Human Rights Act 1998 Balancing ECHR Rights

The Human Rights Act 1998 does achieve the goal of making the ECHR rights ‘effective’ in the United Kingdom while also ‘preserving’ the sovereignty of Parliament. The goals are met in the following way. The first goal is achieved because through the enactment of the Act, the ECHR rights become directly applicable in the UK by becoming statutory rights. In order to strengthen the scheme of protection of the ECHR rights through the Human Rights Act 1998, Section 4 provides the courts in the UK with the power to declare incompatibility between the provisions of any law made in the UK and the ECHR rights. This was essential to make the ECHR rights effective in the UK because otherwise primary legislation is outside the scope of judicial review. Furthermore, Section 6 requires that the actions of the public authorities must be in accordance with ECHR. Therefore, for the achievement of the first goal, that is, to make ECHR rights more effective, the Human Rights Act 1998, provides that in the interpreting of the domestic legislation involving human rights issues, effect to the ECHR rights must be given through interpretation (HRA 1998, Section 3) and public authorities must act in accordance with the ECHR (Section 6). The effectiveness of the legislation to protect ECHR rights can also be seen in the light of Section 4 because there are decisions wherein the court has declared incompatibility between a primary legislation and the ECHR rights. An example can be seen in A v Secretary of State (Belmarsh case), in which case the court decided that there was incompatibility between the ECHR rights and the anti-terror law which allowed indefinite detention of foreign terror suspects. This led the Parliament to repeal the provisions of the primary legislation that were declared to be incompatible with the ECHR rights. In R (Ullah) v Special Adjudicator, the House of Lords has also noted that courts should not dilute the ECtHR jurisprudence unless there is a strong reason to do so. The same Section 4 is also a way for achieving the second goal of the Human Rights Act 1998, which is to preserving’ the sovereignty of Parliament because the courts are not allowed to declare the law to be invalid but to only declare incompatibility between the domestic law and the ECHR rights. Therefore, while the courts are allowed to review the primary legislation to see its compatibility with ECHR rights, this does not go to the extent of allowing the courts to declare the law itself to be invalid. Therefore, even with respect to the ECtHR jurisprudence, the Supreme Court has held that it is not always bound by it. It is also important that the power to amend the primary legislation is left to the Parliament because only the power to declare incompatibility is given to the judiciary; it can be said that this is the way of preserving Parliamentary sovereignty. b) The United Kingdom did ratify the ECHR in 1951 and also allowed individuals to take their cases to the Strasbourg court in 1966. In 1998, the UK enacted the Human Rights Act 1998, which meant that now the rights contained in the ECHR were given the status of statutory rights. This process took longer despite the pressure from some groups within the UK that wanted that UK should enact a Bill of Rights based on the

---

1. Gary Slapper and David Kelly, The English Legal System (Routledge 2009) 24.
2. A v Secretary of State [2004] UKHL 56.
3. R (Ullah) v Special Adjudicator [2004] UKHL 26.
4. R (HS2 Action Alliance Ltd) v Secretary of State for Transport [2014] UKSC 3.
5. Ghaidan v Godin-Mendoza [2004] UKHL 30, [57].
6. A. W. Brian Simpson, ‘Britain and the European Convention’ (2001) 34 (3) Cornell International Law Journal Article 4.
ECHR rights. One of the reasons why it took so long for the UK to enact a Bill of Rights is that once the HRA would be constituted, there was some concern that this would increase cases of judicial review.

The 1998 is unpopular with governments because it places burdens on the governments to abide by the provisions of the ECHR and exposes government decisions to the scrutiny of the courts in the UK as well as the Strasbourg court for assessing whether these decisions can stand under the ECHR jurisprudence. Successive governments may have found it difficult to navigate the ever increasing jurisprudence on ECHR rights and to keep pace with the jurisprudence; this has been articulated by former Shadow Justice Secretary, Nick Herbert as a burden on frontline public servants ‘who struggle to decide what the law is in practice’. One of the areas where controversy related to the 1998 Act has arisen frequently is that the Act allows the judiciary to declare incompatibility between the primary legislation and the ECHR law, which may lead to a situation where a primary legislation that comes into being after considerable parliamentary debate and consensus, may be declared to be incompatible with the ECHR. This was the case in R (Q,D,J,M,F & B) v Secretary of State, where the court decided that the state is under a duty to provide social support and services to destitute asylum seekers. The question of how far support may be given to the immigrants and asylum seekers has been accepted to be a political issue, but the HRA 1998 allows the court to assess such a duty on the part of the state on the basis of ECHR, which may then go beyond what is politically expedient. This may lead to a sense amongst the governments that they are being forced to take decisions due to the application of the HRA 1998, making it unpopular. One of the reasons why the HRA has been unpopular is because it is seen as providing too much protection to terrorists and making parliamentary law dealing with this problem as ineffective as seen in the A v Secretary of State (Belmarsh case) where the court declared incompatibility between the law and the ECHR. Another reason why the law is unpopular is because it is seen as affecting the legislative supremacy of parliament and also making Strasbourg jurisprudence dominant over the UK courts. The Human Rights Act 1998 should not be abolished unless there is another legislation that provides a similar Bill of Rights as is contained in the 1998 Act. The abolition of the HRA 1998 will lead to a situation where both the goals of the Act, which are, making the ECHR rights ‘effective’ and ‘preserving’ the sovereignty of Parliament are possibly threatened. Where on one hand, there will be a vacuum in the protection of rights of the people unless there is a British Bill of Rights to take the place of Human Rights Act 1998, on the other hand, because the UK will be a party to the ECHR (unless it revokes its membership), individuals can still approach the European Court of Human Rights where the laws made by the Parliament can be declared to be contrary to the ECHR and remedies may even be provided. At the same time, the middle course, where individuals could approach the British courts will be missing because HRA 1998 will have been repealed. The British courts could have used the proportionality test to assess the actions of the executive or declared incompatibility between the primary legislation and the ECHR thus allowing the

---

7. Nick Herbert, ‘Human Rights Act: The law that has devalued your human rights’ (Daily Telegraph, 18 December 2008).
8. R (Q,D,J,M,F & B) v Secretary of State for the Home Department (2003) EWHC 195 (Admin).
9. R (Adam, Limbuela and Tesema) v Home Secretary [2005] UKHL 66.
10. A v Secretary of State [2004] UKHL 56.
Parliament to amend the laws as it thinks fit. The principle of ‘margin of appreciation’ could also be applied by the courts to assess that the British laws are not in contravention of ECHR. However, the repeal of HRA 1998 will take these decisions out of the hands of the British courts and leave them solely to the ECtHR.

Question Five

Proportionality has been explained as a process that seeks to “balance the seriousness of the interference against the seriousness of the threats to the interests which are protected within the purposes for which it is legitimate to interfere with rights.” When the court is applying the proportionality test, it is required to consider whether the decision of the executive is such that the extent of the interference is greater than what is reasonably necessary to achieve the legitimate aim of that decision. On the other hand, the unreasonableness standard is applied by the courts to assess the legality of the decision of the executive based on whether that decision is rational or reasonable. This essay discusses whether it is correct to say that the proportionality test has lowered the traditional ‘Wednesbury’ threshold of unreasonableness in judicial review cases while also being selective in application. The essay argues that the application of the proportionality test has led to the lowering of the unreasonableness standard because the as long as the Wednesbury test was applied, the discretionary administrative powers were protected from judicial review unless absurd, irrational or perverse, but this changed with the application of proportionality test. It can be said that application of proportionality principle is selective although there is a possibility that proportionality test may come to apply in all kinds of cases and not only those related with the Human Rights Act 1998 as was the case earlier. Selectiveness can also be seen in how in cases involving human rights as well, the proportionality test may not be applied. Despite there being a difference between Wednesbury test and the proportionality test, it has been considered that the difference is more of degree rather than of kind. There is a conceptual difference which can be seen in the fact that Wednesbury test is concerned with assessing the process of reasoning applied before making a decision and the proportionality test is concerned with the outcome of the decision. In that sense, the latter is one of lowered threshold of unreasonableness because even if the process for making the decision is shown in reasoned decision, it could still be considered to be disproportionate in context of the outcome of the decision. In that sense, proportionality test is contextual in nature with a lowered threshold of unreasonableness involved as compared to the Wednesbury test. ‘Wednesbury unreasonableness’ principle is used by courts to test the legality of the decisions or actions of the executive authorities and as such is a part of judicial review. The threshold of unreasonableness was laid down in the famous Wednesbury judgment. In this case, an important observation was made by Lord Greene, where he noted that when discretion is given it must be exercised reasonably. More importantly, the term ‘unreasonable’ was defined as failure or omission of the decision-maker to call his attention to the matters which he is legally bound to consider and to exclude matters which are irrelevant to what he has to

---

11. David Feldman, Civil Liberties and Human Rights in England and Wales (OUP, 2002) 57.
12. Ibid.
13. M. Elliott, ‘The Human Rights Act 1998 and standard of substantive review’ (2001) 60 C.L.J. 301.
14. Associated Provincial Picture Houses v Wednesbury Corporation [1948] 1 KB 223.
15. Ibid, [229].
consider. Lord Greene noted that if these considerations are not obeyed, then it may be said that the decision maker has acted ‘unreasonably.’ The overarching principle was that if the action or decision of the decision making authority is so absurd that no sensible person could ever dream that it lay within the powers of the authority, it can be said that the action is unreasonable. This is a higher threshold of unreasonableness as compared to the one that is now done under the proportionality test, which is structured in a different way as explained by Lord Steyn in Daly. Unlike the Wednesbury threshold where the decision must be shown to be ‘absurd’, when applying the proportionality test, the judge is not required to touch the level of unreasonableness standard of Wednesbury, but only to see whether the decision is excessive on the basis of whether legislative objective is sufficiently important to justify limiting a fundamental right; the rational connection between the measures and the legislative objective; and whether the means used to impair the right or freedom are no more than is necessary to accomplish the objective. The focus in the proportionality test is not only on reasonableness of the decision but the proportionality of the decision in light of the legislative aim and its nexus with the measures adopted that limit rights of individuals. As such, the threshold has been lowered in the proportionality test and was much higher in the Wednesbury test. The test laid down in Wednesbury is objective and is applied to a situation where the decision is considered to be so absurd that no sensible person would ever dream that it lay within the power of the authority. This was reiterated by Lord Diplock in Council of Civil Service Unions v Minister for the Civil Service. The significance of this case is also that the decision differentiated between illegality and irrationality to say that even if the decision is legal but irrational, it may be struck down by the courts. In other words, even if the decision of the authority is within the scope of the legislative scheme and therefore in that sense, legal, it may be substantially unlawful because it is irrational or unreasonable. However, as noted in Daly by Lord Steyn, irrationality test is more difficult to satisfy while the proportionality test allows a more detailed consideration of how relevant interests are balanced and whether limitation on rights is ‘necessary in a democratic society’ in pursuance of the legitimate aims. This argument can be supported by the inability of the court to give adequate weight to the rights of the individuals in Bancoult. While the threshold is lowered in the case of proportionality test, its application is selective. In the UK, the proportionality test has come via the European law and the European Convention of Human Rights (ECHR). It is important to understand this distinction between proportionality test and the unreasonableness test because it has been held that the proportionality test applies in cases where EU law and Human Rights Act 1998 are engaged whereas irrationality test applies in all other matters of domestic administrative law. Therefore, only in cases which involve the EU law or ECHR rights, will the proportionality will apply. This can be exemplified as follows. The prison policy required that the prisoners must not be present when having their cells searched, and this was questioned on the basis

---

16. Ibid.
17. Ibid.
18. R (on the application of Daly) v Secretary of State for the Home Department [2001] UKHL 26, [27].
19. Bank Mellat v HM Treasury [2013] UKSC 39.
20. Council of Civil Service Unions v Minister for the Civil Service [1985] 1 AC 374, [410].
21. Lester and J. Jowell, ‘Beyond Wednesbury: substantive principles of administrative law’ [1987] Public Law 368, 369.
22. Ibid.
23. R (on the application of Daly) v Secretary of State for the Home Department [2001] UKHL 26, [547].
24. R. (Bancoult) v Secretary of State for Foreign and Commonwealth Affairs (No 2) [2008] UKHL 61.
25. R (on the application of Association of British Civilian Internees: Far East Region) v Secretary of State for Defence [2003] QB 1397.
m pursued. At the same time, courts have also sought to consider whether the proportionality test can be applied in cases other than those involving Human Rights Act 1998. For instance, in R (Association of British Civilian Internees: Far East Region), Dyson LJ considered that there is some difficulty in retaining the Wednesbury test because it is moving closer to proportionality. In R (Alconbury Developments Ltd and others), Lord Slynn was even more expressive of the need to consider whether the proportionality test can be applied even without reference to the Human Rights Act 1998 because the proportionality test appears to have become more a part of the English administrative law, with judges applying the test also when they are dealing with acts subject to domestic law. In Keyu, the UK Supreme Court acknowledged that they may soon have to decide whether to replace irrationality with proportionality. The Supreme Court’s position is that both the tests are similar in that they both require judicial consideration of ‘weight’ and ‘balance’ of the decision. The viewing of the proportionality and Wednesbury test as being similar also can have an adverse impact on the application of review by the applicant as seen in the Pham case, where the Supreme Court chose to remit a case involving revocation of citizenship to be decided by the Special Immigration Appeals Commission (SIAC) instead of using proportionality test to conduct judicial review. Similar outcome was seen in Kennedy. In this sense, application of proportionality test can be seen to be selective.

---

26. R (on the application of Daly) v Secretary of State for the Home Department [2001] UKHL 26.
27. Ibid.
28. R (Association of British Civilian Internees: Far East Region) v Secretary pf State for defence [2003] EWCA Civ 473.
29. R (Alconbury Developments Ltd and others) v Secretary of State for the Environment [2001] UKHL 23.
30. Keyu v Secretary of State for Foreign and Commonwealth Affairs [2015] UKSC 69.
31. P. Craig, ‘The Nature of Unreasonableness Review’ (2013) 66 Current Legal Problems 131.
32. Pham v Secretary of State for the Home Department [2015] UKSC 19.
33. Kennedy v Information Commissioner [2014] UKSC 20.

Book

Feldman D, Civil Liberties and Human Rights in England and Wales (OUP 2002). Slapper G and Kelly D, The English Legal System (Routledge 2009).

Journals

Craig P, ‘The Nature of Unreasonableness Review’ (2013) 66 Current Legal Problems 131. Elliott M, ‘The Human Rights Act 1998 and standard of substantive review’ (2001) 60 C.L.J. 301. Lester A and Jowell J, ‘Beyond Wednesbury: substantive principles of administrative law’ [1987] Public Law 368. Simpson AWB, ‘Britain and the European Convention’ (2001) 34 (3) Cornell International Law Journal Article 4.

Websites

Herbert N, ‘Human Rights Act: The law that has devalued your human rights’ (Daily Telegraph, 18 December 2008) accessed < https://www.telegraph.co.uk/comment/personal-view/3563371/Human-Rights-Act-The-law-that-has-devalued-your-human-rights.html >

Introduction

Human Rights and Social Justice can be defined as a suitable way of fostering social norms and regulations in an effective pattern. In other words, it can be better known for its equality and securing rights of the common man in a country under an ethical guideline of the approaches that may bring some advocacy of international human rights as well. According to the British Institute of Human Rights (2020), it upholds principles of social justice and human rights, as per government regulations as well as having promoting equality of gender, race, and religious aspects. In fact, the British Institute of Human Rights has mainly focused on the transformation of society towards democracy since it was formed by the Council of Europe post World War II. In this regard, it has been well acknowledged that the Human Rights and European Convention on Human Rights may secure and protect a society that is based on equality and having equal opportunities in a country for achieving the majority of benefits and flexibility that is dependent on public policy. The essay represents two views on British society, which is socially just on the basis of legal and ethical norms and rights that have been dependent on the strategic concepts as well as the majority of navigation of ideologies and principles of the country as well.

Discussion

Social Justice in the British Society: A Political Overview

The concept of social justice has been a matter of debate for a long time in different forms. It is since the last fifteen years that the topic has become a part of political discourse, most importantly among the governments who identify themselves as social democrats. According to Carugati et al. (2019), in the purview of the development of a liberal democratic society, the achievement of social justice happens to be a natural outcome towards the spread of enlightenment in society. The concept of social justice gained importance in the UK with the efforts of the leader of the Labor Party in successfully establishing the Commission for Social Justice in the year 1994. At that time inequality and poverty happened to be the two most debatable topics within the UK and hence the UK was considered as one of the most socially unjust countries in the world (Thrift and Sugarman, 2019). The Commission in order to remove this tarnished image of the country pledged to provide social to one and all in the country. The Commission also pledged to provide equal opportunities to every citizen and provide them with equal rights in order to meet their basic needs and demands. The Commission sought to remove every form of inequality in the society and strived to work towards making the British society socially just again. But with the new governments coming into power in the UK, a lot of questions aroused that what are the basic needs and opportunities that the government should provide to their citizens in order to be socially justified towards them. The new governments brought into the forefront a lot of new social programs for the society in order to deliver social justice by providing their basic needs and amenities and creating an opportunity for all. But somehow they failed to address the issues of social exclusion and were unable to reduce the poverty in the society (Warner et al. 2020). The very reason for this was that their goals were not clear and far-sighted and lacked the initiative to promote social equality among all. The social democratic governments in the UK had been criticized time and again due to their incompetence to understand the gravity of issues related to social justice in the British society and henceforth frame effective policies in order to address such delicate issues. These governments mainly focused on the underprivileged and provided them with the basic needs and amenities but they failed to understand the concept of redistribution. They failed to understand the needs and opportunities forms a part of the basic rights of every individual in the society as it is not only the underprivileged that makes up the society but the society is made up of every citizen coming from different walks of life. This created a disparity among society as many were deprived of the social needs and opportunities (Li and Dervin, 2019). Many articles in the media also highlighted the fact the British society to be segregated in terms of ethnicity as most citizens prefer friends from their own ethnic group rather than from other ethnic groups. This indirectly indicates social segregation in British society rather than incorporating social inclusion and integration into society.

Notions of Social Justice in the British Society

The notion of social justice in the British Society has a different perspective on different people in society. To one section of the society, it is about equality of opportunities, while to another section of the society it is all about equality in outcomes. British society happens to be a multicultural society due to the fact of mass immigration between the years 1950 to 1970. The UK government ensures equal rights and opportunities irrespective of the ethnicity of its citizens (Watts and Hodgson, 2019). Multiculturalism and diversity have always been a matter of pride for British society. But the increasing cases of biases based on ethnicity in the last few years has been a question on the ideal of social justice for every citizen in the UK. Several cases of intolerance and attacks on ethnic minority groups had been the major headlines of the leading print and digital media in the UK. On many occasions, the ethnic minority groups had to struggle in order to get the much-needed recognition and respect in British society, which puts the concept of social equality in British society under doubt. The intolerance towards such ethnic minority groups in the British society had been the very reason behind social unrest where the members of such ethnic minority groups adopted violent ways in order to affirm their basic rights (Capeheart and Milovanovic, 2020). Some recent terrorist attacks in the UK had always put the allegiance of the minority ethnic groups towards the UK government and British society under doubt. This enhanced the act of intolerance against them by British society time and again and was deprived of their basic human rights and social justice. Again economic slowdown had been one of the prime causes behind depriving the ethnic minority groups of basic amenities like education, healthcare services, housing, and other social services. There have been many philosophies and theories put forward by authors concerning the notion of social justice. According to John Rawls, social justice is based on the fundamental principle of “fairness” and states that a well-ordered society is about “everyone playing their individual role to act equitably” (Gališanka, 2019). The contemporary politicians in the UK underline social justice as the equality of opportunity, however, a different lobby of politicians contradicts in this matter and underlines social justice as the equality of rules and regulations. According to David Miller, social justice is distributive in nature and how it is delivered to the human society depends on the political and philosophical perspective of society (Stankiewicz, 2019). As identified by Miller, there are three basic and fundamental components that are linked to social justice, that is what the society deserves, what it needs, and ensuring equality. This is what ensures society to be socially just as well as responsible for the needs and opportunities of everyone in society.

Critical Evaluation of the Two Views

It has been acknowledged that Social Justice gained stability in the British Society with the establishment of the Commission for Social Justice in 90s. During that period the British society was considered unequal in terms of poverty and equality. The commission stated social justice, as equal treatment for all citizens, equal rights of all citizens for their basic requirements, equal opportunities for all and eliminating the inequalities. According to O'Brien (2017), the government in the UK did not define social justice previously but now British society is more segregated. The politicians in British focus on the equality of opportunity, processes and procedures. Though it is still noticed that women, disabled, black and the ethnic groups are not privileged of equal rights. The minority children are left behind the British when it comes to education. It is even noticed that blacks are not allowed to keep forth their requirements and this is the reason that blacks are reluctant to the researches based on them, as they have not been involved

As stated by Xie (2018), justice should be distributed in nature, the rights and the privileges should be delivered equally among all the citizens. Though, most of the time, the multicultural societies face difficulties in the recognition of the minor groups. According to Francis et al (2017), till the present day, society is not working towards the reduction of child poverty and the gap between the wealthy and underprivileged, that had increased in past years. The right approach towards social justice, as said by, is the arrangements of society in such a way that all can receive the privileges they deserve. Along with the cultural, the difference in income and prosperity also affect recognition and respect in the society. British society is working towards the betterment of social justice, that is essential for every human. Social justice is defined working together towards an equal society, where the people will be treated with equal dignity and respect irrespective of their culture, colour and income.

The UK Human Rights are working towards the protection of the citizen's rights, creating legal regulations that will help in yeh implementation of the rights. Along with social justice, the commission is working on removing the obstacles the citizens face because of their gender, age, ethnicity, culture and disability. The concept of social justice in British society is linked with rights and citizenship and their need. Citizenship has identified some aspects that are Civil rights that include property rights, legal assurances and liberties Political rights that include voting rights, rights to firm associations, participation in constitutional meeting Social rights that include the right to education, rights to health care, maintenance of housing and income. Social justice is jit only limited to the material aspects but also the non-material aspects, like respect and recognition as an individual irrespective of the group or culture they belong to. The major challenge that lies in the oath to attain social justice in the society is the closed community of politics that have a very primitive concept about the needs and requirements for the citizens. The cultural differences can be eliminated by opening national identity so that all become equally available for discussion. The politicians should ensure that people from all the cultural groups are recognized and encourage them to participate in the process if they determine the principles that will help in establishing social rights in society. These small engagements will help to understand the cultural differences and clear the concept of social justice so that all can be benefited from it. The challenge is greater than it seems to be, but for the beginning, social justice should be involved in terminating the cultural differences.

Conclusion

In considering all the facts and concepts about social rights in British society, it has been observed that the society and the government have evolved in retaining the rights of the citizens. British society has a multicultural society, which is the result of the immigration that took place between the years 1959 to 1970. Social justice was not evenly distributed in the nation thus, the formation of the Rights commission was required. The Rights Commission has worked towards protecting the rights of the citizens. The multicultural society is difficult to manage due to their different beliefs but they are being kept on the same grounds as the citizens. However, being the citizen all has the same rights and duties towards the nation and society. The government has been taking the required steps to ensure all are treated equally irrespective of their culture, religion, ethics, disability, gender or age. The social rights are established so that all are recognised and respected equally. As it is observed, there have been some issues related to education and prosperity, which has to be excluded from society. The citizens as well as the politicians need to work together towards the betterment it yeh society and social rights will have a significant role in the process

References

British Institute of Human Rights. 2020. Social Justice And Human Rights. [online] Available at: [Accessed 25 August 2020]. Capeheart, L., and Milovanovic, D., 2020. Social Justice: Theories, Issues, and Movements (Revised and Expanded Edition). Rutgers University Press.

Carugati, F., Ober, J. and Weingast, B.R., 2019. Is development uniquely modern? Ancient Athens on the doorstep. Public Choice, 181(1-2), pp.29-47.

Francis, B., Mills, M. and Lupton, R., 2017. Towards social justice in education: Contradictions and dilemmas. Journal of Education Policy, 32(4), pp.414-431.

Gališanka, A., 2019. John Rawls: The Path to a Theory of Justice. Harvard University Press.

Li, Y. and Dervin, F., 2019. Constructions of social justice, marginalization, and belonging. In Oxford Research Encyclopedia of Education.

O'Brien, C., 2017. Unity in adversity: EU citizenship, social justice and the cautionary tale of the UK. Bloomsbury Publishing.

Stankiewicz, M.A., 2019. Social Justice–Looking Back. In Art, Culture, and Pedagogy (pp. 194-202). Brill Sense.

Thrift, E., and Sugarman, J., 2019. What is social justice? Implications for psychology. Journal of Theoretical and Philosophical Psychology, 39(1), p.1.

Warner, L., Kurtiş, T., and Adya, A., 2020. Navigating criticisms of intersectional approaches: Reclaiming intersectionality for global social justice and well-being. Women & Therapy, pp.1-16.

Watts, L., and Hodgson, D., 2019. Social justice theory and practice for social work. Springer.

Xie, H., 2018, May. The Quest for Social Justice and Multiculturalism from the Perspective of Gender Alterity. In Proceedings of the XXIII World Congress of Philosophy (Vol. 29, pp.l 131-135).