Quest For Justice - The Ongoing Struggle Of Rohingya Crisis And Its Implications

Author: LawSphereX

Category: General Law

Published: 2026-08-23T20:49:46.719904+00:00

Updated: 2026-08-26T17:09:56.825+00:00

QUEST FOR JUSTICE - THE ONGOING STRUGGLE OF

ROHINGYA CRISIS AND ITS IMPLICATIONS

Tushar Kumar, Department of Law, Aligarh Muslim University Abdullah Ghazi, Department of Law, Aligarh Muslim University Mohammad Tayyab, Department of Law, Aligarh Muslim University

1. Introduction

In their own nation, the Rohingyas of Rakhine state is denied citizenship. Furthermore, the majority of those forced to flee the country have gone to Bangladesh. Throughout the 1980s, 1990s, and most recently in 2017, they were compelled to flee their own nation. Recently, in an episode, Rohingyas were removed from Rakhine State during a significant military operation by the Tatmadaw. With the recent inflow in 2017, Bangladesh has become the shelter for around 1. 6 million Rohingyas. The UN determined that Tatmadaw's 2017 military campaign was only intended to carry out "ethnic cleansing," characterising the assault as a "textbook example" of such activity. 1 The Rohingya people have a centuries-old origin story.

The historical process of many invasions and counter invasions of the kingdom and political entities in and around the presentday countries of Myanmar, Bangladesh, and the Indian subcontinent led to the development of the ethnic identity of the Rohingya. Despite residing in the state of Rakhine. The term "Rohingyas" has a lengthy history; it dates back to the 1950s. Even though the Rohingya people have been suffering for a long time, the word did not originate until the 1950s. This has come to represent their identity in the modern day. 2 The Rohingya crisis underscores the urgent requirement of comprehensive method of addressing the intersection of rights of individuals, conflict resolution, and development. Efforts to promote peace and reconciliation in Myanmar must be accompanied by measures to

1 “Myanmar Rohingya: What You Need to Know About the Crisis”, BBC, Jan. 23, 2020, available at:

https://www.bbc.com/news/world-asia-41566561 (last visited on Mar. 18, 2024).

2 “Rohingya Refugee Crisis Explained”, UN Refugee Agency, Aug. 23, 2023, available at:

https://www.unrefugees.org/news/rohingya-refugee-crisis-explained/ (last visited on Mar. 18, 2024).

address the underlying socio-economic inequalities and political marginalization that have fuelled tensions between different ethnic and religious groups.

2. Background

The Rohingya crisis stems from decades of discrimination and persecution against the Rohingya ethnic minority in Myanmar, particularly in the Rakhine State. Despite residing in Myanmar for generations, the Rohingya have faced systemic oppression, denied citizenship, and subjected to various forms of human rights abuses by the government and military. 3 The roots of the crisis can be traced back to Myanmar's independence in 1948, when the Rohingya, primarily Muslims, found themselves marginalized and excluded from citizenship under the country's citizenship laws. Over the years, successive Myanmar governments have implemented discriminatory policies, including restrictions on movement, marriage, education, and employment, effectively rendering the Rohingya stateless and subjecting them to severe socio-economic and political marginalization.

4 Tensions escalated in 2012 when intercommunal violence broke out between Rohingya Muslims and Rakhine Buddhists, leading to widespread displacement and loss of lives. In August 2017, the situation escalated significantly as the Arakan Rohingya Salvation Army (ARSA), an insurgent faction, launched attacks on numerous police outposts in Rakhine State. This prompted a severe response from the Myanmar military, marked by extensive atrocities such as killings, sexual violence, arson, and large-scale displacement. Consequently, a staggering number of Rohingya refugees sought refuge in Bangladesh, with hundreds of thousands forced to flee to ensure their safety. Since that time, Bangladesh has emerged as host to one of the globe's most significant refugee communities, accommodating more than a million Rohingya refugees in densely populated camps located in Cox's Bazar district.

This humanitarian emergency has drawn widespread global focus and censure, with demands for those responsible for human rights abuses to be held accountable and for the Rohingya population to receive justice. 5

3 “Myanmar Tensions: Dozens of Dead in Rakhine Militant Attack”, BBC, Aug. 25, 2017, available at:

https://www.bbc.com/news/world-asia-41046729 (last visited on Mar. 18, 2024).

4 Rey Ty, “The Rohingya Refugee Crisis” 16 International Journal on Human Rights 49-62 (2019).

5 “Myanmar: No Justice, No Freedom for Rohingya 5 Years On”, Human Rights Watch, Aug. 24,

2022, available at: https://www.hrw.org/news/2022/08/24/myanmar-no-justice-no-freedom-rohingya-5-years (last visited on Mar. 18, 2024).

3. Mass Exodus in 2017

3.1. The Inception-

At the start of 2017, the Rohingya community in Myanmar numbered around one million, positioning them among the numerous ethnic minority groups within the nation. Rohingya Muslims represent the largest Muslim population in Myanmar, mainly concentrated in Rakhine state. They maintain their unique language and cultural traditions, tracing their heritage back to Arab traders and various other groups with deep historical ties to the area. Despite their longstanding presence, Myanmar's predominantly Buddhist government refuses to acknowledge Rohingya citizenship. Instead, the government labels them as illegal immigrants from Bangladesh. Since the 1970s, the Rohingya have migrated in significant numbers throughout the region, often surpassing official population estimates.6

3.2. What prompted their departure from their homes?

In the period leading up to the recent crisis, numerous Rohingya embarked on perilous journeys away from Myanmar to escape communal violence and reported mistreatment by security forces. The mass departure began on August 25, 2017, following deadly assaults by Rohingya Arsa militants on more than 30 police posts. Upon entering Bangladesh, Rohingya refugees recounted fleeing their homes after witnessing military personnel, assisted by local Buddhist groups, setting fire to their villages and committing acts of violence against civilians. Médecins Sans Frontières (MSF) documented that at least 6,700 Rohingya, including over 730 young children, lost their lives in the month following the eruption of violence. Amnesty International documented instances of rape and abuse suffered by Rohingya women and girls at the hands of the Myanmar military.

The majority of this devastation occurred in Maungdaw Township, particularly between August 25 and September 25, 2017, despite Myanmar's leader, Aung San Suu Kyi, announcing the cessation of security operations on September 5, 2017. 7

4. How has the global community reacted to the situation?

4.1. Gambia's Legal Action:

6 Ibid.

7 Eleanor Albert and Lindsay Maizland, “The Rohingya Crisis”, Council on Foreign Relations, Jan. 23,

2020, available at: https://www.cfr.org/backgrounder/rohingya-crisis (last visited on Mar. 18, 2024).

Gambia's legal action centres around allegations of genocide committed against the Rohingya population by Myanmar. In November 2019, Gambia initiated legal proceedings before the International Court of Justice (ICJ), alleging that Myanmar is in breach of the genocide convention. Gambia underscored that both nations are signatories to this convention, thus carrying a responsibility to uphold its principles. 8 Despite receiving support from the Organisation for Islamic Cooperation, Gambia's Attorney General and Justice Minister Dawda Jallow clarified in February that Gambia independently initiated the case, emphasizing that it was not acting as a proxy for the OIC. Jallow asserted the sovereignty of Gambia, stating unequivocally, "We are no one's proxy.

"9 During the proceedings at the ICJ, Gambia's legal team presented compelling evidence of genocide, including satellite images, maps and photographs depicting the military operations against the Rohingya. As a result, the court issued an interim ruling instructing Myanmar to take immediate action to forestall genocide targeting the Rohingya population. This interim action seeks to protect the Rohingya community while the case is subject to additional consideration at The Hague, a process projected to extend over several years. 10

4.2. Myanmar’s Response:

Legal representatives of Myanmar countered in February by contending that the case should be dismissed on the grounds that the International Court of Justice only adjudicates disputes between sovereign states. In contrast, the Rohingya complaint was launched by Gambia, representing the interests of the Organization of Islamic Cooperation. Furthermore, they contended that Gambia lacked the standing to bring the case before the court, due to its lack of direct involvement in the events in Myanmar and no legal dispute existed between them prior to the case being filed.11 8 “ICJ to Rule on Myanmar Objections to Rohingya Genocide Case”, Al Jazeera, July 22, 2022, available at: https://www.aljazeera.com/news/2022/7/22/icj-to-rule-on-myanmar-objections-to-rohingya-genocide-case (last visited on Mar. 18, 2024).

9 Ibid.

10 “The ICJ’s Latest Judgment in the Case of Genocide Against Myanmar”, The Indian Express, Apr. 23,

2022, available at: https://indianexpress.com/article/explained/myanmar-genocide-case-international-court-ofjustice-ruling-explained-8047114/ (last visited on Mar. 18, 2024).

11 Ibid.

4.3. Global Backing for Gambia's Legal Action:

On November 15, 2023, a collective statement of intervention was submitted by the Netherlands, Canada, France, Denmark, United Kingdom and the Germany. This action was motivated by their shared commitment to the objectives outlined in the 1948 Convention on Preventing and Punishing Genocide. Additionally, the Maldives also submitted a declaration to intervene, expressing profound concern regarding the ongoing human rights abuses and brutal attacks targeting the Rohingya Muslims. The Maldives emphasized the necessity of international collaboration in efforts to prevent and penalize genocide.12

5. India's Handling of the Rohingya Crisis

India, not being a signatory to the Refugee Convention of 1951, does not acknowledge the Refugee Cards issued by the UNHCR, implying that Rohingya individuals within India lack explicit rights to access essentials such as rations, employment, housing, and education. Consequently, many Rohingyas are reportedly engaged in activities such as rag-picking and unskilled, informal labour. 13 Nevertheless, it's crucial to emphasize that India is a party to numerous international treaties that mandate states to guarantee fundamental human rights and dignity for all individuals, including those seeking asylum. India has also ratified treaties such as the (ICCPR), (CEDAW), (CRC), which impose affirmative obligations to uphold dignity, respectful life and liberty, and to create an environment that promotes the development of children.

14 Furthermore, Indian Constitution, mandates the state to foster respect for international law and treaty obligations. 15 Courts have consistently interpreted core rights protected by the Constitution in line with international law principles. The Supreme Court of India held that the provisions of the ICCPR are directly enforceable in India. 16 Similarly, the court incorporated

12 “European Nations Join Myanmar Genocide Case”, Al Jazeera, Nov. 17, 2023, available at:

https://www.aljazeera.com/news/2023/11/17/five-european-nations-join-myanmar-genocide-case (last visited on Mar. 18, 2024).

13 Ashley Starr Kinseth, “India’s Rohingya Shame”, Al Jazeera, Apr. 29, 2019, available at:

https://www.aljazeera.com/opinions/2019/1/29/indias-rohingya-shame/ (last visited on Mar. 18, 2024).

14 Ibid.

15 The Constitution of India, art. 51(c)

16 People’s Union for Civil Liberties v. Union of India, AIR 1997 SC 568.

the entire CEDAW into Indian law.17 Moreover, In the absence of conflicting provisions, customary international law was considered automatically integrated into domestic law.18 However, despite these legal obligations, the Indian government's approach to providing protection and assistance to Rohingyas falls short of its international responsibilities. The neglect of Rohingya refugees is argued to be primarily based on religious grounds and is consistent with the growing discrimination and persecution faced by Muslim minorities within India.19

6. Navigating Challenges: Issues Faced by Rohingyas

6.1. Food, Shelter, Education, and Health Issues:

In terms of food security, both registered and unregistered Rohingya refugees face significant struggles in maintaining adequate nutrition. While registered refugees are primarily concerned about the insufficient supply of food, their unregistered counterparts are more troubled by food insecurity, highlighting the pervasive nature of hunger and malnutrition within the refugee community. This challenge is exacerbated by overcrowded living conditions and a reliance on inadequate government rations, underscoring the dire circumstances faced by refugees in meeting their basic nutritional needs. 20 Shelter and living conditions pose another significant challenge, with refugee camps characterized by overcrowding, poor sanitation, and substandard housing.

Refugees, whether registered or not, are forced to reside in makeshift structures made of tin, polythene, or mud, leaving them vulnerable to environmental hazards such as coastal disasters. Additionally, the lack of privacy and limited access to bathing and toilet facilities further compound the difficulties faced by refugees, particularly impacting vulnerable groups like women and children. 21

17 Vishaka v. State of Rajasthan (1997) 6, (1997) 6 SCC 241.

18 Vellore Citizens Welfare Forum v. Union of India 1996 5, 1996 5 SCR 241.

19 Supra Note 13

20 “How Bangladesh Aid Restrictions Impact Rohingyas”, The New Humanitarian, Nov. 19, 2013, available at: https://www.thenewhumanitarian.org/analysis/2013/11/19/how-bangladesh-aid-restrictions-impact-rohingyas (last visited on Mar. 18, 2024). 21 Shahnam Karin and Md. Arif Chowdhary, “Status of Rohingya Refugees in Bangladesh: A Comparative Study with Emphasis on Aspects of Women and Girls in Camps of Kutupalong, Cox’s Bazar, Bangladesh” 7 Open Access Library Journal 1-4 (2020).

Access to education is also limited, despite constitutional guarantees of primary education. High costs, inadequate facilities, and complex admission processes hinder Rohingya children's access to education opportunities, perpetuating a cycle of disadvantage and limiting their prospects for a better future.22 Healthcare services present yet another challenge, with registered refugees facing issues such as limited access to medical facilities, discrimination, and inadequate maternal care. Nonregistered refugees also encounter significant health-related challenges, including insufficient medical services and hygiene facilities. Both groups express dissatisfaction with the healthcare situation, underscoring the urgent need for improvements to address the complex health needs of Rohingya refugees.23

6.2. Social, Economic, and Security Challenges:

All respondents encounter various social, economic, or security issues. Socially, both registered and non-registered refugees grapple with a crisis of national identity and the denial of voting rights. Additionally, feelings of loneliness, inferiority, and social isolation, along with restrictions on marriage, are prevalent concerns. Notably, refugees in registered camps express a higher prevalence of isolation and loneliness, while non-registered refugees face more significant hurdles in obtaining birth certificates and navigating marriage restrictions imposed by Bangladeshi laws. 24 Economically, Rohingya refugees experience a myriad of challenges, including acute poverty, economic instability, and limited job opportunities.

While both groups endure hardships, nonregistered refugees encounter greater complexity in economic insecurity, with issues such as forced labour without wages and coerced donations being more pronounced. Moreover, Rohingya refugees in Malaysia face financial struggles due to restricted access to job markets. 25 Security-wise, both registered and non-registered refugees confront distinct vulnerabilities. Registered refugees report false accusations, sexual assault, and harassment by locals and law enforcement, with documented incidents of violence such as kidnappings and abductions in

22 Id. at 3

23 Id. at 3

24 “Bangladesh”, UNHCR the UN Refugee Camp, Oct. 31, 2019, available at: https://www.unhcr.org/ (last visited on Mar. 18, 2024).

25 Id. at 5

registered camps. Conversely, non-registered refugees express heightened fears of human trafficking and forced illegal activities, indicating a more precarious situation. Particularly, non-registered women and girls are disproportionately vulnerable to sexual and physical assaults. 26 Statistical analysis reveals significant variations between registered and non-registered refugees in fundamental rights, food security, housing, health, and safety concerns. Food uncertainty and limited food variation are more prevalent among non-registered refugees, while fears of eviction from residence are linked to camp category. Additionally, disparities are observed in access to health services, medicine supply, and doctor behavior between registered and non-registered refugees.

While social and economic problems do not significantly differ between the two groups, the scarcity of employment is associated with camp category. Security concerns, including false accusations and harassment, are significantly correlated with refugee status, highlighting varied challenges faced by registered and non-registered refugee types. 27

7. International Implications for Bangladesh and the Rohingya Population

7.1. Erosion of Bangladesh's International Reputation and Risks to Diplomatic Ties:

The declining international image of Bangladesh and its repercussions on diplomatic relations are exacerbated by the involvement of Rohingyas, who are obtaining Bangladeshi passports illegally and engaging in illicit activities abroad, including those related to international terrorism. Administrative weaknesses and corruption within Bangladesh have facilitated Rohingyas in obtaining Bangladeshi passports, leading to approximately 250,000 Rohingyas being treated as Bangladeshi citizens abroad. Consequently, when these individuals commit crimes, it creates difficulties for genuine Bangladeshi immigrants and workers overseas. 28 Since the 1970s, Bangladesh has been a significant source of migrant workers, primarily to Middle Eastern countries like Saudi Arabia, contributing substantially to the country's GDP through remittances.

However, recent deportations of Rohingyas from Saudi Arabia have raised concerns about potential strains on Bangladesh-Saudi diplomatic relations and its impact on

26 Id. at 4

27 H.T.A. Khan and M.A. Rahman, “Humanitarian Emergencies of Rohingya Older People in Bangladesh: A

Qualitative Study on Hopes and Reality.” 47 Ageing International 20-37 (2020). 28 Abdul Halim, “The Rohingya Crisis in Bangladesh: Exploring Global Security Implications” SSRN 3 (2021).

remittance earnings.29 Furthermore, Bangladesh's attempts to address the Rohingya crisis have led to strained relations with China and Russia, as they have supported Myanmar's stance on the issue. This was evident when these countries, along with several others, voted against a UN committee draft on the human rights situation in Myanmar. India's stance on the Rohingya issue initially caused dismay in Bangladesh, but it later softened its approach and expressed support for Bangladesh. However, tensions escalated when the Indian border guard attempted to forcibly push Rohingya refugees into Bangladesh territory, leading to further diplomatic tensions between Dhaka and Delhi. Additionally, recent remarks by the Indian Prime Minister referring to Rohingya influx as "returned to Bangladesh" have sparked diplomatic debates, indicating potential challenges in bilateral relations.30

7.2. Putting Bangladesh-Myanmar Bilateral Relations at Risk:

Bangladesh, widely acknowledged for its peaceful foreign policies, encounters hurdle due to the humanitarian calamity sparked by the Myanmar military's recurrent violations of Rohingya rights. With over a million Rohingya seeking refuge in Bangladesh, the country finds its diplomatic objectives strained. Efforts to resolve the crisis encompass diplomatic manoeuvres, such as bilateral discussions and proposals advanced at global platforms like the UN General Assembly. Nevertheless, progress remains sluggish, with Myanmar failing to foster suitable conditions for Rohingya repatriation. Prior attempts at repatriation, notably in 2005 and 2011, yielded meagre results. Myanmar's recent diplomatic manoeuvres, including border fortifications, raise apprehensions of potential conflict with Bangladesh.

Moreover, the longstanding dispute over maritime borders and Myanmar's distortion of events in Bangladesh exacerbate tensions in bilateral ties. Despite earnest endeavours to uphold peace, the Rohingya crisis persistently challenges Bangladesh's diplomatic pursuits vis-à-vis Myanmar. 31

8. Humanitarian Assistance Efforts

Under the auspices of the Bangladesh Government, the 2023 Joint Response Plan (JRP) for the Rohingya Humanitarian Crisis was initiated on 07 March. This annual document serves as a

29 Id. at 4

30 Id. at 5

31 Id. at 6

fundraising tool and outlines the collaborative approach of the humanitarian community in addressing the identified needs of Rohingya refugees and affected host communities. 32 The 2023 JRP, coordinated by the United Nations (UN) and its collaborating organizations, calls upon the international community to provide financial assistance to meet the urgent needs of Rohingya refugees and Bangladeshi host communities as the refugee crisis approaches its sixth year. With a requested funding of $876 million, the plan aims to assist 1. 47 million individuals, including Rohingya refugees residing in Cox’s Bazar and Bashan Char, as well as Bangladeshi host communities in Ukhiya and Teknaf. It unites 116 partners, consisting of UN agencies, Bangladeshi and international NGOs, with almost half of them being national organizations from Bangladesh.

The JRP prioritizes five main goals, which include facilitating the sustainable and voluntary repatriation of Rohingya refugees/Forcibly Displaced Myanmar Nationals (FDMN) to Myanmar, enhancing the protection of Rohingya refugees/FDMN individuals of all genders and ages, providing life-saving aid to vulnerable populations, supporting the well-being of host communities in Ukhiya and Teknaf Upazilas, and strengthening disaster risk management efforts while tackling the impacts of climate change. 33

9. Diminishing Prospects for Repatriation

The Rohingya refugees in southern Bangladesh face increasingly bleak prospects of returning to their homes in Myanmar, with conditions in the camps deteriorating. Over the past two years, international funding for essential services has significantly decreased as other global crises divert attention, leading to donor fatigue. In 2023, the Rohingya Humanitarian Crisis Joint Response Plan is only 40% funded, forcing the UN to reduce food aid by a third to just $0. 27 per person per day. Additionally, other services have been cut, and the shrinking budgets have resulted in layoffs of refugee volunteers, one of their few legal sources of income. 34 Simultaneously, violence is on the rise in the camps as armed groups and criminal networks establish themselves among the refugees.

Previously, the dominant group was the Arakan Rohingya Salvation Army (ARSA), which instigated attacks in Myanmar in 2016-2017. 32 Future Bleak for Rohingya in Bangladesh, Myanmar”, Human Rights Watch, Aug. 24, 2022, available at: https://www. hrw. org/news/2022/08/24/myanmar-no-justice-no-freedom-rohingya-5-years (last visited on Mar. 18, 2024).

33 “Govt, UNHCR to Launch 2023 Joint Response Plan for Rohingyas Soon”, Dhaka Tribune, Jan. 28,

2023, available at: https://www.dhakatribune.com/bangladesh/281454/govt-unhcr-to-launch-2023-jointresponse-plan-for (last visited on Mar. 18, 2024).

34 Supra Note 32

However, in September 2021, ARSA's killing of a prominent Rohingya community leader drew international attention to the escalating violence. Subsequently, Bangladeshi authorities cracked down on ARSA, leading to the emergence of other armed groups, with the Rohingya Solidarity Organisation (RSO) gaining prominence. Tensions between these groups have led to turf wars, resulting in increased killings and abductions, primarily targeting young men and community leaders. Despite efforts by Bangladesh's Armed Police Battalion to maintain security, they have faced accusations of misconduct and inability to control the situation. Against this backdrop, both Bangladesh and Myanmar, supported by China, have attempted to repatriate Rohingya refugees to Rakhine State since 2023, but key challenges remain unresolved.

35 Myanmar's refusal to meet refugee demands, particularly regarding citizenship, hampers repatriation efforts. Additionally, the emergence of the Arakan Army in Rakhine State poses further complications, as the group controls significant territory along the Bangladeshi border. Without their cooperation, large-scale repatriation is unlikely. As a result, the prospects for most refugees to return home remain distant, exacerbated by Bangladesh's policies restricting refugee liberties and aid dependency. Bangladesh's insistence on speedy repatriation and restrictive policies risk worsening the humanitarian crisis, potentially pushing refugees towards risky coping strategies.

Without improvements in camp conditions and alternative approaches, such as allowing refugees to work and offering durable solutions, the situation is likely to deteriorate further, leaving Rohingya refugees vulnerable to exploitation, violence, and other perils. 36

10. Future Prospects

The future prospects of the Rohingya crisis remain uncertain, hinging on a multitude of factors including political, legal, and humanitarian developments within Myanmar and internationally. One potential outcome is the voluntary and sustainable repatriation of Rohingya refugees from Bangladesh to Myanmar, contingent upon guarantees of safety, security, and basic rights for returnees. However, efforts towards repatriation have faced challenges including ongoing 35 “Rohingya Refugees in Bangladesh: Limiting the Damage of a Protracted Crisis”, International Crisis Group, Oct. 04, 2023, available at: https://www.crisisgroup.org/asia/south-east-asia/myanmar-bangladesh/rohingyarefugees-bangladesh-limiting-damage-protracted (last visited on Mar. 18, 2024).

36 Id. at 3

violence in Rakhine State and reluctance among Rohingya refugees to return without assurances of safety and justice. Another possibility is the resettlement of Rohingya refugees in third countries, yet this option has been met with limited success due to the reluctance of many countries to accept Rohingya refugees and concerns about their long-term integration. Without a resolution to the underlying causes of the crisis, there is a risk that Rohingya refugees will remain displaced, facing overcrowding, inadequate access to basic services, and heightened vulnerability to exploitation and abuse. Efforts to hold perpetrators of human rights abuses accountable through legal mechanisms could provide justice for victims and deter future atrocities, although achieving accountability faces numerous obstacles.

Continued diplomatic efforts by the international community, including regional actors, may advance dialogue and pressure the Myanmar government to tackle the underlying factors contributing to the crisis. Overall, the future of the Rohingya crisis depends on political will, international cooperation, and efforts to address discrimination and violence faced by the Rohingya community in Myanmar. 37

11. Conclusion

The Rohingya crisis represents a complex and deeply entrenched humanitarian and human rights challenge that requires urgent attention and concerted action from the international community. The plight of the Rohingya people, who have endured decades of discrimination, persecution, and violence, demands justice, accountability, and a sustainable solution that addresses the root causes of their marginalization and displacement. Achieving lasting peace, stability, and dignity for the Rohingya population will require political will, diplomatic engagement, and sustained efforts to address the underlying issues of discrimination, violence, and lack of citizenship rights in Myanmar.

It is imperative that the international community continues to support humanitarian assistance efforts, advocate for the rights of the Rohingya, and strive for a comprehensive and inclusive addressing to the crisis that upholds the principles of human rights, justice, and dignity for all.

37 Id. at 6

12. Bibliography

12.1. Articles:

i. Albert, Eleanor and Maizland, Lindsay, “The Rohingya Crisis”, Council on Foreign Relations, Jan. 23, 2020, available at: https://www. cfr. org/backgrounder/rohingya-crisis ii. Bangladesh”, UNHCR the UN Refugee Camp, Oct. 31, 2019, available at: https://www. unhcr. org/ iii. European Nations Join Myanmar Genocide Case”, Al Jazeera, Nov. 17, 2023, available at: https://www. aljazeera. com/news/2023/11/17/five-european-nations-join-myanmargenocide-case iv. Future Bleak for Rohingya in Bangladesh, Myanmar”, Human Rights Watch, Aug. 24, 2022, available at: https://www. hrw. org/news/2022/08/24/myanmar-no-justice-nofreedom-rohingya-5-years v. Govt, UNHCR to Launch 2023 Joint Response Plan for Rohingyas Soon”, Dhaka Tribune, Jan. 28, 2023, available at: https://www. dhakatribune. com/bangladesh/281454/govtunhcr-to-launch-2023-joint-response-plan-for vi.

How Bangladesh Aid Restrictions Impact Rohingyas”, The New Humanitarian, Nov. 19, 2013, available at: https://www. thenewhumanitarian. org/analysis/2013/11/19/howbangladesh-aid-restrictions-impact-rohingyas vii. ICJ to Rule on Myanmar Objections to Rohingya Genocide Case”, Al Jazeera, July 22, 2022, available at: https://www. aljazeera. com/news/2022/7/22/icj-to-rule-on-myanmarobjections-to-rohingya-genocide-case viii. Kinseth, Ashley Starr, “India’s Rohingya Shame”, Al Jazeera, Apr. 29, 2019, available at: https://www. aljazeera. com/opinions/2019/1/29/indias-rohingya-shame/ ix. Myanmar Rohingya: What You Need to Know About the Crisis”, BBC, Jan. 23, 2020, available at: https://www. bbc. com/news/world-asia-41566561 x. Myanmar Tensions: Dozens of Dead in Rakhine Militant Attack”, BBC, Aug. 25,

2017, available at: https://www. bbc. com/news/world-asia-41046729 xi. Myanmar: No Justice, No Freedom for Rohingya 5 Years On”, Human Rights Watch, Aug. 24, 2022, available at: https://www. hrw. org/news/2022/08/24/myanmar-no-justice-nofreedom-rohingya-5-years xii. Rohingya Refugee Crisis Explained”, UN Refugee Agency, Aug. 23, 2023, available at: https://www. unrefugees. org/news/rohingya-refugee-crisis-explained/ xiii. Rohingya Refugees in Bangladesh: Limiting the Damage of a Protracted Crisis”, International Crisis Group, Oct. 04, 2023, available at: https://www. crisisgroup. org/asia/south-east-asia/myanmar-bangladesh/rohingyarefugees-bangladesh-limiting-damage-protracted xiv. The ICJ’s Latest Judgment in the Case of Genocide Against Myanmar”, The Indian Express, Apr. 23, 2022, available at: https://indianexpress.

com/article/explained/myanmar-genocide-case-international-courtof-justice-ruling-explained-8047114/

12.2. Cases Referred:

i. People’s Union for Civil Liberties v. Union of India, AIR 1997 SC 568. ii. Vellore Citizens Welfare Forum v. Union of India 1996 5, 1996 5 SCR 241 iii. Vishaka v. State of Rajasthan (1997) 6, (1997) 6 SCC 241.

12.3. Journals:

i. Halim, Abdul, “The Rohingya Crisis in Bangladesh: Exploring Global Security Implications” SSRN 3 (2021). ii. Karin, Shahnam and Chowdhary, Md. Arif, “Status of Rohingya Refugees in Bangladesh: A Comparative Study with Emphasis on Aspects of Women and Girls in Camps of Kutupalong, Cox’s Bazar, Bangladesh” 7 Open Access Library Journal 1-4 (2020)

iii. Khan, H.T.A. and Rahman, M.A., “Humanitarian Emergencies of Rohingya Older People in Bangladesh: A Qualitative Study on Hopes and Reality.” 47 Ageing International 20-37 (2020) iv. Ty, Rey “The Rohingya Refugee Crisis” 16 International Journal on Human Rights 49-

62 (2019)