNHCR."39 Human Rights Watch welcomes this clarification of the previously implicit principle that in order to conduct a successful voluntary repatriation operation, UNHCR must have access to refugees as well as returnees.
Access to Refugees: Monitoring Returnees
Probably the stage most indicative of ensuring success in any repatriation program begins only after repatriation per se has occurred, in monitoring the consequences of return. UNHCR's Executive Committee has recognized UNHCR's role in events that follow a refugee's return, noting:
The High Commissioner should be recognized as having a legitimate concern for the consequences of return, particularly where such return has been brought about as a result of an amnesty or other form of guarantee. The High Commissioner must be regarded as entitled to insist on [her] legitimate concern over the outcome of any return that he has assisted.40
A necessary prerequisite for monitoring returnees is "direct and unhindered access to returnees" which enables UNHCR to "monitor fulfillment of the amnesties, guarantees or assurances on the basis of which the refugees have returned."41 Such monitoring and the degree of access which makes it meaningful was deemed by the Executive Committee of UNHCR to be "inherent in [the High Commissioner's] mandate."42
UNHCR access to returnees offers numerous additional benefits to a sound voluntary repatriation program. Significantly, such access further ensures that UNHCR can provide more up to date, accurate and complete first-hand information about conditions of return to those who remain in refugee camps in the receiving country. A truly voluntary decision to repatriate of course requires such information. Furthermore, continued UNHCR presence in the areas of return assures those contemplating return that they will have ready access to UNHCR should problems occur. This is particularly important as returning refugees frequently lack the means to travel to UNHCR offices that are far from their repatriation site.
Indeed, several of Human Rights Watch's investigations into human rights abuses involving refugees and mass movements indicate that an active UNHCR presence in the country of origin can have a significant positive impact on the human rights situation of those who have elected to return to their country, and thereby further a durable reintegration and prevent renewed outflows. For example, in the May 1996 report "Tajik Refugees in Northern Afghanistan," Human Rights Watch/Helsinki reported that many returnees in southern Tajikistan felt that the incidence of human rights abuses dropped significantly when UNHCR maintained a visible presence in their village.43 As returnees in one village in Kurgan Teppa province told Human Rights Watch/Helsinki, "Every time the U.N. car comes by [our village], the situation grows a little more calm."44
However, Human Rights Watch has also reported on several occasions that UNHCR has not fielded the necessary number of field staff or that its field staff has not obtained the necessary degree of access to fulfill this central protection function. In Tajikistan, for example, at the same time that Tajik refugee returnees were telling Human Rights Watch/Helsinki that the UNHCR presence was significantly improving the human rights situation in their villages, UNHCR was drastically reducing its staff in southern Tajikistan. Meanwhile continued tensions between those perceived to be associated with the two sides of the civil war suggest a need for continued monitoring of returnees.45 Similarly, Human Rights Watch/Helsinki has found in Bosnia that UNHCR has often not fielded enough staff to maintain the level of access to persons of its concern necessary to fulfill this core protection role.
The overall protection mandate of UNHCR has not prevented it from undertaking recent efforts to share some of its protection functions in monitoring returnees, with the Organization on Security and Cooperation in Europe (OSCE) in particular. While a detailed discussion of the protection role of groups other than UNHCR is beyond the scope of this document, Human Rights Watch believes that there should be further discussion of this issue before UNHCR shares its protection responsibilities again. While sharing the burden of protection may have some benefits, there has also been some concern that refugees' rights may not be sufficiently protected by such arrangements. As a practical matter, UNHCR is simply in the best position to provide protection to refugees, based on expertise, skills, experience and resources.
The sharing of UNHCR's protection role raises the question of the limits of such arrangements. In Tajikistan, beginning in September 1995, UNHCR relinquished to the OSCE certain monitoring functions in all returnee areas, except for the capital Dushanbe.46 Although it is clear that at some point after a repatriation UNHCR must terminate its protection role, in the case of Tajikistan, where there are still some 26,000 refugees awaiting to repatriate (28,000 having returned by March 1996 under auspices of UNHCR) and where hostility against returnees still runs high in areas of return, OSCE is arguably trying to fulfill the kind of monitoring role that UNHCR has traditionally played.
While Human Rights Watch makes no conclusions at present as to the ability of OSCE to fulfill this protection role, we do note that there has been concern, raised by some NGOs as well as some UNHCR staff, why OSCE may be less well-suited than UNHCR for the role of refugee protection. First, there is some concern that OSCE may lack the independence necessary for vigorous advocacy of refugee rights. Second, there are concernsthat the OSCE practice of fielding personnel seconded from member States, for relatively brief stints, may fail to produce the level of experience and expertise in refugee protection that UNHCR employees may accrue. Even a few members of UNHCR's field staff in Tajikistan informally expressed doubt to Human Rights Watch/Helsinki as to OSCE's ability to carry out this protection role properly. With as many as 26,000 Tajik refugees still in northern Afghanistan, the majority of whom are in refugee camps to which UNHCR has still not garnered access, the handover of such protection functions traditionally held by UNHCR to OSCE should perhaps be reconsidered. While UNHCR has certainly relied on a wide range of implementing partners in refugee crises around the world, including for the detection of protection problems, the High Commissioner should perhaps consider not divorcing herself entirely from the protection of a population of her concern until threats to their safety and dignity are significantly fewer and less grave than they were in Tajikistan.
It is true, of course, as UNHCR points out in its Handbook on Voluntary Repatriation, that ultimately the efforts of the organization to monitor returnees amount at the most to "international support for national protection."47 The government must be held responsible for providing security and protection for individuals within its jurisdiction. Nevertheless, UNHCR has a clear mandate to take action to protect refugees after they have returned to their country. As the Handbook on Voluntary Repatriation now makes clear, where
there is evidence that the freedom or security of returnees is at risk due to a lack of state protection, UNHCR should do whatever it can to remedy the situation and relieve the plight of refugees. UNHCR must intervene where human rights abuses or severe discrimination come to light . . . . Where problems and abuses are not isolated and there appears to be a risk of future occurrences, UNHCR should not promote further repatriation, until the problems [sic] is rectified.48
6 Conclusions of the Executive Committee of UNHCR provided some general guidance on UNHCR's activities in connection with voluntary repatriation, with the Executive Committee emphasizing in 1994 that UNHCR plays a "leading role . . . in promoting, facilitating, and coordinating voluntary repatriation." Executive Committee of UNHCR, Conclusion 74 (XLV).
7 Voluntary repatriation and the role to be played by UNHCR was addressed in Executive Conclusions 18 (XXXI) and 40 (XXXVI). The U.N. General Assembly endorsed the Executive Committee's Conclusion 40 in Resolution 40/118, December 13, 1985, endorsing by extension Conclusion 18 as well, as that Conclusion was reaffirmed in Conclusion 40.
8 Executive Committee of UNHCR Conclusion 18(b) (XXXI) (1980).
9 Handbook on Voluntary Repatriation, p. 10.
11 The "essentially voluntary character of repatriation should always be respected [and] . . . . [t]he desirability of appropriate arrangement to establish the voluntary character of repatriation." Executive Committee of UNHCR Conclusion 18 (XXXI) (1980). "The repatriation of refugees should only take place at their freely expressed wish." Executive Committee of UNHCR Conclusion 40 (XXXVI) (1985) (emphasis added).
12 Human Rights Watch/Helsinki, "Return to Tajikistan: Continued Regional and Ethnic Tensions," A Human Rights Watch Short Report, vol. 7, no. 9, May 1995, p. 10.
14 UNHCR had never conducted a proper registration of refugees in Camp Sakhi. As a result, rations for the camp were calculated on the basis of each family claim to number of family members.
15 Human Rights Watch/Helsinki, "Tajik Refugees in Northern Afghanistan: Obstacle to Repatriation," A Human Rights Watch Short Report, vol. 8, no. 6 (D), May 1996, p. 12 (hereinafter, "Tajik Refugees in Northern Afghanistan).
18 This is not to suggest that distrust of UNHCR is the sole or even the main reason access to those camps have been limited. Other significant factors include the reluctance of existing Islamist aid organizations to permit other aid organizations from gaining access. Nevertheless, the actions of UNHCR in Camp Sakhi are frequently cited by leaders of the Tajik Opposition as a basis for their hesitancy in granting UNHCR access to other refugee camps. See "Tajik Refugees in Northern Afghanistan: Obstacles to Repatriation", pp. 12-15.
19 Human Rights Watch/Helsinki, "Tajik Refugees in Northern Afghanistan", p. 14.
20 Human Rights Watch/Asia, "Burma: The Rohingya Muslims Ending a Cycle of Exodus?", A Human Rights Watch Short Report, Vol.8, No.9, September 1996, p. 8.
21 UNHCR suboffice in Cox's Bazaar, "Report on the 1978-1979 Bangladesh Refugee Relief Operation," June 1979, cited in Human Rights Watch/Asia, "Burma - The Rohingya Refugees . . .", note 4. For discussion of other aspects of the Rohingya repatriation, see below in "Neutral, Accurate and Objective Information."
22 Handbook on Voluntary Repatriation, p. 10.
23 Ibid., p. 42 (emphasis in original).
25 Executive Committee of UNHCR Conclusion 18(e) (XXXI) (1980).
26 Human Rights Watch/Asia, "Burma - The Rohingya Muslims", p. 14-21.
27 United Nations High Commissioner for Refugees, State of the World's Refugees: In Search of Solutions, (Geneva: 1995), pp. 62-63.
28 Human Rights Watch/Asia, "The Rohingya Muslims", p. 7. While it is true that ultimately, all UNHCR actions regarding these new asylum seekers may have been governed by its determination that the new arrivals were economic refugees, the UNHCR Asia bureau chief has, in fact, told Human Rights Watch that UNHCR has never made such a blanket assessment of the status of the new arrivals. Such blanket denials of refugee status may violate the right to seek asylum.
29 Presumably, the UNHCR staff in Burma meant that the Rohingyas no longer suffer particularized abuses and, therefore, cannot be refugees. Human Rights Watch does not agree with such an interpretation of the 1951 Convention.
30 Human Rights Watch/Asia, "The Rohingya Muslims", p. 29-32.
31 The exception has been the discussion of two issues in UNHCR's June 1995 Bulletin the alleged forced sterilization of women returning to Burma and the forced attendance of Muslim girls in vocational schools run by the army. Ibid., p. 14.
32 UNHCR, State of the World's Refugees: In Search of Solutions, pp. 62-63.
33 UNHCR, Handbook on Voluntary Repatriation, p. 44.
34 Ibid., p. 44 (emphasis added).
36 Human Rights Watch/Asia, "Asia Watch: Halt Repatriation of Sri Lankan Tamils," A Human Rights Watch Short, vol. 5, no. 11, August 11, 1993.
38 UNHCR, Handbook On Voluntary Repatriation, p. 41.
40 Executive Committee Conclusion 40(l) (XXXVI).
43 Human Rights Watch/Helsinki, "Tajik Refugees in Northern Afghanistan", p. 27. The importance of the UNHCR presence was also noted in UNHCR's The State of the World's Refugees: In Search of Solutions,
pp. 77-78.
44 Human Rights Watch/Helsinki, "Tajik Refugees in Northern Afghanistan", p. 27.
45 Internally displaced returnees, whose political alignment during the war was identical that of those who had fled across the international border to Afghanistan.
46 Human Rights Watch/Helsinki, "Tajik Refugees in Northern Afghanistan", pp. 26-27.