This question will be
addressed in two natural parts, firstly with reference to Natural Law and
secondly discussing a utilitarian approach. This paper will consider capital
punishment in the context of the common good, retribution and conflict with
sanctity of life. Utilitarian justifications of deterrence, mistake,
incapacitation, and societal demand will then be discussed. The analysis of these arguments will be based
on the teachings of Aquinas, Bentham, and Mill in order to assess their
compliance with their respective theories. It will be shown that neither
Natural Law nor utilitarianism is able to justify the usage of capital
punishment.
I
In a Natural Law assessment
of punishment, Aquinas states, presuming an individual person ‘stands in
relation to a whole’,[1]
it is justified on that basis, to execute that person if it were to protect and
maintain the common good.[2]
He qualifies this by saying that those who sin deviate from rational order, surrendering
their human worthiness in doing so, and it is therefore justified to kill that
person just as it is justified to kill a beast. For an evil man is worse than a
beast and more harmful.[3]
A difficulty with this argument is that capital punishment is not necessarily
required to preserve the common good. Alternatives such as banishment or
imprisonment may be equally effective in doing this.[4]
If a primary objective is to preserve the common good, it does not denote what
kind of punishment is required to achieve that preservation, only that preservation
itself is needed. If capital punishment is not required, it follows that a less
severe punishment might be preferred if it is just as effective.
Finnis develops this by
stating legal sanctions constitute punishment, and are ‘required in reason to
avoid injustice, to maintain a rational order or proportionate equality, or
fairness’ for society.[5]
He goes on to say that punishment ‘rectifies a disturbed pattern’[6]
and therefore it is justified to rectify that by creating a proportionate
disturbance onto the original offender. However, this position strongly
resembles one of restitution, to which Grisez responds by saying that it is
obvious that the death penalty does not accomplish this. Victims of crime do
not gain anything when a criminal is executed.[7]
If anything, capital punishment limits restitution, as the criminal ceases to
be able to perform rectifying measures when he is put to death; where capital
punishment is framed in this sense, it is perhaps unwarranted.
An assessment of capital
punishment is not complete without an examination of retributive justice.[8]
Calvert submitted that is was beyond doubt that retributive features of
punishment were a part of Natural Law theory.[9]
In a state of nature, injured individuals seek this against one another in accordance
with Natural Law, and in a state of government, this is enforced through law.[10]
Kant’s description of retributivism is perhaps the ‘most influential’[11]
where he submits that ‘if…he has committed a murder, he must die’ and they must
be executed ‘so that each has done to him what his deeds deserve’.[12]
Kant went as far as to say retribution was the only justification for
punishment,[13]
but rejected the teleological arguments of Aquinas.[14]
Kant’s ‘stringent’[15]
version of this justification is seldom used to defend punishment with
retribution alone.[16]
What this suggests is that certain punishments might need to find other
validations, other than retribution, if it is to be justified. Nevertheless,
Calvert finds that this interpretation of Thomistic retributivism enjoys an
important status within Natural Law and thus its examination is necessitated.[17]
Bedau splits the retributive argument into two principles. Firstly, that crimes
ought to be punished, and secondly that the severity of the punishment ought to
be proportional to the offence.[18]
An examination of this first
argument surfaces no assistance in determining what methods crimes should be
punished,[19]
only that crime per se should be punished. If the lex talionis principle of an
‘eye for an eye’ is used to justify capital punishment for murder, it sits
rather uncomfortably within justice systems that could not permit the same
application for all crimes.[20]
As Bix states, what is the proposed punishment for tax fraud under lex
talionis?[21]
Furthermore, this doctrine fails in another respect, as it supposed that all
murderers are to be executed, without qualification. Equally, why do those who
inflict heinous disfigurement or torture to their victims escape a harsher
penalty, whereas a mercy killer would not? Additionally, if a punishment is to
be a mirror of its crime, an incredibly small number of murders resemble
anything like that of an execution.[22]
As Camus explains, the death penalty could only give equal punishment to those
who had warned their victim of their scheduled death, kept them captive for
months prior, then killed them.[23]
Consequently, lex talionis cannot account for varying degrees of severity
within the crime of murder, and cannot apply universally to all criminal
offences. Therefore, it is perhaps inappropriate as a moral justification of
capital punishment.
Abandoning lex talionis, a
secondary retributive argument maintains that as murder is the most severe of
crimes, it should receive a proportionally severe punishment.[24]
Again, this argument does not justify the death penalty in itself, as it leaves
the following question unanswered: what is proportionally severe? This question
is unhelpful as it leaves ‘ample room for controversy’.[25]
Yet this principle need not be rejected as it is compatible with systems of
imprisonment. Bedau argues that it is quite possible for this doctrine to be
accepted by a Natural Law theorist but that it does not justify capital
punishment any more than it justifies maiming or torture.[26]
Finnis concurs, and states that there is no ‘absolute measure of due
punishment’, such as lex talionis, for it incorrectly focuses on the
consequences of a criminal act rather than its ‘formal wrongfulness’.[27]
Seemingly, retributive arguments, although strong in substance when justifying
punishment generally, fail in justifying specific penalties.
Where Natural Law maintains
retributive features, it perhaps does not follow if capital punishment is to be
rejected one need not reject a general Natural Law theory too. If retributive
is a form of vengeance, as Schwed accepts it is,[28]
then it is perhaps a primitive concept which society has progressed to condemn.
It follows that we should reject it in a civilised society.[29]
Where Aquinas clearly found support for capital punishment within Natural Law,
the question then becomes: can Natural Law change? Although primary precepts of
Natural Law are unchangeable, capital punishment is a secondary precept,[30]
as it is a remote conclusion[31]
from the sustaining of the good of human life.[32]
As secondary precepts can change when additional sources of moral obligation
are discovered,[33] it
follows that if Schwed’s above assertion is accepted, approval of Natural Law
may no longer denote approval of capital punishment. Consequently, Aquinas’
theory may survive even in a climate that denounces the death penalty.
Furthermore, it is argued that
the notion that crimes ought to be punished by death is perhaps in immediate
conflict with the primary Natural Law precept of the sanctity of human life.[34]
If accepted, it is argued that the death penalty becomes morally indefensible
ab initio.[35]
Locke however views this primary precept as a right to life, and argues it is
forfeited when a person has violated that right in another, or commits an act
deserving death.[36]
Yet this doctrine of forfeiture encounters the same problem as Aquinas’ theory
of the common good, it applies the death penalty ‘sweepingly’, and equally
justifies application to relatively minor offences.[37]
It is further flawed as it does not determine to whom such right is forfeited,
nor does it stipulate whether it can be restored.[38]
Furthermore, it is submitted that there is a difference between forfeiting one’s
right to life, and forfeiting one’s life. It does not suppose that there is a
duty on whoever that right is forfeited to, that they must destroy it.[39]
Locke’s theory is drawn from the presumptions that punishment must be
retributive. Yet Locke fails to consider alternative punishment as being
equally retributive in nature, and that ‘there is no intrinsic feature of any
natural right…that makes it subject to loss through forfeiture.’[40]
It is seen perhaps that Natural Law is unable to deduce the customs of
punishment, and is therefore ill equipped to provide justification for the
death penalty.[41]
II
Turning
to a utilitarian assessment, the foundation of the theory states that the test for
judging social arrangement is whether they maximise utility, or, whether they
achieve the greatest happiness of the greatest number.[42]
This is termed the ‘felicific calculus’. This paper adopts a ‘rule-utilitarian’
stance, supposing that a standard of moral rules that are publically accepted
will produce the best utilitarian consequences.[43]
Deterrence is a primary consideration to the utility of capital punishment.[44]
Bentham judged deterrence as a chief utility of punishment,[45]
and considered it to be the ‘real justification’.[46]
Therefore, if deterrence is absent, utilitarianist justifications greatly
diminish. The argument is put that criminals who are executed deter potential
wrong doers from carrying out crimes of their own.[47]
If the deterrent effect of the punishment were to result in the greater net
good, capital punishment would be permissible.[48]
Utilitarianists propose that the death penalty would be ‘justified if the
number of lives saved exceeded the number of executions.’[49]
Presuming the guilty are to be executed, deterrent effects of capital
punishment must be justified in practical terms. It has been found that there
is no conclusive evidence to demonstrate a deterrent effect of capital
punishment,[50]
which was accepted by the US Supreme Court.[51]
These findings are echoed worldwide,[52]
and somewhat overwhelmingly, 88% of criminologists concur that capital
punishment does not have a deterrent effect greater than life imprisonment.[53]
Yet Passell claims that a deterrent effect is incapable of empirical
measurement,[54] and
that Bentham’s paramount utility can only be tested intuitively. A modern
interpretation of this reasons that the more severe the punishment, the greater
utility in deterrence.[55]
However it is submitted that ‘common-sense’ arguments fail with equal measure,
for it is extremely unlikely that there are potential murderers ‘straining at
the leash’ waiting to commit murders at the point of the death penalty’s
abolition.[56]
It is perhaps even more unlikely that murderers calculate their crimes on the
likelihood of capture or execution.[57]
On
a further utilitarianist inspection, one finds the possibility of error to be a
concern to the greater good. Put simply, this is the inherent risk that capital
punishment carries the ability to execute innocent lives due to factual error.
This problem is clearly universal to all punishment, but whereas compensation
can be sought for those falsely imprisoned, no such remedy is available to the
deceased. Cases such as Derek Bentley[58]
and Timothy Evans[59]
are but a few prominent examples where innocent lives have been executed due to
factual mistake. The Council of Europe has determined that it is ‘presumed or
established’ that 27 innocent people have been put to death from 1853 to 1953.[60]
A great social cost is incurred through such miscarriages of justice, and the
problem, when viewed on a global scale, is significantly magnified. Yet as the
families of those who have had their relatives executed have little gain from
seeking posthumous pardons, it is suggest that the true number of miscarriages
of justice is far greater than currently established.[61]
Considering this assertion, the cost to society may outweigh the benefit in
utilitarian terms. As legal errors are far more common than factual mistakes,
Amsterdam suggests that many more innocent lives have been taken at the hands
of capital punishment.[62]
Amsterdam
continues, with particular reference to the US, to say that there have been
many occasions where misinterpretations of the law have led to miscarriages of
justice.[63]
It was held that capital punishment was illegal for the mentally ill,[64]
those under 18,[65]
and as punishment for rape.[66]
For the miscarriages of justice that preceded these decisions, the hundreds
executed who fell into the aforementioned categories had been illegally put to
death at the hands of the state. From this, it is evident that great social
cost is shouldered by the possibility of mistake in both legal and factual
form. The less severe punishment of imprisonment is perhaps less costly, and in
turn, contributes to the greatest happiness. It provides an avenue of
reversibility, and compensation where the offender can be made reasonably whole
for his lost liberty,[67]
whereas the death penalty is unable to do so. The risk of killing the innocent
is perhaps too high to justify the death penalty.[68]
Despite
the cost borne from error, it is argued a utility of capital punishment is
served in the form of incapacitation. Mill specifically referred to a central
principle that punishment in purpose is to ‘prevent harm to…others’.[69]
As a criminal is executed, he is no longer able to commit crimes in public or
when incarcerated, and a preventative utility is, in theory, served.[70]
Yet Sellin argues that this is ‘not a feasible policy’, as judges or juries
cannot predict the future behaviour of convicted criminals.[71]
Where the issue of killings in prison arises, Bedau argues that such murders
are almost always committed by criminals who are imprisoned for crimes that are
disproportionate to apply the death penalty to.[72]
Those convicted of murder are statistically the least likely to commit another
murder,[73]
whereas armed robbers are the most likely.[74]
So, implementing the death penalty solely for the crime of murder would not
fulfil an incapacitative utility. A utilitarian theory might therefore justify
the execution of armed robbers but not murderers. Clearly this is unacceptable
to the rule-utilitarian, and fails to take adequate account of the
proportionality of punishment. Although a slight utility may be found for the
execution of armed robbers, it might come at too great a cost to society
considering the inherent unfairness of an inordinate application.
Beccaria posited a far narrower incapacitative
justification to capital punishment; where to not execute an influential
individual would produce a dangerous revolution due to their power and
connections. He qualifies to say that conditions of anarchism and disorder must
have replaced the rule of law to justify such an execution.[75] Beccaria’s justification sits
uncomfortably with Bentham’s view that capital punishment is ‘more susceptible
(to) abuse than any other mode of punishment’.[76]
In a state of anarchy, accepting a justification for an execution in
exceptionally narrow circumstances amplifies the risk of abuse. Furthermore, such
an execution is likely to invite the re-introduction of the death penalty where
legislation had previously abolished it.[77]
It could be argued the danger of permitting an execution, especially where
society is at its most fragile, would cause far greater societal pain than it could
possibly prevent.[78]
Hart stresses that
utilitarianism, with reference to punishment, is not limited to considering the
harm of particular crimes punished, but should also account for the wider costs
of societal injury.[79]
A further argument to justify the death penalty is thus found in the form of
satisfying a popular demand. Hart entertains this argument by saying that the
death penalty may be justified by a public lust for revenge, for to not do so
may cause societal disorder.[80]
Such disorder could be considered a great social cost, and it follows that the
detriments the death penalty carries my be offset by a wider implication of
societal demand. Justice Stewart in Furman
v Georgia stated that ‘the seeds of anarchy, of self-help, vigilante
justice, and lynch law’ are sown where organised society is unable to impose
capital punishment.[81]
Public support for the death penalty in most western societies has consistently
remained in favour of its use.[82]
As there is no evidence imprisonment rather than death ‘encourages private
blood feuds and other disorders’,[83]
it would be highly improbable in modern western societies to see true vigilante
justice in lieu of abolition. There is, however, a prevailing presumption this
may not be the case for the rest of the world.[84]
Use of capital punishment is
most prevalent in Middle Eastern countries,[85]
perhaps due to strong religious justifications from Islamic scripture.[86]
When viewing this argument in the context of the deeply rooted cultural
approval in the Middle East, quelling public disorder might become a far more
realistic utility. In 2016, at least 87% of worldwide executions were confined
to Iran, Saudi Arabia, Iraq and Pakistan.[87]
Within these countries, it is typical for 99% of the population to be of Muslim
faith,[88]
suggesting that justice might be taken into the hands of those societies to
enforce Sharia if the state refused. This argument could be persuasive if the
death penalty was applied with uniformity in the Middle East, yet this is not
the case. Prior to the Arab spring, executions in the Middle East were ‘not the
norm’,[89]
whilst last year, 10 of 18 Middle Eastern countries with majority Muslim
populations did not carry out any executions.[90]
With no examples of the anarchy in those abolitionist states, it seems there is
‘nothing inherently Islamic’ about capital punishment.[91]
A more prominent flaw is that
a satisfaction of the public demand to avert anarchy ignores factual innocence.[92]
Regardless of the accused’s guilt or innocence, his death is required to avoid
the spiral of citizen violence. This argument not only readily accepts that the
public is correct in its assumption of guilt, but fails to account for where
society is wrong and still justifies the death of an innocent individual.
McBride argues the condemned are then not more than ‘sacrificial lambs’,[93]
serving as scapegoats to please the public. Justifying capital punishment on
this basis would be incompatible with utilitarianism, as a legal system which
arbitrarily punishes its society would result in an anxious and fearful public
uncertain of when a court would require their death.[94] It would seem the utility of executing the
innocent could not outweigh preventing disorder when considering the greater
good.
As well as failing to
consider mistake, the argument also fails to consider that an anarchical,
vigilante public mentality is often transient. Whilst the death sentence for
former Egyptian president Hosni Mubarak was called for by tens of thousands
protesting in 2011, his acquittal in
2017 stirred a nonchalant public response, and nothing that resembled anarchy.[95]
Where public lust is temporary, death, however, is not. The lack of examples to
support Justice Stewart’s argument, combined with the availability of the more
reversible alternative of life imprisonment, appears to show an absence of real
utility for the death penalty concerning vigilante justice.
In
conclusion, this paper finds that arguments spawned from retribution and
secondary precepts of Natural Law do not necessarily justify capital punishment
per se. These philosophies are merely assistive in justifying punishment and
its proportionality, but to submit that these automatically justify the use of
the most severe punishment can be answered simply depending on what is
subjectively defined as most severe. As shown, lex talionis is no more
assistive. On a utilitarian examination, this paper finds that although there
is perhaps some benefit in the use of the death penalty, it is too small to
offset the benefits of alternative punishments such as life imprisonment.
Furthermore, arguments pertaining to deterrence and incapacitation as utilities
of punishment do not have the empirical evidence to determine them overwhelming
in a felicific calculation. Utilities of vigilante justice appear to lack
example to support the hypothesis and seem to be unable to offset issues of
miscarriages of justice, and the failings of deterrence and incapacitation.
Ultimately, neither natural law nor utilitarianism justifies the use of capital
punishment.
[1] Brian Calvert, ‘Aquinas
on Punishment and the Death Penalty’, (1992) 37 Am.J.Juris, 259, 265.
[2] St. Thomas Aquinas, Summa Theologiae, (Ava Maria Press,
2000) II-II, q.64, a. 2 and 3.
[3] Ibid a. 2.
[4] Germain Grisez,
‘Towards A Consistent Natural-Law Ethics of Killing’, (1970) 15 Am.J.Juris, 64,
67.
[5] John Finnis, Natural Law and Natural Rights (OUP,
2011) 262.
[7] Grisez (n 4) 70.
[8] Hugo Bedau, ‘Capital Punishment’ in Tom Regan (ed) Matters of Life and Death (Random House,
1980) 185.
[9] Calvert (n 1) 273.
[10] Philip Hamburger,
‘Natural Rights, Natural Law, and American Constitutions’, (1993) 102(4) Y.L.J.
907, 950.
[11] Ted Honderich, Punishment (Hutchinson & Co, 1969) 11.
[12] Immanuel Kant, The Metaphsics of Morals (Mary Gregor
(tr), CUP, 1996) 104-110.
[13] John Salmond, Jurisprudence (Sweet & Maxwell,
1937) 148.
[14] Calvert (n 1) 274.
[15] Brian Bix, Jurisprudence: Theory & Context (Sweet
& Maxwell, 2012) 125.
[16] Ben Wortley, Jurisprudence (Manchester University
Press, 1967) 436.
[17] Calvert (n 1) 276.
[18] Bedau (n 8) 185.
[19] Claire Finkelstein,
‘Death and Retribution’, (2002) Crim.Just.Ethics, 12, 16.
[20] Finkelstein (n 19) 13.
[22] Ibid 188.
[23] Albert Camus, Resistance, Rebellion, and Death, (Knopf,
1961) 199.
[24] H.L.A. Hart, Punishment and Responsibility; Essays in the
Philosophy of Law (OUP, 1968) 233-234.
[25] Bix (n 15) 125.
[26] Bedau (n 8) 188.
[27] Finnis (n 5) 264.
[28] Roger E. Schwed, Abolition and Capital Punishment (AMS Press,
1983) 43.
[30] Peter Black, ‘Do
Circumstances Ever Justify Capital Punishment’, (1999) 60 Theological Studies
338, 345.
[31] Ross Armstrong, Primary and Secondary Precepts in Thomistic
Law Teaching (Martinus Nihoff Publishers, 1966) 111.
[32] Aquinas (n 2) I-II,
q.94 a. 2c.
[33] Black (n 30) 344.
[34] Aquinas (n 2) I-II, q.
94 a. 2c.
[35] Bedau (n 8) 161.
[36] John Locke, Second Treatise of Government (Whitmore
and Fenn, 1821) 338.
[37] Bedau (n 15) 163.
[38] Ibid.
[39] Ibid 165.
[40] Bedau (n 15) 163.
[42] Ibid.
[43] Kent Greenawalt,
‘Punishment’ (1983) 74 The Journal of Law and Criminology 343, 354.
[44] Thorsten Sellin, The Penalty of Death (Safe Publications,
1980) 3.
[45] Eric Reitan, ‘Why the
Deterrence Argument for Capital Punishment Fails’ (1993) 12(1) Crim.Jus.Ethics
26, 28.
[46] Ted Honderich, Punishment (Hutchinson, 1969) 40.
[47] Glen D. King, ‘On Behalf of the Death Penalty’, in Hugo
Bedau (ed), The Death Penalty in America (OUP,
1980) 308.
[48] Grisez (n 4) 64.
[49] Jonathan Glover, Causing Death and Saving Lives (Penguin,
1990) 233.
[50] Sellin (n 44) 20-29.
[51] Gregg v Georgia 408 U.S. 153 [1972] 185.
[52] Brian P. Blcok &
John Hostettler, Hanging in the Balance:
A History of Capital Punishment in Britain (Columbia University Press,
1983) 262.
[53] Michael Radelet &
Traci Lacock, ‘Do Executions Lower Homicide Rates?’ (2009) 99 J.Crim.L &
Criminology 489, 501.
[54] Peter Passell, ‘The Deterrent Effect of the Death Penalty: A
Statistical Test’, In Bedau & Pearce (eds), Capital Punishment in the United States (AMS Press, 1976) 410.
[56] Hart (n 24) 84.
[57] Van Den Haag (n 55) 65.
[58] R v Bentley [1998] EWCA Crim 2516.
[60] Glover (n 49) 234.
[61] Van Den Haag (n 55) 60.
[62] Anthony G. Amsterdam,
‘Capital Punishment’ in Hugo Bedau (ed), The
Death Penalty in America (OUP, 1980) 349-350.
[63] Amsterdam (n 62) 349.
[64] Ford v Wainwright 477 U.S. 399 [1986].
[65] Roper v Simmons 543 U.S. 551 [2005].
[67] James Michael Martinez,
The Levaithan’s Choice (Rowman &
Littlefield Publishers, 2002) 264.
[68] Bedau (n 8) 182.
[69] John Stuart Mill, On Liberty in Mary Warnock (Ed), Utilitarianism (Word Publishing, 1962)
135.
[70] Sellin (n 44) 354.
[71] Ibid.
[72] Amsterdam (n 62) 354.
[73] Richard A. McGee, ‘Capital Punishment as Seen by a Correctional
Administrator’, in James McCafferty (ed), Capital Punishment (Aldine-Atherton, 2009) 163.
[74] Amsterdam (n 62) 354.
[75] John Hostettler, Cesare Beccaria – The Genius of ‘On Crimes
and Punishments’ (Waterside Press, 2010)
53-54
[76] Hugo Adam Bedau,
‘Bentham’s Utilitarian Critique of the Death Penalty’, (1983) 74 Journal of
Criminal Law and Criminology 1033, 1054.
[77] Ibid.
[78] Werner J. Einstadter, Criminological Theory: An Analysis of its
Underlying Assumptions (2nd Edn, Rowman & Littlefield
Publishers, 2006) 66.
[79] Hart (n 25) 72.
[80] Ibid.
[81] Furman v Georgia 408 U.S. 238 [1972] 308 (not correct)
[82] Roger Hood, The Death Penalty (OUP, 2002) 26.
[83] Gregg v Georgia 408 U.S. 153 [1972] 428.
[84] Oxford Human Rights
Hub, ‘The Death Penalty in the Middle East and North Africa’ (10th
February 2017) < https://soundcloud.com/oxhrh/rightsup-rightnow-the-death-penalty-in-the-middle-east-and-north-africa>
Accessed 30th November 2017.
[85] Benjamin Haas ‘Amnesty
Criticises ‘rogue state’ China as Global Death Penalty Falls’ (Guardian, April
11th 2017)
<https://www.theguardian.com/world/2017/apr/11/amnesty-criticises-rogue-state-china-as-global-death-penalty-toll-falls>
accessed 16th Nov 2017
[86] Rita James Simon &
Dagny Blaskovich, A Comparative Analysis
of Capital Punishment (Lexington Books, 2007) 10.
[87] ‘The Death Penalty in
2016: Facts and Figures’ (Amnesty, April 11th 2017)
<https://www.amnesty.org/en/latest/news/2017/04/death-penalty-2016-facts-and-figures/>
Accessed 14th Nov 2017
[88] ‘The Future of the
Global Muslim Population’ (Pew Research Centre, January 2011)
<http://features.pewforum.org/muslim-population/> Accessed 9th
Nov 2017
[89] Brian Whitaker ‘Death
Penalty is not the Norm in the Middle East’ (Guardian, October 11th
2010) <
https://www.theguardian.com/commentisfree/2010/oct/11/death-penalty-middle-east>
accessed 10th Nov 2017
[90] The Death Penalty in
2016 (n 87)
[91] Oxford Human Rights Hub
(n 84)
[92] James McBride, ‘Capital
Punishment as the Unconstitutional Establishment of Religion: A Girardian
Reading of the Death Penalty’, (1995) 37 J.Church & State 263, 265
[94] Manuel Velasquez, Philosophy: A Text with Readings (10th
edn, Cengage Learning, 2007) 467.
[95] Declan Walsh, ‘Egypt
Roared as Mubarak Fell. It’s Mute as He’s Freed’ (The New York Times, March 24th
2017) < https://www.nytimes.com/2017/03/24/world/africa/hosni-mubarak-egypt.html>
Accessed 30th November 2017.