By Chibueze C. Okorie M.A, LLB., BL.
Legal Periscope made its debut on this stable this day week with a focus on part one of “Assessing the 25% of FCT Abuja Votes Argument – Much Ado about Nothing”. This week, we are furthering discussion on the same topic in a second part which takes a critical look at the “Federal Capital Territory, Abuja under the 1999 Constitution”, the “Anatomy of a Fallacy” among others. We invite you to take a read as we continue the discuss.
Continued from Tuesday, June 20
3.0 THE FEDERAL CAPITAL TERRITORY, ABUJA UNDER THE 1999 CONSTITUTION
3.1 It is safe to insist that those who urge or argue a different valency for the votes cast in the Federal Capital Territory, Abuja in the computation of winner and the valid return of a candidate as duly elected in a Presidential election must find the justification for that argument in the express words of the constitution itself. The conclusion that Abuja votes have that status must be clear and deducible too from the intrinsic character of the whole Nigerian State as a body politic created by the constitutional document and not urged from some long-winding extrapolation or reliance on the import of one conjunctive word, “and”. Considering the importance of the subject of the Presidency and Presidential elections in the whole scheme of the document itself, and the fact that the Constitution presents itself to be a democratic written constitution, that conclusion should not be drawn lightly because the implications and consequences of doing so are heavy. I submit that the express words of the 1999 Constitution do not support that contention; and the whole scheme of the 1999 Constitution itself including its basic assumptions and philosophy, especially as expressed in the CHAPTER II – Fundamental principles of State policy – weigh heavily against that interpretation. So, what exactly is the place and status of the Federal Capital Territory, Abuja under the 1999 Constitution? My thesis is that the status of Abuja under the 1999 Constitution did not radically change from what it was under the framework of the 1979 Constitution. The framers of the 1999 Constitution did not seek to create for the Federal Capital Territory, Abuja a status so radically different from what was envisioned under the 1979 Constitution. The inclusion of the additional words “and the federal Capital Territory, Abuja” in the sections relating to the Presidential elections including the contested Section 134(2)(b) was simply and essentially an attempt to be more precise in the description of the territory making up Nigeria following the subsequent enlargement of federating States up from the nineteen states since 1979 and the physical movement of the federal capital and seat of government to Abuja in 1991. The whole framework of the constitution itself, a comparative analysis between the preceding 1979 Constitution that laid the basic schemata which the 1999 Constitution followed, the loud absence of express words indicating such a drastic change in the electoral valency of the FCT Abuja, and the verifiable historical facts of our constitutional development give the lie to that argument and condemn it as incorrect.
3.2 The examination of the provisions of the 1999 Constitution and the preceding 1979 Constitution with some attendant comparative analysis sheds significant light. Immediately following the Preamble in the 1999 Constitution is Chapter I GENERAL PROVISIONS which very first Part – PART I – is captioned FEDERAL REPUBLIC OF NIGERIA. If one were to discern a prioritization in the manner the Constitution is arranged, one would find that the Constitution is structured such that the document begins with the most basic, fundamental and axiomatic provisions which set the ball rolling. Those provisions found, define and describe the Nigerian State. They also set its basic axiomatic tenets and principles. Chapter I Part I has only three sections: section 1 which defines the supremacy of the Constitution; section 2 which defines, sets and spells out the composition of the Federal Republic of Nigeria, and Section 3 which defines and enumerates the geographical dimensions of the 36 Federating States and the Federal Capital Territory, Abuja. I repeat for emphasis that Section 2 of the CFRN, 1999 falls within that very first portion of the Constitution that is basically definitive of the Federal Republic of Nigeria. That is significant. Let me take the liberty to reproduce section 2 for ease of reference.
Section 2(1) Nigeria shall be one indivisible and indissoluble Sovereign State to be known by the name of the Federal Republic of Nigeria.
(2) Nigeria shall be a Federation consisting of States and a Federal Capital Territory.
Section 2 of the 1999 Constitution is essentially identical with the same section 2 provisions under the 1979 Constitution which provided as follows
Section 2(1) Nigeria is one indivisible and indissoluble Sovereign State to be known by the name of the Federal Republic of Nigeria.
(2) Nigeria shall be a Federation consisting of States and a Federal Capital Territory.
Section 2(2) of the 1999 constitution is key. Just like under the 1979 Constitution, it describes, delimits and defines the territory of Nigeria, what Nigeria encompasses; the geographical territory making up Nigeria. The States and the FCT are the territorial entities that make up and compose the territory and people of Nigeria. Section 3 of the 1999 Constitution defines the area marking the territorial limits of the 36 states; and also, the area marking the territorial limits of the Federal Capital Territory Abuja, in the same and identical manner as Section 3 did under the of 1979 Constitution for the 19 states and the federal Capital Territory, Abuja.
Note further that Section 3(5) provides, in exactly the same identical terms as under the 1979 Constitutionthus;
“The provisions of this Constitution in part I of Chapter VIII hereof shall, in relation to the Federal Capital Territory, Abuja have effect in the manner set out thereunder” (EMPHASIS SUPPLIED)
Thus section3(5) in a real sense inaugurates and points to CHAPTER VIII, PART I as the portion of the Constitution dedicated entirely to the FEDERAL CAPITAL TERRITORY, ABUJA. That portion contains fairly elaborate provisions spanning Sections 297 to 304 which essentially provide for the governance structure of the Federal Capital Territory, Abuja in its special status as the federal capital territory and seat of the federal government. But very significantly, it does not contain anything at all about the nature of the Federal Capital Territory, Abuja’s voting or voter weight or status in a Presidential election. Under the 1979 Constitution the same CHAPTER VIII, PART 1 contained the provisions Sections 261 to 264. Section 261 is identical in wording – ipsissima verba as lawyers would say – with Section 297 under the 1999 Constitution. Section 262 is identical in wording with the current Section 298. Section 263 is identical in wording with the current Section 299. The current Section 300 is a rephrasing and amendment of the old Section 264 paragraphs (a) and (b) in respect of delimitation of Senatorial District and Federal Constituencies for the Federal Capital Territory. Then paragraphs (c), (d) and (e) of the old section 264 under the 1979 Constitution are now paragraphs (a), (b), and (c) of the current Section 301 under the 1999 Constitution. The only fresh provisions which were added to that CHAPTER VIII PART I under the 1999 Constitution are; section 302, relating to the President’s power to appoint a minister for the FCT Abuja; Section 303, creating four (4) Area Councils for the administration and political structure of the FCT Abuja, and Section 304 creating the Judicial Service Commission for the FCT Abuja.
3.3 I have deliberately taken time with the comparative analysis in the portion above for the purpose of showing that in respect of the FCT Abuja, there is essentially nothing different under the 1999 Constitution from the provisions under the 1979 Constitution to suggest the status being argued in its favour by the “mandatory 25% of Abuja votes” protagonists.Clearly, as I have pointed out specifically in the foregoing paragraph above, the framers of the constitution made some discernible express changes to the text in respect of Abuja. It is legitimate Constitutional interpretationgiven this circumstance to conclude that the framers of the Constitution had no intention of giving the votes cast in Abuja a different value or configuration from that of the states of the federation. If the intention of the framers of the 1999 Constitution had been that the Federal Capital territory, Abuja would have the “joker card” status that Ozekhome argues for it, inserting a provision to that effect would have been easy – or should not have been difficult – to include expressly in the constitution and especially in that portion. If the framers of the Constitution intended Section 134(2)(b) among other such subsections dealing with the election of the President to have the meaning and the interpretation proffered by Ozekhome, the language would have been explicit thus:
“He has not less than one-quarter of the votes cast at the election in each of at least two-thirds of all the states in the Federation and not less than one-quarter of the votes cast in the Federal Capital Territory, Abuja.
But there is no such expression. Therefore, it is not merely safe but imperative to conclude that this postulation is extraneous to the intention of the framers of the Constitution and absolutely outside their contemplation. It cannot be read in without doing harm to the Constitution itself. Indeed, even more significant is that against this “mandatory 25% of Abuja votes” position, Section 299 which falls within this same Chapter VIII Part I buttresses the categorization of the Federal Capital Territory, Abuja as “one of a set”. It expressly provides categorically thus:
“The provisions of this Constitution shall apply to the Federal Capital Territory, Abuja as if it were one of the States of the Federation, and accordingly:
(a). . .
(b). . .
(c) The provisions of this Constitution pertaining to the matters aforesaid shall be read with such modifications and adaptations as may be reasonably necessary to bring them into conformity with the provisions of this section.
If you study the whole section 299 you will note well, that all the matters in paragraphs (a), (b) (c), follow the imperative wholesale, all embracing, clause that the provisions of the Constitution shall apply to the FCT Abuja “as if it were one of the states of the federation”, and the particularized paragraphs are specifics that follow in accord with that all embracing provision. Nothing can be more expressly mandatorily definitive. The fact that Abuja is to be treated as if it were one of the states of the federation is further underlined in the introductory clause of Section 301 providing thus “without prejudice to the generality of the provisions of section 299 of this Constitution in its application to the Federal Capital Territory, Abuja, … followed by provisions in the said section 301 which go on to make adaptation of certain references in order to adapt the referenced offices and authorities for a State in a way they can apply to Abuja. The inescapable conclusion is that the Constitution deems the FCT Abuja as a member of the class of States. So, with 36 States and Abuja, the deemed member of the class, in terms of number of like entities we have a total of 36+ 1 equals to 37.
One more thing that the protagonists of this position in issue have not factored in is the placement of the Sections 299 and 301 in the whole scheme of the constitution and its effect on interpretation of all things relating to the FCT Abuja vis-à-vis the States of the Federation. Section 299 is later than 134. In the interpretation of Statutes, subsequent sections ordinarily modify earlier sections if there is an inconsistency (to the extent of the inconsistency) or doubt as to meaning; in the same way that later legislation are deemed to modify earlier legislation to the extent of the inconsistency. Applying the same principle, Section 134(2)(b) is inherently subject to the effect of Section 299, which said subordination is emphasized by Section 301.
3.4 Within the context of the foregoing constitutional framework, I take issue with Ozekhome’s contention that;
“Both sections 297 and 301 clearly donate all the attributes and powers of a state (Legislative, Judicial, Executive offices designation and powers to the FCT as a separate legal entity”.
as well as when he contends too as follows
“There is no ruckus or brouhaha with the clear provision of the courts as stated above. This is because the Constitution is clear on the separate and distinct status of the FCT. It is treated as any other state in Nigeria. Consequently, a community reading of sections 2(2), 3(1)(4), 297, 299, 301 and 302, shows that the contemplation of the draftsman was indeed to consider FCT as separate and distinct from any other State in the Federation”
I must comment that I find it interesting, amusing too I must confess, that Ozekhome keeps using the phrase “separate and distinct” when referring to Abuja as if by a repetition of that phrase one would arrive at a different position to justify the status he is claiming for Abuja with respect to votes in a Presidential election. But it really does not add much more than the obvious to the argument. What the sections 297 and 301 do is simply to give Legislative, Executive and judicial jurisdictions over Abuja to the Federal Legislature and Executive, and to create a judiciary for Abuja. That is one. Secondly, I find that his tendentious use of that phrase “separate and distinct” is actually at variance with the authorities he cited. The authorities expressly say that “it is as if Abuja is one of the States of the Federation”, and that is absolutely and clearly expressed in the Constitution. So, Abuja is sitting in the same class as the States of the Federation. So, the phrase “separate and distinct” has no magical quality to add to that classification even by manifold repetition. If anything, it is actually common to each of them sitting in the class of States. Abia is as “separate and distinct” from Imo, as Katsina is as “separate and distinct” from Kaduna, or as Lagos is as separate and distinct from Ogun. They are each as “separate and distinct” from the other as they all are separate and distinct inter se. But separateness does not put any of them outside the class or over and above the class designated in Sections 2(2) or 297, 299 or 301 and yet they are all sitting in one class as belonging to that class. How can that be so difficult to see?
I find it interesting that the commentators on this issue appeal to the interpretation principle that prizes fidelity to the words of expression in the statute or instrument that is the subject of interpretation. How they can subscribe to that golden rule and yet posit the kind of interpretation in respect of the FCT, Abuja which they are peddling is truly a wonder to me. The treatment of Section 134(2)(b) as referring to a class within which the FCT Abuja falls is most in consonance with the golden rule which is the prime canon of interpretation. I will quote in extenso the Supreme Court case of ATTORNEY-GENERAL, ANAMBRA STATE V. ATTORNEY-GENERAL FEDERATION (2007) ALL FWLR) PT. 379) 1218 at 1252, B-H where the Court (referencing with approval the entry on the consideration of words in Statutes in HALSBURY’S LAWS OF ENGLAND, 3RD EDITION Vol. 32 pages 364 and 365) stated admirably the kernel of that Golden rule thus:
“The Golden Rule is that the words of an Act are prima facie to be given their ordinary and natural meaning, or. as is sometimes said, their proper meanings See St. John, Hanstood Vestry V. Cotton (1996) 12 App. Cas 1 at page 6 Per Lord Halsbury L.C; Wokes v. Dan Castar Amalgamated Collieries Ltd (1940) A.C. 1014, *1940) 3 All ER 549, at page 1022 and page 553 respectively per Viscount Simon L.C.:
‘The rule has been in existence for many years and the classical statement of it is contained in the judgment of Wesley Dale in Grey v Pearson (1857) where he said;
“In construing Wills and indeed statutes, and all written instruments, the grammatical and ordinary sense of the words is to be adhered to, unless that would lead to some absurdity, or some repugnance or inconsistency with the rest of the instrument, in which case the grammatical and ordinary sense of the words may be modified so as to avoid that absurdity or inconsistency but no further”.
If the words of an Act are clear and explicit, they themselves are the best evidence of the intention of the legislature and no reference may be made to other sources of information”
The inescapable conclusion therefore is that the proper interpretation of the effect of Section 134(2)(b) is that the candidate to be returned as elected in a Presidential election must fulfill the territorial spread condition by having not less than one-quarter of the votes cast at the election in each of two-thirds of the number of 37 entities making up the federation. In this connection, the Supreme Court decision of 1979 in AWOLOWO V. SHAGARI which was decided when the entities in question were nineteen (19) in number would be instructive and helpful in determining what constitutes two-thirds of thirty-seven) 37 entities. Both 19 and 37 have a remainder of 1 when divided by 3. But that is a matter for another day. It is not the issue we are addressing presently here. The issue we address here is whether there is a constitutional requirement that 25% of the FCT Abuja must be won to make a return in a Presidential election. And we submit that the FCT Abuja must not mandatorily be part of that spread won for a valid return. If the required spread is met by a candidate in States qua states in exclusion of the FCT Abuja, the vote score in terms of territorial spread would still be sufficient under section134(2)(b) for a valid return.
4.0 THE ANATOMY OF A FALLACY
4.1 I already stated from the beginning of this piece that the “mandatory 25% of FCT Abuja” argument is the result of muddled thinking. False premises cannot give rise to a true conclusion. If the premises are false or one of the premises is false, the conclusion cannot be true. If the premises are incorrect or one of the premises is incorrect, the conclusion cannot be correct. That is basic logic. Anyone can fall victim to fallacy. Humankind’s tendency to fallacy is well documented by logicians and manifest in the history of thought and philosophy. There are a number of false and mistaken ideas which form the premises of the argument this piece is aimed to counter. I begin with the one that appears to have caught the popular fancy and is most handy for protagonists of the 25% of Abuja argument. That fallacy is evident in Ozekhome’s piece cited above when he tries to present his argument in the following way and states for the purpose of example:
“If I request to see 24 lawyers in my law firm AND OKON, it means I must see 25 persons in all; but Okon must be one of the 25 persons. So, if 25 persons in my law firm show up, without Okon, have I had all the persons I want to see? The answer is No. To satisfy my request Okon must show up in addition to the 24, thus making the 25 persons I desire to see.”
This is a fallacious argument. Logicians call is the fallacy of false analogy. It pretends to be the same kind of proposition as the requirements of section 134(2)(b) of the Constitution but in fact is not. This Ozekhome’s example is definitely not analogous to the Constitutional provision which it pretends to mimic. For an analogy to have effective logical force the operative items – subjects of the comparison – must have an essential similitude with reference to the quality necessitating the analogy. That similitude is the essence of that analogy. To be analogous means to have a sameness in the respect or quality which is the essence of evoking the similitude. If you check the meaning of the word “analogous” you will find terms like “similar”, “like”, “corresponding”, “equivalent”, “comparable”, “related”, “akin”, “parallel”. There is no such similitude here between the Constitutional provision and Ozekhome’s example. The capitalization on the word “and” is definitely not such a similarity for the essence of the argument. Juxtaposed on a propositional calculus or analysis, both statements, – that is, the constitutional provision and the Okon example above – do not match. The Constitution speaks of fractions of a class of items. His example speaks of whole items plus an item. Furthermore, the excluded premise in Ozekhome’s “Okon example” is that his example does not include the definition that the Constitution has already given to what constitutes Nigeria and the status of the FCT Abuja as “one of a set” , an item in a collective, as already analyzed in the foregoing parts of this piece. Ozekhome’s “Okon example” also commits a second fallacy which logicians refer to as the fallacy of the straw man. It is a smart ploy in an argument that distorts the issue, takes up a shadow (straw) of the real issues in the argument, smartly makes the fresh shadow (straw) “the opposing argument” as to pretend that the straw man is the real thing, then knocks down the shadow and states proudly, “I have knocked down your argument”, when in fact the essence has not been addressed. Setting up a straw man and knocking him down is far easier than knocking downs the real man.
4.2 A careful reading of Ozekhome’s argument shows it is replete with several instances of the logical error of begging the question, described as petitio principi by logicians. Almost at every turn of the argument one finds him slipping the conclusion he is trying to arrive at into the premises that should ground the conclusion. That, in simple language is going around in circles. A few ready examples follow. Under part of his piece with sub-title ‘THE DEFINITION OF THE FEDERAL CAPITAL TERRITORY, ABUJA’ Ozekhome states thus:
“The Federal Capital Territory is defined in Part II of the First Schedule to the Constitution. The definition is in relation to Sections 3 (Chapter 1) and 297 (Chapter VIII) of the Constitution. Section 299 of the 1999 Constitution which is in Chapter VIII flows directly from the provisions of Section 297 of the Constitution. Section 299 of the Constitution states that “the provisions of this Constitution shall apply to the Federal Capital Territory, Abuja as if it were one of the states of the Federation.” Part II of the Constitution also defines the FCT as a land area of its own, separate and distinct from the land mass of any other State. Consequently, the 1999 Constitution has introduced a new dimension different from the 1979 Constitution by adding a further requirement of 25% in “and the Federal Capital Territory, Abuja.”
One wonders how this progression of sections provide premises for the conclusion that “Consequently, the 1999 Constitution has introduced a new dimension different from the 1979 Constitution by adding a further requirement of 25% in “and the Federal Capital Territory, Abuja.”.If anything, Section 299 of the Constitution actually puts the FCT Abuja within a class and makes it a member of that class, indeed expressly “as if it were one of the States of the Federation”. And then one wonders, is Ozekhome not aware that all these provisions of the 1999 Constitution he cited to justify his “separate and distinct” status for the Federal Capital Territory were already present in the 1979 Constitution?
Another one of the several instances of begging the question fallacy is under the part he sub-titled ‘CANONS OF INTERPRETATION VIS-À-VIS THE 25% CONUNDRUM’. Therein one would find this amazingly exotic piece of reasoning where Ozekhome makes this absurd leap to an equally absurd and unwarranted conclusion that does violence to the Constitutional provisions when he states;
“Thus, Section 134(2)(b) of the Constitution after generally stating all the States of the federation where the 25% requirement is a sine qua non for a presidential candidate to be deemed duly elected, rather than exclude the FCT, Abuja as one of the States of the Federation where the 25% is a requirement for a presidential candidate went further to specifically use the word “and” to include the FCT as one of the States of the Federation where the 25% is a sine qua non. It is settled law that the use of the word “and” is conjunctive in interpretation of Statutes. The implication is that after meeting the 25% requirements in 2/3 of the States of the Federation, the candidate must go forward to meet the said 25% requirement in the FCT, Abuja, before he can be deemed duly elected.” (UNDERLINING MINE FOR EMPHASIS)
In the first place, he is wrong when he argues that “Thus, Section 134(2) (b) of the Constitution after generally stating all the States of the federation where the 25% requirement is a sine qua non for a presidential candidate to be deemed duly elected”. Of course, Section 134(2)(b) does no such thing. This makes another untrue premise that spots the landscape of Ozekhome’s argument and makes it fallacious. Section 134 does not generally state all the states of the federation where the 25% requirement is a sine qua non; what section 134 does is to reflect the percentage and the scope within the class of the entities that make up the federation and which form the ONE constituency for the contest. It is important to make the point that most of the arguments about the import of the word “and” are rooted in the wrong assumption and false consideration that Section 134(2)(b) is a listing and where there is a listing the word “and” individuates the operating initial phrase or clause to each item in the list. Note that in no part of the (b) subsections of Section 134 is the word “AND” placed in a list or series by the framers of the Constitution. And furthermore – this bears repeating – section 134(2)(b) certainly does not at all come close to “generally stating all the states of the federation where the 25% requirement is a sine qua non”. It is clear, and ought to be from a contextual analysis and community reading of the express words of the Constitution that the word “and” preceding “the Federal Capital Territory, Abuja” in Section 134(2)(b) denotes a member of a collective. There is no listing in that Section 134(2)(b) so all that argument is diversionary waste-work. Section 134(2)(b) simply reflects the composite entity that is Nigeria. And it cannot be otherwise, because Section 131(4) of the 1999 Constitution provides that “for the purposes of an election to the office of President, the whole of the Federation shall be regarded as one constituency”.
4.3 Another interesting piece of this same fallacy of begging the question is where Ozekhome postulates that,
“What the law states is that the candidates must have 25% of votes in these states, and the FCT Abuja. The law does not contemplate that the candidate must win these States. The jurisprudence behind these provisions is to ensure that the President as the Numero uno citizen of the Nation, enjoys a reasonable range of widespread acceptance by majority of the people he seeks to govern, including those inhabiting the seat of power where he would govern from”.
And I ask, from where does he deduce this jurisprudence of “including those inhabiting the seat of power where he would govern from”? Where is the basis of that postulation? I submit that there is no such jurisprudence. It is a fictio mentis sine fundamento in re: a fabrication of the mind without any foundation in reality. So, one is bound to conclude from the tenor of the whole argument, that the basis for urging a mandatory requirement 25% of votes cast in the Federal Capital Abuja is essentially and fundamentally a sentimental one for which there is no basis in the Constitution. The same sentimental argument is evident in Ozekhome’s rejoinder to Dr. Kayode Ajulo in Ozekhome’s piece earlier referred to (Supra) where Ozekhome stated thus;
“The FCT, Abuja, is the political nerve centre of Nigeria. It has been imbued with such a special status as a miniature Nigeria in such a way that any elected president must have to compulsorily win the required 25% vote in the FCT, Abuja, after winning 25% votes in 24 states. The reasons for this are not far-fetched. FCT, Abuja, is the melting pot which unites all ethnic groups, tribes, religions, people of variegate backgrounds; and other distinct qualities and characteristics in our pluralistic society. It is indeed a multi-diverse and multi-faceted conglomerate of the different and distinct peoples of Nigeria, which according to Prof Onigu Otite, has about 474 ethnic groups which speak 530 languages. The FCT, Abuja, is thus regarded as the “Centre of Unity”, which is a testament to its inclusiveness of all tribes, religions, ethnic groups, languages and peoples of different backgrounds. Simply put, FCT, Abuja is a territory or land mass that is made up of individuals from every State and virtually from all the Local Government Areas in the country. It is itself made up of 6 Area Councils, quite distinct from the 768 LGAs in Nigeria, thus bringing the total to 774 LGCs in Nigeria. Consequently, scoring 25% of votes cast in the FCT, Abuja, is a Presidential candidate’s testament to being widely accepted by majority of the Nigerian people. The President is not expected to be a tenant in his seat of power. Will he pay rent to the 24 states he scored 25% votes? I do not know. Or do you?
I have quoted him in extenso for the purpose of making the error more manifest. Clearly, his argument is heavy on sentiments, but factually false and constitutionally unwarranted. It is a “wish list” for the Federal Capital Territory, Abuja: interesting ideals for sure that would make a case for a good speech on Abuja as a centre of unity. But where is all that in the Constitution? And I ask again, would it not have been simpler and more honest to make that “mandatory 25% of FCT Abuja” argument on a purely sentimental basis instead of canvassing it as mandated by the words of the Constitution when it clearly is not? GMTNews
Chibueze C. Okorie is a Legal Practitioner based in Port Harcourt. He is an author and also teaches Philosophy of Law at the Seat of Wisdom Seminary, Umuahia, an affiliate of the Pontifical Urbanian University, Rome. He can be reached via his email address: chibuezeokorie@gmail.com
To be continued…
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