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RIC Query - Ethiopia (18 April 2001)

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Response to Information Request Number:ETH01004.ZAR
Date:April 18, 2001
Subject:Ethiopia: Information on the Oromo Ethnic Group, the Oromo Liberation Front (OLF), and the Oromo People's Democratic Organization (OPDO)
From:INS Resource Information Center
Keywords:Ethiopia / Armed resistance movement / Civil and political rights / Cultural identity / Democratic rights / Elections / Ethnic minorities / Ethnicity / Freedom of political opinion / Nationalism / Political participation / Political opposition / Political representation / Right to self-determination


1) What are the major clans and sub-clans of the Oromo and in what provinces are these clans found?

2) Is the Oromo People¿s Democratic Organization (OPDO) comprised only of Oromos, or can Tigrayans [Tigreans] hold positions in the OPDO?

3) What is the Oromo Liberation Front (OLF) fighting for that OPDO cannot offer?

4) What are the ultimate goals of the OLF and how do they differ from the goals of the OPDO aside from the OPDO being a member of the Ethiopian People¿s Democratic Front (EPRDF)?

5) Does the OLF have the right to engage in armed struggle following elections in 2000 that the State Department found to be "free and fair"?

6) Does the Ethiopian government have the right to arrest and detain supporters and members of the OLF?



The Oromo ethnic group constitutes between 30 and 40 percent of Ethiopia¿s population of 61 million. They are widely dispersed, ranging from northern Kenya to northern Ethiopia, and there is "considerable differentiation among the numerous Oromo communities" (Markakis 1994, 231). Ethnic Groups Worldwide states:

"The Oromo (Galla) are the largest ethnic group [in Ethiopia]¿[and] were at one time concentrated in the southern highlands but have now spread to other regions. The "Oromo" ethnic category is composed of a number of linguistically related groups including the Boran, Shewa, and Welega. The Oromo are not unified politically and there are important differences in social organization, religion, and economy across the groups: most are farmers, though some are herders; some are Muslims, others are Christians, and still others adhere to indigenous religions" (Levinson 1998, 131-132).

Despite being the largest ethnic group in the Horn of Africa, the Oromo were "less united religiously and socially than the Amhara and Tigreans" and never formed one Oromo state (Minorities at Risk Project June 1998, 3). According to one analyst, due to their political fragmentation, they "have been traditionally marginalized in Ethiopian politics, 'always on the outside looking in.' At the same time, successive governments have succeeded in co-opting significant sections of the Oromo¿ (de Waal 1994, 32). In the second half of the 19th century, Oromo lands were conquered and expropriated by Abyssinians, who "turned the majority of Oromo peasants into their tenants" (Markakis 1994, 231). For more than a century until the overthrow of Emperor Haile Selassie in 1974, Amhara and Tigre governments and landlords maintained political and economic control over the Oromo land and people.

The Oromo Liberation Front (OLF) was formed in 1973 and engaged in armed struggle against the Marxist-Leninist regime of Lt. Col. Mengistu Haile Mariam¿the Dergue¿that overthrew Haile Selassie in 1974. According to analyst Marina Ottoway, the OLF was "faction-ridden, poorly led, and chronically unable to decide whether its ultimate goal was an independent Oromia or a federal Ethiopia," and was "an ineffective participant in the war against Mengistu, doing little fighting" (Ottoway 1999, 68). The liberation movements that played the major part in defeating the Mengistu regime were the Eritrean People¿s Liberation Front (EPLF)¿which went on to govern Eritrea following the defeat of the Dergue and a 1993 referendum on Eritrean independence¿and the Tigrayan [Tigrean] People¿s Liberation Front (TPLF), which sought to bolster its strength beyond Tigray province by forming ethnically based "people¿s democratic organizations" in the regions of the other major ethnic groups¿the Amhara, the Oromo, and the groups of southern Ethiopia¿and uniting them with the TPLF in a coalition, the Ethiopian People¿s Revolutionary Democratic Front (EPRDF). In 1989, the TPLF formed the Oromo People's Democratic Organization (OPDO) from "former prisoners of war who agreed to fight against the Dergue, as a rival to the OLF" (de Waal 1994, 30).

Following the defeat of the Mengistu regime in 1991, the OLF joined with the EPRDF in a Transitional Government that would lay the groundwork for elections and a transition to democracy. Just prior to elections in mid-1992, the OLF and other parties pulled out following disputes over the encampment of military personnel and claims of harassment of party members. The elections went ahead and the EPRDF won overwhelmingly, though some 50 to 60 percent of eligible voters did not participate (Minorities at Risk Project June 1998, 12). In the decade since the overthrow of Mengistu, the TPLF and its allies in the EPRDF have consolidated power based on a system of ethnic federalism that devolves substantial power and authority to ethnically based regional governments while maintaining centralized control in the hands of the TPLF leadership. The Ethiopian government has been accused of serious human rights violations against political opponents and hundreds of supporters and suspected members of the OLF have been detained and others tortured, disappeared, or killed. The OLF has continued to wage a low-level armed struggle for self-determination against the Ethiopian government, but in the view of most analysts, does not pose a major threat to the continued rule of the TPLF / EPRDF government.


A report by the Minorities at Risk Project at the University of Maryland provides a breakdown of the Oromo into four main groups:

"First, the western Oromo, mainly in Wallaga [Welega, Wallagga, Wollega], had largely been Christianized by the Protestant Mekane Yesus Church. The first leaders of the OLF came from the group¿s elite youths. Secondly, the northern Oromo of Mecha-Tulama, living in Shoa and the area to the south of it, are mostly Christians of the Ethiopian Orthodox Church and have become more integrated into Amhara culture than other Oromo groups. This group speaks Amharic as well as Oromifa (the Oromo language). Thirdly, the southern Oromo of Arsi and Borana had a semi-nomadic life style. Some are Muslims and others belong to traditional religions. Members of this group support the OLF. Fourth, the eastern Oromo of Harage [Harege, Hareghe, Hararge, Harerghe] consists of the Muslim urban people of Harar and Dire Dawa and rural populations living around these towns and the areas to the west of them. This group traditionally linked itself to the Arab world. Some of this group's clans such as the Jara support the IFLO [Islamic Front for the Liberation of Oromia]" (Minorities at Risk Project June 1998, 3).

Another report provides a detailed breakdown of Oromo clans and sub-clans and their origins:

"Oromo have several clans (gosa, qomoo). The Oromo are said to be of two major groups or moieties descended from the two 'houses' (wives) of the person Oromo represented by Borana and Barentu (Barenttuma). Borana was senior (angafa) and Barentu junior (qutisu)¿ The descendants of Borana and Barentu form the major Oromo clans and sub-clans. They include Borana, Macha, Tuuiiama, Wallo, Garrii, Gurraa, Arsi, Karrayyu, Itu, Ala, Qaiioo, Anniyya, Tummugga or Marawa, Orma, Akkichuu, Liban, Jile, Gofa, Sidamo, Sooddo, Galaan, Gujii and many others. However, in reality there is extensive overlap in the area they occupy and their community groups. And since marriage among Oromo occurs only between different clans there was high degree of homogeneity" ("The Oromo People and Oromia" 1998, 3).

"The Oromo¿ are found in all the regions of the Ethiopian Empire except for Gondar. They make up a large proportion of the population of Ilubbabor, Arsi, Baale, Shawa, Hararge, Wallo, Wallagga, Sidamo and Kafa. They are also found in neighboring countries such as Kenya and Somalia" ("The Oromo People and Oromia" 1998, 3).


The formal political positions of the OLF and OPDO regarding Oromo rights and interests have much in common, but the strategies and activities undertaken by the two organizations are fundamentally different. Each claims to have as its objective self-determination for the Oromo people and advancement of the political, economic, social, and cultural interests of the Oromo. However, the OLF, seeing no space to work openly and without repression to achieve its objective of an independent Oromia or a loose federation with other nationalities through the current Ethiopian political system, is waging an armed struggle to attain its objectives. The OPDO works within the EPRDF coalition to represent the interests of Oromos within Ethiopia¿s decentralized (but controlled) system of "ethnic federalism" (BBC 8 May 1990; OLF n.d.).

For the OLF, the "fundamental objective of the Oromo liberation movement is to exercise the Oromo peoples' inalienable right to national self-determination, and to form, where possible, a political union with other nations on the basis of equality, respect for mutual interests and the principle of voluntary association" (OLF n.d.).

The OPDO, in its Political Programme, defines its objective as to "respect the national interests and rights of the Oromo people, and ensure their democratic right to self-determination, including the right to establish their own independent state" (BBC 8 May 1990). OPDO seeks also to:

". . . struggle for the establishment of a democratic system in Ethiopia in order to facilitate a voluntary democratic alliance based on equality . . . to further ensure the welfare of the Oromo people . . . [and to] work to persuade the Oromo people to accept a democratic alliance voluntarily" (BBC 8 May 1990).

Since its foundation in 1973, the OLF has waged a continuous low-level armed struggle for self-determination except for a short period following the overthrow of the Mengistu regime in 1991 when the OLF collaborated with the EPRDF in the Transitional Government. Since the OLF¿s founding, its struggle has been weakened by the heterogeneity and differentiation within the Oromo people, by the Front¿s own lack of unity and clarity regarding ultimate objectives, and by its much more limited strategic vision and organization compared to its main competitor, the TPLF. Alex de Waal argues:

"The OLF is itself splintered: it was founded in the east before being taken over by Christian westerners, and still shows the fault line. As a general rule, Oromos from Harerghe (east) [also Hararge, Harage, Harege, Hareghe], agitate for independence, while those from Wollega (west) [also Wallagga, Wallaga, Welega] are prepared to accept a degree of autonomy within a united Ethiopia" (de Waal 1994, 33).

Discussing the strengths and limitations of the OLF vis-à-vis the rival TPLF, he continues:

"The OLF was unable to build a strong united leadership, and was unable to move beyond shallow nationalist politics towards a deeper articulation of the needs of the Oromo peasantry. In part, this was because of the high degree of class, regional and religious differentiation among the Oromo, and also the continued existence of powerful traditional elites. This meant that the OLF remained a more pluralistic and diffuse organization than the TPLF, with many different loci of power and authority, and differing local forms of organization. While this was democratic, it also meant that building an effective military machine was almost impossible. In addition, the organization was unable to build upon the concrete experiences of Oromo peasants to build a political programme. The OLF programme still consists largely of platitudes about democracy and human rights, and a general commitment to self-determination for the Oromo people" (de Waal 1994, 33).

Marina Ottoway presents a similar assessment of the weaknesses of the OLF, arguing that the Front was an "ineffective participant in the war against Mengistu" (Ottoway 1999, 69), and following the overthrow of the Marxist regime and the OLF¿s withdrawal from the Transitional Government and the 1992 elections:

"[T]he TPLF dealt with the OLF as a security problem to be solved by force. The TPLF army enjoyed overwhelming superiority, and the war did not last long. By late summer, 18,000 OLF fighters had been taken prisoner; they were demobilized and later freed. This short conflict eliminated the major domestic security threat faced by the government, but it also narrowed its political base, reducing participation and increasing control. The OLF itself was reduced to an ineffective organization without a strategy to re-engage politically and without the capacity to bring about change by force" (Ottoway 1999, 69).

A central weakness of the OLF has been their lack of definition regarding their overall objective: "the OLF," Ottoway argues, "wavered between the ideal of an independent Oromia, the desire for a large degree of autonomy, and the dream of supplanting the TPLF as the dominant political organization in the country" (Ottoway 1999, 70). Alex de Waal, writing in 1994, reported "evidence of a split in the OLF between the more conciliatory Deputy Secretary General Lencho Leta [Letta] and the more confrontational Secretary General Galassa [Gelassa] Dilbo" (de Waal 1994, 27-28). In 1997 there were reports that:

". . . informal negotiations between OLF and government broke down in the spring after splitting the OLF into two positions: that of its secretary-general Gelassa [Galassa] Dilbo who wanted to continue the struggle against the regime and that of his deputy Lencho Letta [Leta] who was more in favor of legalizing the OLF" (Minorities at Risk Project June 1998, 21).

While the OLF has been able to maintain a low-level armed conflict against the Ethiopian government in recent years, it does not appear to pose a significant short- or medium-term threat to the continued existence of the current Ethiopian government. A critical assessment of the Ethiopian government, just prior to the conflict with Eritrea, concluded, "the EPRDF seemed firmly entrenched and Prime Minister Meles secure in his leadership in early 1998" (Vestal 1999, 192).

The OPDO¿s strengths and weaknesses are of a very different kind from those of its rival for Oromo support, the OLF. The critical initial weakness of the OPDO was that it was viewed as a creation of the Tigrean TPLF, formed to broaden its base of support and to obtain and then maintain power following the overthrow of the Mengistu regime. There is little argument that the OPDO originated as a creature of the TPLF. In the assessment of Marina Ottoway:

"In 1991, the TPLF had power based on its military superiority over the other movements. It could not transform such power into political authority without dealing with the ethnic problem. As a Tigrean nationalist movement, it had no support in other regions, nor could it hope to gain it¿Oromos and Amharas could never vote for a party dedicated to the cause of Tigrean liberation. In the last period of the war against Mengistu, when the fighting started spreading from Tigray to other regions, the TPLF took the first steps to address the problem, promoting the formation of ethnic movements in other regions and of an umbrella organization, the Ethiopian People¿s Revolutionary Democratic Front (EPRDF) to bring them together. But in 1991 these EPRDF-aligned parties were perceived as tools of the TPLF and thus had little legitimacy; many of their officials were young draftees in the Mengistu army who had defected or were taken prisoner and had then turned into party organizers with the sponsorship of the TPLF. Furthermore, they were competing with preexisting ethnic movements like the OLF" (Ottoway 1999, 66-67).

Political opponents continue to depict the OPDO as a tool of TPLF leaders who maintain control over key decisions, a view shared by many outside analysts of Ethiopian politics. Theodore Vestal states, "In every regional government, a shadow party organization operated as a disciplined phalanx to carry out the will of the EPRDF leadership" (Vestal 1999, 125). He argues:

"Important decisions are made by party leaders behind closed doors. Not a single important political or organizational question is decided by government officials or mass organizations without guiding direction from the party. The Front [TPLF] stands above all, and the leaders do not test their policies in a forum of free speech and fair elections. Instead they mobilize and enforce consent" (Vestal 1999, 125-126).

Ottoway argues that while there has been devolution of authority to the regions in economic and some other areas, "[p]olitically . . . there is no decentralization" (Ottoway 1999, 72).

"EPRDF affiliates dominate all the regions, thus guaranteeing the basic homogeneity of policies. With the backing of the TPLF and the EPRDF, access to greater resources, and strong-arm methods that make it difficult for opposition parties to compete, the EPRDF affiliates control, in the words of an Ethiopian official, "most of the political space," leaving the opposition to operate at the margins. Faced with the certainty of defeat, most opposition parties, including the OLF, choose to boycott elections, thus surrendering the political space even more completely to the government parties" (Ottoway 1999, 72).

While questions regarding the origins and autonomy of the OPDO vis-à-vis the TPLF / EPRDF will undoubtedly continue, the organization has made some important advances in its decade of membership in the governing EPRDF coalition. The OPDO won 174 of 178 seats for the House of People¿s Representatives and all but two of the 535 seats in the State Council in the 2000 elections (BBC 15 June 2000). Despite the absence of genuine opposition and a political system that has been described as "democratic form without democratic content" (Ottoway 1999, 77), the U.S. State Department reported, "[a]ccording to international and local observers, elections were generally free and fair in most areas" (U.S. DOS Feb. 2001).

Access to state resources, OLF weakness, and social, economic, and religious differences among the Oromo have provided space for the OPDO to compete for allegiance among the Oromo people. De Waal argues:

"The fragmented organization of the OLF has meant that, since May 1991, there has been a scramble for the allegiance of the Oromo. The OPDO has played the classic role of trying to co-opt a significant section of the Oromo people, with some success in the more centralist- oriented regions" (de Waal 1994, 34).

Even a strong critic of the content of Ethiopia¿s "ethnic federalism" acknowledges that real steps have been taken to devolve certain powers and authority to the regions:

"All available evidence suggests that the government has made serious efforts to transform Ethiopia into a federation by building up the capacity of the states to carry out their functions . . . While the tax base of the state governments remains narrow, necessitating transfers from the central government, these transfers are increasingly in the form of bloc grants, which allow the states to make autonomous policy decisions . . . These and other changes suggest that a transition toward federalism is taking place on the ground, not only in words" (Ottoway 1999, 71).

While political control continues to be centralized, the devolution of certain areas of decision-making to the regions has provided significant resources to the OPDO and other ethnic organizations within the EPRDF coalition to build popular support. A recent United Nations IRIN report concluded, "while there was initial resistance to the OPDO in the [Oromia] region in 1991-1992, regional observers and local political sources told IRIN it had gained acceptance as a regional administration" (U.N. OCHA-IRIN 28 Nov. 2000).

The current situation in Ethiopia, following conclusion of a peace agreement with Eritrea, appears delicate. There were reports in late March 2001 of the detention of a group of TPLF party dissidents, including Siye Abraha Hagos, the former defense minister, who had long opposed Prime Minister Meles Zenawi. Points of contention between the Meles and Siye groups appeared to include charges of corruption against members of the "Siye group," Meles' conduct of the war against Eritrea, and the extent to which powers should be devolved from the central government to the regions. An Ethiopian analyst considered that the close division within the TPLF Central Committee would require Meles to turn to the EPRDF for support and would hence "strengthen the hand of political forces in some of the regions" (U.N. OCHA-IRIN, CEA 27 Mar. 2001).

In recent weeks, a leader of the OPDO, Yonathan Dibsa, a minister in charge of the regional state¿s justice and administrative affairs and an OPDO representative to the executive committee of the governing EPRDF coalition defected while participating in a delegation and announced he would join the OLF. Dibsa denounced the corruption and human rights violations prevalent in Ethiopia and claimed that:

". . . the TPLF, the hard core of the EPRDF, holds an iron fist over all the spheres of power, which¿ is illustrated by the fact that the ¿real president¿ of the [Oromia] regional state is a bearded Tigrean [Tigrayan] by the name of Solomon Tesfaye (whose nickname is Timmo, i.e., the bearded one), a TPLF high cadre who 'commands even Kuma Demeksa [the regional president] himself'" (ION 17 Mar. 2001; ION 3 Mar. 2001).


No information was found among the sources consulted by the RIC, which could provide a conclusive response to the question above, however, the following information may be useful in analyzing these issues. The Oromo Liberation Front's claim to be engaged in a legitimate armed struggle for national self-determination, and the Ethiopian government's claim that the OLF is an illegal movement that is no more than a band of terrorists, are clearly competing, mutually exclusive claims. The OLF argues that the rights of the Oromo people are being denied under the existing regime in Ethiopia, that Oromo nationalists are harassed and oppressed for attempting to exercise basic democratic rights, that the current system of "ethnic federalism" in Ethiopia is a sham designed to maintain Tigrean (TPLF) control over the country and its resources, and that armed struggle is the only means left to Oromo nationalists to gain their right to self-determination (OLF n.d.).

The Ethiopian government argues that the rights of the Oromo people¿up to and including the right to secede from Ethiopia¿are guaranteed in the Ethiopian constitution and that those seeking change have the opportunity to do so within the existing political system; that the OLF has "committed atrocities against its own people, and has rejected a democratic option in favour of 'chauvinistic violence'" (U.N. OCHA-IRIN 28 Nov. 2000) and that the government has the right to treat the OLF as a "terrorist organization" (Africa News 30 Mar. 2001).

In evaluating these competing claims to legitimacy, a number of factors may be noted: Ethiopia has had a series of elections in the past ten years, including the first election for a national government held in 1995. Commenting on the latter, the U.S. State Department reported that international and domestic observers judged the election to be generally free and fair. The State Department noted, however, that most opposition groups boycotted the elections (U.S. DOS Feb. 2001). The State Department's assessment relates largely to the procedural conditions under which the elections took place rather than the broader question of whether the Ethiopian political system is a democratic one. In the view of a number of analysts of Ethiopian politics and society, the control exercised by the TPLF over the political life of the country, the lack of political space allowed to opponents of the EPRDF government, and the serious human rights violations committed against political opponents, call into question the "democratic" credentials of the Ethiopian government (See, de Waal 1994, 28-32; Ottoway 1999, 72; Vestal 1999, 125-126; and for human rights violations, see HRW Dec. 1997, 24-27; OSG Feb.-Apr. 1999).

This response was prepared after researching publicly accessible information currently available to the RIC within time constraints. This response is not, and does not purport to be, conclusive as to the merit of any particular claim to refugee status or asylum.


AFRICA NEWS. 30 March. "OLF Warns Peace Agreement Threatened." (NEXIS)

BBC Summary of World Broadcasts (BBC). 8 May 1990. "Ethiopia: New Oromo Movement Issues Political Programme," from Voice of the Ethiopian People for Peace, Democracy and Freedom "Political Programme of the Oromo People¿s Democratic Organization," broadcast on 29 April 1990. (NEXIS)

BBC Worldwide Monitoring (BBC). 15 June 2000. "National Electoral Board endorses election results." (NEXIS)

De Waal, Alex. 1994. "Rethinking Ethiopia," in THE HORN OF AFRICA, Edited by Charles Gurdon (New York: St. Martin¿s Press).

Human Rights Watch (HRW). December 1997. ETHIOPIA: THE CURTAILMENT OF RIGHTS (New York: Human Rights Watch).

INDIAN OCEAN NEWSLETTER (ION). 17 March 2001. "Latest Defection Costly for Regime." (NEXIS)

INDIAN OCEAN NEWSLETTER (ION). 3 March 2001. "Cops Policed by Law Courts." (NEXIS)

Levinson, David. 1998. ETHNIC GROUPS WORLDWIDE: A READY REFERENCE HANDBOOK (Phoenix, Arizona: Oryx Press).

Markakis, John. 1994. "Ethnic Conflict and the State in the Horn of Africa," in Katsuyoshi Fukui and John Markakis' ETHNICTITY AND CONFLICT IN THE HORN OF AFRICA (London and Athens, Ohio: James Currey Ltd. and Ohio University Press).

MINORITIES AT RISK PROJECT. June 1998. "Ethiopia," University of Maryland, Center for International Development and Conflict Management. [Internet] URL: (Accessed 29 March 2001).

OROMIA SUPPORT GROUP (OSG). February-April 1999. "Human Rights Abuses in Ethiopia," Press Release No. 27 (Malvern, Worcester, U.K.: Oromia Support Group).

OROMO LIBERATION FRONT (OLF). No date (n.d.). "Our Mission," from Internet site of the Oromo Liberation Front. [Internet] URL: (Accessed 29 March 2001).

"The Oromo People and Oromia," Summary information adapted from book by Gadaa Melbaa (Khartoum, Sudan, 1998). [Internet] URL: (Accessed 12 April 2001).

Ottoway, Marina. 1999. AFRICA'S NEW LEADERS: DEMOCRACY OR STATE RECONSTRUCTION, Carnegie Endowment for International Peace (Washington, D.C.: Brookings Institution Press).

United Nations, Office for the Coordination of Humanitarian Affairs, Integrated Regional Information Network (U.N. OCHA-IRIN). 28 November 2000. "Oromo armed groups oppose conflict with Eritrea." [Internet] URL: (Accessed 29 March 2001).

United Nations, Office for the Coordination of Humanitarian Affairs, Integrated Regional Information Network for Central and Eastern Africa (U.N. OCHA-IRIN, CEA). 27 March 2001. "Ethiopia: Government Moves on Dissident Group." [Internet] URL: (Accessed 19 April 2001).

United States Department of State (U.S. DOS). 25 February 2000. COUNTRY REPORTS ON HUMAN RIGHTS PRACTICES FOR 1999 - VOLUME 1, "Ethiopia." [Internet] URL: _hrp_report/ethiopia.html (Accessed 29 March 2001).

United States Department of State (U.S. DOS). February 2001. COUNTRY REPORTS ON HUMAN RIGHTS PRACTICES FOR 2000, "Ethiopia." [Internet] URL: (Accessed 1 March 2001).

Vestal, Theodore M. 1999. ETHIOPIA: A POST-COLD WAR AFRICAN STATE (Westport, Connecticut: Praeger).


AFRICA NEWS. 30 March. "OLF Warns Peace Agreement Threatened." (NEXIS)

BBC Summary of World Broadcasts (BBC). 8 May 1990. "Ethiopia: New Oromo Movement Issues Political Programme," from Voice of the Ethiopian People for Peace, Democracy and Freedom "Political Programme of the Oromo People¿s Democratic Organization," broadcast on 29 April 1990. (NEXIS)

BBC Worldwide Monitoring (BBC). 15 June 2000. "National Electoral Board endorses election results." (NEXIS)

INDIAN OCEAN NEWSLETTER (ION). 17 March 2001. "Latest Defection Costly for Regime." (NEXIS)

INDIAN OCEAN NEWSLETTER (ION). 3 March 2001. "Cops Policed by Law Courts." (NEXIS)

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