LS 348: Animal Law Term Test 1

Who invented the Equal Consideration of interest theory?

Peter Springer

What is the Equal Consideration of Interest Theory

• If we're going to have a progressive civil society that is enlightened, then we must provide equal consideration and think about the interests of animals

Why are Animals Tested On?

Because it is immoral to test on humans, and it is a cheap commodity compared to using tech

What does PETA believe

• Would rather euthanise animals than subject them to cruelty

• Takes a very radical position

• Protects future mistreatment by eliminating the animal

What is the Alruistic Approach

• Animals do not have rights, you need to be a third party who applies on an animal’s behalf

How were animals constituted under the law in 1700-1800’s

• One can abuse his own horse, but not another’s

• The law made that distinction based on the financial value of the animal and its use

What is the ASPCA and what does it constitute

• Created in the 1860’s

• Animals are considered under the law as property, but pets like dogs can be mistreated

• Legislation is varied in each state

What is the role of the courts

• To interpret the language of the law

• Judiciary discretion

• Courts define things for us, then create precedent

What are the two approaches to animal law

• Advocacy

  • rights based

• Descriptive

  • legalistic; applying law straight from the books

How is an advocacy, rights based approach problematic

• Becomes a pandora’s box

• What defines animal rights, how does the law catch up with this, how can we incorporate these rights into legislation

Why is a descriptive approach to animal law problematic

• problematic because it does not account for facts that are not addressed by legislation

• Campers the ability to defend/prosecute

• Less room for change

How does an advocacy approach align with the objectives of the legal system?

• Advocacy aligns with the animal rights movement

1. Animals are put on earth to serve humans

2. Maltreatment must cease via laws

3. Grant legal righthood

• Advocacy formalises and codifies rights of animals

What does granting legal righthood look like?

• Non-human rights

  • Given to corporations, fetus, rainforests, geographical areas

• Intervenor status

  • Someone who represents animals

    • EX. marineland

      • An animal justice group has intervened and advocated for the closing of marineland

Expand on the example of marineland

• Animal justice groups have intervenor status

• They advocate for the closing of marineland

• Marineland justifies keeping the animals as conservation of species

How does a descriptive approach align with the objectives of the legal system?

• Works with whatever legislation is already there

Why does an advocacy approach work better than descriptive

• Advocacy formalises and codifies the rights of animals

• Descriptive is unable to represent clients or defend animals adequately

  • Since the legislation is not used to animal rights, the system of law becomes constrained and discretionary

    • It is up to the court to determine an outcome

      • Most judges have poor knowledge of animals, or empathy towards animals

Why is judicial discretion problematic

• It is up to the court to determine an outcome

• Judges may have poor knowledge of animals, or empathy towards animals 

• Progressive society would not accept cruelty 

  • A child who harms an animal will be more likely to harm humans

What is cockfighting

• Was defined as a noble sport in 1973 Kansas

• The bird used in the fight was not considered an animal

• Cockfighting was legal 6 days of the week, except Sunday (Church)

• Very expensive and tedious to investigate

• Is illegal, but still happens 

What is rights/advocacy within the law broken into

• Rights Based

  • Goal: grant legal status of animals and decrease exploitation

  • Deploys the rule of law to master complex human and animal relations

  • Aims for protection under and benefit from the law, redefine animals from property to persons

• Reformist

  • Less fundamentalist

  • Goal is to reduce pain and sufferning

  • We do not need to give animals' rights, but can still protect them against harm

  • Codes of Practice are necessary, hard to enforce though

  • Aims to permit:

    • Damages when there is negligence, intentional killing, emotional distress

    • Allow for cause of action when companion animal is lost

    • End AGRO practices

      • ex. cutting beaks of baby chicks

    • Denounce puppy mills

    • Seek damages from government agencies for failure to protect in cases of animals for research, marine mammals, endangered species

Puppy Mills

• Cruelty loopholes

• Bill 100 Puppy Mill Ban and Animal Cruelty Prevention Act 2001 was lost

• PAWS limits the frequency of breeding and has created permits

• There is no black letter of law, or explicit legislation surrounding them

• Importing animal, works alongside human/sex trafficking

What is the current state of animal welfare in canada

• We have a lack of precedent in this area, so it is up to the courts to recognise sentience and create reform

Define Sentience

• the ability to have experiences and feel things regardless of cognitive ability

What was the historical view on animals in the CJS 1800’s and prior

• Lawyers were only interested in animals if they impacted a criminal case

• One was allowed to abuse his own cattle (farm animal, livestock), but not another’s 

• Law made distinctions based on financial value of the animal 

  • Ex. cows are economically valuable, dogs are not

What is S 444 of the CCC

• Killing, maiming, wounding, injuring, endangering cattle

What is S 445 of the CCC

• Killing, maiming, wounding, injuring, endangering other animals who are kept for a lawful purpose

How are animals defined by the federal legislation (CCC)

• Animals are defined as property

• Judges have softened their approach through interpretations

• The CCC has a 5 year max penalty, which constitutes an indictable offence 

• Judges are still typically harsher on people who commit crimes against cattle due to their economic value

What is S 447 of the CCC

• keeping of a cockpit

Why is it hard to prosecute at the federal level

• Prosecution must demonstrate Mens Rea

• wilful neglect

• This would require a record of neglect, and animal cruelty often goes undetected

What is PAWS

• Ontario’s Provincial Animal Welfare Services Act

• Took 3 readings to pass

• Bans the breeding of wildlife (which was municpal jurisdiction before)

• Distress now includes the psychological state of animals, and animal behaviouralists are brought into courts

• Better training for inspectors of animal cruelty

• There are now higher maximum penalties for animal cruelty, like prison

What is a Critique of PAWS

• Definitional Issues

  • The legislation is very vague,

    • Like what is distress

  • However, if the language is made more specific, it would eliminate many cases from being prosecuted

• Warrants

• More explicit list of prohibitions

  • Prosecution sees patterns of animal crulty, which is why they want more definition, however judges also like the ambiguity so that they can interpret themselves

What factors are under the jurisdiction of municipal law

• Animal control and care

• Public health and safety issues

• Licensing, identification, breed bans, standards of care, exotic pet restrictions

• Business/commercial licensing (pet stores, breeding)

• Spaying/neutering

  • To control overpop, behavioural issues

• Permits

  • ex. only allowing 3 dogs per household, dogs must be tethered

Define Codes of Practice

• Concerned with farm animals, transportation, kennel, cattery, sled dogs, branding

• Permit lawful excuse

  • Situations that may cause an animal distress, but you are protected under the law

• Minimum industry standards are outlined

• The National Farm Animal Care Council (NFACC) is included/referenced in provincial legislation

What are the Pros of Provincial Legislation

• more commonly used than federal

• It is broad

• There is a lower burden of proof, with strict liability offences

• Cost of recovery/rescue is covered in some provinces

• There are standards of care that must be upheld

• Much cheaper and faster compared to federal route

Define Strict Liability Offences

• No mens rea is required, only actus reus to be proved guilty

• Accused cannot defend themselves

What are the Cons of Provincial Legislation

• Bc it is broader, it is harder to prosecute

• Strict liability often violates the accused’s right to defend himself

• A lower burden of proof means a lower sentence

What are the Pros of Federal Legislation

• Creates a ban from the accused owning an animal across all provinces

• Harsher penalty

  • Can be an indictable offence (fines and imprisonment)

• Able to lay charges under the CCC alone, through the RCMP

What are the Cons of Federal Legislation

• Youth Offenders Act

  • Complicates things, should the child really be punished or charged as an adult

• Higher burden of proof and more requisites

• Must prove mens rea and causation, and specific intent

• More costly and longer trial 

Define Causation

• Causation: Tight nexus between the defendants action and the crime

• Things that can differ causation: Novus Actus

  • Something happened in between that caused the result

Past Legislation

• Bill C27, Bill C-10B

• Bill C-15B - focused on individual acts of violence, does not solve any issues because it is so narrow

• Most of legislation has been human centred

  • It was very focused on killing animals without lawful purpose

    • This is problematic because lawful purpose is very vague term (critique)

    • This also creates definitional issues (critique)

• There is no moral status

• The interests of animals are only protected when there is human interest involved

  • EX. fishery laws, limits on fishing are so the food cycle is sustained

Which political parties are in support of animal rights?

• NDP and Liberal

Which political parties are against animal rights?

• Conservatives

• Specifically stray away from the humanisation of animals

Why do many bills die after readings?

• This is a pattern

• There is a lack of political will and no effort to get bills pushed through

What is the Role of Senators

• Pass, propose, reject bills

• Important role in scrutinizing

• Typically the senate wants more precise language, but that is problematic because it limits the amount of cases that can be prosecuted

• They are also wary of criminalising animal use industries

• They villify animal activists

Explain the Jane Goodall Act

• Introduced in 2022, first reading in 2023, process had been prolonged

• Bill was to protect animals kept in custody, and seeking to end animals for entertainment (zoos)

• Three categories of Zoos

  • Accredited zoos

    • Toronto Zoo

  • Unacredited zoos

    • African Lion Safari

  • Private ownership zoos

    • Roadside zoos

  • Trying to eliminate exploitation of animals for entertainment purposes

    • Only want accredited zoos, that perform the “highest standard of care”, conservation of animals 

    • AZA would remain open, as long as they continue highest standard of care, CAZA would shut down

    • Now CAZA organisations are trying to prove they are also providing conservation

    • Who would determines highest standard of care

      • The ministries

What are the Oppositions to the Expansion of Animal Rights?

• Humanisation → Animal rights

  • The more humanisation of animals, makes us give them greater rights, however animals cannot ask for them 

    • Colour of right

      • The legal doctrine to defend oneself

      • Creates a slippery slop, leading to inefficiency in court systems

    • Court backlog

• Complexities of Omnibus Bill

  • Radical modifications, removing animals from property, classification section of CCC, lumping provisions together instead of making new bills

• Criminalisation

  • To what extent do we want to criminalise industries

  • Economic interests of animal-use industries, targeted and wanted more precise clarification (ex. Brutal, vs unnecessary pain), branding practices

  • We use animals to test because they are cheapest

Reasons to Move Beyond the Status Quo

• Laws should reflect the will of the people

  • There is a public concern over needless harm

• Recognise the link of animal cruelty to human cruelty

  • People who abuse animals will eventually abuse humans

• Sentience

  • Current legal systems conceptualise animals as un-feeling entities

    • Animals feel and have psychological states

  • Concern with cattle exception - afforded greater protection (economic value)

  • Move to definition, replace animal with vertebrate other than a human being

Deontological Theory (Moral Theory)

• Non-consequentialist

• Developed as a reaction to Singer

  • It is necessary to affirm right

  • Is it sufficient to believe that animals are protected under the law, or should we move towards animal rights movements

• Equal Value Concept

  • Value of an animal in comparison to a human, can be equal but unique

• Moral agents (humans) and moral patients (animals)

  • Both have rights, humans have a moral obligation and choice, one is morally unnaccountable

Nature of Rights

• Legal rights are designated by the legal system

• Moral rights are universal

  • And automatically should be applied to all subjects of life

• Rational agency

• Kantian Perspective

Kantian Perspective

• Rights afforded to those with rational agency

• However, humans with little to no rationale (babies, disabled, cognitively impaired) are given rights but animals are not

Feminist Care

• In response to Singers Theory of Ethics

• Argues other theories are masculine in nature and preoccupied with scientific rationalism

• Concerned with the suffering of animals and how socio-cultural economic and political systems cause that suffering

• Adopts a situationist approach

  • Rejects dualist conception of humans as dominant

Utilitarianism Theory

• Started with Bentham

  • Moral calculations are necessary because animals feel pain

• It is fundamental to law and morality that humans are obligated not to inflict harm

• Predicated on the idea of minimal suffering, no unnecessary pain

• Animals should not be afforded rights, but consideration

• Singer supports the use of animals as long as the benefits outweigh the costs

  • Ex. animal experiments for producing life saving vaccines

Green Criminology

• Focuses on the harms against the environments, animals and humans committed by institutions and people

• Traditional criminology has ignored the effects of crime on animals

  • Animals are characterised as passive actors rather than moral patients

  • Traditional crim is speciesist 

Dogfighting

• Illegal in the US and UK

• Dates back to the romans

• Perceived as a victimless crime

• Level 1: Street Fights

  • Informal, occurs everyday, no rules or rewards

• Level 2: Hobbyists

  • Small audiences, organised fights, every few weeks, more training

• Level 3: Professional Dogmen

  • every few months, invite only, organised very well, elite sport, groups of people involved, high knowledge of the breeds and rules, dogs of “reputable bloodlines”, connection to the history, and view dogfighting as a tradition

• Motivations are to appear more masculine

• Dogs who act ‘cowardly’ are killed to prevent the passing of genes

• Breeding stand

• Harmful procedures to prep for fights

Critical Legal Theory

• Very little legal analysis of animal rights

• CLS promotes a greater theorization of animal rights

• CLS calls for a more precise, contextualized articulation of legal animal rights

• Areas that require attention:

  • Importational of morality

    • moral rights do not create protections for animals

    • We need codification and enforcement

  • Rights growing from laws that already exist

• Move away from interpretive laws

• CLS differentiates simple rights from fundamental rights 

  • Simple: can be infringed easily

  • Fundamental: hard to infringe, correlates with humans

    • ex. right to life, bodily integrity, freedom from unnecessary pain

    • Legal advantages of fundamental rights:

      • Procedural

      • Substantive

      • Transformative

Procedural Advantage

• Can achieve standing and improve the enforcement problem (or lack of)

• Enforcement would become decentralised

• Requires access to justice to invoke such rights and procedrual protection and legal right hood is the vehicle

Substantive Advantage

• Codify interests and rights

• Legal protections

  • Equality, substantive guarantees, elevating burden to those who commit infringements

• Eliminate weak justifications for harm, and uphold proportionality

  • we could shut down industries if we allow animal rights

Transformative

• Builds a legal infrastructure that permits increments of change

  • Slow change to avoid slippery slopes

• Progressive realisation

• The law transforming towards animal rights

• Building animal rights into the law

What are the types of animal abuse

• Simple neglect

  • Interventions, most common

• Abandonment

  • Difficult to bring forward charges

• Hoarding

  • Most complex, recidivism

  • Most common

  • Hard to prove wilfulness because it is a mental illness, can please NCR

• Substandard Breeding

  • Puppy/kitten mills

• Intentional Abuse/Harm

  • Easier to prosecute than neglect or hoarding

  • Sentience is recognised when there are visible injuries that can be recorded

  • Expert witness vets

• Fighting

  • S447, difficult to investigate/prosecute

  • No proof without witnesses

• Beastiality

  • CC 160

  • Not common because these cases go undetected

  • Animal cannot provide consent (this is recognised in fed & prov leg)

  • Linked to child sexual abuse

• Agro

  • Codes of practice used to regulate

  • Hard to go after these groups if they are well funded

What is the Role of the SPCA

• Prov jurisdiction

• Powers are derived from PAWS (each province has their own)

• Underfunded and underresourced

  • Relies on charity, not government funding

  • Patchwork funding

  • Delayed responses

How is Manitoba different from other provinces

• Manitoba is funded through state funding

• Complaint driven (reactive) system

• the Chief Vet Office (CVO) manages animal protection sector and has the power to appoint APO’s

• Quasi Legal Actors

  • APO’s have 8 hours of training

  • Can lay charges under prov legislation

  • police can lay charges under federal CC

    • There must be mens rea

• Relies on a mix of funding support for APO’s (animal protection officers)

  • They are funded through patchwork

  • In Manitoba 60% of APO’s are internal workers, well funded

    • The other 40% are externally contracted

      • Contract culture: less responsibility, begins and ends with contract, individuals know there is an end contact date, they are only being paid for a certain capacity, which then impacts their dedication to work

  • Strong workforce compared to other provinces

  • Manitoba is an outlier, and researchers suggest we should follow this model

    • Provincial government fully supports animal rights

What is a critique of the Manitoba case study

• Increased training

  • Dangerous job, not enough training

• Partnerships

  • Not in law enforcement, if you want to seize an animal, you must get a warrant

  • Police should be trained in animal welfare, so they can work with the SPCA

Purpose of investigations

• Assist animal, decrease distress

  • As indicated by manitoba study, act 2 I A

    • Food and water provision most common issue, canines

  • 2nd most common, heat and cold

    • Providing sufficient shelter for animals

What are some of the options provided to an APO

• Desistance and deterrence

  • Curb, and stop a re-offence

    • In Manitoba, they will ask for mandate, a change in behaviour

      • If there has not been improvement or compliance, 

      • They will wait for a change in behavior, then seize the animal, and then apply charges

What is information gathering

• Intel

• You must build a record, history, and put together as must evidence as possible, because animal rights cases are not taken seriously in courts

  • This is key to enforcement

  • Vet reports, eyewitness testimony, photographs

Warrants

• Must obtain consent in order to enter someone’s property unless there is a direct observation of distress

  • From owner of property

  • Exigent circumstances - see distress that needs immediate attention

• Owners are given an initial opportunity to relieve distress

• If the owner complies, there will be no more action

• If an individual is non-compliant, you must obtain a warrant for seizure

  • When seized, the animal will become evidence

    • There must be reasonable grounds, that the animal is in distress

The Problem with Warrants

• Used under the CCC but not for animals

  • Seizing an animal applies as though you have seized property

• Could contravene S8 of the Charter

  • Unreasonable search and seizure

• Animals will be seized and kept as ‘evidence’

  • Similar to fingerprints, rape kits

  • Means that the animal will not be cared for, but rather quarantined to preserve evidence

• Under PAWS, warrants can be granted for removal

  • Adoption, fostering

  • Civil system and conflict over seizures of property may take place at the same time as the cruelty case

• What do you do with the animal?

  • There is a cost for adoption and fostering

• If you're seizing ‘property’ there may be both a civil and criminal case

When can you seize an animal

• Failure to relieve distress after reasonable time

  • Ambiguous term

• Environment is causing distress

• Immediate action to remove the animal from critical/present distress

• The use of are agreements are required if the SPCA returns the animal to the owner

  • Can be problematic, because how would they be enforced, and may go undetected

Once an animal is seized, what does the SPCA have the power to do?

• Keep an animal in custody if convection upheld

• Adopt, sell the animal

• Demand owner to pay costs associated with seizure

• Courts will demand restitution payments from offenders

  • Ikea Monkey $83000

Explain Mandated Reporting

• Vets are mandated to report suspected neglect/abuse

• Vets and Vet Techs are granted in unity

  • They cannot be prosecuted, so this makes them unafraid to report anything

• When animals are held, it is up to the discretion of the vet (for a reasonable time without unreasonable delay)

What are some problems with warrants

• Used under CCC but not for animals, rather for property

  • Could contravene S8 of the Charter (unreasonable search and seizure)

• Animals will be seized and kept as evidence

• Under PAWS, warrants can be granted for removal

  • Adoption, fostering

  • Civil system and conflict over seizures of property make take place at the same time as  a cruelty case

How are charges laid

• Every province has their own legislation

• 3 options: PAWS, CCC, or both (if there are multiple charges common and necessary)

• Courts and judges want to see if there are multiple charges and if this is recurring, so there is weight to the case

• PAWS - for minor violations

  • Failure to provide potable water (minor neglect)

  • If there is an investigation, and the owner  changes their habits then there won't be a case

• When charging under PAWS and CCC, prosecution should arrange a plea bargain with the provincial law

  • A way of securing some kind of conviction

• CCC is reserved for serious crimes (violence)

  • High Recetivism rates 

• Concurrence with other serious crimes, and bring one massive complaint forward, that carries weight

  • Tactical value, strategy used by lawyers

How are charges assessed

• Prosecution should take into consideration the 

  1. Likelihood of conviction when determining which charges to lay

  2. Public interest

     • Vulnerability of victims

     • Dependency on owners/humans

     • Harsh penalties are available to the court

     • Formal responses required to ensure sentences such as pet bans

       • Difficult to enforce

     • Protection from future violence and re-offending

       • Must assess risk

Burden of Proof and Defences

• The concept of likelihood of conviction 

  • is there sufficient evidence and can one defend themselves

Inviable Defences (cannot use)

• I cannot afford vet care

• I didn't mean to hurt him

• I had to kill the dog to save my hens

• I killed the dog because it looked like it was about to attack

• Those animals aren't mine

What are the requisites under the law

R v Greenley

• He started strangling the dog until it stopped struggling, rather than stopping the strangling, Greenley continued until the dog was clearly dead

• Actus reus is present because of the omission

  • The failure to act, and wilfully applying pressure

• Colour of Right

  • Doctrine used in self defence cases

  • Who has the right to end an animals life

• Legislation

  • CC 445 - offence of killing via strangulation until death

• Held: Greenely was convicted, it was clear that Greenley initially had the right to use force against the dog to prevent it from continuing to attack him when he met Roche at the front door

• Continuing to strangle the dog was not a reasonable or justifiable course of action

What was Greenley’s Sentence?

Greenley’s Sentence

• Conditional Discharge 

• 1 Year probation

• $50 fine

What are some factors for the prosecution to consider

• Length of trial, access to representation, other party if difficult 

• Not uncommon for prosecution and defence to work together to come up with a solution

  • Criminal case would have discovery

  • Pre-trial conference - they don't want to go to trial, go behind chambers and assess inculpatory and culpatory and see if they can avoid trial

• Experts are costly

• Complexity of cases

  • Ex. hoarding, mental health, anything that would influence a prosecutor from moving forward

How are charges approved?

• 1 count per offence, not per animal

• Avoid strict or precise language in order to not limit the way in which the offence can be proven

• Charge from initial offence - show history to courts (seizure of animal by SPCA)

• Limitation dates for laying charges are stricter for summary offences (6M)

  • Statute of limitations, would be done to prevent backlog, efficiency, bad memory, preservation of evidence, constitutional challenges - can only place someone in remand for certain time

• Solution - proceed by indictment if the end of the offence date range has passed 6 months and it is a serious crime

Crucial Elements of an Offence

• Mens Rea 

• Intent under CC

• Wilfully S429 (Recklessness, act or omission)

• Do not have to prove malice or that offender knew animal was suffering or that the accused intended for the animal to suffer

• Standards: objective predictability, and reasonable person standard

Define Mens Rea

• Intent under CC

• Wilfully under S429

• Do not have to prove malice or that

• Standards: objective predictability 

  • Consistency between cases in terms of disposition/sentencing

  • Apply tests, doctrines, in order to find out the standard of care, evaluate whether the person is guilty 

• Standards: Reasonable person

  • Would a reasonable person foresee the consequences of their actions 

Define Objective Predictibility

• Consistency between cases in terms of sentencing

• Apply doctrines, tests to find out the standard of care and evaluate whether the person is guilty

Define Reasonable Person

• Would a reasonable person foresee the consequences of their actions

Define Actus Reus

• Proof of injury or death, unnecessary pain, administering poison, neglect

• This is needed for the actus reus component

  • EX. SPCA conducts an investigation, they have rights to cease carcasses, pens, anything that will demonstrate actus reus

What is a critique of PAWS

• Focuses on concept and legal requisite of distress

  • Wide ranging definition of distress

    • For example, potable water

• What constitutes distress depends on the situation

  • Vague language was used to allow for discretion, so that investigate powers may exercise based on what they see

    • This is why it is wide range in terms of distress

    • A narrow definition of distress would exclude many cases, unable to proceed bc it does not fit the definition

• Trying to proceed criminally, you would have to show the mens rea component

What are the principles of sentencing

• Denounce and deter behaviour

• Curve recidivism

• Pet bans may work temporarily, but often owners go back to abusing animals after it is over

What happened in 2008

• increase in max sentence and hybrid

  • Prior to this courts did not recognise that animals felt psychological pain and sentient

  • Legislation intent → shift to harsher penalties

    • EX. in cases of injury and death, jail term even if 1st offence

  • When we create laws and look back on the effectiveness of them, we would typically look to the logic, rationale, and if it is achieving its objective

  • This shift has moved toward more prosecution and harsher penalties

    • Does not necessarily mean that judges are dispensing harsh penalties 

  • Injury/death of animal means prison time, even if it was a first offence 

    • However, you really have to build a strong case

  • Typically jail is not for long periods (1-2 years plus a fine) unless its killing a canine 

Factors of Sentencing

• Relevant Legislation

• Mitigating factors

• Aggravating

• Ban option should be considered

  • Joint submission can be used to move a trial faster

• Place a number of animals and inspection provision (without notice)

• Restitution to SPCA for seized animals

  • Ikea monkey

    • Pay back money to the court for pro bono fees

    • Takes a lot of money to seize animals, etc

    • So money must go back into the system

• Precendent

  • Refer to case law

  • NCPAC

    • Database where they can keep track of cases

  • Important if trying to cultivate an environment of reform

    • Helps to have prior knowledge to use as rationalization for better sentencing

What are mitigating factors in sentencing

• youth

• colour of right

• mental state

What are aggravating factors of sentencing

• criminal record

• history of violence

What is patchwork

What is a piecemeal framework

• It creates a breakdown of functions and there is a lack of discipline