2016 was one of the bloodiest years in the recent history of Europe. European states increased their security measures in order to prevent and protect their peoples from Islamic terrorists and Islamic extremism. Europe and West found a new phenomenon without precedent and now they are called to battle with it.
However, the real nightmare is not the constant fear of terrorists but the rising fear of our Muslim neighbor. How many times have you suspiciously watched a Muslim imam during the boarding time of your flight? How many times have you felt in sorrow or in anxiety about a Muslim woman wearing a niqab? How many times have you found yourself thinking that all women in Muslim countries get married before their teens or that all men beat their wives? Religion has started to set boundaries, bridge walls and bring hostile feelings into the surface: hostile feelings against our religious and cultural “unknown”.
Living permanently in Greece, I came face to face with the refugee crisis. Greece had to deal with thousands of Syrians coming from a different cultural, political and religious background. This was the breaking point where we understood the impact and the power of the Greek Orthodox Church in the Greek political and social life. First of all, in order to understand all these facts, I should mention the privileged position of the Church in the Greek Constitution. According to the Article 3, which governs the relations between the State and the Greek Orthodox Church, of the Greek Constitution (1986), the Greek Orthodoxy is the prevailing religion and the Greek Orthodox Church has the full autonomy to run all the operations related to the religious affairs. The Greek Orthodox dealt with the refugee and migrant crisis in really bad terms. Many bishops referred to them as a miasma for the Greek society and a crusade against them has to be started in order not to let them convert Christians into Islam. In September 2016, when the first refugee children would go the Greek primary schools, some Church’s representatives condemned this action and put the blame on the State that these children should not sit next to the Greek young generation. The ex-Minister of Education, Mr. Nikos Filis made an effort to change thecourse of religion in High Schools and introduce the course of World religions. The reaction of the Church led to replacement from another Minister who would follow the instructions of religious leaders and would maintain the course in the form of indoctrination as it is since the late ’50s. The specific form of the course puts in the margin, students from different religions, humanists or atheists and does not provide an inclusive school community.
Moreover, Greece is one of the countries that have not yet built a mosque for the Muslim communities. Muslim communities gather and pray in their own apartments or basements which serve religious purposes. The building of a mosque is one of the most problematic debates in Greece, especially after the pressure by the Turkish government in order to reopen the Theological School of Halki (closed since 1971).
As I already mentioned, both secular and less secular states of Europe such as Greece, are called to deal with problems and difficulties arising from religions and their embodiment in the field of politics and of human rights. This paper is going to discuss some of the most alarming issues in the current public debate related to religious expression. A special emphasis will be put on the relations between Islam and Christianity.
This article is divided in the following parts: The first part is going to examine the secular character of Europe and its challenges and consequences in a multireligious society. The second part is going to examine the issue of Muslim women veil and its ban from National Laws as well as women rights in both Muslim and Christian communities. Both primary sources and secondary sources have been selected in order to investigate the issues from various perspectives. A special attention has been paid on the decisions of the European Court of Human Rights on cases related to freedom of religion and freedom of expression.
A Secular Europe
According to the study of Pew Research Center which was conducted in 2010, Europe counted 550, 2 millions of Christians, 139,9million Non-religious and 43,3million Muslims. The prevailing religion in every single country in Europe was Christianity except for Estonia and Czech Republic where the majority of population was non-religious (59.6 % and 76.4 % respectively). Only in Albania, Islam is the prevailing religion counting 80.3% of the population. Following this study, in 2015, European Commission conducted a research related to values and European spirit. For Europeans, the most important things are the human rights, peace, life respect, individual rights and religion. Instead, they believe that the followings things represent most European Union and are less important for them: respect for other cultures, Law of the State (l’ état de droit) and democracy.
What is secularism and secular identity?
According to Casanova, secularization of Europe is an undeniable social fact. Religion does not play a key role in the fate of people and a new social model emerged in the recent decades of European history. According to Ferrari, secularization is the process where decisions affecting politics, law and economics must be based on reason, not on the faith of one or other citizen. The private and the public life are completely separated. In the era of secularization, religion belongs to the sphere of private life and public life has no room for religious affairs. Taking into account the flux of foreign minorities in Europe which carried with them new cultures and religions, secularism was the ideal solution to create inclusive societies without discrimination on the grounds of those cultural elements. To prevent the danger of a clash and to ensure the equal treatment of all religions, it is essential to ground the public sphere on a principle that is universal and neutral and therefore capable of being accepted by all people regardless of their religion: this principle is human reason. Consequently, Church and State are two different entities with different goals and different means which sometimes may cooperate for the social and common good.
Secularization has been a new and universal concept which according to Weber is a unique feature of European thought. But how has secularization emerged and prevailed in European societies? According to Linda Woodhead, there have been numerous social and political changes which favored the emergence of secularism after the 1970’s. First of all, individual rights gained ground and people determined their lives as they wished without letting anyone get involved in their decisions. Other changes such as late capitalism and consumer capitalism, tertiary knowledge open to large part of people, urbanization, globalization of economy in the post-colonial era, well — educated and skillful young people from all the social classes, women rights and women emancipation, sexual revolution and feminist movements, political emancipation constituted the fertile ground where secularism built its own building. Linda Woodhead offers two definitions for secularization. The first one is the social secularization which is the process whereby religion loses its power and influence over and within society while personal secularization has to do with the decline of individual allegiance and commitment to religion. State marginalized Church in Western states but still lays on its support in cases of emergency. Church still has impact on many people lives and its messages are strong enough even if many people decide not to follow strictly these guidelines and instructions.
A secular Christian identity
Someone would wonder how European and enlightened, secular societies are compatible with the rates of the study by Pew Research center where the majority identify themselves as Christian. As Casanova mentions, large numbers of Europeans even in the most secular countries still identify themselves as “Christian”, pointing to an implicit, diffused and submerged Christian cultural identity. According to Casanova, “secular” and “Christian” identities are intertwined in complex and rarely verbalized modes among most Europeans. However, scholars coming from different backgrounds, support the view that European secularism is selectively secular and is more friendly towards Christianity and less tolerant towards other religions and especially Islam. According to them, European secularism is a result of Christian cultural identity which still applies its standards and ignores other cultures and religions. Ferrari mentions related to that view that this secularism is double-standard secularism where the conditions of access to the secular public sphere, apparently the same for all religions, are actually more demanding for non-Christians religions whose doctrinal and organizational characteristics are less compatible with the secular profile that distinguishes the public sphere. The secular character of the current European societies has a lot been under doubt by the leaders of the Church and of various religions. The Ecumenical Patriarch Bartholomew I in his message towards the “Le Parti Populaire Européen” for its 21st Congress writes “ The history of Europe which contains some common features has been abandoned by modernity. We have to take into consideration the religious dimension if we want cohesion…and this is why our Church and PPE have started a fertile dialogue since 1995”.
Le Foulard Islamique and Women rights in Christianity & Islam
During summer 2016, mainstream and social media were full of images from arrests of Muslim women wearing burkini in French beaches. Burkini is officially banned by French Law and these arrests generated a wave of protests by human rights activists and Muslims all over the world. These protests had to do with the freedom of expression of Muslim women and Muslims in general and if finally the French secular state treats equally everybody without discrimination. On the other side, secularists talked about respect to the secular state of France and its laws of forbidding ostentious religious symbols.
France is the first European secular state where the State and Religion were separated and where the neutrality (Laïcité) of the State towards religion was applied. The Government passed the Law of 9 December 1905, installing in France a regime of Separation of Church and State which remains the current regime. The State must provide to everyone the possibility of attending at the ceremonies of his Church and of being instructed in the beliefs proper to his chosen religion. Equality between the various religions implies that there is no state religion, no “official” or dominant religion, no recognized Churches..No religion has a particular public status. Toleration must be extended to all religions, and even to unbelief. What is more, the church must be subject to political control.
These values have been reflected also on the European Convention of Human Rights and especially on the Article 9, paragraph 1 which protects the freedom of religion. The second paragraph sets the limits between the public and the private sphere where religion belongs Article 9 (2) allows governments to limit “manifestations” of religion or belief, albeit “only to such limitations as are prescribed by law and are necessary in a democratic society in the interests of public safety, for the protection of public order, health or morals, or the protection of the rights and freedom of others” The wearing of veil brought initially in France a clash of cultures and traditions. As Ferrari writes, “On the one hand, immigration have brought into Europe an increasing number of people who follow religions that are not traditional in the Old continent (in particular, Islam): on the other hand an increasing number of citizens claim the right to follow publicly the tenets of their religion in matter of dress codes, gender relations, family law and so forth, and this is outside the private domain to which religion had been confined.
The veil of Muslim women reflected a symbol of oppression in European secular societies and lack of human rights. In 2004, the French National Assembly passed a legislation which makes it illegal for Muslim women to wear headscarves within French public schools. To be precise the legislation refers to the banning of ostentatious religious symbols within the secular domain of the public school system. The Jewish kippa (yarmulke) as well as “oversize” crosses are prohibited with the Muslim headscarf.The ultimate objective was the complete assimilation of these religious groups to the French values and principles and the creation of a more cohesive and inclusive society. The scarf only gradually became a charged political symbol of the presence of Islam in France. The beginning was made in 1989 where a principal in secondary school in Creil (a suburb in Paris) expelled three girls because they wore the headscarf. After this, a series of social battles in favor of the scarf or against the scarf was followed for many years. Cultural differences were brought into the surface. Muslim women who wear a hijab often being represented as agents of “fundamentalism” or “terrorism” and as indicators of the inassimilable nature of Muslims in Europe. On the one hand, people defended the cultural and religious traditions and the freedom of religious expression and on the other hand, people defended the secular values, the place of religion in the private sphere, the freedom of Muslim women from oppression, violence and patriarchal structures. Each side accused the other of ignorance or xenophobia but both sides defended human rights from a different perspective.
But what Muslim women say about this? Islam as every religion is internally diverse and has many branches with different views, more or less strict, towards human rights and women rights. In the study of Sara Silvestri, 132 Muslim women living in European countries took part in order to reach some conclusions regarding how they embody their Islamic tradition in their daily lives. Young generations are eager to access Islamic knowledge, to intellectually, spiritually and critically “own” their religion. Many women seek personal empowerment through close and conscious adherence to religious performance, by studying the Quran and Arabic independently, by attending lectures, by becoming able to challenge tradition and to dispute male leadership from within. Also, many women reject the male dominant and traditional forms of Islam and stop belonging to institutions and conservative communities. Consequently, they live their own spirituality in their own unique way even when they do not follow religious practices (non organized Islam). In the study of Nadia Jeldtoft, where she interviews people who do not belong to organized Islam, she states “ The practices have been adapted to fit into everyday life. They are spiritual because they provide interviewees with a space of their own to practice Islam on their own terms.” As Jeldtoft mentions, the nature of this form of religion is private and internalized with an individual approach. Many Muslim women believe that headscarf is a symbol of universal values and modesty and they feel better wearing it and not oppressed.
It is of crucial importance to make a short comparison with the liberty that women enjoy in Christianity. Europe has its roots in Catholicism and later some countries were led by Lutheranism and Protestantism. After the Early Christianity, the position of women got deteriorated and they became objects under the ownership of their family male members or second class citizens. Lutheranism place the male in the position of everybody’s master (paterfamilias) and women were confined in the domestic sphere with no public speech or influence. A new model of civic order where women were excluded, was promoted by Lutheran theology. Apart from their marginal role as care takers of their family, women also were depicted as devils who try to bring troubles (witch hunting).
After many centuries, women started playing a more crucial role in the Church and its operations. In a money based economy, men were absolutely interested in the profit making and women took care of charity affairs. In the last decades, modernity paved the way for Christianity. Its traditional and conservative methods were not tolerant by young people and radical measures should be taken in order to find an effective balance. Female autonomy led to the first steps for the change in the traditional typology of gender models in Christianity. In November 2016, Pope Francis extended power to priests to forgive abortion. This is the next big step of Roman Catholicism to the female reproductive autonomy which was unconceivable some years ago. Female reproductive autonomy was established as a human right in international law by the Convention of the Elimination all Forms of Discrimination against women, in force since 1981 ratified by 168 states. The Holy See, along with eight Muslim States has not signed this Convention, nor the 1952 Convention on the Political Rights of Women.
From Davos to Munich
An overview of the views and attitudes of European officials during the Davos and Munich Conference and their comparison with each other suggests that the security, economic, and political concerns of European countries have not only not diminished but are increasing.
During the World Economic Summit in Davos, the Chancellor of Germany and the President of France both gave a significant warning about the return of nationalism and populism to Europe. This warning has been sent in a time when Far-Right movements in Europe have been able to gain unbelievable power and even seek to conquer a majority of parliaments and form governments.
In her speech, Angela Merkel emphasized that the twentieth century’s mistake shouldn’t be repeated. By this, the German Chancellor meant the tendency of European countries to nationalism. Although the German Chancellor warning was serious and necessary, the warning seems to be a little late. Perhaps it would have been better if the warning was forwarded after the European Parliamentary elections in 2014, and subsequently, more practical and deterrent measures were designed. However, Merkel and other European leaders ignored the representation of over a hundred right-wing extremist in the European Parliament in 2014 and merely saw it as a kind of social excitement.
This social excitement has now become a “political demand” in the West. The dissatisfaction of European citizens with their governments has caused them to explicitly demand the return to the twentieth century and the time before the formation of the United Europe. The recent victories of right wing extremists in Austria, Germany and…, isn’t merely the result of the nationalist movement success in introducing its principles and manifestos. But it is also a result of the failure of the “European moderation” policy to resolve social, security and economic problems in the Eurozone and the European Union. In such a situation, European citizens find that the solutions offered by the moderate left parties didn’t work in removing the existing crises in Europe. Obviously, in this situation “crossing the traditional parties” would become a general demand in the West. Under such circumstances, Merkel’s and other European leaders’ warnings about the return to the twentieth century and the time before the formation of the United Europe simply means the inability of the Eurozone authorities in preventing the Right-extremism in the West.
These concerns remain at the Munich Security Conference. As Reuters reported, The defense ministers of Germany and France pledged to redouble their military and foreign policy cooperation efforts on Friday, inviting other European countries to participate if they felt ready to do so.
In a speech to the Munich Security Conference, German defense minister Ursula von der Leyen said Europe’s countries would not be able to respond nimbly enough to global challenges if they were stymied by the need to decide joint foreign policy approaches unanimously.
“Europe has to up its pace in the face of global challenges from terrorism, poverty and climate change,” she said. “Those who want to must be able to advance without being blocked by individual countries.”
Her French counterpart Florence Parly said any such deepened cooperation would be complementary to the NATO alliance, which itself was based on the principle that members contributed differently depending on their capacities.
“The reality has always been that some countries are by choice more integrated and more able to act than others,” she said.
The push comes as Germany’s political class reluctantly concedes it must play a larger security role to match its economic pre-eminence in Europe, amid concerns that the European Union is unable to respond effectively to security concerns beyond its eastern and southern borders.
But in their deal for another four years of a “grand coalition” government, Chancellor Angela Merkel’s conservatives and the Social Democrats have agreed to boost spending on the armed forces after years of post-Cold War decline.
The deal, which must still be ratified by the Social Democrat membership, comes as Germany reluctantly takes on the role of the continent’s pre-eminent political power-broker, a role generations of post-war politicians have shied away from.
Days after U.S. Secretary of Defense James Mattis reiterated President Donald Trump’s demand that European countries spend more on their militaries, Von der Leyen pledged to spend more on its military and the United Nations, but called in return for other countries not to turn away from mulitlateralism.
The pledges come as the EU seeks a new basis on which to cooperate with Britain, traditionally one of the continent’s leading security players, after its vote to leave the EU.
Earlier on Friday, the leaders of the three countries’ security services said close security cooperation in areas like terrorism, illegal migration, proliferation and cyber attacks, must continue after Britain’s departure.
“Cooperation between European intelligence agencies combined with the values of liberal democracy is indispensable, especially against a background of diverse foreign and security challenges,” they said.
First published in our partner Tehran Times
Election Monitoring in 2018: What Not to Expect
This year’s election calendar released by OSCE showcases a broad display of future presidential, parliamentary and general elections with hefty political subjecthoods which have the potential of transforming in their entirety particularly the European Union, the African Union and the Latin American sub-continent. A wide sample of these countries welcoming elections are currently facing a breadth of challenges in terms of the level of transparency in their election processes. To this end, election observation campaigns conducted by the OSCE Office for Democratic Institutions and Human Rights (ODIHR), the Council of Europe, the Organisation for American States (OAS), the United Nations Electoral Assistance Division, the National Democratic Institute, Carter Center and even youth organisations such as AEGEE and Silba are of paramount importance in safeguarding the incorruptibility of election proceedings in fraudulent and what cannot be seen with the naked eye type of fraudulent political systems, making sure elections unfold abiding national legislation and international standards.
What exactly does an election observation mission supposed to accomplish?
An election monitoring mission consists of operational experts and analysts who are all part of a core team and are conducting their assignments for a period of time varying between 8 and 12 weeks. Aside from the core team experts and analysts, there can be short-term or long-term observers and seconded observers or funded observers. Joining them, there is usually a massive local support staff acting as interpreters and intermediaries. Generally, an election observer does not interfere with the process, but merely takes informative notes. With this in mind, it is imperative of the observer to make sure there isn’t any meddling with votes at polling stations by parties and individual candidates; that the people facilitating the election process are picked according to fair and rigorous benchmarks; that these same people can be held accountable for the final results and that, at the end of the day, the election system put in place by the national and local authorities is solid from both a physical and logical standpoint. Oftentimes, particularly in emerging democracies, the election monitoring process goes beyond the actual process of voting by extending to campaign monitoring.
In practical terms, the average election observer needs to abide by certain guidelines for a smooth and standardised monitoring process. Of course, these rules can vary slightly, depending on the sending institution. Typically, once the election observer has landed in the country awaiting elections, their first two days are normally filled with seminars on the electoral system of the country and on the electoral law. Meetings with candidates from the opposition are sometimes organised by the electoral commission. Talking to ordinary voters from builders to cleaners, from artists to businesspeople is another way through which an election observer can get a sense of what social classes pledged their allegiances to what candidates. After two days in training and the one day testing political preferences on the ground, election day begins. Since the early bird gets the worm, polling stations open at least two hours earlier than the work day starts, at around 7am. Throughout the day, observers ask voters whether they feel they need to complain about anything and whether they were asked to identify themselves when voting. Other details such as the polling stations opening on time are very much within the scope of investigation for election monitors. Observers visit both urban voting centres and rural ones. In the afternoon, counting begins with observers carefully watching the volunteers from at least 3 metres away. At the end of the day, observers go back to their hotels and begin filling in their initial questionnaires with their immediate reactions on the whole voting process. In a few weeks time, a detailed report would be issued in cooperation with all the other election observers deployed in various regions of the country and under the supervision of the mission coordinators.
Why are these upcoming elections particularly challenging to monitor?
Talks of potential Russian interference into the U.S. elections have led to full-on FBI investigations. Moreover, the idea of Russian interference in the Brexit vote is slowly creeping into the British political discourse. Therefore, it does not take a quantum physicist to see a pattern here. Hacking the voting mechanism is yet another not-so-classic conundrum election observers are facing. We’re in the midst of election hacking at the cognitive level in the form of influence operations, doxing and propaganda. But, even more disturbingly, we’re helpless witnesses to interference at the technical level as well. Removing opposition’s website from the Internet through DDOS attacks to downright political web-hacking in Ukraine’s Central Election Commission to show as winner a far-right candidate are only some of the ways which present an unprecedented political savviness and sophistication directed at the tampering of the election machinery. Even in a country such as the U.S. (or Sweden – their elections being held September of this year) where there is a great deal of control over the physical vote, there is not much election monitoring can do to enhance the transparency of it all when interference occurs by way of the cyber domain affecting palpable election-related infrastructure.
Sketching ideational terrains seems like a fruitful exercise in imagining worst-case scenarios which call for the design of a comprehensive pre-emptive approach for election fraud. But how do you prevent election fraud? Sometimes, the election observer needs to come to terms with the fact that they are merely a reporter, a pawn which notwithstanding the action of finding oneself in the middle of it all, can generally use only its hindsight perspective. Sometimes, that perspective is good enough when employed to draft comprehensive electoral reports, making a difference between the blurry lines of legitimate and illegitimate political and electoral systems.
Can Europe successfully rein in Big Tobacco?
In what looks set to become the ‘dieselgate’ of the tobacco industry, a French anti-smoking organization has filed a lawsuit against four major tobacco brands for knowingly selling cigarettes with tar and nicotine levels that were between 2 and 10 times higher than what was indicated on the packs. Because the firms had manipulated the testing process, smokers who thought they were smoking a pack a day were in fact lighting up the equivalent of up to 10, significantly raising their risk for lung cancer and other diseases.
According to the National Committee Against Smoking (CNCT), cigarettes sold by the four companies have small holes in the filter that ventilate smoke inhaled under test conditions. But when smoked by a person, the holes compress due to pressure from the lips and fingers, causing the smoker to inhale higher levels of tar and nicotine. According to the lawsuit, the irregularity “tricks smokers because they are unaware of the degree of risk they are taking.”
It was only the most recent example of what appears to be a deeply entrenched propensity for malfeasance in the tobacco industry. And unfortunately, regulatory authorities across Europe still appear unprepared to just say no to big tobacco.
Earlier this month, for instance, Public Health England published a report which shines a positive light on “tobacco heating products” and indicates that electronic cigarettes pose minimal health risks. Unsurprisingly, the UK report has been welcomed by big tobacco, with British American Tobacco praising the clear-sightedness of Public Health England.
Meanwhile, on an EU-wide level, lawmakers are cooperating too closely for comfort with tobacco industry executives in their efforts to craft new cigarette tracking rules for the bloc.
The new rules are part of a campaign to clamp down on tobacco smuggling, a problem that is particularly insidious in Europe and is often attributed to the tobacco industry’s own efforts to stiff the taxman. According to the WHO, the illicit cigarette market makes up between 6-10% of the total market, and Europe ranks first worldwide in terms of the number of seized cigarettes. According to studies, tobacco smuggling is also estimated to cost national and EU budgets more than €10 billion each year in lost public revenue and is a significant source of cash for organized crime. Not surprisingly, cheap availability of illegally traded cigarettes is also a major cause of persistently high smoking rates in the bloc.
To help curtail cigarette smuggling and set best practices in the fight against the tobacco epidemic, the WHO established the Framework Convention on Tobacco Control (FCTC) in 2005. The first protocol to the FCTC, the Protocol to Eliminate Illicit Trade in Tobacco Products, was adopted in 2012 and later ratified by the EU. Among other criteria, the Protocol requires all cigarette packs to be marked with unique identifiers to ensure they can be tracked and traced, thereby making smuggling more difficult.
Unsurprisingly, the tobacco industry has come up with its own candidates to meet track and trace requirements, notably Codentify, a system developed by PMI. From 2005 through 2016, PMI used Codentify as part of an anti-smuggling agreement with the EU. But the agreement was subject to withering criticism from the WHO and other stakeholders for going against the Protocol, which requires the EU and other parties to exclude the tobacco industry from participating in anti-smuggling efforts.
The EU-PMI agreement expired in 2016 and any hopes of reviving it collapsed after the European Parliament, at loggerheads with the Commission, overwhelmingly voted against a new deal and decided to ratify the WHO’s Protocol instead. Codentify has since been sold to the French firm Impala and was rebranded as Inexto – which critics say is nothing but a front company for PMI since its leadership is made out of former PMI executives. Nonetheless, due to lack of stringency in the EU’s draft track and trace proposal, there is still a chance that Inexto may play a role in any new track and trace system, sidelining efforts to set up a system that is completely independent of the tobacco industry.
This could end up by seriously derailing the EU’s efforts to curb tobacco smuggling, given the industry’s history of active involvement in covertly propping up the black market for cigarettes. In 2004, PMI paid $1.25 billion to the EU to settle claims that it was complicit in tobacco smuggling. As part of the settlement, PMI agreed to issue an annual report about tobacco smuggling in the EU, a report that independent researchers found “served the interests of PMI over those of the EU and its member states.”
Given the industry’s sordid history of efforts to prop up the illicit tobacco trade, it’s little surprise that critics are still dissatisfied with the current version of the EU’s track and trace proposal.
Now, the CNCT’s lawsuit against four major tobacco firms gives all the more reason to take a harder line against the industry. After all, if big tobacco can’t even be honest with authorities about the real levels of chemicals in their own products, what makes lawmakers think that they can play a viable role in any effort to quell the illegal cigarette trade – one that directly benefits the industry?
Later this month, the European Parliament will have a new chance to show they’re ready to get tough on tobacco, when they vote on the pending proposal for an EU-wide track and trace system. French MEP Younous Omarjee has already filed a motion against the system due to its incompatibility with the letter of the WHO. Perhaps a ‘dieselgate’ for the tobacco industry might be just the catalyst they need to finally say no to PMI and its co-conspirators.
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