PENAL REFORM AND PRISON OVERCROWDING IN LATIN
AMERICA AND THE CARIBBEAN- What To Do, What Not To Do. The Good Examples Of
Costa Rica And The Dominican Republic1 -Status of prison overcrowding in Latin America and the Caribbean. Importance of identifying theorigin of overcrowding in order to be able to reduce it effectively. Effects of income distribution
inequality on crime and on prison overcrowding. Truly comprehensive policies and actions are required.
What to do speciﬁcally in penitentiary systems. What not to do. Inconvenience of private prisons in
middle and low income countries. The good examples of Costa Rica and the Dominican Republic. The
need to persist and become renovated.

Status of prison overcrowding in Latin America and the Caribbean

This presentation is one result among others of the ILANUD/RWI Penitentiary Systems and Human
Rights Programme that ILANUD has been implementing over almost four years with the generous
co-operation of the Raoul Wallenberg Institute of Human Rights and Humanitarian Law, RWI, andthe Swedish International Development Agency, SIDA, 2006-2009, with participation of the nineteen
countries of Latin America.
Since the creation of ILANUD in 1975 the issue of prisons has constituted one of its permanent
programmes. In this area special attention has been paid to prison overcrowding, the most serious
problem that the countries of Latin America and the Caribbean have been facing for the past two
decades, which we measure on the basis of density for every one hundred places.
The two tables below show the current density in the regionʼs penitentiary systems. As can beobserved, the prisons in 25 out of the 29 countries in both tables were overcrowded2, and in mostcases exceeding the critical overcrowding parameter of 120% or over, established by the European
Committee for Crime Problems (Comit? Europeen 1999 : 43) which we also utilize to assess thesituation in the Latin American region.
It is necessary to make clear that due to the following and other reasons the overcrowding situationis actually more serious than these tables show:a) the figures in the tables are averages of the total figures for all prisons in the penitentiary
system of each country. In reality it occurs that there is little or no overcrowding in some facilities
while very high densities even of several hundreds and in inhuman conditions are found in some cases;b) in an attempt to alleviate the serious situation, penitentiary officials do whatever they can
within their narrow range of possibilities, making changes with the furniture and the facilities. They
provide bunk beds, frequently of several tiers of berths (in one case we counted as many as eight
berths per bunk bed); they also convert areas that were devoted to other uses before (for instance,
1

2

A previous version of this document was delivered in the workshop on Penal Reform and Prison Overcrowding
held at the 18th Session of the United Nations Commission on Crime Prevention and Criminal Justice, Vienna
International Centre, April 15th 2009. The translation from the Spanish original was made by Orlando García
Valverde.
The exceptions are Costa Rica, among the countries of the Latin American group, and Belize, Dominica andTrinidad and Tobago in the Caribbean group. The table shows Argentina also without overcrowding, but theﬁgure corresponds only to the Federal Penitentiary Service. In some of the provinces the situation is the same asat the regional level.

131

hallways, recreation rooms, etc.) into sleeping quarters, and build bedrooms in areas that wereformerly open yards or soccer ﬁelds. The result of such transformations is an increase in sleeping
quarter capacity but at the expense of the quality of life in prisons which becomes worse. Prison unit
capacity becomes thus redeﬁned: for instance, a prison with an original capacity for 500 individuals
will now be described as having a capacity for 1,000. This makes it very diﬃcult to measure the actual
capacity of the systems, and it may be asserted that the figures in these tables are optimistic. In
reality densities are higher and frequently very much higher.
It is obvious, we might add, that in addition to being a cruel, inhuman and degrading treatment, as
expressed by the Inter-American Court of Human Rights, critical overcrowding damages all essentialfunctions of penitentiary systems: health, nourishment, rest, visitation, work, education, security ofboth inmates and personnel, etc.
PRISON OVERCROWDING IN COUNTRIES OF LATIN AMERICA
1999-2002

2005-2006

POPULATIONDENSITY
X 100 PLACESPOPULATIONDENSITY
X 100 PLACES

Argentina (02-05)*

52,914

118

Bolivia (99-06)

8,315

162

7,721

207

Brazil (02-06)
Colombia (01-06)

239,345132

401,236173

71,837

136

81,367

117

Costa Rica (02-05)

7,626

110

8,407

99

Chile (01)33,620141

42,532

Dominican Republic (99-05)*

14,188256

13,887138

Ecuador (01-05)

7,859

115

14,331161

El Salvador (02-05)

11,506167

12,853

162

Guatemala (99-09)

8,169

113

10,962128

Honduras (99-06)

10,869209

11,178141

Mexico (00-05)

151,662126

210,140128

Nicaragua (02-05)

6,885

104

6,103

104

Panama (02-05)

10,423

137

11,688161

Paraguay (99-05)

4,088

151

6,290

128

Peru (02-05)

27,417138

37,445

154

Uruguay (01-06)

4,903

151

6,584

145

Venezuela* (00-06)

20,659113

26,047115

COUNTRY

99

E. Carranza, ILANUD*Argentina
Argentina: The 2005 ﬁgure is only for the Federal Penitentiary Service. There was overcrowding in provincial penitentiary services.
*Dominican
Dominican Republic:
Republic The 2002 figures are from the Commission for the Definition, Implementation and Supervision of the Nationʼs
Penitentiary Policy and the calculation was made taking into account only 21 prisons, 12 having been excluded, since according to theCommission《all prisons have collective cells and due to numerous remodeling and expansion works it is impossible to determine exactly
the capacity of the 32 facilities there are in the country.》

PRISON OVERCROWDING IN THE CARIBBEAN 2008
PRISONERS
Antigua & Barbuda

DENSITY PER 100
PLACES

208

131

Bahamas

1,084

129

Belize

1,334

86

254

85

Grenada367

374

Jamaica

4709

111

St .Kitts & Nevis

232

155

Saint Lucia

503

101

St. Vincent & Grenadines

376

188

Dominica

132

Suriname

1,600

135

Trinidad & Tobago

3,510

88

Source: International Centre for Prison Studies, Kingʼs College, London.

It is important to identify the origin of overcrowding in order to be able to reduce it
effectively.

Prison overcrowding in Latin America and the Caribbean cannot be solved simply by making
changes inside prisons. Prison systems are the last link of《an inmate production chain》which
generally starts with the police, continues at the prosecutorial agency and moves on to the courts
before arriving at the penitentiary system which receives and lodges the inmates with a very little
chance or with no chance at all to turn them back or to exert an influence towards correcting
and reducing such《production chain.》 Although a good professional performance on the part ofpenitentiary officials is very important to attain acceptable standards of dignity and respect for thebasic rights of those in prison, the prison staﬀ by themselves have very limited possibilities to reduce
overcrowding, it being indispensable for the prosecutorial agency and the judges to apply preventive
imprisonment and prison sentences more prudently.
Nor can overcrowding be solved simply by building more prisons, although in some cases it isnecessary to build facilities. The countries of the region have a high vegetative population growthrate and some also in terms of immigration. This means that, even if it were possible to maintainconfinement rates stable, prison populations will always show a certain growth that will generally
require additional space.
But it occurs that in addition to the vegetative growth of the countries, populations conﬁnement
rates have also been growing at an accelerated pace with very few exceptions since the end of theeighties and the beginning of the nineties, whereby the absolute figures concerning individuals in
prison have grown impressively having multiplied themselves by 2 and 3 between 1992 and 2008,
and no country has the economic capacity to solve the problem solely by building new facilities (seetables for rates at the end of the document). The origin of such growth of prison rates lies in theoperation of the entire chain of criminal justice system links and in the need to tackle crime and othersocial conﬂicts not only through prison sentences, but also with non penal responses and with penal
responses other than imprisonment, and this also has to do with crime increases, the consequent alarmon the part of the population, and with structural reasons resulting from the manner in which income
distribution has been managed within globalization3. Very rigorous research has been conducted withrespect to the latter, which proves that income distribution inequality measured by the Gini coeﬃcient
has a signiﬁcant and strong eﬀect which results in an increase in the rates of crimes committed against
both individuals and property. This has been measured for the crimes of homicide and robbery andburglary in 39 UN member countries, the co-relation having been veriﬁed within the countries andparticularly among countries (Carranza, E., 2007, 2006; Fajnzilver P. et al., 2002; Bourgignon
F., 2001). It couldn't be by chance that both, crime, and prison populations would grow at such anaccelerated pace and simultaneously throughout the entire region.

Truly comprehensive policies and actions are required

We may conclude from the preceding that public policy concerning crime and criminal justice mustbe truly comprehensive, not merely of a criminal nature, and that it must be accompanied by policies
that will reduce inequality in income distribution. This has been said for years in numerous criminal
policy documents of United Nations where it is explained that crime is a social phenomenon and thatin order to keep crime levels low and to benefit from a good criminal justice it is indispensable toattain good levels of equality in the exchange and distribution of income and development within the
countries and among countries. It is indispensable to insist on this. Otherwise we shall become stuckon the search for《good technocratic practices》rather than satisfying the basic needs of prisons and3

On globalization and how it has been managed see Joseph Stiglitz 2002.

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criminal justice systems. It is the same case as with the basic needs of our societies in terms of health,food, water, education, housing, labour, etc. It has been proven that countries that meet such basic
needs with justice and equality have good ratings in other areas such as culture, art, and sciences, aswell as low levels of social violence and crime.

What to do specifically in penitentiary systems. What not to do. The good examples of Costa
Rica and the Dominican Republic

Once the need for comprehensiveness in policies and actions has been established we must then ask
ourselves what to do speciﬁcally in penitentiary systems to reduce overcrowding and related problems.
In many countries of Latin America and the Caribbean we ﬁnd examples of good penitentiary staﬀ
members who perform their jobs admirably with great dedication although in very diﬃcult conditions.
We observed this again while we were implementing the ILANUD/RWI Programme. However, theseexperiences are generally focused on a province, a prison, or a wing of a prison, and are frequently
individual eﬀorts that normally are not aﬀorded the necessary support or continuity and that become
ultimately interrupted.
Not to preclude other examples that would also deserve to be brought to public attention, weshall refer to two notable cases characterised by the fact that they constitute country-wide nationaland comprehensive reforms where a model has been coherently under development for thirty years
in one case and for ﬁve in the other. In other words we shall not be referring to two《proposals》,
or to two cases of《good practices》but to two speciﬁc realities that have been and are being shaped
comprehensively in the penitentiary systems of two countries, and which have also been accompaniedby considerable coherence and comprehensiveness in terms of actions in their criminal justice systems
and also, to a certain extent, in terms of State policies in other social and economic areas. These are
the cases of Costa Rica and the Dominican Republic. The current model of Costa Rica has been underdevelopment, with small variations, for 30 years. That of the Dominican Republic is younger but willsoon enter into its sixth year of coherent development after three consecutive administrations.
Without ignoring the important differences in terms of history, culture, language, per capita
income, etc., that separate these two countries from the Northern European countries and Canada,
and focusing our appreciation exclusively on penitentiary systems, we feel that both, Costa Rica, andthe Dominican Republic are developing a State penitentiary system that is very similar to that of citedcountries in the areas indicated, although with a necessary adjustment to their situation and realityof middle income countries trying to solve not only the specific overcrowding problem, but that of
the comprehensiveness of their penitentiary systems as well, as the only way to attain success in the
pursuit of better dignity and basic rights standards for both the inmates and the staﬀ, and also as the
only way to do so at a reasonable cost (since prison, by its very nature, is very expensive and requires
a considerable investment).
The model or strategy implemented by both countries has the following characteristics:a) It was introduced thanks to a political decision from the highest level of government: thepresidency of the republic and the respective ministry. This was an essential requirement in bothcountries to install the prison reform;b) Key staff members were very carefully selected on the basis of their vocation, educational
background, knowledge of the subject matter and full-time dedication to the job (head of thepenitentiary system, of the staﬀ training school or institute, and of each prison), as were other oﬃcials
in related areas, such as the head of crime policy.
The prevailing situation in Latin America in general, with exceptions, is that the heads of themain prisons do not arrive at such positions with a background in penitentiary studies or experiencein the ﬁeld or both. Many of them who belong to the army or the police are appointed temporarily

134

in the penitentiary system; others are normally civilians who are appointed in such capacity by thegovernment in power but also without a background in penitentiary studies or experience in the ﬁeld
or both. ILANUD has veriﬁed cases of great functional instability, with a rotation of directors generalevery six months on average.
In Costa Rica the directors general of the Social Adaptation Department are always staﬀ members
selected from among those already in the penitentiary career; so are the heads of prisons and of thePenitentiary Training School. The case of the Dominican Republic is very interesting: two parallelsystems function in the country: the《new》one with eleven prisons already and growing with the
opening of new or remodelled facilities exclusively under new《PST》oﬃcials (VTP4) who enter into
the system after eight months of training at the Penitentiary Training School; and the《old》one whichstill has 24 prisons and which gradually disappears in the course of consolidation of the new system.
All oﬃcials with the leadership of such change have maintained their stability since the beginning of
the process.
c) Continuity has been uninterrupted in the reform programme. It is indispensable for the
penitentiary reform to outlast the diﬀerent administrations and for it to last from eight to ten years
in order to become consolidated. In Costa Rica the process started in 1975 and it has been able tosurvive for eight administrations. In the Dominican Republic it started in July 2003 and it is into thethird administration.5d)

The penitentiary career was created in both countries.

In most countries of the region there is no penitentiary professional career and penitentiary oﬃcials
are not beneﬁted by stability in their positions. Both, Costa Rica, and the Dominican Republic createdprofessional penitentiary careers with the guarantee of stability on the job and social security andretirement beneﬁts.6e) In both countries a training school or institute that selects and trains necessarily all personnel
that enters into the system and that provides continuously in-service training was created. All
penitentiary personnel must be adequately trained and know the institution for which it works as well
as develop an interest in it.
f) In both countries a considerable initial investment was made. The governmental decision toestablish the new system must be accompanied by the necessary resources. Both, Costa Rica, and theDominican Republic devoted considerable initial resources to the project.
It is indispensable to invest on: i) well remunerated personnel and an adequate inmate:staﬀ ratio;ii) facilities; no overcrowded prison can function adequately, just as no hospital, school or any otherinstitution in overcrowding conditions could; iii) an annual budget that would make it possible to makethe necessary expenditures for the system to function adequately, including food, health, education,etc., as well as the monthly salary of the staﬀ.
g) Both countries continued to make regular annual investments. Periodic investment isnecessary to maintain the level and advancement of the system. If the system is neglected the costto recover it is very high, but the most serious consequence is the loss of trust on the part of thestaﬀ and the inmates, who shall interpret that this was one more promise by the politicians in vogue
and that placing your life at stake by opposing very powerful and violent interests that would be456Abbreviation for Penitentiary Surveillance and Treatment in Spanish.
The process started in July 2003; a new administration took over in August 2004 and it was re-elected for the
2008-2012 period.
In Costa Rica technical and professional personnel are protected by the Civil Service administration, andpenitentiary police are protected under the General Police Law and the General Penitentiary Police Regulations.

135

aﬀected by the reform was not worth the risk. Constant investments must be made on: i) personnel,
providing in-service training periodically to all operators to maintain and raise their professional
level (in the Dominican Republic all prison staﬀ without exception beneﬁts at least once a year froma week of training); ii) recruiting new personnel to maintain the adequate inmate:staﬀ ratio; and iii)
infrastructure, adjusting periodically the system's infrastructure capacity. Both, Costa Rica and theDominican Republic have been complying with this requirement.
h) The penitentiary reform did not focus on the overcrowding problem in any of these countries;
nor did it limit itself to the construction of one or several high security, high cost megaprisons. The
purpose of the reform in both countries was to attain comprehensiveness of the penitentiary systemthrough the adoption of dignity and quality standards for all inmates in all prisons, and throughobservance of the principle of equal justice for all. Both, Costa Rica and the Dominican Republicestablished State penitentiary systems to such effect using public resources rather prudently andintelligently.
Oﬀers were made to both countries for construction of private prisons which would lodge only asmall fraction of all inmates and at a very high cost. Initially Costa Rica signed a pre-contract for
construction of a private prison with a capacity for 1,200 inmates for 73 million dollars. Later thegovernment realised its error and did not proceed with the pre-contract; instead it built facilities at its
own expense for 2,600 inmates, more than double the number of inmates, for only 10 million dollars.
The government realised that if it built that prison whose management and maintenance would beundertaken by private enterprise for twenty years at a daily per capita cost of US$37 per inmate while
the cost within the State system was US$11, the cost of operation of that prison alone would keep itfrom being able to make other improvements in the rest of the system which was responsible for 80%of the inmates. The government decided to improve the situation of all individuals under conﬁnement
raising the daily per capita amount for all the population to US$16.
An offer was made also to the Dominican Republic for the building of a similar prison for 1,200
inmates, for 53 million dollars. The government, which had already built and refurbished nine prisonsthat were operating with good quality standards for slightly more than 10 million dollars did not
accept the oﬀer either, and continued with its State comprehensive penitentiary programme which is
generating very good results.
The ILANUD/RWI Penitentiary Programme found several similar cases in other countries of theregion.
The following table explains why, in addition to the inconvenience of their high costs, private
prisons cannot solve the overcrowding problem in middle and low income countries7 while instead theyworsen the situation notably throughout the system.
The introduction of a private prison into a penitentiary system with a minimum budget, several or
many overcrowded prisons, and a shortage of materials and personnel, such as is the case in generalof the penitentiary systems of the Latin American countries since the eighties, creates a situation ofprivilege for a small group, in addition to the fact that it further deteriorates the rest of the system.
We explain this by means of a typical example:
Three years ago countries X and Y built their last prison. Country X built a State prison; country
Y built a private prison. Both countries have 10 prisons with a total capacity for 10,000 inmates, butboth have 15,000 inmates, which is to say that both work at 150% of their capacity. Country X has
10 State prisons; country Y has 9 State prisons and 1 private prison. Let us see its situation in thefollowing tables:
7

136

We use the World Bank country classiﬁcation. In its classiﬁcation all Latin American countries, with the exceptionof Haiti and Nicaragua, are middle income countries. Haiti and Nicaragua are low income countries (World Bank
2005:289, 2000:335).

COUNTRY X WITH A CAPACITY FOR 10,000, BUT WITH 15,000 INMATES
10 PRISONS WITH A CAPACITY OF 1,000 EACH

DISTRIBUTION OF INMATES PER PRISON

0 private prisons0

10 public prisons

1,500
COUNTRY Y

WITH A CAPACITY FOR 10,000, BUT WITH 15,000 INMATES

10 PRISONS WITH A CAPACITY OF 1,000 EACH

DISTRIBUTION OF INMATES PER PRISON

1 private prison

1 000

9 public prisons

1 550

In country X the limited penitentiary resources can be distributed equitably with better results.
However, in country Y overcrowding increases progressively in State prisons while an unfair
distinction of doubtful constitutionality is established between those who are serving time in Stateprisons and the few who are serving time in the private prison in a situation of privilege.
And in countries where the prison population is characterised by a high growth rate, such as inthose of Latin America, overcrowding becomes worse as time goes by; it accumulates inequitably
suﬀocating those in State prisons, in contrast with the privilege of a few who remain, at a very highcost, in the private prison.

The need to persist and become renovatedWe have highlighted the general features of two successful reforms in the region although each
item would deserve a more extensive review. Such a review can be is find in the book “Crime,
Criminal Justice and Prison in Latin America and the Caribbean: How to Implement the United Nations Rights
and Obligations Model” (Elías Carranza et alii, ILANUD/SIGLO XXI, México 2009).
The consolidation in Costa Rica of its new penitentiary system not only solved the endemic
overcrowding problem but it also established a system that is recognised internationally for its lower
level of violence8 and respect for the basic rights of both inmates and staﬀ members. This is the samecase of the new penitentiary system in the Dominican Republic. ILANUD has been able to verify it
in both countries by means of successive visits; it cooperates with both countries in this and othercriminal justice matters, and feels that these are two penitentiary systems that deserve a careful lookon the part of third countries since with the necessary adjustments they may serve as very valuable
orientation in the horizontal processes of the transfer of knowledge.

References
BOURGUIGNON F. 2001
Crime as a Social Cost of Poverty and Inequality: A Review Focusing on Developing Countries . In
Facets of Globalization, World Bank Discussion Paper # 415
CARRANZA El as et alii 2009
Crime, Criminal Justice and Prison in Latin America and the Caribbean: How to Implement the United
Nations Rights and Obligations Model , ILANUD/SIGLO XXI, México.
----------------------- and SOLANA Emilio 2007
Seguridad frente al delito en Costa Rica. Magnitud y manifestaciones de la violencia delictiva en las dosúltimas décadas 《Security(
vis-à-vis crime in Costa Rica. Magnitude and form of violent crime overthe past two decades.》). A document prepared for the State of the Nation Programme. Costa Rica.
----------------------- 2006

8

Prisons, such as close systems in general, are characterised throughout the world by the generation of higher
levels of violence than those that characterise life outside. It is necessary, then, to encourage the greatest
transparency possible in them in order to reduce violence and to reduce the use of prison to the minimum
indispensable level.

137

Distribución del delito y victimización en la sociedad Global 《distribution(of crime and victimisation in
the global society》), ILANUD 2006.
COMITÉ EUROPEEN (1999)
Comité Européen pour les problèmes criminels. Projet de rapport sur le surpeuplement des prisons
et l’inflation carcérale . (European Committee on Crime Problems.《Draft report on prison
overcrowding and overuse of imprisonment.》) (cdpc plenary/docs 1999/18F Add I - Rec CP
Surpeuplement).
FAJNZYLVER Pablo et al. 2002
Inequality and Violent Crime. Journal of Law and Economics, vol. XLV, April.
STIGLITZ Joseph, 2002
El malestar en la globalización 《Globalization(
and Its Discontents》), Taurus, Madrid.
PENITENTIARY RATES IN COUNTRIES OF LATIN AMERICA 1992-2008
IT INCLUDES FEDERAL AND PROVINCIAL/STATE PENITENTIARY SYSTEMS, AND IN SOME CASESINDIVIDUALS HELD IN POLICE PRECINCTS.
Argentina

92

93

94

95

96

97

98

99

00

01

02

03

04

05

06

63

64

68

74

97

96

99

106

118

126

141

157

163

164

152

79

85

101

109

96

80

86

85

74

80

81

107

131

133

132

133

169

182

193

211

219

226

Bolivia
Brasil

119

07

08

Colombia

92

96

97

98

120

129

128

139

157

170

157

178

199

207

179

174

188

Costa Rica

104

105

109

121

133

160

162

169

168

183

187

190

196

196

191

186

189

Chile

154

153

148

153

161

170

179

203

215

216

221

228

226

228

259

290

318

R. Dominicana

145

135

151

161

129

140

165

168

189

150

143

148

164

166

Ecuador

74

81

81

85

95

81

79

70

65

63

69

77

87

91

107

128

118

El Salvador

101

103

109

124

138

157

136

112

130

158

177

180

188

186

184

226

258

101

101

96

87

84

83

88

62

Guatemala75

Honduras

110

113

139

160

166

153

160

178

170

159

148

148

México

101

104

97

101

108

116

127

142

152

163

183
170

177

185

196

200

200

202

Nicaragua

78

78

91

98

111

106

132

143

128

124

131

112

116

117

111

121

120

Panamá

176

215

221

229

269

282

292

294

293

320

341

361

360

359

356

342

275

70

75

74

78

67

74

85

92

107

109

105

99

100

Perú

77

80

83

88

96

100

105

108

108

104

104

108

116

123

136

149

153

Uruguay

96

99

100

99

101

106

120

122

129

148

170

203

215

213

198

212

231

101

112

106

97

85

104

104

103

98

76

96

Paraguay

Venezuela

E.Carranza, ILANUD. Prepared with penitentiary data provided by the governments of each country and population data from the Latin
American and Caribbean Demographic Centre, CELADE.

PRISON RATES IN THE CARIBBEAN
Antigua & Barbuda

1995 (341) 1998 (278) 2005 (269)

Bahamas1998 (478) 2002 (410)

Barbados

1993 (238) 1998 (291) 2002 (317) 2005 (367)

Belize1992 (310) 1995 (293) 1998 (448) 2001 (384) 2003 (420) 2006 (516)Dominica1992 (387) 1995 (392) 1998 (421) 2004 (418)Grenada1998 (352) 2002 (333) 2005 (265)

Jamaica

1992 (178) 1995 (171) 1998 (162) 2003 (176)

St .Kitts & Nevis

1995 (295) 1998 (288) 2001 (441) 2004 (559)Saint Lucia

1992 (210) 1995 (263) 1998 (216) 2001 (296) 2004 (294)

St. Vincent & Grenadines

1992 (294) 1995 (323) 1998 (390) 2001 (270) 2005 (338)Suriname1992 (308) 1995 (302) 1998 (382)Trinidad & Tobago

1992 (269) 1995 (299) 1998 (353) 2001 (370) 2004 (302)

Source: International Centre for Prison Studies; Kingʼs College, London.

138