The Remaking of Sectarian Fault Lines in Pakistan: Why Violence in Kurram Tribal District Matters?
In 2025, Sunni-Shia violence has re-emerged in Pakistan’s Kurram tribal district, triggering tit-for-tat attacks from rival sectarian tribes. However, the current spate of violence in Kurram is qualitatively different from its previous iterations and warrants closer scrutiny. Kurram is one of the seven Newly Merged Districts (NMDs) of Khyber Pakhtunkhwa province, which were incorporated in 2018 following the 25th Constitutional Amendment. A case study of sectarian dynamics in Kurram offers critical insights into the future trajectory of the overall Sunni-Shia conflict in Pakistan, especially in the wake of the Iran-Israel conflict, which could result in a strong sectarian backlash by the Iranian proxies in the country. Pakistan’s position on the Iran-Israel conflict will shape the reactions of the Iranian proxy groups, especially in Kurram.
Over the past two decades, Kurram’s sectarian conflict has metastasised from a local to a regional issue, with strong links to developments in Syria. Though history is an important marker for the genesis of the sectarian conflict in Kurram, it is no longer the sole factor to understand the current spate of violence. In Kurram, sectarian identities, land disputes and external interference coincide to account for the current phase of tensions. Hence, local conflict resolution interventions revolving around efforts to foster peaceful co-existence amidst recurrent violence with its attendant internal and external catalysts have become somewhat ineffective.
Introduction
Kurram district is a lush green valley that takes its name after the Kurram River which passes through it, sharing a border with Afghanistan on three sides.[1] It is surrounded on the north and west by Afghanistan’s Nangarhar, Khost and Paktia provinces, on the east by Orakzai and Khyber districts, on the southeast by Hangu district and on the south by North Waziristan district. The Spin Ghar (Koh-e-Safaid, or White Mountain) in the north separates Kurram from Afghanistan.[2]
There are two major tribes in Kurram: Turi (Shia) and Bangash (Shia and Sunni). Besides these two tribes, other small tribes settled in the area are Jajjis (Sunni brethren of Turi), Orakzai, Parachamkani, Alisherzai, Zaimusht, Mangal, Syeds, Zadran and Muqbils. The Turi tribe owns about 70 percent of the cultivated fertile land in Kurram and had political influence in local as well national politics before the 1979 Afghan War.[3]
Kurram is divided into three subdivisions, i.e., Upper Kurram – where the district headquarter Parachinar is also located – Lower Kurram and Central Kurram. Shias dominate the upper parts of the Kurram valley and Parachinar; Sunnis inhabit mountainous Central Kurram; while Lower Kurram has a mixed Shia and Sunni population.[4]
History of Sectarian Conflict
The existence of feuds and hostilities in Pashtun society due to land and property matters is a well-known fact, and Kurram is no exception to the norm. Kurram’s landed aristocracy always had problems with the Afghan kings and paying revenues to the latter.[5] In the past, there was the Islamzona (puritans) force, which was formed by the Orakzai of Tirah to oust the landed Shia Turi from Kurram, and which used religion as an excuse and the strategy of chur (i.e., massive pillaging which takes place once an area has been taken over by a tribe, forcing local communities to leave their houses and businesses). Chur was also used against the Sikhs in Kurram and Tirah to loot them. According to the elders of Kurram from both Shia and Sunni sects, the skirmishes in 1938 were part of a “British conspiracy” to weaken the tribes to keep them under colonial control. In 1961 and 1971, there were sporadic incidents of violence,[6] but mostly regarding water, forest, mountain or land issues.[7]
Iranian Revolution – Afghan Jihad and Sectarian Proxy Warfare in Kurram
The sectarian conflict in Kurram has its origins in two important developments: the 1979 Iranian Revolution, which ushered Shia (followers of Twelver) clergies into power;[8] and the Afghan Jihad (predominately involving Sunnis/Wahhabis).[9] These two important events changed the politics, demographics and nature of local conflicts in Kurram. The Iranian Revolution opened confrontational blocs in the Middle East for the then superpowers, and Kurram consequently became a focus of attention in the Afghanistan-Pakistan context.
Besides, a new tussle started in Afghanistan, dislocating more than three million Afghan refugees into Pakistan. Meanwhile, the recruitment of “jihad volunteers” from across Pakistan resulted in a fundamental demographic and power shift in the erstwhile Federally Administered Tribal Areas (FATA). This recruitment was done in Sunni seminaries or madrassas specifically established in the Afghanistan-Pakistan tribal belt during the 1980s to train, ideologise and recruit militants.
In Kurram, the Shia community got closer to Iranian clergies and established several madrassas to counter their Sunni counterparts. The non-participation of Kurram Shias in the Afghan War also irked the powers involved in the conflict; hence, propaganda was initiated about the Kurram Shias demanding a separate province and a state.[10] Although it was not a demand for a separate state, noted Shia scholar Arif Hussain Al Hussaini started a movement and the political party Tehreek-e-Nifaz-e-Fiqh-e-Jafria (TNFJ) to protect Shia interests.
Arif Hussain Al Hussaini – Political Islam and International Politics
In the 1960s, after completing his elementary and religious schooling, Hussaini went to al-Hawza al-Ilmiyya in Najaf, Iraq, where he met Ruhollah Musavi Khomeini, popularly known as Imam Khomeini, the spiritual leader of the Iranian Revolution. Hussaini attended Khomeini’s lectures and prayed after him. Due to his involvement in Khomeini’s political struggle in Najaf, he also faced continuous harassment by and detention at the hands of Saddam Hussein.
In the late 1970s, Hussaini emigrated to Qum, Iran, with a Wikalat Nama (a letter of Imam to issue fatwas and collect khums – a religious tax that requires Shia Muslims to pay one-fifth of their profits to various beneficiaries – in his name). He started rallying support for Khomeini. Due to his political activities, he was arrested, threatened and tortured by the Shah’s government. However, the Shah’s monarchy and government fell in 1979 and the Islamic Revolution took over.[11]
After returning to Pakistan, Hussaini started his political struggle as a representative of Khomeini.[12] He was elected as the leader of TNFJ and Peshawar became his party’s headquarters.[13] Hussaini’s speeches against the then military dictator and army chief General Zia-ul-Haq and the United States (US)[14] paved the way for sectarian violence across Pakistan. However, Kurram became the hub of this sectarian proxy war due to its geography and long-standing Sunni-Shia tribal enmities on land and resource issues. During the 1980s and 1990s, tribal people faced violence sponsored by different proxies, which created unbridgeable gaps between Sunni and Shia Pashtuns living in Kurram, apart from escalating levels of violence. The détente period in Kurram sectarian violence came after the assassination of Hussaini and the disintegration of the former Union of Soviet Socialist Republics (USSR).[15]
Pashtuns – Land Disputes and Identity
Prior to the US-led global war on terror, in the Afghanistan-Pakistan border areas, feuds between clans, families, tribes or sectarian groups were viewed from a cultural and land disputes prism only. In the absence of a formal justice system, an alternate dispute resolution mechanism, popularly known as jirga, was used.[16] However, in current circumstances, such tribal disputes are becoming more noticeable and are quickly being tagged as terrorism, thus instilling more fear and uncertainty. A case in point is the killing of teachers in Parachinar on May 4, 2023.[17] In border districts, land ownership rests with the entire tribe, with no formal records kept. Most of the time, the boundaries are not marked, thus creating ownership disputes between various subclans of the tribes in the area. Often, when a dispute arises, each tribe has its own side of the story and old documents (mostly British colonial-era records) to support its claims. In 2018, with the 25th Constitutional Amendment, the FATA was merged with Khyber Pakhtunkhwa, and it was expected that, through revenue records, land would be formally and legally distributed between tribes and then individuals.[18] This spurred activity towards possession and land grabbing of unaccounted-for lands in all districts in the FATA region.
In Kurram, land possession amongst Pashtuns is not only viewed as material wealth but also considered part of their identity and honour. Each dispute has centuries-old history and in each case skirmishes have occurred dozens of times, causing casualties and deaths. These disputes have triggered the ghairat–badal (honour-revenge) aspect of Pashtun tribal culture. In many cases, a dispute arises from a violation of the last agreed-upon arrangement; one party violates the arrangement, thus instigating the other party, who then opts for violence as part of ghairat-badal.[19]
In the settled districts of Khyber Pakhtunkhwa, since formal accounts of land ownership do not exist, any property dispute is settled in the court of law based on the Revenue Department’s records. In border districts, barring some exceptions, only vague ownership exists amongst the tribes, with no official records and unmarked boundaries, creating persistent land disputes. The absence of a formal justice system further complicates this issue.[20] Following the ex-FATA’s merger, even after Pakistan’s judicial system was extended to these areas, the courts are not fully functional. In the case of a dispute, the judge is unable to give a verdict as no formal record is held by the Revenue Department. Even in cases where verdicts are given, they cannot be implemented due to the absence of effective policing in these areas.[21]
Post 2001 – Violent Extremist Actors and Sectarian Conflict in Kurram
The nature of sectarian conflict completely changed in Kurram district with the involvement of Al-Qaeda (AQ); Sunni extremist groups such as Sipah-e-Sahaba Pakistan (SSP), Lashkar-e-Jhangvi (LeJ) and the Tehreek-e-Taliban Pakistan (TTP); and the Afghan Haqqani Network. In 2001, Kurram’s Shia Turi tribe refused to give sanctuary to AQ and the Taliban, while the Sunni Bangash and Orakzai tribes provided full support to these groups.[22]
In addition, the strategic importance of Parachinar both in terms of demography (a Shia-dominated area with small pockets of Sunnis) and geography (the geospatial information systems of US drones did not work due the mountainous and rugged terrain and unpredictable weather patterns), has remained the focal point of all militant groups operating in the Afghanistan-Pakistan border region. Of these, the Haqqani group of the Taliban has remained an unavoidable influence in Kurram for two key reasons.
First, due to Kurram’s proximity to the Haqqani Network’s base in North Waziristan at the time, the Taliban were provided a protected route to the predominantly Sunni-populated areas of Kurram. Second, Kurram is 60 miles from Kabul, along the shortest route from the Loya (Greater) Paktia region of Afghanistan that includes Khost, Paktia and Paktika provinces. During the 1980s, Paktia hosted AQ’s founder Osama bin Laden and his cadre of Arab fighters. They used Kurram to move between Paktia and Jalalabad, building roads to facilitate easy access. In Paktia’s Jaji district, bin Laden constructed his sanctuary, which eventually became a cave complex that served as the forward-deployed base for foreign fighters assisting in the anti-Soviet jihad.[23]
The Spin Ghar in the Kurram region is also a recurring theme in the Islamic State of Khorasan (ISK)’s literature.[24] In 2014, two decades after Paktia hosted bin Laden, ISK built its first tamkin in Nangarhar, announcing its presence in Pakistan and Afghanistan. Tamkin is central to IS’ method of insurgency and refers to power consolidation by the group and the establishment of a state-like governing authority (khilafah) over a territory.[25]
In Kurram, the TTP emerged in 2007, stoking a sectarian war in the region, where the TTP and the Haqqanis were closely allied. Many believed that the Haqqanis were simultaneously the instigators, arbiters and, ultimately, benefactors of this conflict. The TTP exploited the issues of land and water between the Shias and Sunnis in Kurram and transformed them into a deadly sectarian war. There were major clashes in 1996 after the murder of a college principal by Shia activists in Parachinar; over 200 Sunnis and Shias were killed.[26] In October 2007, the TTP’s founder Baitullah Mehsud sent a group of 400 Taliban members to purge Kurram’s Shia Turi tribe. According to an official report, between 2007 and 2009, as many as 1,500 people died and 5,000 injured in this sectarian war. According to the United Nations High Commissioner for Refugees (UNHCR), more than 17,000 people, including women and children, fled to Afghanistan in January 2008.[27] Later, the 2008 Murree Accord[28] was signed between the warring groups to end the sectarian conflict and to open the blocked Thall-Parachinar highway.[29] However, the closure of roads and various sectarian skirmishes multiplied Shia and Sunni militant groups in Kurram.
The Zainabiyoun Brigade
After 2008, many of the educated and skilled youth of Kurram migrated to different parts of Pakistan. At the same time, the more affluent ones emigrated to Europe, Canada and Australia. However, those from the lower strata of society moved to Iran to earn a living.[30] It is pertinent to mention that Hussaini’s sons, after his assassination in 1988, formed a network of seminaries all over Pakistan.[31] After completing their basic education, the brilliant students from this madrassa network were sent to Iran to pursue higher studies; some returned to Pakistan while others stayed in Iran.[32]
Of these Pakistani madrassa students, some were recruited, trained and funded by Iran to form the Zainabiyoun Brigade. Iran promised them employment. Iran also exploited their shared Shia faith as a tool, such as by laying emphasis on the protection of religious shrines and graves targeted by the Islamic State (IS) in Iraq and Syria.[33] Most of the members of the Zainabiyoun Brigade hail from Shia-dominated Parachinar, the capital of Kurram district, where Pakistan’s government control is weak.[34]
The Iran-backed Zainabiyoun Brigade could become Pakistan’s new internal security challenge if Pakistan is forced to maintain neutrality in the event that the US joins the Israel-Iran conflict to destroy the latter’s nuclear facilities.[35] Pakistan has a complex relationship with Iran, marked by mutual suspicion, mistrust and sectarian rivalry as well as episodic cooperation and aligned interests on certain issues such as Afghanistan. Approximately 15 to 20 percent of Sunni-majority Pakistan’s population are Shia Muslims who look towards Iran for spiritual guidance. Since the 1980s, Pakistan has maintained a semblance of neutrality in the Iran-Saudi sectarian tensions to ensure sectarian harmony at home.[36]
Presently, Al-Mustafa Institute in the Iranian city of Qum is a recruitment centre for Pakistani youth to join the ranks of the Zainabiyoun Brigade.[37] Thus, very easily, with the right training and networks, Iran has recruited segments of the marginalised population from Pakistan for the Zainabiyoun Brigade, which was used in the Syrian civil war.[38] It is important to note that neither Hussaini’s seminaries nor his Shaheed Foundation Pakistan has come under any scrutiny, but the lesser-known, Parachinar-based Ansar-ul-Hussain and Khatam-ul-Anbiya were banned for their links with militants in Syria.[39] The Pakistani government’s policy in dealing with sectarian outfits has mostly revolved around low-key actions without much public acknowledgement, for fear of a sectarian backlash.
Trajectory of Conflict Building in Kurram Post-2021
After 2007’s deadly clashes, Kurram is once again embroiled in sectarian clashes. Three incidents are of particular note with reference to Kurram’s recent sectarian crisis. First, on November 21, 2024, the large-scale sectarian attack on a convoy of Shia passengers in the Bagun area of Kurram, instigating a full-fledged Shia-Sunni battle.[40] Second, on December 8, 2024, the fall of Syria to Hayat Tahrir al-Sham,[41] evicting Iranian militias, including the Zainabiyoun Brigade. Third, on December 11, 2024, the assassination of Haji Khalil Haqqani by ISK through a suicide bombing in Kabul.[42] Khalil Haqqani had played a key role in the 2008 Murree Accord, which brought peace in Kurram.
Due to the perpetual nature of disputes amongst tribes in Kurram, a propensity to stock weapons exists. These caches of weapons are known as qoumi aslaha (tribes’ ammunition) and are used against each other in the event a dispute erupts. Each incident further compels the tribes to hoard more weapons.[43]
This tendency to acquire arms provides an opportunity to militants to access weapons. At times, militant groups at the lower level get physically involved in the killings of opponents to settle scores for the honour of their tribes. Such disputes tarnish the image of law enforcement agencies and allow militants to utilise such events to further their agendas by creating chaos and fear.[44] In most cases, a tribe would look towards its outlaws, criminals and even globally designated terrorists to come and play their part as a tribal obligation to retaliate against its rivals. Thus, a normal land dispute or even an individual fight may eventually pit an entire district, clan or tribe against each other. This phenomenon is not restricted to the local level, as any action against a Shia or Sunni community gets immediate attention at the national level, spurring a reaction in Pakistan and neighbouring Afghanistan.
Conclusion
The Israel-Iran war will have serious repercussions for the Shia-Sunni conflict in Pakistan, especially in Kurram and other sectarian flashpoints, if the conflict persists and the US joins the fray. The persistence of Iran-Israel tensions will present Pakistan with a catch-22 situation. On the one hand, siding with Iran at the diplomatic level would alienate its Sunni Gulf allies and the US. On the other, a neutral position grounded in demands for a politically negotiated settlement could trigger a strong sectarian backlash from the Iranian proxies in the country for more to be done. So far, Iran has not employed religious symbolism and language while fighting Israel. However, if Tehran gives a call to Shia Muslims around the world to defend Shia interests against Israel, Pakistan would be confronted with a difficult situation both locally and regionally. At the same time, a regime change or a weakening of Iranian state authority would embolden the Baloch separatist groups along the Iran-Pakistan border.
Separately, at the local level, in 2019, the government in Khyber Pakhtunkhwa initiated a host of measures to bring the Newly Merged Districts (NMDs) on par with the rest of the districts in the province. However, due to the absence of government architecture and state apparatus, the process remained painfully slow. As a result of numerous meetings and consultations, a blueprint for the development of the erstwhile FATA was approved, which involved instituting a mechanism to plan and steer decision-making. Several guidelines were adopted for a stage-wise transition to introduce constitutional, political, financial and administrative initiatives, followed by judicial reforms. However, the serious issue of land and revenue records was intentionally put on the back burner, as it would open the floodgates to disputes for which the district administration is neither equipped in terms of legal and law enforcement resources nor competent enough to handle.
It seems the authorities have decided that they would take up the issue of land reforms after state organs are fully developed in the NMDs. The Khyber Pakhtunkhwa government tried land reforms and hired the services of international firms, but the project was eventually shelved due to security reasons and lack of funds. Although the alternate dispute resolution mechanism, or jirga, has been kept intact, it is not adequately equipped to deal with land disputes which involve militants and other non-state actors. Practically speaking, things are heading nowhere in peace-building in Kurram, and it means the political rhetoric and blame game will continue with more devastation and hate.
About the Author
Iftikhar Firdous is an academic and journalist with a PhD in psycholinguistics. He has been an editor for Pakistan’s major English publications. Currently, he is the founding editor of The Khorasan Diary – a platform dedicated to research and news from conflict zones. He has been reporting extensively from conflict zones on militant organisations’ ideologies and strategies. He can be reached at [email protected].
Thumbnail photo by Hamid Roshaan on Unsplash
Citations
[1] According to a 2017 census, Kurram’s total population is 619,553 (58 percent Sunni and 42 percent Shia). For details, see M. Barthorp, The North-West Frontier British India and Afghanistan: A Pictorial History, 1839-1947 (Blandford Press, 1986).
[2] The total area of Kurram is 3,380 square kilometres. Thus, Kurram’s area percentage in the erstwhile FATA is 12.42 percent.
[3] A.M. Bangash, “Political and Administrative Development of Tribal Areas: A Focus on Khyber & Kurram” (unpublished PhD diss., University of Peshawar, 1996), 31-42.
[4] Farmanullah et al., “Sunni-Shia Conflict in Kurram, Pakistan: Genesis, Factors and Remedies,” Elementary Education Online 20, no. 5 (2021): 7629-7640.
[5] Ibid.
[6] Charles Chenevix Trench, The Frontier Scouts (Butler & Tanner Ltd, Frome and London, 1985).
[7] Author’s recorded minutes with Sunni Bangash and Shia Turi elders in Kurram.
[8] Michael Axworthy, Revolutionary Iran: A History of the Islamic Republic (Oxford University Press, 2013).
[9] Gregory Fremont-Barnes, The Soviet Afghan War: 1979-89 (Bloomsbury Publishing, 2024).
[10] See Muhammad Khurshid Khan, “Kurram Agency Crises: An Analytical View and Suggested Way Forward,” IPRI Journal X, no. 2 (2010).
[11] Tasleem Reza Khan, Safeer-e Noor Shaheed Arif Hussaini (Al-Arif Academy, 1994).
[12] Maleeha Lodhi, “Pakistan’s Shia movement: An Interview with Arif Hussaini,” Third World Quarterly 10, no. 2 (1988): 806-817, https://doi.org/10.1080/01436598808420083.
[13] Khan, Safeer-e Noor.
[14] See various Shaheed Allama Arif Hussaini videos on YouTube.
[15] B. Fowkes, The Disintegration of the Soviet Union: A Study in the Rise and Triumph of Nationalism (Palgrave Macmillan, 1997).
[16] Shaheen Sardar Ali and Javaid Rehman, Indigenous People and Ethnic Minorities of Pakistan: Constitutional and Legal Perspectives (Curzon, 2001).
[17] Javid Hussain, “Seven Teachers Among Eight Killed in Kurram Attacks Over ‘Land Dispute’,” Dawn, May 5, 2023, https://www.dawn.com/news/1750909.
[18] Farooq Yousaf, Pakistan, Regional Security and Conflict Resolution: The Pashtun ‘Tribal’ Areas (Routledge Taylor & Francis Group, 2021).
[19] Z. Kakakhel, Pukhtana Da Tareekh Pa Ranna Kay (University Book Agency, 1965).
[20] Babur Nama, trans. Annette S. Beveridge (Sang-e-Meel Publications, 1979).
[21] Government of Pakistan, Report of the Senate Committee on States and Frontier Regions (SAFRON) Regarding Arising Problems in Merged Districts After Merger with Khyber Pakhtunkhwa (Senate of Pakistan, 2021-2022), 1-6.
[22] See various reports in well-reputed Pakistani newspapers.
[23] Peter L. Bergen, The Osama bin Laden I Know, (Free Press, 2006), 329.
[24] “Monitoring,” The Khorasan Diary, https://www.thekhorasandiary.com/category/monitoring.
[25] Amira Jadoon with Andrew Mines, The Islamic State in Afghanistan and Pakistan: Strategic Alliances and Rivalries (Lynne Rienner Publishers, 2024), 91.
[26] Mariam Abou Zahab, Unholy Nexus: Talibanism and Sectarianism in Pakistan’s “Tribal Areas” (Sciences Po Center for International Studies, 2009), https://www.sciencespo.fr/ceri/sites/sciencespo.fr.ceri/files/art_mz.pdf.
[27] Daily Times, January 2, 2008.
[28] In 2008, the Bangash and Turi tribes of Kurram signed a written declaration for permanent peace in Murree. The rival tribes agreed they would vacate occupied bunkers and return to their respective areas. In the case of a violation of the agreement, the offending tribe would have to pay a fine of 60 million rupees.
[29] “Kurram Groups Sign Accord to Open Key Highway,” Dawn, October 9, 2011, https://www.dawn.com/news/665032/kurram-groups-sign-accord-to-open-key-highway.
[30] Author’s recorded minutes with people of Kurram district.
[31] Author’s recorded minutes with a member of Anjuman-e-Hussainia Kurram.
[32] Author’s recorded minutes with social activists from Upper and Lower Kurram.
[33] See various local and international news reports on the Islamic State (IS), which mention recruits from Parachinar, Kurram.
[34] Aydin Guven, “ANALYSIS – Iran-Backed Zainabiyoun Brigade Could Become Pakistan’s New National Security Problem,” Anadolu Agency, February 25, 2025, https://www.aa.com.tr/en/analysis/analysis-iran-backed-zainabiyoun-brigade-could-become-pakistan-s-new-national-security-problem/2033585.
[35] Saeed Shah, “Pakistan Fears Militants Will Thrive on Restive Border If Iran Destabilised,” Reuters, June 19, 2025, https://www.reuters.com/world/china/pakistan-fears-militants-will-thrive-restive-border-if-iran-destabilised-2025-06-19/.
[36] Adnan Aamir, “Pakistan Fears Risk of Spillover from Iran-Israel Conflict,” Nikkei Asia, June 18, 2025, https://asia.nikkei.com/Spotlight/Iran-tensions/Pakistan-fears-risk-of-spillover-from-Iran-Israel-conflict.
[37] Author’s recorded minutes recorded with a son of Hussaini’s close associate. Many international news agencies have also reported about Al-Mustafa Institute.
[38] Farhan Zahid, “The Zainabiyoun Brigade: A Pakistani Shiite Militia Amid the Syrian Conflict,” Terrorism Monitor 14, no. 11 (2016), https://jamestown.org/program/the-zainabiyoun-brigade-a-pakistani-shiite-militia-amid-the-syrian-conflict/.
[39] Author’s recorded minutes with social activists in Lower and Upper Kurram.
[40] Author’s recorded minutes with local people of Parachinar, Kurram.
[41] “Syria’s Civil War: The Descent Into Horror,” Council on Foreign Relations, December 20, 2024, https://www.cfr.org/article/syrias-civil-war.
[42] “Taliban Leadership Tracker,” Middle East Institute, 2024, https://talibantracker.mei.edu.
[43] Author’s interview with the Deputy Commissioner of Kurram tribal district, November 15, 2024, Parachinar.
[44] Ibid.
