Cambodia: Judicial harassment of Mr. Chan Soveth

Chan Soveth (Photo: Ir Channa, RFI)

URGENT APPEAL - THE OBSERVATORY

KHM 004 / 0812 / OBS 075
Judicial harassment
Cambodia
August 16, 2012

The Observatory for the Protection of Human Rights Defenders, a joint programme of the International Federation for Human Rights (FIDH) and the World Organisation Against Torture (OMCT), requests your urgent intervention in the following situation in Cambodia.

Description of the situation:

The Observatory has been informed by reliable sources of a citation to appear in court issued against Mr. Chan Soveth, Senior Investigator and Deputy Head of the Monitoring Section of the Cambodian Human Rights and Development Association (ADHOC).

According to the information received, on August 9, 2012, the Phnom Penh Municipal Court issued a citation summoning Mr. Soveth to appear before an investigating judge on August 24, 2012.

Mr. Soveth was charged with “providing assistance to the perpetrator” of a “crime” under Article 544 of the Cambodian Criminal Code, and faces an imprisonment sentence of one to three years and a fine of two million to six million Riels.

Exact details behind this charge have not yet been disclosed by the government, but they appear to be connected to a long-standing land dispute in Kratie province. On May 16, 2012, the government sent in hundreds of armed security personnel, supported by helicopters, to evict villagers who were living in an area in Kratie province marked for development by a Russian company. During the eviction, Ms. Heng Chantha, a 14-year-old girl, was shot dead. Government officials later justified the operation by claiming the villagers, some of whom are members of the Independent Democrats Association, were part of a secession movement. ADHOC released a statement on May 17 and condemned the killing of the young girl[1]. It is believed that the charges against Mr. Soveth are linked to his sheltering of a land activist involved in this issue. The court citation was signed on August 9, 2012, just eight days after Prime Minister Hun Sen made accusatory references in a nationally televised speech to an unnamed “human rights worker” for his role in providing assistance to villagers in relation to this land dispute.

Cambodia: Assault on freedom of expression continues with conviction of UN staff

Seng Kunakar: Arrested and sentenced by a Sunday Kangaroo Court for printing and distributing article posted on KI-Media

International Federation for Human Rights (FIDH)

PRESS RELEASE

Cambodia: Assault on freedom of expression continues with conviction of UN staff

http://www.fidh.org/Cambodia-Assault-on-freedom-of-expression

Paris-Bangkok, 23 December 2010. The International Federation for Human Rights (FIDH) deplores the arrest and conviction of a warehouse staff of the World Food Program (WFP) in Cambodia, all of which occurred in two days. The astonishingly quick conviction on the weekend comes merely nine days after the new Penal Code went into effect on 10 December. The new Code contains a number of problematic provisions that could be used to criminalise the peaceful exercise of the freedom of expression.

Mr Seng Kunnaka was arrested on 17 December before noon by the Russei Keo district police and was accused of sharing with his co-workers leaflets he printed from the online news blog KI-media, which carries articles and opinion pieces that are often critical of the Cambodian government. Barely two days later, on the morning of 19 December, Mr Kunnaka was found guilty by the Phnom Penh court of incitement to commit a felony under article 495 of the new Criminal Code, and was sentenced to six months imprisonment and fined 1 million riel (approximately 900 Euros or 246 US dollars).

The conviction of an individual for simply sharing written materials with his co-workers is the latest example of a persistent trend of the government's attempt to muzzle dissident and opinions critical of the authorities through repressive legislations. Similarly, Mr Leang Sokchouen, a staff of the Cambodian League for the Promotion and Defense of Human Rights (LICADHO), an FIDH member organization, was sentenced to prison on unfounded disinformation charges on 30 August 2010 in a trial marked by glaringly flawed legal proceedings. Mr Leang was accused of involvement in the production and distribution of anti-government leaflets in Takeo province.(1)

“With this latest deliberate assault on freedom of expression, the Cambodian authorities are becoming ever bolder in their repression and the democratic space is getting ever smaller,” said Souhayr Belhassen. “The United Nations system as a whole must stand up for one of its own and for the fundamental rights and freedoms under threat in Cambodia. Countries sending millions upon millions of development assistance to Cambodia must reflect deeply whether their funding has truly contributed to the progress of Cambodia towards greater freedom.”

(1) Amnesty International, Human Rights Watch, the International Federation for Human Rights (FIDH) and the World Organisation Against Torture (OMCT), “Cambodia: International Groups Condemn Sentencing of Local Rights Staffer: Arbitrary Arrest, Unfair Trial Marked by Flawed Legal Proceedings,” 1 September 2010. Available at: http://www.fidh.org/Cambodia-International-Groups-Condemn-Sentencing

Press Contacts :

FIDH : Arthur Manet + 33 1 43 55 90 19

FIDH - Cambodia/Open letter to International Buyers sourcing from Cambodia

International Federation for Human Rights (FIDH)

Open Letter to International Buyers sourcing from Cambodia

Paris, 24 September 2010

Subject: Responsibility of international buyers in the protection of workers’ rights in Cambodia

To international buyers,

The International Federation for Human Rights (FIDH) is deeply concerned that a recent peaceful and lawful strike by garment and apparel workers in Cambodia has been met with legal threats and court-sponsored retaliation, with tacit approval from the Cambodian government, against union leaders and workers.

The strike, which began on September 13, saw the participation of hundreds of thousands of workers from the Coalition of Cambodian Apparel Workers Democratic Union (CCAWDU), the National Independent Federation of Textile Unions of Cambodia (NIFTUC), and 13 other unions. The workers are seeking an increase in the current wage to meet minimum living standards. On September 16, union leaders agreed to temporarily cease the strike after they accepted a proposal from the Ministry of Social Affairs, Veterans and Youth Rehabilitation inviting union representatives to a negotiation meeting to be held on September 27.

During the strike, the Minister of Social Affairs, Veterans and Youth Rehabilitation and the Minister of Labour and Vocational Training publicly called for the investigation and prosecution of union leaders and a crackdown on the strike. The Prime Minister approved the two Ministries’ request to authorize the police and local authorities to take such actions.

According to court documents obtained, some provincial and municipal courts have ordered the suspension of at least 92 union workers in Kampong Speu and Kandal provinces. Since the cessation of the strike, as many as 200 union leaders have reportedly been suspended for their involvement. Reliable sources warn that at least nine union leaders are at risk of being served arrest warrants for organising the strike. Intimidation and harassment by the police, employers and factory security guards were reported, including seizure of communication equipment and publicly announced legal threats.

Our organization recalls that the Cambodian Constitution, the Labour Law (1997) and ILO Conventions 87 and 98, which Cambodia ratified, all guarantee the right to organise, the right to strike and the right to collective bargaining. The use or threat of legal actions against union leaders and workers are blatant violations of these basic rights.

The strike was called to demand an increase in the minimum wage for workers in the garment and shoe industry, taking into consideration all relevant factors, including costs of living and inflation. In July 2010, members of the Cambodian Labour Advisory Committee (LAC), comprised of government officials, industry representatives, and some unions, agreed to an increase in the minimum wage from US$ 56 to US$ 61 per month, which would come into effect on October 1, 2010 and not be subject to review until 2014. One study has shown that the absolute minimum wage on which a garment worker could afford to live is between US$72-75 per month1 whereas another study indicated that US$93 per month would constitute a reasonable living wage2.

Our organisation recalls that Article 104 of the Cambodian Labour Law of 1997 mandates that a minimum wage “must ensure every worker of a decent standard of living compatible with human dignity”. Furthermore, the four-year duration of the new minimum wage of US$61 seems in contradiction to Article 107 of the Labour Law which stipulates that the wage be “adjusted from time to time in accordance with the evolution of economic conditions and the cost of living”. Article 7(a)(ii) of the International Covenant on Economic, Social and Cultural Rights (ICESCR), to which Cambodia is a State Party, also guarantee the right to enjoy just and favourable conditions of work that ensure a “decent living for themselves and their families”.

The demand of the strike is legitimate and its organisation and implementation have been strictly legal and peaceful. That the Cambodian government decided to take such repressive and threatening actions against those involved casts serious doubt about its commitment to respect labour standards and workers’ right. Such a situation undermines the working conditions in Cambodia’s garment factories and makes it difficult for international firms to uphold their commitments to ensure respect of workers' rights throughout their supply chain and thereby to avoid reputational risks.

Considering your company is sourcing from Cambodia, FIDH requests your public and principled support to uphold the highest social and labour standards as a buyer and reassure consumers that the products they are purchasing are not made by workers whose basic rights are being violated.

In this regard, we strongly urge your company to:

• Urge the Cambodian authorities to immediately cease and refrain from all acts of legal threats and judicial intimidation against union representatives, workers and labour activists for their involvement in the legal and peaceful strike;
• Request factories from which you are supplied to reinstate all workers who have been unjustly suspended, served warrants, or investigated for their role in the strike;
• Call on the Cambodian authorities and employers to engage in good-faith, honest and transparent negotiation with unions and workers in order to realise a reasonable increase in the current wage to meet minimum living standards, consistently with prevailing economic conditions and cost of living, and as required under Cambodia's international human rights obligations;
• Further urge the Cambodian authorities to fully guarantee workers’ rights to organise, strike and engage in collective bargaining, freely and without fear of legal consequences or personal retaliation; and
• In line with your commitment to ensure that workers are treated fairly and equitably throughout your supply chain, we urge you to continue operating in Cambodia even in the event that the minimum wage is increase, and to reflect the wage increase in the negotiation with the Cambodian garment and apparel factories, including for the orders already made.

We sincerely hope you will take into consideration our deep concerns and recommendations. FIDH would welcome the opportunity to engage with your company to discuss your position in the on-going situation in Cambodia and the steps your company will take or have taken to address our concerns.

Sincerely yours,

Souhayr Belhassen
FIDH President

Press Contacts:
FIDH : Karine Appy/Fabien Maitre + 33 1 43 55 14 12 / + 33 1 43 55 90 19

The new Law on Demonstrations : A terrible setback for freedom of assembly

International Federation for Human Rights (FIDH)
Cambodian Human Rights and Development Association (ADHOC)
Cambodian League for the Promotion and Defense of Human Rights (LICADHO)

Press Release

Cambodia

The new Law on Demonstrations : A terrible setback for freedom of assembly
http://www.fidh.org/The-new-Law-on-Demonstrations-A-terrible-setback

Paris – Phnom Penh, 29 October 2009 - The International Federation for Human Rights (FIDH) and its member organizations in Cambodia, the Cambodian Human Rights and Development Association (ADHOC) and the Cambodian League for the Promotion and Defense of Human Rights (LICADHO), express their deepest concern at the draft Law on Demonstrations adopted earlier this month by the National Assembly of the Kingdom of Cambodia.

Freedom of assembly is currently regulated by the Law on Demonstrations of 1991, which requires the organizers of a peaceful protest to inform the authorities in advance. In practice, the authorities interpreted this law as requiring an express authorization before any demonstration can be organized.(1) In 2008, e.g., ADHOC reported that the authorities imposed restrictions on public demonstrations relating to land and natural resources conflicts, and workers’ rights. Of 155 peaceful strikes and demonstrations that took place last year, 108 (70%) were suppressed forcibly by the armed forces. In addition, the authorities often refused to authorize demonstrations, or delayed granting authorization for demonstrations shortly before they were due to take place. Unauthorized strikes and demonstrations were suppressed by force.

Against this background of abuse of the existing law, the replacement of current legislation by an even more restrictive law on demonstrations is worrying. The text has been adopted by the National Assembly without previous consultation with civil society, and the version submitted to Parliament for approval has not been made public or circulated beforehand. This opacity and lack of participatory and consultative mechanisms in the legislative process is in itself a cause of serious concern.

As regards the text of the law adopted this month, it represents a setback in relation to the existing legislation, which was already restrictively interpreted by the authorities.

Based on their analysis of the current text as adopted earlier this month by the National Assembly (the analysis is available at the following link: http://www.fidh.org/IMG/pdf/Analysis_assembly_law_Oct_09-2.pdf), FIDH, ADHOC and LICADHO call upon the Senate of the Kingdom of Cambodia to reject this text in its current form, and to propose amendments to the above-mentioned provisions so that the text be fully compliant with Cambodia's international human rights obligations.

Since Cambodia will be examined under the Universal Periodic Review conducted by the UN Human Rights Council, on 1st December 2009, we call upon UN member states to raise this issue as a matter of priority with the Cambodian authorities.

Based on the EU Guidelines on Human Rights Defenders, the European Union should express its deep concern at this draft legislation as it stands, and call upon the Senate of Cambodia to reject the text, or significantly amend it.
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Notes :

[1] The 1991 Law on Demonstrations says demonstrations are “acceptable” provided they are not “detrimental to public tranquility, order or security”. The 1991 Law on Demonstrations states that “authorities in each commune or ward through which a group of demonstrators will march shall be informed at least three days beforehand in writing”. The authorities are obliged to issue a receipt for the gathering unless they believe it has “characteristics conducive to causing turmoil”, in which case they can ban the assembly within 48 hours. If the assembly organizers disagree, a final decision should be made by “higher authorities” within 24 hours. This law clearly sets out a process of notification and yet it was been willfully misinterpreted to mean assembly organizers must apply for permission to gather. In both the Constitution and the 1991 Law of Demonstrations, the justifications set by the Law for restricting the right to freedom of assembly have been widely misinterpreted, against the spirit of freedom of assembly. Since early 2003, permission has been routinely denied to peaceful protests on whimsical security grounds. See LICADHO, Freedom of Assembly in Cambodia, November 2006, p. 5 (http://licadho-cambodia.org/reports...).
--
Emmanouil Athanasiou
Responsable du Bureau Asie - Head of Asia Desk(FIDH) -
International Federation for Human Rights
Fédération Internationale des Ligues des Droits de l'Homme
17, Passage de la Main d'Or
75011 Paris, France
Tél.: 0033 1 43 55 25 18
Fax.: 0033 1 43 55 18 8

Open Letter by FIDH, COHRE, HRW and AI Regarding the Forced Eviction of Residents of Boeung Kak Lake

4 December 2008
Source: Amnesty International

Open Letter by International Federation for Human Rights (FIDH), the Centre on Housing Rights and Evictions (COHRE), Human Rights Watch and Amnesty International Regarding the Forced Eviction of Residents of Boeung Kak Lake in the Phnom Penh Municipality.

To Mr. Kep Chuktema, Governor of the Municipality of Phnom Penh:

We write to you to express our deep concerns about recent developments affecting residents of the Boeung Kak Lake area in central Phnom Penh. Some residents near the lake have been forcibly evicted, while others are facing eviction amid rising water levels, and threats and harassment. Government officials and company workers have threatened residents in and around Boeung Kak Lake and NGOs supporting them, when they have campaigned against the filling of the lake and imminent eviction. Heavily armed police, including military police, frequently harass community leaders and NGO workers and block access to the area. Journalists face intimidation when reporting about the developments, including on 27 November 2008 when police took reporters in for questioning about their coverage of the situation.

As you know, in February 2007 the Municipality of Phnom Penh entered into a 99-year lease agreement for US$79 million for 133 hectares, including Boeung Kok lake and surrounding land, with a private developer, Shukaku Inc. According to the government, the company will turn the area into "pleasant, trade, and service places for domestic and international tourists," including by filling in 90% of the lake. On 26 August 2008 a company began filling the lake, which has worsened flooding and caused the destruction of some houses.

The development will lead to the eviction of almost 4,000 families, despite many of the affected families having strong legal claims to the land under the Land Law. Without prior meaningful consultation, affected communities are currently being made non-negotiable offers of compensation or houses in a relocation site on the outskirts of Phnom Penh. The compensation offered is insufficient for families to obtain comparable alternative housing. Housing at the relocation site is not adequate: infrastructure is poor, basic amenities including clean water is lacking, and access to work opportunities is very limited given the distance from the city. Moreover, offers include no formal security of tenure for those agreeing to move.

Residents have sought to halt the filling of the lake which is gradually destroying homes, and have requested more compensation. However, the Municipality has told residents that they do not have the right to demand anything more than the offered compensation.

We also note with concern the prevalence of forced evictions in Cambodia. Forced evictions are evictions that are carried out without adequate notice, consultation with those affected, legal safeguards or assurances of adequate alternative accommodation. They violate Cambodian law and Cambodia's international human rights obligations.

The development of the lake breaches Cambodian law. According to the 2001 Land Law, the lake itself is inalienable state land (so-called state public property), and as such cannot be leased for longer tha 15 years, during which time the function of the property must not change. In August 2008, a subdecree reclassified Boeung Kak Lake into private state land, in what appeared to be an attempt to validate the lease.

The agreement also appears to breach other domestic law and implementing regulations as the environmental impact assessment has not been made widely available to the public or to the affected communities, and because no open bidding process preceded the agreement.

As noted above, the development of the Boeung Kak lake breaches Cambodia's international human rights obligations. According to the UN Committee on Economic, Social and Cultural Rights, Cambodia, as a state party to the International Covenant on Economic, Social and Cultural Rights (ICESCR), is obliged to ensure, before any planned evictions, that all alternatives are explored in consultation with those affected by the eviction. Evictions may only occur in accordance with the law and in conformity with international standards, including genuine consultation with those affected; adequate notice and information on the proposed eviction, and provisions of legal remedies for those affected. Evictions may only occur if they do not render individuals homeless or vulnerable to the violation of other human rights.

We therefore call on the Municipality of Phnom Penh to ensure that the rights of the residents of Boeung Kak lake are respected and protected, and that victims of forced evictions are provided with effective remedies, including restitution of housing, land or property. We also request that arbitrary arrests, intimidation and restrictions of the right to peaceful protest be stopped immediately.

Recent research by Amnesty International and local partners indicates that 150,000 people in Cambodia are living under threat of forced eviction, including up to 70,000 in Phnom Penh alone. The government should end forced evictions and introduce a moratorium on mass evictions until the legal framework and relevant policies are in place to ensure that evictions are conducted only in accordance with Cambodia's international human rights obligations.

The evictions taking place to pave the way for the development of Boeung Kak are emblematic of a broader problem of violations of the right to adequate housing in Cambodia. The Cambodian government has an obligation under international law to protect the population against forced evictions. Everyone -- whether owners, renters or unregistered settlers -- should possess a degree of security of tenure which guarantees legal protection against forced eviction, harassment and other threats.

We sincerely hope that you will take into consideration our concerns. In this regard we would like to request a meeting with you and relevant officials to discuss Boeung Kak lake and related matters.

Yours sincerely,

Souhayr Belhassen, President, International Federation for Human Rights (FIDH)
Salih Booker, Executive Director, Centre on Housing Rights and Evictions (COHRE)
Brad Adams, Asia Director, Human Rights Watch
Sam Zarifi, Director, Asia-Pacific Programme, Amnesty International.

Cambodia Tribunal Allows Victims of the Khmer Rouge to Participate in Proceedings

28/03/2008
Cambodia / ECCC

The International Federation for Human Rights (FIDH), the REDRESS Trust (REDRESS) and Avocats Sans Frontières (ASF), with headquarters in Belgium, welcome the landmark ruling of the Pre-Trial Chamber of the Extraordinary Chambers in the Courts of Cambodia (ECCC) to allow victims of the Khmer Rouge atrocities to participate in the Courts proceedings.

Although the decision on the 20th March [1] only applies to this specific case and situation, FIDH, REDRESS and ASF believe that the ruling sets an important precedent in the interpretation of the rules applicable to civil party participation before the ECCC. It is a landmark decision in international criminal justice and a major achievement for victims of gross human rights violations, whose voices have long gone unheard.

According to the Courts decision, victims can be full parties to the criminal proceedings. This allows victims to participate in specific proceedings, such as appeals against provisional detention orders. The Pre-Trial Chamber found that the Tribunals rules make it clear that civil parties have the right to participate in the investigative phase of the procedure. Contrary to the arguments of the Defence, the Pre-Trial Chamber found that civil party involvement did not affect the rights of the Defendant to a fair trial.

The decision follows the participation of victims at a hearing on the appeal against the provisional detention of Mr. Noun Chea, one of the five persons so far indicted by the Tribunal. At the hearing, the Defence had challenged victim involvement at that particular stage of the proceedings. Considering the fundamental character of the issue to be decided upon, the Pre-Trial Chamber invited amicus curiae submissions. REDRESS, ASF and FIDH filed an amicus brief on 21st February 2008, arguing that victim participation at this stage is in accordance with international standards [2].

The Chamber sought guidance in Cambodian law provisions, and found that these were in accordance with international law developments in the area of victim participation.

Background

The ECCC is a hybrid tribunal created as a result of an agreement between the United Nations and the Government of Cambodia. It has jurisdiction to try the top Khmer Rouge leaders who committed serious crimes between 1975 and 1979 [3]. The Tribunal’s rules on victim participation are ground-breaking because victims will be permitted to join in the proceedings as civil parties, going beyond the regime of victims’ participation before the ICC. The 20th March 2008 decision is the first ever decision on civil party involvement in proceedings made by this Tribunal.
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[1] The ECCC Pre-Trial Chamber decision of 20 March 2008 on civil party participation in provisional detention appeals is available on the ECCC website.

[2] The FIDH-REDRESS-ASF amicus brief on civil party participation is available on the FIDH website.

[3] i.a. genocide, crimes against humanity, war crimes and other breaches of Cambodian criminal law.

More resources needed for the Victims Unit to fulfil its mandate effectively

19/03/2008
International Federation for Human Rights (FIDH)

Cambodia / ECCC

An FIDH mission was sent to Phnom Penh from 14 to 20 February 2008. The FIDH delegation was able to assess the work of the Extraordinary Chambers in the Courts of Cambodia (ECCC), set up to try the Khmers Rouges.

The ECCC is providing a first-ever opportunity, in the history of international criminal justice, for victims of crimes to participate in trial proceedings as civil parties [1]. This provision is based on Cambodian law and gives victims the same procedural rights as the other parties, for instance, the right to participate actively in hearings, to be represented by a lawyer, to examine the witnesses and the accused, and to claim reparation.

During its mission, FIDH observed that close to 700 victims had indicated willingness to participate in proceedings, either by lodging a complaint with the co-Prosecutors, in other words, sending information on the crimes, or by expressing their will to stand up as a complainant before the co-investigating judges, speaking directly as a party to the proceedings. Up to now, four victims have been accepted as civil parties and spoke directly at the hearings on 4 February 2008 concerning Nuon Chea’s detention [2].

FIDH encouraged the creation of the Victims Unit [3], which became operational in November 2007. In compliance with Rule 12 of the Internal Rules, the Victims Unit assists victims in filing complaints and joining as civil parties. Its tasks also include informing victims of their rights and helping them to participate by providing the necessary legal assistance.

However, FIDH is very concerned about the lack of resources for this Unit, which, for this reason, may not be able to carry out its unique and innovative mandate. To fill the gap, civil society organisations are providing information and assistance to victims, but here again, resources, especially for legal representation, are too small. Although these associations play a very important role, they cannot replace the essential role played by the Unit of the Extraordinary Chambers.

FIDH regrets that the supplementary budget proposed by the Extraordinary Chambers for approval by the United Nations does not request for additional resources for the Victims Unit, which is sorely short of funds considering the scope and importance of its mandate.

"The role of the Victims Unit is essential in allowing the victims to participate effectively and contribute to the search for truth by the Extraordinary Chambers. This is why we are calling for the international community, the donor states and the United Nations to allocate sufficient human and financial resources for the Victims Unit to be able to inform the victims of their rights, facilitate their participation in proceedings, support their legal representation, enable them to receive psychological support and, if necessary, physical protection, and equip them to demand reparation, as provided for in the Internal Rules of the Extraordinary Chambers. Recognising their exemplary involvement with the Chamber, the international community should also provide the Cambodian civil society organisations with the support needed to continue their work," said Souhayr Belhassen, FIDH President.

Background:

After lengthy negotiations between the United Nations and the Cambodian Government, the Extraordinary Chambers became operational in November 2005. Their jurisdiction enabling them to try the top Khmer Rouge leaders led to the investigation and arrest of five leaders of a regime (Kaing Guek Eav, alias Duch, former director of the S21 detention centre; Nuon Chea former right-hand man to Pol Pot; Ieng Sary, former minister of foreign affairs; Ieng Thirith, former minister of social affairs, and Khieu Samphan, former president of the state presidium of Cambodia), that caused the death of over three million victims between 1975 and 1979.

The ECCC are hybrid chambers composed of Cambodian and international judges and civil servants. The functioning of this system presents a difficult challenge but could also have a positive long-term effect on the Cambodian judiciary by strengthening its independence and expertise.
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[1] FIDH, REDRESS and ASF have submitted an amicus curiae brief to the ECCC concerning the participation of victims as civil parties, available in English on the FIDH website.

[2] "Historic achievement in international criminal law: Victims of Khmer Rouge fully involved in proceedings of the ECCC", Declaration by the Victims Unit, February 2008.

[3] See Comments by FIDH, ADHOC, LICADHO and the Collectif des victimes des Khmers Rouges to the draft Internal Rules of the Extraordinary Chambers, November 2006, available on the FIDH website.