Category Archives: Gender

Sexual Violence in Africa, Climate Change, and the U.S. Secretary of Energy

U.S. Secretary of Energy Rick Perry is fending off criticism for comments he made about the relationship between fossil fuels and sexual violence against African women. He said in South Africa that using fossil fuels to generate electricity in Africa would lower rates of rape because, “When the lights are on, when you have light that shines — the righteousness, if you will — on those types of acts.” To paraphrase, the literal light of electricity (and figurative one of God?) would stop some acts of sexual violence. The general feedback in the media has been about his unclear reasoning and the ridiculousness of linking a light bulb to a pervasive social problem. To approach it more moderately though, I believe he was just hypothesizing that light in homes would make women logistically safer. It was a somewhat silly notion that just shouldn’t have been said aloud so flippantly. Here is the text of his statement:

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However, the issues of fossil fuels, climate change, and gender-based violence are actually not unrelated—they’re just related in a way totally contrary to Perry’s comments. This is an opportunity to better understand how fossil fuels are actually bad for women in sub-Saharan Africa, and why it is alarming that one of the world’s most powerful policymakers on energy would miss this.

 

Climate change: Fossil fuels, the Fahrenheit, and female farmers

First, climate change is particularly threatening to poor women in Africa who are assault victims during climate change migrations. As an example, the Sudanese Civil War, including the genocide in Darfur, was due in part to desertification of grazing lands for livestock. As these grazing lands turned to hot desert, ethnic groups were forced to move to new areas to keep their animals fed. This migration caused conflicts with those already present in the area, spurring violence that entailed sexual assaults as military strategy. As the temperature of the earth rises, such conflicts will only increase in pastoral and agricultural societies that rely on the land for their survival.

Additionally, 50-80% of all agricultural workers in developing countries are women, an economically vulnerable group. Thus, they will lose out more from climate change that alters their growing and harvesting conditions more than men, who are more likely to be employed in non-farming or industrialized sectors. Financial vulnerability also forces rural women to work farther away from home and its protections, e.g. moving to a city alone, walking farther each day to access suitable land, or engaging in sex work to survive. Hence, climate change affects the safety of women in developing countries in particular ways.

Perry may have been referring to the boon of fossil fuels across the globe, it’s not clear from his quote, but Africa is pivotal to the natural resource industry in the 21st century. The eastern coast of central Africa, specifically around the Gulf of Guinea, has some of the sweetest crude in the world, meaning it is high quality and requires less refinement than sand-filled oil, thus raising profit margins. We should assume that, as U.S. Secretary of Energy, Perry knows this, and would be aware that expansion of this industry across the globe entails its expansion in Africa.

 

Sexual violence and natural resource extraction

Perry’s assertion that increased extraction of fossil fuels would lower sexual assault rates is probably the opposite of what would happen in sub-Saharan Africa.

In developing countries, there is some evidence to suggest a correlation between militarized natural resource extraction sites and violence against women in the area. There are several explanations for this. One is that jobs in the natural resource sector require men to move away from their families, and thus the kinship ties, social norms, and social boundaries that help regulate their behavior. This is not to say that men need to be socially monitored to not commit gender violence, but that all people rely on authority, rules, and the actions of those around them to know what is acceptable. (Imagine the otherwise responsible American university student acting badly on spring break vacation in Mexico—this is an example of how the removal of norms in a new environment changes how we comport ourselves.) Additionally, valuable natural resources require increased (male) security agents to keep operations running. So, natural resource extraction presents the conditions under which sexual violence can become more common.

Secondly, natural resource corporations can become their own mini-governments and, conveniently, their own law enforcement in developing countries. In line with James Scott’s work on state theory, I found that foreign oil companies operating in the Niger Delta employ their own private security forces, erect clear perimeters around extraction sites, exploit local labor at informal and very low wages, and function largely outside of the control of the Nigerian government. In drawing a comparison to a government, Nigerian oil companies a) employ their own military, b) maintain distinct geographic boundaries, c) draw some form of “taxation” through labor, and d) function autonomously. These are four measurements of state strength. Accordingly, gender violence perpetrated by employees or other affiliates of the company could easily go unpunished, as the company acts as its own police force of sorts. So, natural resource extraction then presents the conditions under which sexual violence can go unrecognized.

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Fossil fuel economies are no help to women

On a larger scale, the fossil fuel industry economically marginalizes women of the global south in nearly every way. First, it is a male-dominated industry that offers few jobs for females, who can earn income largely through the agricultural or informal sectors. Childcare responsibilities and unequal domestic duties make it difficult for women to work far away from the home, which jobs in natural resources call for. There is spurious evidence that such economic disenfranchisement increases rates of prostitution, and the gender-based violence and HIV/AIDS that accompanies that phenomenon. Oil, gas, minerals and other natural resources do not increase employment or economic opportunities for women.

Secondly, the African men it employs often spend long hours far away from their families or live at their work site altogether, as there may be low population density around drilling or mining sites. This only serves to exacerbate the inequality in domestic work in the home.

Third, modern economic investigations reveal that, as a whole, women don’t fare so well when the bulk of family income is in the form of cash paid to men. It separates women from control of family finances, and UN reports indicate that less of that money makes it home to children than if women earn it. Even in historical examinations, there is the theory that the transition from (comparably more gender equal) agricultural lifestyles to (comparably male-based) cash economies, as result of European investment in Africa, hastened the transition from traditionally matrilineal family structures to patrilineal ones.

Although this is just my conjecture, I imagine that Rick Perry has heard of the use of rape as a weapon of war, probably in the context of the Congo. It is doubtful that he was aware that South Africa suffers from a prolific scourge of sexual assault in its townships, and it is just a coincidence he made his remarks from there. He knows so little about the region that he may have been attempting to bring together the issues of fossil fuels and gender violence to further his energy agenda, without realizing that the reasons for gender-based violence in different parts of Africa vary—mass displacement, militarization, ethnic cleansing, geography, etc.

Drawing on the issue of violence against women to further a totally different agenda is misleading and exploitative.

As an aside, from my brief scan, it appears that most news articles on Perry’s comments referred to his “trip to Africa.” He was in Capetown, South Africa to be exact. This ambiguity regarding his location matters. Capetown is one of the richest cities on the continent, a worldwide tourism spot, and frankly, totally unrepresentative of anywhere else in Africa. The fact that Perry discussed development for the whole continent from this city, based on a conversation with a local girl, demonstrates his lack of understanding of the region—one common among Western policy-makers. The media’s description of his trip ignores the fact that Africa is the second largest and second most populous continent in the world (20% of earth’s land mass, with a population of over one billion). It’s ethnic, linguistic, and religious diversity is unparalleled. It is unimaginable that reports would refer to his “trip to Europe” if he was in Geneva or his “trip to North America” if he was in New York. Coverage of African politics deserves more nuance than that.

An obvious last thought: Wouldn’t solar panels be the best solution for Africa?

 

 

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Some Kidnapped Chibok Girls Released by Boko Haram

Last month marked the three-year anniversary of Boko Haram’s kidnapping of 276 girls from a government school in Borno State in northern Nigeria. The Islamic fundamentalists recently released 82 of those girls who have been missing since April 2014, allegedly after the Nigerian government released five of its fighters from prison. There are 113 girls still living among the fighters who haven’t been returned to their families.

 

 

What major news outlets haven’t shown is why rebels take “bush wives” at all. The coverage has tended to portray the kidnapping as a purely political act. However, for my M.A. thesis I researched the role of both female child soldiers and bush wives in West African civil wars. (For a book review I wrote, click here.) I found that kidnapping of girls goes beyond just the political.

bushwives

The civil wars of the 1990s in countries such as Liberia, Sierra Leone, and Ivory Coast saw unprecedented use of child soldiers. While the boys were often trained as fighters, girls fulfilled various support roles.  They cooked and cleaned at rebel camps.  They acted as porters for goods in and out of camps. They engaged in espionage at times. Some researchers pointed out how the girls helped meet the emotional needs of fighters, many barely adults themselves.

They also had children with the fighters, which entrenched a cycle of dependence on their captors. They had little chance of fleeing the camps with a child on their back, or did not want to endanger their child’s well-being (one Chibok girl allegedly chose to stay with her husband and child in Boko Haram). After three years, we now know that many of those girls kidnapped by Boko Haram have also had “bush babies” (the African term).

The humanitarian community now has the chance to apply lessons from the Disarmament, Demobilization, and Reintegration (DDR) programs of the 1990s to the Nigerian situation. Then, kidnapped girls were often given a cursory physical evaluation upon their release or cessation of hostilities, with little follow-up care for their children and absolutely no therapeutic care for their mental health. A significant obstacle for girls of the 1990s was also reintegration back into their home communities. After having conceived children with the enemy, families and neighbors were often hesitant or unwilling to welcome girls home. The International Committee of the Red Cross, a leader in helping care for the Chibok girls, must tend to the social and psychological after-care of today’s Nigerian girls in a way that was overlooked twenty years ago in other West African countries.

However, the situation for the returning Chibok girls is more complex than “us versus them” like in previous conflicts. Most people of Borno state come from a more cohesive ethnic group, the Hausas, and share the religion of Islam. The lines between the rebels and villagers may not be as clear as in West Africa. Also, the international attention on the Chibok case may lend families in their home communities a greater sense of sympathy for the girls’ plight. This sense of sympathy will be much needed in the coming years as they rebuild their lives.

One of My Presentations on Women’s Protests

Below is an excerpt from part of a talk I gave on women’s role in Nigerian protests against oil extraction. Oil activities are blamed for environmental destruction, police violence, corruption, and lack of economic growth.

One of my research findings on Niger Delta oil politics was what I termed “positional arbitrage.” This means that local chiefs and male elites used their positions to help incite protests against oil companies and the government at times, as they were well positioned to gain from women’s demonstrations.

The talk also covers some other details about the oil reform movement in the region.

Ending Child Marriage Step-by-Step

Across sub-Saharan Africa, marriage of minors is still a prevalent problem, particularly among young girls from impoverished families. In Nigeria, the practice is far more common in the Muslim North, where some areas practice Sharia law that allows for child marriage. “The Nigerian government made child marriage illegal in 2003, but according to campaigners from Girls Not Brides, 17% of girls in the country are still married before the age of 15. In the Muslim-dominated northwest, 48% of girls are married by the age of 15 and 78% are married by the time they hit 18.”

This is obviously a challenge for development, as girls who marry young are unlikely to finish schooling or stay within the protective proximity of their parents. There are countless health problems associated with childbearing at a young age, common among child brides. It threatens both the health and human rights of young girls.

For this reason, it was lauded news that “Malawi banned child marriage last week through new legislation that increases the legal age of marriage from 15 to 18, representing a major victory for girls in a country that has one of the highest rates of child marriage in the world.” Malawi could function as a model nation in Africa for reforming the ways marriage and girls’s rights are approached.

Dissertation on Niger Delta women and the oil movement published

My dissertation is available online. If you are unable to access it because you are outside the academic network, please feel free to contact me for a copy. I am an avid supporter of open, author-permitted access to publications.

ABSTRACT:

Since the discovery of oil in the Niger Delta in 1958, there has been an ongoing low-level conflict among foreign oil companies, the federal government, and rural community members in southern Nigeria. Armed insurgents and small cadres of male protesters have resisted oil activities, demanding environmental cleanup, employment, and local compensation for extractive operations. In 2002, however, large groups of women began engaging in peaceful protests against oil companies and the state, making the same demands as men. Current work describes these women as coming together autonomously to assert their rights in the face of corporation exploitation.  This project challenges such accounts and investigates how common perceptions of law and politics inform women’s role in the oil reform movement.

Employing constructivist grounded theory, this dissertation argues that women’s protests were largely a product of local elite male politicking among oil companies and federal and state governments. The first finding is that local chiefs, acting as brokers engaging in “positional arbitrage,” urge women to protest because it reinforces their own traditional rule.  In this sense, women have not implemented new tactics in the movement but instead are the new tactics. Secondly, Niger Delta women see law as innately good but identify individuals as the corrupting force that thwarts law’s potential for positive change. Women also perceive a binary between local and state law, thus allowing chiefs to act as gatekeepers between women and the state. As a qualitative case study, the project uses in-depth interviews, direct observations, and archival documentation to analyze a series of all-female demonstrations that occurred around oil extraction sites in Rivers State from 2002-2012. Ultimately, these findings welcome a more critical look at social movements by identifying ways in which apparent episodes of resistance may actually be reconfigurations of existing power arrangements.

Methodology:

 

 

grounded theory

For a link to my final dissertation, please see:

http://pqdtopen.proquest.com/doc/1666393541.html?FMT=ABS

Why Bad Leaders Are Inherited, And What We can Do About It

This is an excellent post by a friend that touches upon the lack of women in leadership as a whole, whether it be in the U.S. or Nigeria. I would add that because men have historically held positions of political power, they enjoy the “incumbent advantage,” which is well studied in the U.S. Those (male) politicans currently in office enjoy a more expansive socio-professional network, a potential ability to time elections in their favor, and greater name recognition (regardless of performance). Additionally, incumbents also have easier access to campaign funds and state resources that can be used to bolster their own campaigns, if even indirectly. These dynamics would make for an uphill battle in changing the gender ratios of government seats.

incumbency

How would the incumbent advantage take form in African politics?

ChewyChunks

Sociologists and economists try to explain why the people choose such poor leaders. They argue it’s due to the appeal of the narcissist, or because we’re really not self-aware, or because leaders have always been men and men are just deficient at important leadership qualities. While these all contribute, I think evolution offers the most intriguing insights.

First, let me give these other views a fair hearing.

Groups do tend to choose people who rate high on the narcissist scale, in part because those people are the most aggressive self-promoters, and contend that they are the most qualified of all, a prediction that more competent leaders would be unable to refute. Narcissists to seek leadership positions because they are obsessed with having power. Yet in a variety of studies, narcissistic leaders do no better or worse than any one else as leaders. That helps explain our…

View original post 1,636 more words

Gender Essentialism (Part III)

When is it not in women’s best interest to embrace the motherhood frame to propel forward female protests? The problem with this essentialism in resistance is that it may compromise an ideological tenant for a pragmatic one. By definition, essentializing must simplify the experiences and forms of knowledge of participants in resistance, and thus inevitably omit those that are outliers. It is tempting to suspend a commitment to including individual needs if it means substantively furthering a cause beneficial to the subaltern group as a whole; it may serve as a means to an end.  Tangible gains for social movements through the use of strategic essentialism may not outweigh the ideological costs of its use.

It can be problematic for a social movement to use this maternal identity as the basis for political authority, as it excludes those who are not mothers and confines participants to the mothering role.  As Tripp, Casimiro, Kwesiga, and Mungwa (2009) describe it, “their roles may limit them to [only] that of mother. It also associates women’s participation with what many consider a natural role rather than agency and choice. It may prevent women from entering into politics on an equal basis with men if the focus is on their roles as mothers”. Additionally, such a tendency simplifies the variation in women’s lives.

In the Delta context, for example, the role of chiefs’ wives in resistance is very different from that of non-elite female farmers. Elite wives must navigate a different social terrain, in which their husbands may be using them to influence the actions of women in the community or, conversely, in which they may be able to exercise an unusual amount of autonomy. The princess of * told me, “My grandfather was founder of * [so] no, I cannot really go to protest, but I can tie my wrapper and turn it upside down to protest when I want in my house”.  Farmers, on the other hand, may act with more freedom since they are not royalty or, conversely, their positions may mean they don’t have the resources or social capital to behave as autonomously as an elite woman.  So, not only must one eschew gender essentialism and cultural essentialism but also socioeconomic or any other essentialism that discounts the variations in the ways that women experience society based on their economic, educational, or marital status.

One of the disadvantages of mothering as a frame can be found in a paradox: being mothers can justify women’s presence but, once they are engaged, then it constricts their actions within the movement. As an illustration, a majority of the two dozen female protesters I spoke with at Occupy Nigeria reported that their husband or a male organizer had directed them to come.  None of them had made their own signs or banners. They all said that they would not return to protest for another day. They didn’t take up the bullhorn as often, nor did they chant very loudly, and they marched together in back of the procession behind the men. If women were not choosing to protest on their own, or were not exercising autonomy during protest, then it presents a paradox: Motherhood is their justification for public engagement, yet that same gender construct constrains their independent participation within that space of engagement. So, in all, the maternal frame offers the contradiction of empowering women to demonstrate while also possibly limiting their chance for success.

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Gender Essentialism (Part II)

Mother protesting in Jos, Nigeria

Mothers protesting in Jos, Nigeria

Women across sub-Saharan Africa, not just the Niger Delta, have used the motherhood trope in both formal and informal mobilizations, engaging in what Molyneux (1985) has termed “combative motherhood” to justify and frame their resistance. Formerly apolitical mamas from rural Kenya marched through Nairobi and then disrobed to demand the release of their sons from political imprisonment, acting on principles of care and justice and strategically employed motherhood. Ivorian women marched through Abidjan to speak out against the violence of the Gbagbo regime and, later, to force peace talks in order to end the civil war there in 2011. Aya Virginie Toure, the leader of the “One Thousand Women March” in 2011, remarked that they were just marching as their mothers had done when their fathers had been imprisoned under colonial rule, and that mothers make the best last resort in resistance (Bannister, 2011). In Nigeria, Maryam Babangida’s Better Life for Rural Women and Maryam Abacha’s Family Economic Advancement Program placed women within the role of wife and mother, thus arguing that government policies aimed at helping women should focus on their ability to financially provide for their families. In the Niger Delta protests, women’s main grievance was that companies had not offered enough employment to the women’s sons. During my observations of protests, women also regularly chanted that they couldn’t afford to provide “chop,” i.e. food, to their children and that their babies were sick because of environmental damage.

Aya Virginia Toure, leader of the Thousand Women March

Aya Virginia Toure, Ivorian leader of the “One Thousand Women March”

This essentialization of female identity (see previous post) can be a benefit for protesting women in that it draws upon the one ability that men can never have—bearing children. Discursive exploitation of motherhood can give women an edge as they attempt to enter male-dominated political space. It can reify their collective identity as they attempt to come together in resistance and can help bridge cross-ethnic or cross-religious boundaries. It can place a burden on power holders to respect protesting women enough to listen. For example, Congolese women convened inattentive male negotiators to see a play depicting the suffering the civil war had caused the country’s children, “humbling” the men into returning to the negotiating table. Essentialization of motherhood may also be embraced because it appears to be an indigenous frame of resistance in a way that the contemporary human rights paradigm, often viewed as Western, is not.

Additionally, embracing this gender construct protects female protesters from the repressive violence that men experience. The maternal frame adopted by groups demanding information on the disappearances of loved ones in El Salvador, Argentina, and Guatemala protected them from the extreme violent repression that was prevalent against dissidents in those countries in the 1970s and 1980s. Likewise, the Federation of South African Women used their motherhood as a shield from violence during their work with the anti-pass campaigns of the 1950s.

Nigerian women have voiced the belief that soldiers are less likely to fire upon or use violence against women, especially mamas.  An interviewee said that in the Niger Delta, “Army and police will start beating and shooting people. It is only the women that they will not do that to, but the men they will beat and some will die”. They have demonstrated that by bringing children to sit-ins, holding green leaves, wearing their wrappers upside-down, and baring their breasts, they use their motherhood as both a conduit for their demonstrations and as a shield through which they may protect themselves from violence. This protection then extends to men who are engaged in gender-mixed demonstrations, which is a significant reason that elite men in the Niger Delta have encouraged women’s participation in resistance. Celestine Akpobari, a local NGO Director, described how, during Saro-Wiwa’s movement, “[FOWA] women began to stay at the front of demonstrations because of the belief that the military wouldn’t shoot women” (2/9/2012).

Although the motherhood identity may seem to empower women towards greater political engagement, it can also be a constricting force as well, as described in Gender Essentialism (Part III).

Demonstrators protest in Warri, Nigeria in 2005. The protesters demonstrated against what they claim to be the shooting death of activists and demanded that ChevronTexaco implement the July 17, 2002 Memorandum of Understanding and threatened to carry out more protest on ChevronTexaco oil facilities if their demands are not met.

Demonstrators protest in Warri, Nigeria in 2005. The protesters demonstrated against what they claim to be the shooting death of activists and demanded that ChevronTexaco implement the July 17, 2002 Memorandum of Understanding and threatened to carry out more protest on ChevronTexaco oil facilities if their demands are not met.

Gender Essentialism (Part I)

An encyclopedia entry of mine, “gender essentialism,” was just published in the Encyclopedia of Diversity and Social Justice (2015) by Rowman & Littlefield. The entry stemmed from my research on the motherhood trope common in African women’s protests. During Occupy Nigeria in January 2012, women’s reverberating chants were always about needing jobs to provide for their children, or how they needed oil spills cleaned up so they could grow food for their children.  They regularly framed their resistance in terms of their role as mothers, thus essentializing their gender and their role in the resistance. Here is the text of the encyclopedia entry to offer further background:

Gender essentialism is the view that people have inherent and immutable personal characteristics based on their sex, and that these characteristics give rise to gender-specific experiences. This notion is often linked with the “difference” model of feminism (contrast with the “equality” or “social constructivist” model), both of which posit that fundamental dissimilarities between men and women explain their material and social differences.  Some gender essentialists may argue that women are naturally more peaceful, nurturing, communicative, and moral than men, thereby affecting their personal relationships and careers. Other essentialists focus on women’s shared social conditions rather than their attributes, and emphasize their marginalization within the economy and family unit, e.g. the gender wage gap. More specifically, some essentialists find that women’s childbearing alone fundamentally defines their social role and status.

Gender essentialism has been espoused by those who wish to undergird and explain role differentials among men and women, as well as by gender-equality activists wishing to create solidarity among women. The latter claim that certain generalizations can be made about “womanhood,” “motherhood,” and “the family,” and that these serve to further global standards for the status of women. Gayatri Spivak unintentionally began a movement towards “strategic essentialism” when she speculated that marginalized groups may find it advantageous to temporarily act as if their identities are stable and homogenous in order to achieve their political goals.

In response to essentialism, anti-essentialists maintain that all aspects of gender are socially constructed. Particular contexts create the class, race, and cultural differences among women’s interests. They charge that essentialism is marred by ahistorical, racist, classist, and heterosexist elements. Postmodern and particularly Black feminists emphasize that every perspective is socially situated, and charge that essentialists fail to see the “intersectionality” of discrimination.  Coined by Kimberlé Crenshaw, the study of “intersectionality” examines how biological, social, cultural, and economic categories interact on multiple levels in order to create inequality; intersectionality is at odds with gender essentialism. Some Postcolonial/Third World feminists have charged that, in trying to avoid gender essentialism, anti-essentialists have in turn actually engaged in a form of “cultural essentialism,” defining women’s identities and experiences not by their gender but rather by their nationality or culture.”

The encyclopedia can be found on google books.

diversity

Deltan Women’s Trust in Courts

The previous post about the recent settlement from Shell favoring the Bodo community, in which the company agreed to pay over $83 million dollars to avoid litigation, made me wonder about the potential for increased use of courts as a mean of collective action for Niger Deltan women. Although the Shell settlement arose from cases filed in British courts, I considered whether women would start viewing Nigerian courts as a place to seek justice as well.

However, my research several years ago indicated that, at least then, women did not view Nigerian courts as viable conduits through which they could help remedy environmental damage. Some rural women told me that courts are unfair because you can “pay the lawyer to speak well for you,” and another colorfully said, “What is bad about Nigerian court is that a child can be born today and you can put the case in court, and the child will graduate from university and the case will still be in court.” Across Nigeria, Afrobarometer’s public opinion survey asked rural women, “How much do you trust courts of law?”:

2002-2003 2005-2006 2008-2009 2011-2012 Average*
Not at all 33% 27% 19% 20% 25%
Just a little 41% 35% 36% 36% 37%
Somewhat 17% 26% 30% 31% 26%
A lot 3% 9% 11% 12% 9%
Don’t know 6% 3% 3% 1% 3%

(*The weighted average takes into account the number of respondents in each survey, which varied from 2002-2012. There were a total of 4671 respondents for all 4 surveys during this decade. My chart shows that trust in courts increased a bit during this period but was still very low (raw data taken from Afrobarometer 2012).)

A prominent women’s rights activist told me: Community groups do not have the resources to pay the fees of a legal practitioner.  Also, they don’t have faith in the legal system because of corruption. It is assumed that the oil company can buy up the lawyer and spend money to disturb the legal system, so communities will not actually have access to justice.  There is no faith in the system.  That is why community groups do not even make the effort to go to court.

Indeed, Nigerian courts and legal institutions have long been acknowledged as among the most corrupt. The Mo Ibrahim Index regularly ranks Nigeria “very low” on its measurements of rule of law, placing it 43rd out of 52 African countries in 2012.  Indeed, half of my respondents said that corruption impedes their chances of succeeding in courts. Considering corruption and the unequal playing field for grassroots activists, it is unsurprising that women have chosen to protest over engaging with formal law.

Nigerian Supreme Court.

Nigerian Supreme Court.