THE INJURED PARTY IN SOMALILAND CRIMINAL PROCEDURE: PROCEDURAL STATUS, STATUTORY RIGHTS AND PROSECUTORIAL RELATIONAHIP Mohammed Ahmed Abdi Ba’aluul October, 2026.

 

THE INJURED PARTY IN SOMALILAND CRIMINAL

PROCEDURE: PROCEDURAL STATUS, STATUTORY

RIGHTS AND PROSECUTORIAL RELATIONAHIP

Mohammed Ahmed Abdi Ba’aluul

October, 2026.

 

CHAPTER ONE: INTRODUCTION AND METHODOLOGICAL BLUEPRINT

1.1 Context, Research Axis, and Core Questions

The position of the injured party (persona offesa) in criminal proceedings raises a basic question about the relationship between state authority and private redress (Bassiouni 1993). In Somaliland, criminal procedure is governed by the Criminal Procedure Code (Legislative Decree No. 1 of 1 June 1963), which continues to operate within the constitutional framework established by Article 130(5) of the Somaliland Constitution. The Code’s allocation of powers between public prosecutors and injured parties therefore calls for close doctrinal examination (Tonini 2017).

It is tempting to assume that recognition as an injured party automatically brings an independent role in criminal proceedings or standing equal to that of the state. The statutory position is more limited and requires closer analysis (Grevi 2014). This study asks whether the 1963 Code allows shared prosecutorial authority, recognises an independent private actor, or instead produces structural subordination: the injured party has a recognised legal status and can influence proceedings in specific ways, but does not hold ultimate control over the criminal action (Delmas-Marty and Spencer 2002).

The study examines this question through eight connected research questions:

•   Power Distribution: How does the Code distribute procedural powers between the injured party andpublic prosecuting authorities?

•   Procedural Autonomy: Is the injured party an independent procedural actor under Article 14(1)?

•   Control vs. Influence: Does the injured party possess procedural control over investigations, or merelyprocedural influence?

•   Compulsion: Can the injured party compel prosecution against the will or inaction of the state?

•   Charge Termination: Can the prosecution terminate or withdraw charges under Article 112 despite theinjured party’s objection?

•   Subsidiary Prosecution: Can the injured party independently initiate or continue criminal proceedings(azione penale privata)?

•   Review Rights: Does the Code provide a statutory mechanism for the injured party to challengeadministrative prosecutorial dismissals or file closures (archiviazione)?

•   Appellate Standing: Does the injured party possess independent standing to appeal criminalconvictions, acquittals, or civil damages awards?

1.2 Doctrinal Methodology and Four-Stage Analytical Process

To answer these questions, the study uses a four-stage doctrinal method based on close statutory reading and established legal research practice (Hutchinson 2016). Figure 1.1 summarises the process, which moves from the wording of the Code to an overall assessment of the injured party’s position:

• Figure 1.1: Four-Stage Doctrinal Methodology for Analysing the Injured Party’s Standing

◦ Stage 1: Provision-by-Provision Statutory Verification — Direct textual examination of statutory provisions across all procedural phases, from initial reporting to appellate review.

◦ Stage 2: Capacity Categorization — Systematic separation of the injured party’s distinct procedural roles (informant, complainant, witness, civil claimant) to avoid conceptual conflation (Italian Codice di Procedura Penale 1930).

◦ Stage 3: Functional Power Testing — Evaluation of specific statutory permissions, constraints, and omissions to determine whether private actions can direct, alter, or halt public proceedings.

◦ Stage 4: Doctrinal Synthesis — Aggregation of statutory findings to deliver an objective determination regarding the injured party’s true institutional standing relative to the state's prosecutorial monopoly.

Figure 1.1 therefore shows how the analysis moves from individual provisions to a broader account of institutional power.

1.3 Conceptual Framework, Variables, and Operational Definitions

A. The Core Variables

The study examines the relationship between four main variables:

•   Independent Variable (Public Prosecution Architecture): The statutory monopoly over penalinvestigation, charging, trial direction, and charge discontinuation granted exclusively to state authorities under Articles 1, 12, 13, and 112 of the CPC.

•   Dependent Variable (Injured Party Standing): The statutory status, participatory capacities, andprocedural rights granted to the persona offesa under Article 14(1) across the pre-trial, trial, and appellate phases.

•   Mediating Variables (Analytical Boundary Filters): The conceptual tools used to measure therelationship between public power and private participation without distortion—specifically, the distinction between procedural control and procedural influence, the four-way doctrinal distinction, and the Category A/B/C framework.

•   Outcome Variable (Structural Subordination): The cumulative doctrinal reality emerging from statutorysynthesis, proving that recognized the status of the injured party coexists with exclusive state control over public criminal action while recognizing legally defined forms of victim influence.

B. Operational Definitions

Four working concepts guide the analysis:

•   Procedural Control vs. Procedural Influence:

•   Procedural Control: The authority to direct investigations, change charges, compel prosecution, or endproceedings. Under Articles 1 and 112, these powers belong to state authorities.

•   Procedural Influence: The ability, where the Code allows it, to prompt state action, provide evidence, orprevent proceedings from starting unless a required condition is met. Examples include reporting an offence (Article 17), filing a formal complaint (Article 21), giving evidence (Articles 103 and 135), and bringing a civil claim (Article 14(2)).

2. The Four-Way Doctrinal Distinction: This distinction keeps four legally different capacities separate (Roxin and Schünemann 2014):

Criminal participation ≠ Complaint Standing ≠ Civil Claimant Standing ≠ Appellate  Standing.

A right or status in one of these areas does not, by itself, create a right or status in another.

3 .The Category A / B / C Analytical Framework: This three-part classification is used to assess statutory rules and gaps:

•   Category A (Express Prohibition): Explicit statutory provisions barring private action.

•   Category B (Conditional Permission): Statutory rights granted subject to strict procedural conditions(e.g., complaint timeframes or civil claim deadlines).

•   Category C (Statutory Silence): Legislative omissions. Silence is not treated as either an expressprohibition or an implied right. It means that an injured party may lack an operative route to act where the Code provides no enabling procedure.

4.The Accessory Civil Model (Accessorium Sequitur Principale): Governed by Articles 14, 119, and 130–131, this tool evaluates how private civil claims attached to criminal proceedings remain structurally tethered to the public criminal action, collapsing inside the penal forum upon a merits-based criminal acquittal (Article 130(2)).

1.4 Structural Roadmap of the Doctrinal Study

Table 1.1 gives the reader a guide to the study. It links the main findings to the relevant provisions, research questions, and analytical categories across the five chapters.

• Table 1.1: Structural Roadmap of the Doctrinal Study

Finding #	Doctrinal Finding Summary	Governing Provisio ns	Addressed Research Questions	Analytical Category
1	Recognized Legal Identity Without Autonomy	CPC Arts. 1, 14(1)	Questions 1 & 2	Category C (Silence)
2	Procedural Influence via Gatekeeping Veto	CPC Arts. 17, 21	Questions 3 & 4	Category B (Conditional)
3	Absolute State Control Over Public Penal Action	CPC Arts. 1, 12, 13, 112	Questions 5 & 6	Category A (Monopoly)
4	Subordination of Legal Representation	CPC Art. 15(6)–(7)	Questions 1 & 2	Category A/C
5	Accessory Dependence of Civil Claims	CPC Arts. 14, 119, 130	Questions 1 & 8	Accessory Model
6	Bifurcated Appellate Standing & Silence	CPC Arts. 208, 211, 226, 230	Questions 7 & 8	Category B vs. C
7	Structural Subordination (Outcome Variable)	Synthesis of All Chapters	Overarching Research Axis	Cumulative Reality

Note: Developed by the author to map doctrinal progression from starting point in the Code to overall assessment.

CHAPTER TWO: STATUTORY STATUS, REPRESENTATION, AND THE LIMITS OF INDEPENDENT ACTION

Introductory Transition

Chapter Two first locates the injured party’s procedural position within scholarship on procedural justice and victims’ experiences. That literature provides context for the importance of the inquiry but does not determine the meaning of the Somaliland Criminal Procedure Code. The chapter then turns to the Code’s allocation of public prosecutorial power alongside its recognition of the injured party under Article 14(1), asking whether that recognition creates an independent procedural role or leaves the injured party with more limited forms of participation and influence.

2.1 Scholarly Perspectives on Victim Participation and Procedural Justice

The injured party’s position in criminal proceedings is not only a question of statutory classification. It also belongs to a wider scholarly discussion about procedural fairness, the experience of being heard, and the relationship between individuals and public justice institutions. This literature helps explain why the legal position of an injured party warrants examination, while leaving the interpretation of Somaliland law to the Code itself.

The procedural-justice literature associated with Lind and Tyler (1988) and Tyler (1990) emphasises that people’s assessments of legal authorities are shaped not only by outcomes but also by how procedures are conducted. Perceived fairness, respectful treatment, and opportunities to express one’s views can influence how people understand the legitimacy of legal institutions. These works provide a conceptual reason to take procedural treatment seriously; they do not establish that any particular participatory right exists under the Somaliland Criminal Procedure Code.

Victim-focused research develops this concern by examining how victims experience their encounters with criminal justice institutions. Laxminarayan, Henrichs and Pemberton (2012), in a study of victims in the Netherlands and New South Wales, examine perceptions of procedural and interactional justice, including process control and decision control. Their findings illustrate that victims’ perceptions of justice can involve both the manner in which they are treated and the degree of influence they perceive themselves to have. The study is relevant here as contextual scholarship, not as a legal comparison with Somaliland.

Other scholarship draws attention to the possible costs of poorly managed encounters with the justice system. Herman (2003) discusses the potential benefits of seeking justice alongside the risks that legal processes may create for victims, including the possibility of retraumatisation. Wemmers (2013), examining victims’ experiences as cases pass through the criminal justice system, reports an association between unfair procedures and victims’ recovery. These studies underline why institutional treatment matters, but their findings should not be assumed to describe victims’ experiences in Somaliland without local evidence.

A systematic review by Laxminarayan, Bosmans, Porter and Sosa (2013) examined factors associated with victims’ satisfaction with criminal justice. The review identified factors relating both to procedure and to outcomes, while noting that the findings across studies were mixed. This qualification is important: the literature supports careful attention to victims’ procedural position, but it does not justify a universal claim that one procedural arrangement will produce the same experience or response in every setting.

For the present study, this scholarship performs a limited and deliberate function. It explains the broader intellectual and institutional significance of examining the injured party’s position and acknowledges earlier contributions to the field. It does not supply an independent source of legal rights, determine the meaning of any CPC provision, or replace the provision-by-provision doctrinal method. Whether the injured party may report an offence, lodge a complaint, participate in proceedings, pursue a civil claim, or appeal a decision must be established from the applicable statutory text. The following sections therefore return to the Somaliland Code and distinguish legal status, conditional permission, express restriction, and statutory silence.

2.2 Legal Identity and Multi-Role Capacities (Articles 1 and 14)

Article 1 establishes the starting point: criminal proceedings are a public function exercised by the public prosecutor. Article 14(1), by contrast, defines who qualifies as an injured party:

"The person injured by the offense (persona offesa) is the subject who has suffered the direct harm, material or moral, produced by the criminal act."

Under the four-way doctrinal distinction, Article 14(1) recognises the injured party as a legal subject (persona offesa), a status different from being a witness or a civil claimant (Conso and Grevi 2005). But the provision does not give the injured party independent power to investigate or direct a prosecution. It identifies the person who has suffered harm; it does not transfer responsibility for enforcing the criminal law from the state to that person.

In addition, a victim may embody multi-role capacities throughout a single proceeding:

•   Informant (denunciante): Supplying factual information to law enforcement (Article 17).

•   Complainant (querelante): Exercising a gatekeeping condition of prosecution (Article 21).

•   Civil Claimant (parte civile): Seeking restitution or civil damages (Article 14(2)).

•   Witness (testimone): Providing sworn testimony (Articles 103, 135).

These roles may overlap in one case, but each carries a different procedural function. Taking on one role does not transfer control of the criminal case from the state.

2.3 Legal Representation and Structural Asymmetry (Article 15)

Article 15 offers another way to see the difference between the position of the accused and that of the injured party. While Article 15(1)–(2) protects the accused’s right to legal defence, Article 15(6) limits the injured party to one legal representative during the proceedings.

Importantly, Article 15(7) establishes an operational rule regarding counsel withdrawal or default:

"The withdrawal, default, or absence of the legal representative of the injured party shall not interrupt or stay the progress of the criminal proceedings."

Article 15(7) illustrates the practical effect of the state’s control over the criminal action. Under Article 15(3)–(5), a failure in the accused’s legal representation requires judicial intervention to protect the fairness of the proceedings. The absence or withdrawal of the injured party’s lawyer, by contrast, does not stop the trial (Cross 1991). The injured party may participate, but that participation is not a condition for the state to continue the prosecution.

CHAPTER THREE: PRE-TRIAL PROCEEDINGS: ACTIVATION WITHOUT CONTROL

Introductory Transition

Having considered legal status and representation, Chapter Three turns to the pre-trial stage. It asks whether the injured party’s ability to report an offence or lodge a formal complaint also brings any power to direct an investigation, or whether those decisions remain with state authorities.

3.1 Reporting, Complaints, and the Power of Activation (Articles 17 and 21)

The Code provides two distinct routes by which information from an injured party or another person may reach the authorities:

•   Information / Reporting (denuncia - Article 17): Allows any person or injured party to report an offense.Evaluated under the A/B/C Framework, Article 17 represents a Category B (Conditional Permission) to inform authorities, coupled with Category C (Statutory Silence) regarding supervisory rights. Filing a denuncia triggers police investigation but grants the reporter zero rights to supervise or direct law enforcement.

•   Formal Complaint (querela - Article 21): Required for specific offenses where prosecution is conditionedupon the injured party’s explicit request (Somali Penal Code 1962, Arts. 81–84).

Where a querela is required, Article 21 makes it a condition for prosecution (condizione di procedibilità). The injured party therefore has a limited gatekeeping role: without the required complaint, the state cannot proceed (Ferrajoli 1989). This is a form of procedural influence, not procedural control. The complaint opens the way for proceedings, but it does not give the complainant authority to direct the Attorney General’s investigation or charging decisions.

3.2 Prosecutorial Monopoly and the Absence of Compulsion or Review (Articles 1, 12, 13, and 112)

The distinction becomes clearer when the Code is examined for who controls investigations and decides whether a case should continue:

•   Prosecutorial Monopoly (Articles 1, 12, 13): The Office of the Attorney General and police investigatorspossess sole authority to direct pre-trial inquiries, gather evidence, and formulate charges.

•   State Charge Withdrawal (Article 112): Under Article 112, the public prosecutor may withdraw chargesor enter a nolle prosequi under judicial supervision. The Code contains no provision requiring victim consent or allowing victim vetoes over charge withdrawals.

•   Absence of Private Prosecution and Review: The 1963 Code contains no mechanism for privatesubsidiary prosecution (azione penale privata). When police or prosecutors close an investigation (archiviazione), the Code exhibits Category C (Statutory Silence) regarding injured-party-initiated administrative or judicial review.

In the absence of a statutory review route or a mechanism for private subsidiary prosecution, the injured party has no clear means under the Code to compel action when the state declines to proceed. The power to bring a matter to the authorities’ attention is therefore different from the power to determine what follows.

CHAPTER FOUR: TRIAL PARTICIPATION AND CIVIL CLAIMS: THE ACCESSORY MODEL

Introductory Transition

Chapter Four moves from the pre-trial stage to the trial itself. It keeps separate two roles the injured party may perform: giving evidence relevant to the prosecution and seeking financial recovery as a civil claimant.

4.1 Trial Participation and Evidentiary Subordination (Articles 103 and 135)

When the injured party gives evidence at trial under Articles 103 and 135, they do so in the legal capacity of a witness (testimone).

Giving evidence is subject to the Code’s rules of evidence. Under Articles 103 and 135, the injured party testifies under oath and may be questioned by the court and cross-examined by the defence. The Code does not expressly set out a separate power for the injured party, acting only as a witness, to call other witnesses independently, control the questions asked, or manage the presentation of the prosecution’s case (Taruffo 1992). The injured party’s evidence may be important, but the conduct of the trial remains in the hands of the court and the public prosecution.

4.2 Civil Damages Claims and Accessory Dependence (Articles 14, 119, 130, 131, and 220)

An injured party who wishes to seek financial recovery within the criminal trial must formally join as a civil claimant (parte civile) under Article 14(2)–(3). This option is subject to specific procedural rules:

•   Temporal Preclusion (Article 119 / 131): The civil claim must be submitted prior to the prosecutor's finalsumming-up (Category B). Failure to meet this deadline precludes civil joinder within the penal forum.

•   Judicial Determination on Conviction (Article 130(1)): Upon issuing a conviction, the court may rule oncivil restitution and damages.

•   The Accessory Model (Accessorium Sequitur Principale - Article 130(2)): If the criminal trial ends in amerits-based acquittal, the civil claim attached to the proceeding summarily collapses and is extinguished within the criminal forum.

These provisions show that a civil claim brought within the criminal case is closely tied to the course and outcome of the public prosecution (Cordero 2012). Article 220 provides a separate route for pursuing civil remedies in the civil courts. Within the criminal trial, however, the civil claim follows an accessory model: the injured party’s financial claim does not give them control over the public prosecution (Kaser 1984).

CHAPTER FIVE: APPEALS, INSTITUTIONAL SYNTHESIS, AND DOCTRINAL CONCLUSIONS

Introductory Transition

The final chapter considers appeals and brings together the findings from the preceding chapters. It distinguishes appeals concerning civil remedies from challenges to criminal outcomes, then assesses what that distinction reveals about the injured party’s overall position under the Code.

5.1 Appellate Standing: Bifurcated Jurisdiction (Articles 208, 211, 220, 226, 227, and 230)

Under the 1963 Code, the injured party’s ability to appeal depends on the type of decision being challenged. Articles 226 and 230 set out relevant procedures for giving notice and lodging an appeal:

•   Civil and Cost Appeals (Category B - Permitted): Under Articles 208 and 211, an injured party joined asa parte civile possesses clear standing to appeal portions of a judgment concerning civil restitution, damages, or trial costs, supported by procedural notice and filing modalities under Articles 220, 226, and 227.

•   Penal Appeals (Category C - Absent): Conversely, the Code exhibits complete statutory silenceregarding injured-party-initiated appeals against criminal acquittals, charge reductions, or sentence leniency. The right to challenge penal outcomes remains restricted under Articles 208 and 230, belonging exclusively to the public prosecuting authorities.

The four-way distinction remains important at the appellate stage. Standing to appeal a decision on civil damages does not, by itself, confer standing to challenge a criminal acquittal. The injured party’s appellate role is confined to the forms of redress the Code permits.

5.2 Doctrinal Synthesis and Seven Principal Findings

The analysis in Chapters Two through Five answers the eight research questions set out in Section 1.1. Table 5.1 brings the results together in seven principal findings:

• Table 5.1: Synthesis of Statutory Findings and Research Questions

Finding #	Doctrinal Finding Summary	Governing Provisio ns	Addressed Research Questions	Analytical Category
1	Recognized Legal Identity Without Autonomy	CPC Arts. 1, 14(1)	Questions 1 & 2	Category C (Silence)
2	Procedural Influence via Gatekeeping Veto	CPC Arts. 17, 21	Questions 3 & 4	Category B (Conditional)
3	Absolute State Control Over Public Penal Action	CPC Arts. 1, 12, 13, 112	Questions 5 & 6	Category A (Monopoly)
4	Subordination of Legal Representation	CPC Art. 15(6)–(7)	Questions 1 & 2	Category A/C
5	Accessory Dependence of Civil Claims	CPC Arts. 14, 119, 130	Questions 1 & 8	Accessory Model
6	Bifurcated Appellate Standing & Silence	CPC Arts. 208, 211, 226, 230	Questions 7 & 8	Category B vs. C
7	Structural Subordination (Outcome Variable)	Synthesis of All Chapters	Overarching Research Axis	Cumulative Reality

Note: Summarizes the systematic linkage between positive statutory provisions, analytical categories, and research resolutions.

5.3 Final Conclusion

This study concludes that, under the Somaliland Criminal Procedure Code of 1963, the injured party is neither a co-equal prosecutor nor an independent controller of criminal proceedings. The analysis of the Code from the reporting stage through appeal points to a consistent pattern of structural subordination.

The Code does recognise the injured party as a legal subject (persona offesa), gives them a limited role in triggering proceedings where a formal complaint is required (querela), and allows them to seek civil redress as a civil claimant (parte civile). These forms of recognition and influence matter. They do not, however, transfer control of the criminal action (azione penale) from the state to the injured party. The central finding is therefore not that the injured party has no role, but that the role is limited: the Code permits participation through specified channels while reserving the direction and continuation of public prosecution to state authorities.

ACADEMIC BIBLIOGRAPHY

I. Primary Statutory & Constitutional Sources

•   Constitution of the Republic of Somaliland (2001), official English and Somali translations, Hargeisa,Somaliland.

•   Somaliland Criminal Procedure Code (Legislative Decree No. 1 of 1 June 1963), Official Gazette of theSomali Republic, Year IV, No. 6 (1 June 1963).

•   Somali Penal Code (Legislative Decree No. 5 of 16 December 1962), Official Gazette of the SomaliRepublic, Year III, Supplement No. 1 (16 December 1962).

•   Italian Penal Code (Codice Penale, Regio Decreto 19 ottobre 1930, n. 1398).

•   Italian Code of Criminal Procedure (Codice di Procedura Penale, Regio Decreto 19 ottobre 1930, n. 1399- historical baseline for the 1963 Somali CPC).

II. Comparative Legal Treatises & Monographs

•   Bassiouni, M. Cherif, International Criminal Law: Sources, Subjects, and Contents (3rd edn, MartinusNijhoff Publishers 2008).

•   Conso, Giovanni, and Vittorio Grevi, Commentario Breve al Codice di Procedura Penale (CEDAM 2005).

•   Cordero, Franco, Procedura Penale (9th edn, Giuffrè Editore 2012).

•   Delmas-Marty, Mireille, and J.R. Spencer (eds), European Criminal Procedures (Cambridge UniversityPress 2002).

•   Ferrajoli, Luigi, Diritto e Ragione: Teoria del Garantismo Penale (Edizioni Laterza 1989).

•   Kaser, Max, Roman Private Law (R. Dannenbring tr, 4th edn, Unisa Press 1984).

•   Roxin, Claus, and Bernd Schünemann, Strafverfahrensrecht (28th edn, C.H. Beck 2014).

•   Taruffo, Michele, La Prova dei Fatti Giuridici: Nozioni Generali (Giuffrè Editore 1992).

•   Tonini, Paolo, Manuale di Procedura Penale (18th edn, Giuffrè Editore 2017).

III. Scholarly Articles & Methodological Literature

•   Bassiouni, M. Cherif, 'Human Rights in the Context of Criminal Justice: Identifying InternationalProcedural Standards and Appropriate National Responses' (1993) 3 Duke Journal of Comparative & International Law 235–290.

•   Damaška, Mirjan R., 'Evidentiary Barriers to Conviction and Two Models of Criminal Procedure: AComparative Study' (1973) 121 University of Pennsylvania Law Review 506–589.

•   Damaška, Mirjan R., The Faces of Justice and State Authority: A Comparative Approach to the LegalProcess (Yale University Press 1986).

•   Herman, Judith Lewis, ‘The Mental Health of Crime Victims: Impact of Legal Intervention’ (2003) 16(2)Journal of Traumatic Stress 159–166. https://doi.org/10.1023/A:1022847223135

•   Hutchinson, Terry, 'Doctrinal Research: Researching the Jury' in Laura Cahillane and Jennifer Schweppe(eds), Legal Research Methods: Principles and Practice (Clarus Press 2016) 7–22.

•   Langbein, John H., 'The Criminal Trial Before the Lawyers' (1978) 45 University of Chicago Law Review263–316.

•   Laxminarayan, Malini, Jens Henrichs and Antony Pemberton, ‘Procedural and Interactional Justice: AComparative Study of Victims in the Netherlands and New South Wales’ (2012) 9(3) European Journal of Criminology 260–275. https://doi.org/10.1177/1477370812439641

•   Laxminarayan, Malini, Mark Bosmans, Robert Porter and Lorena Sosa, ‘Victim Satisfaction with CriminalJustice: A Systematic Review’ (2013) 8(2) Victims & Offenders 119–147.

https://doi.org/10.1080/15564886.2012.763198

•   Lind, E. Allan and Tom R. Tyler, The Social Psychology of Procedural Justice (Plenum Press 1988).https://doi.org/10.1007/978-1-4899-2115-4

•   Tyler, Tom R., Why People Obey the Law (Yale University Press 1990).

•   Wemmers, Jo-Anne, ‘Victims’ Experiences in the Criminal Justice System and Their Recovery fromCrime’ (2013) 19(3) International Review of Victimology 221–233.

https://doi.org/10.1177/0269758013492755