Download Women, Justice and Law

Women, Justice & Law
by Rajeshree Dutta Kumar
Introduction
The demand that women should have the same social and legal status, with due
recognition to their differences, has long been central to women’s struggle. The core
and central concern of feminist politics has been to overcome the problem of gender
asymmetries that result in discrimination, subordination and oppression in various
forms. Feminists have politicised sexual difference, arguing that women’s
subordination is not an inevitable natural destiny but the result of an institutionalised
social hierarchy called gender. Feminists have demonstrated how the range of
gendered behaviour cannot plausibly be understood as biologically ordained and
inescapable but must be the product of interlocking social forces.
Feminist Politics, Justice and Law
Women have always found themselves to be systematically excluded from dominant
traditional theories. The reasons for this are many. They have been traditionally
associated with the private sphere, on which the liberal theories of justice do not
operate. Sometimes women have been excluded on the plea that they could not be
seen as a coherent identity. Therefore, women need to direct their theoretical attention
to patriarchal discourses, those that have been openly hostile to and aggressive about
women and the feminine.
1
Women seem to be largely preoccupied with their inclusion in those spheres,
from which they have been excluded by creating representations, which would enable
them to be regarded as men’s equal. Their inclusion meant that the issues concerning
women’ lives- the family, sexuality, the private or domestic sphere, interpersonal
relations- be included. Though they have gained ground in the struggle for equality,
serious challenges still remain. The inclusion of women in theories is not simply
possible, as the patriarchal discourses seemed incapable of being broadened or
extended to include women without major upheavals and transformations. There
would hardly be any space to accommodate women’s inclusion and equal
participation.
The project of women’s equal inclusion further appears to be women’s
sameness to men, only women’s humanity and not their womanliness. Women’s
inclusion entails entering into a zone, the norms of which are based on masculine and
patriarchal patterns. Not only this, women’s sameness to men also entails a complete
neglect of women’s specificities and their being different. On the other hand, a
profound look into the unfavourable attitude of society towards women reveals that
gender inequality is deeply entrenched in policies, legislation and social institutions.
Our social, political and legal institutions have been increasingly faced with issues
concerning the injustices of gender and their effects. These issues are being decided
within a fundamentally patriarchal system, founded in a tradition in which
‘individuals’ are assumed to be the male heads of households.
Since the forces that shape gender operate across both the traditional public
spheres of politics, law, church, and economy, and the private sphere of sexual and
domestic life, feminist arguments challenge the traditional boundaries of the political.
2
Power relations permeate domestic life, diminishing women’s public power and
opportunities. At the same time, these domestic hierarchies are legally defined and
maintained. Attention to gender thus reveals complex interpenetration of public and
private. The slogan ‘the personal is political’, summarizes a broad range of feminist
arguments that redescribes sexual difference as gender hierarchy and criticize the
existing hierarchy as unjust.
Feminists struggle for equality affirms women’s potential for equal
intelligence, ability, and social value. The idea behind it is to eliminate or restructure
the social constraints imposed on women because the ‘raw materials’ of socialization
are fundamentally the same for both the sexes. If the two sexes could be re-socialized,
if their social roles could be readjusted or restructured, they could be rendered equal.
The difference between the sexes would no more be significant. Effective strategies
for gender equality require a reassessment of ends as well as means. The ultimate goal
is not simply to ensure women’s full participation in organizations that wield social,
economic and political power; it is rather to change the nature of those organizations
and the way power is distributed and exercised. Our priority should be to empower
women as well as men to reshape the institutions that are shaping them. At issue is not
simply the equality between the sexes, but the quality of life for both of them.
But those who believe that the difference should be acknowledged argue that
the project of sexual equality takes male achievements, values, and standards as the
norm for which women should also aspire. Women are treated as equals with men so
far as the underlying system and its power relations remain unquestioned. In order to
achieve equality between the sexes, women’s specific needs and interests- what
distinguishes them from men- are minimized and their commonness or humanity
3
emphasized. Policies and laws codifying women’s legal rights to equality- antidiscriminatory and equal opportunity legislation- have tended to operate against
women. It is thus a discontentment within the politics of equality that leads us to the
demand for the acknowledgement and recognition of the difference. Therefore, we
should not see the problem of equality and difference as conflicting or dichotomous,
but as congruent and in harmony with each other.
The study undertakes to explore the conflicts of equality and difference
concerning women in the context of the patriarchal theories of justice and law. The
central focus would be on the apparent pretence of neutrality in the theories of justice
and law. The reason for taking up justice and law is that we are contesting constantly
the need for justice and law in our day-to-day lives. Hence our endeavor would be to
unfold the patriarchal character of justice and law by articulating the implicit, tacit,
and nontheorized experiences of women and to take them to the level of theory with
the help of the model of care ethics and the discourse model. By articulating the
female experience, we not only engage in a critique of theory, but we also contribute
to the process of transforming women’s consciousness by giving female activities and
experiences public presence and legitimacy.
The study is concerned with the politics of equality and difference and the
surrounding claims that theories of justice and law have been cognitively inadequate
because of their biased nature towards gender. The reason behind this is that they
have failed to take into account the standpoint, the activities, and the experiences of
women. This gender bias or blindness is not an accidental omission but a deliberate
one, which in turn affects the cognitive plausibility of these theories. Now, if we have
to correct this problem we need to identify sets of experiences, activities, as well as
4
patterns of thinking, feeling, and acting which can be characterized and known as the
domain of women. Further, such experiences, activities, and the like are the
consequence of women’s social position or of their position within the sexual division
of labour. Whereas male individuals have been active in the public sphere of
production and politics, women’s activities by and large and throughout history have
been confined to the ‘domestic/reproductive’ and private spheres.
Both the theories, justice and law, refer to the ‘public’ realm, where adult men
deal with other adult men in accordance with conventions, mutually agreed upon.
Familial relationships, on the other hand, are ‘private’, governed by natural instinct or
sympathy. Though superficial appearances can easily lead to the impression that the
theories of justice and law are inclusive of women, in reality, they continue the same
tradition of ‘separate spheres’ by ignoring the family, its division of labour, and the
related economic dependency and restricted opportunities of most women.
Women must reconsider their engagement with the language of law. There is
growing feminist unease at the interface of the law with sexuality. The failure of the
law to deliver justice in feminist terms is understood to be a result of the interpretation
of the law in sexist ways, so that law’s capacity to be just would be freed from the
biases of individuals. The study tries to show that the existing theories of justice and
law are inadequate from the perspective of feminist understanding. They fail to
recognize women’s needs or articulate their experiences. They express a limited, male
perspective and are, thus, a source of and reflection of men’s patriarchal power. The
justice theory and the concept of law, being universal in character, always consider
abstract individuals as their subjects of inquiry and knowledge. This leaves women
5
altogether within a different sphere as their problems are specific, particular and
contextual.
Women continue to believe that the law can be used to achieve their goal.
However, it is argued that the law is inherently biased against women and that it fails
to recognise women’s needs or articulate their experiences. Feminists have to contest
the current problem within the framework of justice and law. We must seek to
validate women’s experiences and differences as new starting points for equality
analysis. There is a need for a new framework for law that takes serious account of
difference, including that of gender and the social relations it entails. The neglect of
gender, even in critical approaches to the law, must be examined. Along with the
acknowledgement of differences, we should challenge and emphasize the systematic
gender-based oppression and subordination embedded in both social structures and
available legal rules.
It is, however, argued that the insistence on emphasizing the plural nature of
women’s experience is destructive to legal feminism. The fact that women do not
have a uniform experience raises the question of whether we can continue to rely on
the category of woman in our analyses. The answer could be: instead of
conceptualizing woman as a monist category, it is possible to understand it in terms of
plurality. As a woman, an individual’s identity is constructed not only by sex but also
by class, ethnicity, minority status, religion, and various factors. This enables us to
capture the relative significance of these factors in an active manner. Their
significance is not fixed but varies with social, historical, and economic contexts as
well as the social phenomena being considered. It is possible to emphasize some
aspects of our identity in one context and other aspects in other contexts. However,
6
which aspect of one’s identity is more relevant in a given context has to be a matter of
self- determination. The justification for a multiplicity of perspectives is that it does
not valorize the domination of any one.
The concept of law generally emphasizes the role of law reform in changing
the position of women or even ending the oppression of women. These claims are
premised on the assumption that it is only when the legal system ceases
discriminating against women in granting formal rights, it can help women to
overcome their oppression. The contemporary legal status of women in most countries
is a result of the initial efforts and struggles of liberals for formal legal equality, which
is not sufficient. We have to demonstrate the male bias inherent in law’s basic
assumptions and concepts. We should seek to expand the parameters of legal
knowledge by relating the experiences of women to conventional jurisprudential
issues.
Catharine MacKinnon1 argues that emphasizing the so-called positive qualities
of women is dangerous because it reinforces women’s submissiveness. She notes that
the history of women’s oppression is replete with examples of the ‘special’
characteristics of women being used to justify their subjugation. In contemporary
societies, women’s experience is one of overwhelming domination. It is thus not
useful to pretend that if law made no distinction on the basis of gender, everything
would be all right. Although there are varied opinions amongst legal feminists and
they may usually be depicted as distinct and possibly mutually incompatible, the
ultimate goal of all of them is to achieve parity between men and women.
1
Catherine MacKinnon. 1987. Feminism Unmodified: Discourses on Life and Law. Cambridge MA:
Harvard University Press, 1987. Also see, Catherine MacKinnon. 1993. Only Words. Cambridge, MA:
Harvard University Press.
7
All of these views rely on different concepts of ‘woman’ and different
assumptions about the nature of women. The category ‘woman’ as an analytical
device is as undeniably important for legal feminists as for all feminists. However,
feminists need to articulate the manner in which ‘woman’ is constructed. If, as argued
by many legal feminists, experience is the source of knowledge, it becomes
imperative to discuss whether a universal feminine experience can be identified. A
related issue is whether the questions depend partially on the purpose of the analysis.
For instance, different conceptions apply depending in part on whether one relies on
the category ‘woman’ to expose and rectify the male bias of legal concepts; to give
expression to lived experiences and shared views of sections of communities silenced
until now; to devise appropriate political strategies to transform the legal and social
systems and create a genuinely non-oppressive society.
However, there is considerable scope for expanding the notion of law that
avoids the limitation of a linear understanding of women based exclusively on gender
oppression. We need to use women’s diversity as the starting point: it can offer the
possibility of understanding not only where women are located in different
relationships of power with men but also how women’s differences determine where
they are located in relationships of power with other women. Recognizing the
multiplicity of women’s experiences, that is, how race, religion, sexual identity,
marital status, caste and class mediate women’s experiences of gender, enable us to
deconstruct law’s hegemonic understanding of the world and provide spaces for
alternative understandings or perspectives to be included. It will create the possibility
of formulating more specific legal and non-legal strategies to challenge the different
ways in which women are subordinated.
8
Catherine MacKinnon argues that liberalism supports state intervention on
behalf of women as abstract persons with abstract rights, while in reality the state is
patriarchal in the feminist sense. Abstract rights authorize only the male experience of
the world. She sees the state as embodying and ensuring male control over female
sexuality even while it juridically prohibits excesses. Her critique of the law and her
understanding of gender as domination of women by men has certainly served the
purpose of radically questioning the myth of the neutrality of law which continues to
have a powerful hold over feminist imagination. Yet she herself makes law the focus
of her feminist politics.
Modern legal systems are marked by a quest for certainty, consistence and
uniformity. However, law when interpreted, reflects social and individual biases and
is thus distorted from its purpose of neutral arbitration in the interests of social justice.
This understanding has been attacked from within feminism for reinstating the
assumption that biases and prejudices are external to the law. They argue that law
proceeding from its parliamentary source is just and untainted by the values that
influence individual judges.
Further, the fixity of meaning required by legal discourse has generated a
dilemma. When ‘equality before the law’ is interpreted as men and women being the
same as each other, courts do not uphold any legislation intended either to compensate
for past discrimination or to take into account gender specific differences like
maternity. Treating ourselves as gender-neutral persons can only marginalize us and
devalidate our experience. Nevertheless, the approach that puts emphasis on the
recognition of difference denies women the claim to equality altogether.
9
In other words, feminists seeking social justice through law have come up
against the limits set by the criterion that law be uniform and consistent. It can either
recognize sameness that disadvantages women or the difference that justifies
discrimination. Either way women find the law written and interpreted from a male
point of view based on male experiences of reality.
The legal sanctions and
administrative structures are perceived as alternative means of controlling women’s
behaviour.
Feminists share the assumption that inequalities between the sexes are deeply
embedded in law. They believe that even benign discrimination, such as protective
laws for women or affirmative action, do not contribute to real equality. Mackinnon
develops a theory of feminism based on the premise that in a world based on gender
hierarchy, men view themselves as knowing subjects, while viewing women as
objects. The law and the apparatus of the state reflect this relationship. Constitutional
rights are an inadequate protection against male dominance because most of the
injuries done to women are done by private individuals and constitutional rights only
protect individuals against harms caused by state. We must call for a feminist
jurisprudence to create new theories of the relationship between life and law.
Catherine MacKinnon identifies sexual objectification as the most important aspect of
women’s oppression. It follows that the appropriate objective of legal feminism is to
prevent sexual objectification. However, in third world countries, woman in addition
to sexual objectification has to protect herself against physical abuse, save herself
from being burnt alive for bringing inadequate dowry, prevent herself from being
turned out of her house with nowhere to go and no social security system to fall back
upon, or avoid starvation for herself and her children.
10
We shall explore the place of law within feminist politics in a constitutional
democracy. We begin with the general perception that society is steeped in patriarchal
values and practices, and that the law and the state are seen as the only agents with the
power and legitimacy to bring about egalitarian social transformation. Our efforts
should be to see if we can formulate a framework which ensures that the
discriminatory nature of particular laws is redressed and to create new laws in areas of
judicial void. Law cannot play the role of an emancipatory force for the upliftment of
women’s conditions. Hence, comes the idea that law is not enough. The constant
recourse to law creates a series of new legislations that often mean the increase of
state control, while the implementation remains unsatisfactory. But recourse to law
can also be considered as a substitute for the other harder option of building a
movement for an alternative vision.
The final objective of feminist politics is to have women as freely acting
subjects. But the present subject of such politics is either constrained by oppressive
power relations or produced by asymmetrical power relations. In both the cases we
cannot have a subject who can actually exercise her free will. While conforming to
legal and state-centred conceptions of political practice, we also need to think
creatively about newer forms of political engagement that are located in realms we
have not seriously engaged with.
In this study our effort has been to explore the relationship between morality and
legality from a feminist perspective. The concept of justice, as we know, has been
central to feminist moral discourse and politics. Women’s struggles for gender justice
have extended and deepened the very idea of rights, and these rights have come to be
enshrined in the legal system. However, feminist criticism has unmasked the apparent
11
neutrality of the available conceptions of justice and law. The prevailing notions of
justice have been shown to be rooted in patriarchal conceptions of morality. The
existing legal systems are based on conceptions of law that hide oppressive patriarchal
structures of power.
The patriarchal conceptions of justice have failed to meet the often-conflicting
demands of equality and difference raised by women’s movements. The modern
formal system of law understands itself as an expert domain increasingly doing away
with the need for grounding in morality.
On the one hand, feminist struggles
understand themselves as struggles for justice, articulate their claims as claims of
right and seek to enshrine these rights in the legal system. On the other, the universal
claims of justice and law are shown to be hiding particular interests. This papaer is an
attempt to solve this paradox by reformulating the concepts of justice and law in the
light of recent feminist criticism. Once we make these concepts gender-sensitive, we
can rethink their relationship in a manner that ensures that the possibilities of a
democratic feminist politics remain open.
Feminist criticism of available notions of justice and law has led some to the
rejection of the normative grounding of feminist politics in justice and also to treating
law as a strategic or pragmatic manner for the advantage of women. We shall argue
that justice is an indispensable concept for feminism. However, we agree with the
critics that the available conceptions of justice based on formal equality do not allow
the articulation of gender difference and make themselves vulnerable to patriarchal
appropriation. Even in an ideal society where the formal equality of all is realised,
certain moral claims of women will remain unheard. Such claims can only be made in
the distinct voices of women.
This thesis is an attempt to work out a more
12
encompassing and gender sensitive notion of justice that will recognise and include
these moral claims as claims of justice. That the claims of women make a difference
to justice can be acknowledged without falling into any essentialist notion of
‘woman’. Such a reworked concept of justice enables us to refigure the relationship
between morality and legality without invoking any strong notion of foundationalism
but at the same time going beyond the liberal and social welfare paradigms of law.
Part I
We shall propose that among the available conceptions of justice, John Rawls’s2
theory of justice as fairness comes closest in capturing the moral and political
aspirations of feminism. Within a liberal framework, it combines the demands for
equality and difference. It ensures equal distribution of rights and liberties while
explicitly addressing the unequal status of disadvantaged sections like women.
Moreover, Rawls rejects metaphysical and moral foundations for his theory of justice
and seeks a political grounding. However, Rawls’s theory of justice has been
subjected to severe criticism. We shall provide a detailed discussion of the prominent
criticisms of Rawls. They unearth two weak points in his notion of justice. Firstly,
disembodied moral subjects in the stipulated original position fail to represent the
moral concerns of women and their lived experience as a marginalized section of
humanity. While the formal subject does secure formal equality it hides the concrete
differences that make women what they are. Secondly, Rawlsian presupposition of the
family as essentially just, has failed to address the question of injustice within the
institution of family. A feminist theory of justice demands a situated and embodied
2
John Rawls. 1971. A Theory of Justice. Cambridge, MA: Harvard University Press.
13
moral subject and explicit acknowledgement of the ethical issues within family. Such
an ethics affirms universality which is not formal but concrete. It also questions the
distinction between the public and private spheres and explicitly addresses the ethical
issues embedded in the private that has so far been kept off the purview of a theory of
justice.
Part II
Care ethics proposes a moral framework that offers to meet the feminist demand for
an embodied moral subject and takes up the mother child relationship as a
paradigmatic moral situation. Care ethics, as proposed by Carol Gilligan, 3 brings out
the distinct voice of women to moral thinking and opens up moral subjectivity to their
lived experience. However, care ethics, at least in its well-known formulations, has
placed itself as an alternative to a morality of justice. The present work argues against
this dichotomy. While the theory of justice needs to accept the embodied moral
subject capable of emotional attachments, the ethics of care should open itself to the
question of justice so that it can respond to the claims of rights posed by women’s
struggles. In Seyla Benhabib’s4 reformulation of Jurgen Habermas’s5 discourse ethics
we find the possibility of a frame work which can negotiate between justice and care
and also create an opening to rethink the relationship between morality and law from
a feminist perspective.
Carol Gilligan. 1982. In a Different Voice: Psychological Theory and Women’s Development.
Cambridge, MA: Harvard University Press.
4
Seyla Benhabib. 1992. Situating the Self: Gender, Community and Postmodernism in Contemporary
Ethics. New York: Routledge.
5
Jurgen Habermas. 1996. Between Facts and Norms: Contribution to a Discourse Theory of Law and
Democracy. Cambridge UK: Polity Press.
3
14
Part III
Discourse/communicative ethics, as proposed by Habermas, emphasises the
intersubjective and linguistic processes involved in the constitution of identity and,
also the social grounding of norms within discourse. In discourse, Habermas sees the
possibility of a morality rooted in human linguistic and cognitive competence. The
social and political institutionalization of this competence, according to him, is a
historical achievement of humanity in concrete contexts. Thus, his discourse model
retains an emphasis on universality while conceiving moral agents to be historically
situated, intersubjectively constituted and norms to be socially generated and
discursively testable.
However, Habermas’s discourse model has not succeeded in meeting all some
feminist aspirations. While discourse ethics is articulated as universally applicable, it
reflects a gendered world. Feminist critics argue that the formal and procedural nature
of discourse ethics, its emphasis on the public sphere, and the restricted nature of
discursive language it presupposes, serves to exclude from moral scrutiny many
questions of special concern to women.
Seyla Benhabib has reformulated Habermas’s discourse ethics from a feminist
perspective to identify gender injustices and to conceptualize more emancipatory
social and political relationships. She presents an ethics of discourse in such a way
that there can be no moral prejudgment that does not decide which aspects of a person
are relevant to the situation, and that does not acknowledge the specific parameters of
the situation at hand. According to her, for the growth of moral perspective and
development of interactional structure, both the standpoints of the generalized other
15
and concrete other are significant. Further, only when practical discourse has no
limitations in advance can the perception of the other in her concrete individuality and
concrete needs be guaranteed. Benhabib further contends that moral judgment should
involve enlarged thinking or reciprocal recognition, the ability to reverse perspectives
with others in order to see the world as they see it.
She claims that discourse ethics should be based on a conversational model of
enlarged thinking that makes it possible for a universalist ethical perspective to
incorporate concrete experiences of women as situated, while retaining its desirable
universalism. The validity of a moral theory is based on the recognition of the dignity
of the generalized other through an acknowledgement of the moral identity of the
concrete other. Here, we do not juxtapose the generalized other and the concrete other
or see normative validity exclusively in one or another standpoint but try to think
through the ideological limitations and biases that arise in the discourse of universalist
morality. With the help of contemporary feminist critics, the thesis tries to strengthen
Benhabib’s discourse model which creates an opening for a new relationship between
law and morality. We use a revised and strengthened version of Benhabib’s discourse
model to study the relationship between morality and law.
Part IV
Habermas’s theory of law can be seen as a major attempt to explore the relationship
between law and morality. A basic component of his legal theory is his analysis of the
relationship between the two. On the one hand, law is to be considered as a functional
complement of morality. It institutionalizes morality by means of reducing
uncertainties about what is prescribed to be done. On the other hand, the fact that law
16
is to be seen as an institutionalization of morality, explains that we have to describe
law as impregnated by morality. The role of law towards morality subjects law to a
continuous questioning of its legitimacy from the view point of its legal subjects.
Since law is seen as an instrument of authority and also a source of social integration,
it must be autonomous from morality. Its validity must be different from that of
morality. If this is not the case then law grounded in morality will produce
uncertainties in moral argumentation.
Habermas proposes his notion of procedural law against the existing liberal
paradigm and the social welfare paradigm. The thesis strengthens and enlarges
Habermas’s concept of procedural law by bringing out the weaknesses of the liberal
paradigm and the social welfare paradigm, both of which will be discussed
subsequently in the study. However, feminists have been critical of these paradigms
arguing that they perpetuate real inequalities.
According to the procedural concept of law, legitimacy of lawmaking lies in
an institutionalized procedure that converts citizens’ participatory rights into the
binding decision of political power through communication. Habermas sees modern
law as a system of rights comprised of a set of abstract rights recognized by all
citizens in the form of the constitution or moral codes. Viewed as a system of rights,
modern law brings together popular sovereignty and human rights, showing the cooriginality of private and public autonomy.
The individual rights that are meant to guarantee to women, the autonomy to
pursue their lives in the private sphere cannot even be adequately formulated unless
the affected persons themselves first articulate and justify in public debate, those
17
aspects that are relevant to equal or unequal treatment in typical cases. The private
autonomy of equally entitled citizens can be secured only in so far as citizens actively
exercise their civic autonomy. Thus, Habermas tries to base his notion of law on a
communicative structure.
However, Habermas attaches far too much importance to public autonomy
neglecting the pursuit of private autonomy of individuals. This makes Habermas’s
proceduralism unable to recognize the plurality of heterogeneous claims to selfrealizing autonomy by women. Further, according to Habermas, a legal order is
legitimate to the extent that it equally secures the co-original private and political
autonomy of its citizens; at the same time, however, it owes its legitimacy to the
forms of communication in which alone this legitimacy can express and prove itself.
The normative burden, hence, shifts from the competence of legal persons to the
forms of communication. Habermas describes that the law translates ordinary
language into specialised codes that are recognisable to the parties in the
parliamentary
democracy.
This
transformation
of
ordinary
language
into
institutionalised language requires a level of abstraction to which different particular
and specific linguistic expressions are expected to reach. We believe that language, if
not sufficiently, at least adequately represents our distinct forms of life and our
cultural diversity. This language is being tampered with in order to equip it to meet
the level of abstraction. Since our lives and specific experiences are embedded in
language, therefore somewhere down the line our specific experiences get ignored at
the cost of Habermas’s universalist demand for abstraction in language. Women are
the worst sufferers of the universalist nature of law and legal discourse.
18
Part V
To conclude, we shall propose that women’s moral judgment is more contextual,
more immersed in the details of relationships and narratives. The contextuality,
narrativity, and specificity of women’s moral judgment is not a sign of weakness or
deficiency but a manifestation of a vision of their moral maturity According to this
vision, the respect for each other’s needs and the mutuality of efforts sustain moral
growth and development. The need, therefore, is of a morality in which care occupies
a central position since this will not relegate its links with legality entirely to the
public domain. A care based morality demands that we think of law not merely in
terms of punishing and reforming institutions but also in terms of caring and
supporting ones.
19