Right/Freedom of Association/Culture and Politics

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Freedom of Association

Is there general and widespread belief that this right is a fundamental right that should generally be protected (and that exceptions should be rare)? 🖉 edit

Freedom of Association refers to the right to associate and interact with organizations and individuals in terms of organizing and demanding common interests. The Office of the United Nations High Commissioner for Human Rights defines this right as, “The right to freedom of association involves the right of individuals to interact and organize among themselves to collectively express, promote, pursue and defend common interests. This includes the right to form trade unions.”(OHCR). This right is stated under the 20th article of the United Nations Declaration of Human Rights, which states, “(1) Everyone has the right to freedom of peaceful assembly and association. (2) No one may be compelled to belong to an association.”(United Nations 1948). This right is generally associated with labor unions and is stated as the right of ‘Freedom of Association and Collective Bargaining’ according to the International Labour Organization which is a United Nations body that advances economic justice and rights such as the freedom of association.

This right is generally interpreted and defined differently under different constitutions pertaining to the various importance of the right to the environment and culture of the country. For example the United States’ constitution does not explicitly state the right to freedom of association rather in the first amendment it states, “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof; or abridging the freedom of speech, or of the press; or the right of the people peaceably to assemble, and to petition the Government for a redress of grievances.”(US Constitution Annotated 2022). Therefore the United States supports a form of association and does not allow the prohibition of ‘assembly’ of individuals ‘peaceably’. This right is often associated and phrased in constitutions as the ‘Freedom of Association and Collective Bargaining’ this implies a distinction between the two concepts; with collective bargaining being associated with the demands rather than the organization of the individuals.

Liberal democratic countries often support this right based on common understandings from the English philosopher John Locke who in his writing of "Two Treatises of Government". Locke championed three fundamental unalienable rights which are: the right to life, liberty, and property. As such he does not explicitly state the right of freedom of association, yet he does describe the right of individuals to join together in pursuit of their interests. Locke argues, “The natural liberty of man is to be free from any superior power on earth, and not to be under the will or legislative authority of man, but to have only the law of nature for his rule.”(Locke 1689) individuals have the natural right to associate with others based on mutual consent, forming communities and engaging in collective endeavors. He believed that individuals should have the liberty to create associations, including religious congregations, trade unions, and political organizations, in order to protect and advance their shared interests.

Furthermore, John Locke introduced the concept of the ‘Social Contract’ exploring the idea of a collective agreement that establishes the norms, behaviors, and rules necessary for the formation of a society and a functioning government. John Locke, in his influential work "Two Treatises of Government," argued that individuals willingly enter into a social contract to form a civil society. This organized entity consent to be governed by an authority that protects their natural and unalienable rights of life, liberty, and property. Locke argues that if the government violates this social contract by infringing upon these fundamental rights, they have the right to resist and potentially overthrow the government.

The idea of the social contract highlights the notion of individuals entering into a collective agreement to form a society and a government that serves their common interests and protects their rights. The concepts put forth by Locke contribute to the understanding of the relationship between individuals and the government, as well as the rights and responsibilities that arise from this social contract in terms of freedom of association.

Furthermore, this right according to international organizations, specifically the International Trade Union Confederation, which has utilized an index to rank and identify the extent of the adoption of this right around the world(The International Trade Union Confederation 2022). According to the index, all countries generally have a clause or article that pertains to a form of right of freedom of association but many countries obstruct this right through justifications of ‘Free Speech’ of businessmen against their employees, ‘National Interests’, among other reasons for infractions on this right.

Whereas, the exceptions of the right generally exist in different frequencies, it is generally unjustified according to the ILO and ITUC to obstruct this freedom, whereas according to the OHCR in their comparative study Authoritarian regimes tend to obstruct this freedom for their political and national interests and while they may allow association to exist it would ultimately be ineffective. For example, the ILO details in its ‘Arab States Workers' Organizations’ page figures which detail the limitations of the application of the right of freedom of association in which a multiplicity of Arab countries do not allow for migrant workers to join trade unions. This is seen as the ILO states, “With the exception of Bahrain and Oman, across the Arab States migrant workers are excluded from trade union representation by law.” This shows a general common exception based on the environment of freedom of association in the case of the Arab states, many of which have a significant labor pool of expatriate workers.

To conclude, while most states are part of the International Labour Organization (ILO) and almost all countries recognize the constitutional right to association, the limitations and exceptions to this right vary significantly based on the specific environment and cultural context.


Constitution Annotated. 2022. “U.S. Constitution - First Amendment Resources Constitution Annotated Congress.gov Library of Congress.” Constitution.congress.gov. 2022. https://constitution.congress.gov/constitution/amendment-1/#:~:text=Congress%20shall%20make%20no%20law.

ILO. n.d. “8.Freedom of Association and Collective Bargaining (Decent Work for Sustainable Development (DW4SD) Resource Platform).” Www.ilo.org. https://www.ilo.org/global/topics/dw4sd/themes/freedom-of-association/lang--en/index.htm.

———. n.d. “Workers’ Organizations (Arab States).” Www.ilo.org. https://www.ilo.org/beirut/areasofwork/workers/lang--en/index.htm. Locke, John. 1689. Two Treatises of Government. S.L.: Blurb.

McCombs School of Business. 2022. “Social Contract Theory.” Ethics Unwrapped. 2022. https://ethicsunwrapped.utexas.edu/glossary/social-contract-theory#:~:text=Social%20contract%20theory%20says%20that.

“OHCHR Freedom of Assembly and of Association.” n.d. OHCHR. https://www.ohchr.org/en/topic/freedom-assembly-and-association#:~:text=The%20right%20to%20freedom%20of.

Rousseau, Jean-Jacques. 1964. The First and Second Discourses. Bedford Books. ———. 1987. On the Social Contract. Indianapolis: Hackett Publishing Company, Inc. (Orig. pub. 1762.).

The Editors of Encyclopedia Britannica. 2016. “Social Contract.” In Encyclopædia Britannica. https://www.britannica.com/topic/social-contract.

The International Trade Union Confederation. 2022. “2022 ITUC Global Rights Index.” The International Trade Union Confederation. Sharan Burrow, General Secretary. https://files.mutualcdn.com/ituc/files/2022-ITUC-Rights-Index-Exec-Summ-EN_2022-08-10-062736.pdf.

United Nations. 1948. “Universal Declaration of Human Rights - English.” OHCHR. United Nations. December 10, 1948. https://www.ohchr.org/en/human-rights/universal-declaration/translations/english.

Does public polling reveal insights about the right as experienced in different countries? 🖉 edit

The World Bank measures freedom of association across 156 countries using a scale ranging from 0 ( very low freedom of association) to 1(very high freedom of association). Looking at high income countries, with the exception of Israel, Kuwait, United Arab Emirates and Singapore, freedom of association is generally reported to be above the world median. Additionally, among wealthier countries, the World Bank data demonstrates that levels of freedom of association have remained generally fixed since 1975, when the data was first collected. In particular, the data reveals Burundi, China, Cuba, Equatorial Guinea, Eritrea, Iran, North Korea, Saudi Arabia, South Sudan, Syria, Tajikistan, Vietnam, and Yemen to have very low levels of freedom of association (below 0.3). Countries with very high levels of freedom of association (above 0.8) were more numerous, including the United States, the United Kingdom, Trinidad and Tobago, Switzerland, Sweden, Sri Lanka, Spain, South Africa, Slovenia, Sierra Leone, Senegal, Portugal, Peru, Papua New Guinea, Panama, Norway, New Zealand, Netherlands, Namibia, Mongolia, Mexico, Mauritius, Malawi, Liberia, Latvia, South Korea, Japan, Jamaica, Italy, Ireland, Honduras, Greece, Ghana, Estonia, Denmark, Czech Republic, Cyprus, Costa Rica, Canada, Benin, Belgium, Australia, and Albania.

An Open Government Partnership (OGP) report reveals additional insights about freedom of association. The report surveys individuals within 78 OGP partnered countries about elements of freedom of association. Furthermore, the survey presents that approximately 25% of freedom of association issues within OGP countries are rooted in restrictive laws on foreign funding. Additionally, the survey demonstrates that OGP countries presenting challenges to freedom of association generally have not taken actions towards better protecting the right in the future. When asked to respond to “In practice, people can freely join any political organization they want”, the majority of OGP countries responded “Agree” or “Strongly Agree”. Though, when asked to reply to “In practice, people can freely join any (unforbidden) political organization they want”, a large number of OGP countries, approximately 20%, responded “Disagree” . This finding demonstrates that in reality, freedom of association may be less protected by countries’ governments than it is perceived to be.

Within the International Labor Organization, the Committee on Freedom of Association (CFA) addresses violations of freedom of association. In their 2018 annual report, the CFA reported 402 freedom of association complaints from Africa, 410 from Asian and the Pacific, 657 from Europe, 1,681 from Latin America and 186 from North America. Furthermore, their data reveals decreases in complaints in Africa, Asia and the Pacfic, and North America and increases in complaints in Latin America in 2018. 100% of the freedom of association cases examined by the CFA were brought about by workers, rather than employers. 50% of these workers were from the private sector. Violations of trade union rights and civil liberties composed the majority of freedom of association cases investigated by the CFA.

Is this right exercised in different ways depending on the political governance regime in place (democracy, autocracy, hybrid regime)? 🖉 edit

The United States Supreme Court has recognized two types of associative freedoms protected under the Constitution; expressive and intimate (Congress, Amdt 1.8.1). Expressive association covers an individual’s right to form and join groups or unions that express a collective purpose, while intimate refers to an individual’s right to maintain private associations (Hudson Jr., 2009). Freedom of association is covered under Article 20 of the Universal Declaration of Human Rights and Article 22 of the International Covenant on Civil and Political Rights. The United States Court system has recognized both aspects of freedom of association through multiple court cases such as Boy Scouts of America v. Dale and Roberts v. United States Jaycees (Hudson Jr., 2009). The United Nations Human Rights Office states “Freedom of association is an essential element of democracy that serves as a vehicle for the exercise of many other rights guaranteed under international law, including the right to freedom of expression (UN Human Rights. 2023). Examples of expressive association include interacting and organizing amongst other citizens to collectively express and promote common interests, as well as the right to form and join trade unions, or work for non-governmental organizations(NGOs). Within the intimate aspect of association, those in democracies have a right to hold private relationships and associations without interference. In major democratic regimes such as the United States and the United Kingdom, freedom of association is respected and protected. In the United States, “officials respect the constitutional right to assembly; laws and practices give wide freedom to NGOs and activists to pursue civic and policy agendas; and federal law guarantees trade unions the right to organize and engage in collective bargaining (Freedom House, 2023).” In the United Kingdom, the freedom to assemble, go on strike, and bargain collectively are also all respected. NGOs may also operate freely, and workers have a right to organize trade unions, and even their own Labour Party. While perfect freedom is not always the case, as seen in examples of police brutality against protesters in the United States, and in the UK with the Police, Crime, Sentencing, and Courts Act of 2022, freedom of association is generally upheld and protected within democratic regimes. However, global democracy is on the decline, and in the 2015 John Hopkins University Press’ Journal of Democracy, Douglas Rutzen discusses how authoritarianism is placing an increasing threat to civil society. He says, “Since 2012, more than 160 laws constraining the freedoms of association or assembly have been enacted or proposed in 60 countries. This trend is consistent with the continuing decline of democracy worldwide(Rutzen, 2015, 30).” Freedom in the World 2023 shows us that 2022 was the 17th consecutive year of a global decline in freedom. As freedom of association is recognized by international law, this is not reflected when exercised within authoritarian regimes. In Countries such as Venezuela, freedom of association is strongly restricted and those who exercise this right can face major consequences. “The government is being investigated for crimes against humanity regarding how they treat opposition protests; Human Rights activists and members of NGOs face harassment, threats, and arrest; and the government has cracked down on labor unions with opposition unions and several labor union leaders have been arrested or killed (Freedom House, 2023)”. The autocratic regime of Kazakhstan also has strict restrictions on those who assemble and protest. Those who fail to follow these restrictions are subject to detainment, torture, and death as seen in the 2022 gas price protests in western Kazakhstan. “NGOs continue to operate but face government harassment when they attempt to address politically sensitive issues. There are extensive legal restrictions on the formation and operation of NGOs…Workers have limited rights to form and join trade unions or participate in collective bargaining. The government is closely affiliated with the largest union federation and major employers, while genuinely independent unions face repressive actions by the authorities. The country’s major independent trade union body was dissolved in 2017(Freedom House, 2023).” Intimate association is also not free within an autocracy as seen in Russia. Although private relationships are allowed, social media is heavily monitored, minority religious groups are often targeted, and political repression has impacted private discussions with cases of citizens reporting others for expressing views or associations in opposition to the government. “The government restricts freedom of assembly. Overwhelming police responses, the excessive use of force, routine arrests, and harsh fines and prison sentences have largely discouraged unsanctioned protests, while pro-Kremlin groups are able to demonstrate freely… The government has also relentlessly persecuted NGOs, particularly those that work on human rights and governance issues. Civic activists are frequently arrested on politically motivated charges(Freedom House, 2023).” Exercising freedom of association within an autocratic regime is heavily restricted and poses a major risk. While sometimes possible to assemble and protest, it is not without registration and approval, being met with police force, or facing other significant consequences. As the middle ground between democracy and autocracy, hybrid regimes recognize freedom of association accordingly. Freedom House ranks countries on a scale of 1-4; democratic regimes typically place at a 3 or 4 regarding freedom of association, whereas autocratic regimes place at a 0 or 1. However, hybrid regimes consistently place at a 1, 2, or 3 depending on the nation. As declared by the European Parliament, Hungary has now transitioned from a deficient democracy, into a “hybrid regime of electoral autocracy. (European Parliament Press Release, 2022).” However, according to Freedom House, Hungary exemplifies a true hybrid regime with the possession of liberty and limitations to the freedom of association. The freedom to assemble is constitutionally protected and often respected, scoring a 4/4; however, associations with NGOs that go against the government agenda are subjected to stigmatization, monitoring, and fines placing associative freedom at a 2/4 (Freedom House, 2023). The hybrid regime of Jordan, a constitutional monarchy with an elected lower house in parliament, has a registration system for the formation of associations that must be approved by authority (Makary, 2007). In the International Journal of Not-for-Profit Law’s 10th volume issued in 2007, Marc Makary examines the case studies of Jordan and Lebanon and the guarantees of freedom of association in non-democratic environments. He states “While freedom of association in Jordan is protected by the Constitution, its laws are contrary to the standards for freedom of association set by International Law. Article 16 of the Constitution grants Jordanians the right ‘to establish societies and political parties provided that the objects of such societies and parties are lawful, their methods peaceful, and their by-laws not contrary to the provisions of the Constitution.’ While Article 16 seems to provide space for individuals to establish associations, its paragraph (iii) places the establishment of associations and political parties under the control of the law with Jordanian Law N° 33 of 1966 granting absolute discretion to the Minister of Social Affairs or the Minister of Interior to register associations, ban undeclared associations, and establish long and burdensome administrative procedures (Makary’s, 2007). ” Makary’s findings have not changed much since 2007, as the current hybrid regime strictly limits free assembly, heavily monitors and regulates NGO operations in an arbitrary manner, and limits the industries in which unions may form with the limited right to strike (Freedom House, 2023). Hungary was on the more positive end of the spectrum with middle averaging scores, contrary to Jordan with scores of 1/4 and 0/4 regarding freedom of association. Hybrid systems can fluctuate how much freedom they allow for people to associate with each other. Democratic regimes remain at the top levels of ability regarding the right to exercise freedom of association without interference; whether that be through assembly, union membership, expressive group discussion, or intimate association, citizens of democracies face little to no limits. In contrast, Autocratic regimes place heavy restrictions and limits on the exercise of this freedom and often punish those who do. While the actions do not vary much depending on the regime, the ability to do so freely without interference is truly where the differences lie.

European Parliament. 2022. “MEPs: Hungary Can No Longer Be Considered a Full Democracy. News. European Parliament.” Www.europarl.europa.eu. September 15, 2022. https://www.europarl.europa.eu/news/en/press-room/20220909IPR40137/meps-hungary-can-no-longer-be-considered-a-full-democracy.

Freedom House. 2023. “ Freedom in the World 2023 Country Report.” Freedom House. 2023. https://freedomhouse.org/explore-the-map?type=fiw&year=2023

Gorokhovskaia, Yana, Adrian Shahbaz, and Amy Slipowitz. 2023. “Marking 50 Years in the Struggle for Democracy.” Freedom House. 2023. https://freedomhouse.org/report/freedom-world/2023/marking-50-years.

Jr, David L. Hudson. 2009. “Freedom of Association.” Www.mtsu.edu. 2009. https://www.mtsu.edu/first-amendment/article/1594/freedom-of-association.

Makary, Marc. “Notification or Registration? Guarantees of Freedom of Association in Non-Democratic Environments: Case Studies of Lebanon and Jordan.” n.d. ICNL. Accessed June 19, 2023. https://www.icnl.org/resources/research/ijnl/notification-or-registration-guarantees-of-freedom-of-association-in-non-democratic-environments-case-studies-of-lebanon-and-jordan.

Rutzen, Douglas. "Authoritarianism Goes Global (II): Civil Society Under Assault." Journal of Democracy, vol. 26 no. 4, 2015, p. 28-39. Project MUSE, doi:10.1353/jod.2015.0071.

United Nations Human Rights. 2023. “OHCHR Freedom of Assembly and of Association.” n.d. OHCHR. https://www.ohchr.org/en/topic/freedom-assembly-and-association#:~:text=Everyone%20has%20the%20rights%20to,protests%2C%20both%20offline%20and%20online.

United States Congress. Constitution Annotated. Amdt1.8.1 Overview of Freedom of Association. https://constitution.congress.gov/browse/essay/amdt1-8-1/ALDE_00013139/

Is this right interpreted and exercised in different ways in different countries? Focus on particular countries in which the right is interpreted distinctively 🖉 edit

The right to freedom of association is recognized by the United Nations as universal and intrinsic to every human being, encompassing an individual’s right to interact and organize with others to collectively “express, promote, pursue and defend common interests”. The Universal Declaration of Human Rights, a key text in the history of international human rights law, states in its Article 20 that “everyone has the right to freedom of peaceful assembly and association” and “no one may be compelled to belong” to one, with an individual’s right to “form and to join trade unions for the protection of his interests” being expanded upon in Article 23 (UN General Assembly 1948, 5-6). Freedom of association is also closely related to freedom of assembly, with the latter often being seen as falling under the umbrella of “association”. However, this freedom is not guaranteed to the same capacity in every state, with countries having their own interpretations and practices of the right within their legal code, in part due to their unique cultural and political context. This results in different protocols and limitations related to the formation of associations, with some states interpreting the right in a more restrictive manner and outlawing certain groups, placing obstacles in their creation, or impeding them through particular practices, while other states are more lenient as long as the organizations are not engaging in violent practices.

While the Constitution of the United States recognizes and protects the rights to freedom of assembly, freedom of speech, and freedom to petition the government, it does not explicitly mention the right to freedom of association. However, as the report by the UN’s Special Rapporteur on the rights to freedom of peaceful assembly and of association in the U.S. affirms, “The right to freedom of association is implicitly guaranteed by the first and fourteenth amendments of the Constitution, read together, which protect the rights of free speech and assembly and due process, as affirmed by the Supreme Court in a number of cases” (“Report..” 2017, 10). These cases include NAACP v. Alabama and Bates v. Little Rock (1960) in which the Supreme Court recognized the right of individuals to “associate together free from undue state interference” and that “freedom of association finds protection within the First Amendment’s free speech and assembly clauses” respectively (“Case Studies” 2023, 1). This gives citizens the ability to “associate, organize and act collectively”, forming special interests groups and allowing workers to unionize, though the latter is “regulated by several pieces of legislation at the federal, state and local levels” and laws that are “supplemented by court and tribunal decisions that establish related standards and principles” (“Report…” 2017, 10). The freedom of association is not absolute in the United States, as “forms of association that are neither ‘intimate’ nor ‘expressive’ within the meaning of First Amendment Case law may not receive constitutional protection” (“Overview of Freedom of Association” 2023). Nevertheless, even individuals who form associations for the purpose of engaging in assembly can be subject to government oversite, as the UN’s Special Rapporteur wrote that the “Supreme Court has held that the right to assemble is not absolute, allowing the authorities to impose restrictions on the time, place and manner of assembly and to require permits”, though they are “prohibited from restricting assemblies based on their content”. He further noted that the “interpretation by the Supreme Court of this right falls short of international standards, owing to the approach to restrictions on the time, place and manner of assembly” (7). Under the legal code, the Supreme Court has also held that “compelled association” can violate the Constitution: "in some circumstances, laws requiring organizations to include persons with whom they disagree on political, religious, or ideological matters can violate members’ freedom of association, particularly if those laws interfere with an organization’s message” (“Overview of Freedom of Association” 2023).

Freedom of association in Niger is explicitly granted in article 9 of the country’s constitution, giving citizens the right to form unions, non-governmental organizations, and political parties with certain restrictions. During a visit to Niger to report on the right to freedom of peaceful assembly and of association, Special Rapporteur Clément Nyaletsossi Voule noted: “Ordinance No. 84-06 of March 1, 1984, on the regime of associations reaffirms discrimination in the Nigerien Constitution against territorial associations and indigenous peoples, where associations of a regional or ethnic nature, specifically associations of ethnic groups, tribes and other territorial divisions are prohibited (Voule 2022, 13). He further wrote that this “censorship of certain types of associations is not in line with international standards relating to freedom of association and the obligation of democratic states to guarantee pluralistic spaces and to ‘leave no one behind’ in the implementation of sustainable development goals.” (13). The legal code in Niger does not allow for the creation of these groups, interpreting the right to freedom of association differently than in countries where it is not prohibited to form political groups along those lines. Though the Constitution of Niger does provide for the right to association, Special Rapporteur Voule emphasized that in practice it can be quite difficult to exercise in the country: “The Special Rapporteur became aware, during interviews with representatives of civil society, of the time needed to register associations and receive recognition orders, which can range from two to ten years. While these deadlines are provided for by Ordinance No. 84-06, the procedure established by Decree No. 2022-182 may accentuate the slowness of the process, making it practically impossible to create associations, in particular those whose purpose is to respond to the current political and social situation and to act accordingly.” (Voule 2022, 16) Niger’s ability to exercise the right is considerably hindered by its slowness in carrying out the registration process, creating a discrepancy between its legal code and the reality for its citizens.

Iran, a theocratic state, guarantees freedom of association in its constitution, though with certain restrictions. In its 2022 Country Report on Human Rights in Iran, the U.S. Department of State stated that the Iranian Constitution protects the “establishment of political parties, professional and political associations, and Islamic and recognized religious minority organizations, as long as such groups do not violate the principles of freedom, sovereignty, national unity, or Islamic criteria, or question Islam as the basis of the country’s system of government” (“Iran” 2023, 40). Authorities have the power to regulate them and decide whether an association violates the constitution, with the Department of State’s report stating that the government limited freedom of association through “the imposition of arbitrary requirements on organizations” and broadening “arbitrarily the areas of civil society work it deemed unacceptable, to include conservation and environmental efforts” (40). While providing for the right under its legal code, the government interprets it in a more restrictive manner and heavily regulates it, prohibiting the formation of several types of groups, such as trade unions and labor organizations The non-profit organization Freedom House found that labor organizations and nongovernmental agencies that seek to address human rights violations are routinely suppressed, though “groups that focus on apolitical issues also face crackdowns” (“Freedom in the World” 2023).

While the right to freedom of association is considered a universal human right, it is not applied in a standard manner. Countries often hold different standards for the freedom, with their own rules and regulations, interpretations, and practices.


“Case Studies: Freedom of Association.” 2023. Case Categories The First Amendment Encyclopedia. https://www.mtsu.edu/first-amendment/encyclopedia/case/12/freedom-of-association.

“Freedom in the World 2021 Country Report: Iran.” 2021. Freedom House. https://freedomhouse.org/country/iran/freedom-world/2021.

“Freedom in the World 2023 Country Report: Iran.” 2023. Freedom House. https://freedomhouse.org/country/iran/freedom-world/2023.

“Iran.” 2023. U.S. Department of State. U.S. Department of State. March 20. https://www.state.gov/reports/2022-country-reports-on-human-rights-practices/iran/.

“Report of the Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association on His Follow-up Mission to the United States of America.” 2017

“Overview of Freedom of Association.” 2023. Constitution Annotated. https://constitution.congress.gov/browse/essay/amdt1-8-1/ALDE_00013139/.

UN General Assembly. 1948. Universal Declaration of Human Rights, , 217 A (III), https://www.un.org/sites/un2.un.org/files/2021/03/udhr.pdf

Voule, Clément Nyaletsossi. 2022. Report of the Special Rapporteur on the Rights to Freedom of Peaceful Assembly and of Association in Niger https://documents-dds-ny.un.org/doc/UNDOC/GEN/G22/388/85/PDF/G2238885.pdf?OpenElement