Content Listing

Summary

The first question we have to deal with is – at least at first sight – rather simple: which law shall decide on the legal gender of an intersex person and the consequences of that gender in cross-border cases, if that person has links to more than one jurisdiction? This question is, of course, crucial: while all jurisdictions of the world agree that natural persons can be legally male or female, there is no such agreement on the question whether intersex persons can acquire a special gender status, for example, a third category of legal gender (however this is named). Currently only a few jurisdictions offer such a specific gender status for intersex persons. In order to answer this seemingly easy question, several issues need to be distinguished and dealt with separately. First, is gender for private international law purposes a matter of fact or a matter of law (on which see Section 1 below)? If the latter, we then have to decide on the applicable law (on which see Section 2 below). However, the problem can also arise as a preliminary question (on which see Section 3 below). Finally, every jurisdiction will have to deal with the recognition of an intersex status acquired abroad (on which see Section 4 below).

WHAT IS THE NATURE OF THE QUESTION?

When addressing private international law issues of intersex, one first has to clarify whether the attribution of a legal gender to a certain person is a legal question and, if so, whether it is a question of substance or procedure.

It is, of course, rather obvious that the legal gender of a person is a question of law and not of mere facts, and therefore the issue of the applicable law arises. The gender of a natural person is different from merely factual personal criteria, for example, the colour of the person's eyes, the birth weight, or the religion of a person – all criteria, which might be registered in some jurisdictions in the civil status registers or identity documents. The fact that many jurisdictions contain provisions on the recognition of the preferred gender identity for transsexual and transgender persons makes clear that the gender of a natural person has to be a legal question.

Summary

Early Rabbinic Judaism is the name given to the group of people who produced, from the first to approximately the seventh century CE, the post Biblical canonic texts of Judaism. This ‘new’ Judaism, which grew in parallel to early Christianity, was highly invested in the concept of law. This is reflected not only in interpreting the Hebrew Bible which is considered to be a book of laws, but also in the production of a legal codex of their own time (the Mishnah, edited in the early third century), and its interpretations (the Palestinian Talmud, edited in the fifth century, and the Babylonian Talmud, which had several layers of editing, the latest of which is in the seventh century). These legal codices still serve as the basis for any ruling on questions relating to intersex people in Jewish law, and often in Israeli law.

In this chapter we wish to portray the ways in which rabbinic literature bridged the gap between a classification system which acknowledges more than two sexes, and a legal system (based on the Biblical law) which only thinks with two sexes and two genders, or rather, does not differentiate between sex and gender. We also wish to point to an historical process by which the recognition of existence of more than two sexes was gradually rejected, as the binary categories of men/women and gender division became more important and constructed. Rabbinic literature is an interesting locus not only of itself, but also in comparison to Roman law and modern law. It addresses gender and sex division in a manner that echoes the ways we tend to think of as modern and born out of the spirit of feminism and deconstruction. Those ancient Jewish texts ask: are there indeed only two sexes? Does the mere recognition that there are indeed more create any implications to the status of such individuals in society? How does a legal system, which is based on a code that only recognises two sexes, incorporate and interpret the natural and discursive reality of more?

What we will show is that while rabbinic literature is able to acknowledge and even categorise different intersex people, the legal system often pushes those people into gender categories as either men or women.

Summary

INTRODUCTION

Often ignored by the law, intersexuality has been the subject of numerous decisions by the Colombian Constitutional Court. For more than 20 years now, this court has discussed the issue of sexual diversity, producing a consistent legal framework for practitioners, activists and intersex people. Such a framework, interestingly, was developed through the interpretation of general constitutional provisions – such as those aimed at protecting dignity (Article 1 Constitución Politica, henceforth CP), the free development of the personality (Article 16 CP) and the right to equality (Article 13 CP). Moreover, the Constitutional Court has demonstrated a significant will to engage with a difficult area of law from an interdisciplinary angle, relying not only on traditional medical sources, but also on critical theory and activists ‘insights.

To set the Court's activity in context, we must recall that the model of medicalisation applied to intersexuality, as we know it today and as it has come to be gradually – de facto – challenged by the Colombian Constitutional Court, was developed in the mid-1950s in the United States, essentially under the scientific direction of the psychologist Dr. John Money and his team. According to him, what we now call gender identity seemed to be independent from physical characteristics and be the result of different stimuli, including education and social models, which influenced the development of the individual at the early stages of life. Among these stimuli, genitals were given a paramount importance. In Money's understanding, any conflict among the stimuli – primarily, genitalia deviating from established standards of maleness and femaleness (henceforth, non-normative or diverse) – could trigger misalignments with the attributed social gender – what one may call now a ‘trans condition’ – which was perceived as a risk to psychological health. Normalisation – so to say – of non-normative genitalia was thus prescribed. After the initial gender assignment based on the interpretation of biological markers, came surgical and hormonal therapies, aimed at giving a more usual look to the intersex anatomy. Additionally, practical considerations also played a determinant role in gender assignment – especially with biological males – in consideration of the technical limitations to phallus reconstruction. Boys for whom masculinisation was not a viable option would be reassigned to the feminine gender and subject to consistent treatments.

Summary

Until the eighteenth century, the legal approach to ‘hermaphrodites’, although it presented distinctive features, was influenced by ancient classical texts and by post-classical literature and scholarship. The latter were in turn more or less informed by the ancient sources, but often also reprocessing those sources for contemporary political or social purposes. Both canon law and secular law were also influenced by Christian religious beliefs and doctrines, which to some extent affected the broader popular culture and attitudes to sexuality and gender issues. As those scholarly and popular approaches sometimes intertwined with legal (in particular, forensic) discussions of intersex cases, a brief introductory reference to some aspects of that broader cultural context may be useful. Another necessary contextualisation (which, however, can only be mentioned peripherally in this introductory contribution) is the interaction between medical science and law on this issue.

THE WESTERN CULTURAL TRADITION: THE ‘HERMAPHRODITE’ AS A TOPOS DRAWN AND ADAPTED FROM THE ANCIENT CLASSICAL CULTURE

Among the non-legal sources which have affected legal literature and thinking on transsexuality, intersexuality, sexual orientations, and gender issues in general, the Greek-Roman mythology – as witnessed already by the continuous use of the word ‘hermaphrodite’ as a term of art in legal authorities until the nineteenth century – has been a powerful factor. It was a cultural reference which contributed to maintaining the notion that intersexuality occurred, even if it was perceived as a challenge to the natural and social order.

In his Pro populo anglicano defensio (1651), Milton countered the attacks by the French author Claude Saumaise against the English regicides. In the preface, Milton included a pun on Saumaise's Latinised name (Salmasius), comparing him with the nymph Salmacis, who caused the metamorphosis of Hermaphrodite, and associating his opponent with ‘effeminate minds’, ‘emasculating’ generous minds, and reduced by the weakness of this argument to a ‘half-man’. Here we have an example of the mythological reference used in a polemical political text, and using the reference to Hermaphrodite in a pejorative, denigrating, sense.

Summary

Preamble

We affirm that intersex people are real, and we exist in all regions and all countries around the world. Thus, intersex people must be supported to be the drivers of social, political and legislative changes that concern them. We reaffirm the principles of the First and Second International Intersex Fora and extend the demands aiming to end discrimination against intersex people and to ensure the right of bodily integrity, physical autonomy and self-determination.

Demands

Summary

INTRODUCTION

Gender identity refers to the core sense of the self as male, female or somewhere on the spectrum outside the binary. Though Facebook users can now choose from (at least) 71 gender identities, a number of them are distinct by virtue of variation in other domains, such as gender role behaviour and sexual preferences. For example, the identity ‘Femme’ is usually interpreted as a feminine-identifying gay woman. Though there tends to be a high degree of covariance among gender identity, gender role and sexual preferences, they are independent constructs. Indeed, the vast array of gender identities colouring the current social landscape appears to have spawned from conscious appreciation of independent variance of domain-specific characteristics.

The recent expansion of gender expression in the form of varied identities highlights the complexity of any one person's gendered experience. While only a minority of these identities represent distress on the level felt by those who eventually seek medical intervention, they represent factors which may contribute to such outcomes. For example, the identity label ‘Butch’ represents a lesbian who sees herself as more masculine than other women, or in comparison to a lesbian who identifies as ‘Femme’. Nevertheless, the Butch-identified person does not seek to change her identity label or physical status to male in alignment with a masculine gender role and sexual orientation. From a clinical perspective, the difficulty lies in distinguishing subtle differences between the two conditions. Potential influential factors include self-perceptions of gender typicality, felt pressure with respect to typicality and gender contentedness. The degree to which one feels out of place among same-gender peers, while feeling pressure to conform and low levels of contentedness may prompt one to seek physical gender change. But how do we explain the variance in self-perceived gender typicality, felt pressure and gender contentedness? Upbringing, cultural norms and religious beliefs are likely to play a role. From a completely pragmatic perspective, sexual orientation may play a significant role for individuals living in cultures where homosexuality is a crime on religious grounds.

Summary

The right to legal recognition of sex and gender identity is recognised as a fundamental and human right in Germany, as is protection against discrimination and violence based on gender identity and gender diversity in the context of the principle of non-discrimination. Against this background, the German Institute for Human Rights was commissioned by the Federal Ministry for Family Affairs, Senior Citizens, Women and Youth (BMFSFJ) to prepare a report on gender diversity in law, which was published in February 2017.

The report entitled ‘Gender Diversity in Law – Status Quo and Development of Regulatory Models for the Recognition and Protection of Gender Diversity’ examines how the legal recognition and protection of the diversity of physical sex development, gender identities and gender expression in Germany against the background of fundamental and human rights can and must be improved. the authors conclude that the current legal rules, in particular with regard to the situation of intersex persons and trans/transsexual persons, are inadequate. The report is an in-depth analysis of the current law, and uses a comparative as well as a socio-scientific assessment of the civil status regulation for the blank gender entry of intersex new-borns (§ 22 para. 3 Civil Status Act – Personenstandsgesetz – PStG). Several types of regulatory models for the recognition and protection of sex and gender identities have been developed (Part 1 and Annex of the report). Ultimately, the report recommends the drafting of a comprehensive legal framework on the recognition and protection of gender diversity (Part 2 of the report).

The development of regulatory alternatives was carried out in consultation with intersex and trans/transsexual persons, their parents, associations, counsellors and academics, and the initial draftof the Bill sent to an extended circle of independent organisations with a perspective on inter and trans/ transsexuality as well as by scientists and practitioners for comments.

SOCIAL-SCIENTIFIC ASSESSMENT OF § 22 PARA. 3 OF THE CIVIL STATUS ACT

The focus of the social-scientific assessment was the amendment of the Civil Status Act (PStG), which came into effect on 1 November 2013 and according to which children who ‘cannot be attributed to the female or the male gender’ (…) are to be entered without a gender specification in the register of births (§ 22 para. 3 PStG).

Summary

INTRODUCTION

When Katja in her late puberty still had not had her period, her mother sent her to the doctor. This was the start of a two-year medical tour from one expert to the other. Their conclusion was that Katja had no pubic hair and no uterus, but why that was so remained unclear, at least to Katja. Most confusing was that Katja's mother made her promise not to talk to anyone about the'secrets in her tummy ‘. It was only when Katja was in her forties that she discovered that she had an XY, thus ‘male’ chromosomal make-up. Even more shocking was the discovery that her parents and her doctors had known this all along. The decision to keep this knowledge from Katja was based on a medical protocol according to which children with irregular sex characteristics were told as little as possible, to avoid ‘gender confusion’. The protocol had been adopted in the Netherlands following the then famous (now infamous) John/Joan case of American doctor John Money, who believed in the possibility to raise children in a specific gender, regardless of their physical characteristics. To ensure the successful gender development of a child as – in this case – female, it was imperative to keep any information from Katja that might raise doubts about her gender. Thus, it made sense not to tell Katja about her chromosomal make-up.

Katja was born in the early 1940s, but her experiences are shared by generations of people after her, since the medical protocol to not disclose information to intersex/DSD individuals that potentially could cause ‘gender confusion’, was only abandoned around 2003.

The main impetus to change the policy of secrecy regarding sex variations seems to have come from the spread of the World Wide Web: with access to the internet increasing, it became impossible to keep medical facts from the general public. The internet disclosed medical information on intersex conditions that had hitherto been accessible only to the medical profession. This in turn made many individuals with an intersex condition realise they were not in fact unique, as they had been led to believe.

Summary

AIM AND PURPOSE OF THIS BOOK

Issues surrounding legal gender have been the subject of much debate in the last decades, at least in the Western jurisdictions. However, much of this debate was focused on recognition of the preferred gender, i.e. the legal issues surround the legal status of transsexual and transgender persons. the legal issues concerning intersex persons, which are distinct and must be considered as such, have received much less attention, particularly in national jurisdictions. From a legal perspective, the key issues are (1) the designation of a legal gender and the right to a gender identity, and (2) the legitimacy of surgical and other medical interventions, as well as injuries caused by them, particularly on new-borns without the capacity to consent. Particularly the latter is of grave concern, and there is a wide debate about the soundness of judicial deference to the clinical management of these conditions as primarily medical matters, as it has become apparent that irreversible surgical interventions and hormonal therapies have been carried out on infants and very young children without long-term data confirming their necessity, safety and efficacy.

The aim of this book is to highlight the need and urgency to deal with these crucial issues, and by providing a wide range of accessible material to make these issues more visible to the general public and thus to further and broaden the debate. To this end, this book not only comprises purely legal views (Parts III–IV), but also medical and psychological (Part I) as well as theological and historical ones (Part II).

TERMINOLOGY

But in order to engage in any debate, it is necessary to deal with matters of terminology first, which can be very controversial. It is important to acknowledge at the outset that experiences of gender and sexed bodies are deeply personal and therefore inevitable vary from person to person. Hence, it is impossible to choose a terminology that would reflect everyone's experience of self, and any term chosen therefore may be perceived as inappropriate and even as hurtful. Therefore, it is important to state clearly that the intention of all authors of this volume is to be respectful, and that no offence or disrespect is intended.

Summary

INTRODUCTION

Like everyone else, individuals whose bodies are different from the majority of the population on account of variations in their sexed development seek to live a fulfilling life: to be happy; to experience good health and mental well-being; to have agency and the freedom to choose how they live their life; and to be treated justly, equitably within society and not be subjected to harm by others. Like everyone else, their well-being is caught up with their sense of self, identity and narrative, ‘their story’ and, this is shaped by language, by the ways in which they are recognised by others, by their actions in the world and the actions of the world upon them. Clearly people with variations in sex development are likely to have to negotiate particular challenges in making sense of their embodiment and in realising certain common human aspirations – including intimate relationships and parenthood. So, alongside the usual cast list of those who play a key role in the shared and fundamentally human task of making sense of the self – parents, siblings or friends – or the key institutional settings of socialisation (education, employment), contemporary individuals with variations in sex development are also very likely to be shaped by extensive experience of clinical medical settings.

This chapter seeks to set the experience of people with unusual sexed embodiment within the larger narrative of Christianity, the cornerstone of Western culture and thought, especially of its morality. The first substantial section will therefore consider theological and ethical reflections within early Christianity through a focus on two surprisingly pertinent passages within authoritative writings – The Gospel according to Matthew and Saint Augustine's City of God. It will be argued that in both, the authors challenge inherited cultural categories in ways that rehabilitate and promote the well-being of individuals with variations in sex development. this section is followed by a consideration of the contemporary situation. Here, particular attention is drawn to the dissensus that exists between the medical sphere that focuses on ‘disorders of sex development’ and the more identitarian orientation of some intersex activism and human rights advocacy.

Summary

INTRODUCTION

The term ‘intersex children’ is often used as a short term for children born with ambiguous sex characteristics, or put differently, diagnosed as having special medical conditions associated with differences in sex development. In fact there are a number of varieties, but the common feature is that it is difficult to determine whether the child is a girl or a boy. A major question is whether the child should be assigned a sex at birth or in early infancy and go through surgery and other forms of treatment to obtain that sex. For decades such medical interventions have been performed in the belief that they were necessary. However, doubt has been cast on whether it is possible to successfully assign a gender to an infant. Not only is it questionable whether the treatment is beneficial to the person concerned, but it has also gradually become known that the treatment in many instances has had various harmful effects on the children (and later adults) concerned, both physically and mentally. Consequently, over the last 10 to 15 years increasing attention has been paid to the person's human rights in this regard.

Children have rights under the UN Convention on the Rights of the Child (CRC) as well as under all other human rights conventions. This chapter mainly deals with the CRC, which focuses specifically on children and whose provisions are adapted to their special situation and needs, but other conventions will be mentioned where they are relevant. The chapter seeks to interpret and apply the CRC in the context of intersex children, in order to answer the question of whether a child may and should be assigned a sex in the early stages of life. The aim is also to outline the more specific obligations of the state under the Convention in this respect.

Almost all states in the world have ratified the CRC, making it a globally recognised instrument. The implementation of the CRC in the various countries is monitored by the UN Committee on the Rights of the Child, which is a body comprised of 18 members from around the world, so-called independent experts.

Summary

INTRODUCTION

On 15 April 2014, the Supreme Court of India (the Court) handed down judgment in National Legal Services Authority v. Union of India (NALSA). NALSA recognised the identities and rights of Hijra and transgender persons in law, echoing earlier decisions by neighbouring countries, Pakistan and Nepal. By embracing Hijras and transgender persons within its constitutional fold, the judgment in NALSA made a promise to them of the promotion and protection of fundamental rights as enshrined within the Constitution of Indian (the Constitution).

Upon its arrival, NALSA was in turn hailed as ‘landmark’ and as ‘embodying a long tradition of openness by the Court by simultaneously celebrating the universal idea of humanity and values, while emphasising the importance of national and local identities’ and derided for vague unenforceable orders and making ‘gross generalisations ‘about Hijra and transgender persons, slipping as it did in and out of’ different notions of transgender identity ‘pointing to’ an administrative nightmare without further clarification ‘.

Delineations in law are important; otherwise uncertainty remains as to whom the Court's newly announced recognition applies. For intersex persons this can become an acute problem – intersex persons may be straight, gay, lesbian, bisexual, asexual, and may identify as female, male, both or neither. This ability to transcend and traverse sexual orientations and gender identities has rendered intersex persons almost invisible and uniquely vulnerable, as if unnecessary of recognition and protection in the law. The lives of individuals with non-conforming sex binary bodies can be a precarious one of fear and violence, attempting to fit into the sex binary. 10

NALSA appeared to open a space for challenging the gender binary straitjacket by recognising and protecting gender variations in law in India. Recognition in law is the passport to identification documents, which in turn enables access to other fundamental rights, such as housing, welfare benefits, education and healthcare. This chapter asks what does NALSA mean for intersex persons in India? Does the promise made to Hijra and transgender persons include or extend to intersex individuals? On one level, the answer will inevitably lie in how NALSA is interpreted and applied; Jackuline Mary v.

Summary

INTRODUCTION

Mammalian sex development is a binary process established before birth so that the expectation at birth is that the sex of the baby is instantly recognisable as being female or male. When that is not the case, the term intersex has historically been used to describe an infant in whom the external genitalia are ambiguous in appearance and could be consistent with either a male or a female. Such a degree of ambiguity in humans is estimated to occur in in 4,500 to 5,500 births. If less severe forms of atypical genital development are also included, the problem affects as many as 1 in 300 births.

In order to understand the origins of intersex development, this chapter reviews how the outcome of the biological process of sex development is binary in the human fetus yet the embryological structures are present for that outcome to be bipotential. For that to happen, the bipotential structures must develop in response to biological drivers. These are genes and hormones which are produced during a critical period of fetal life and expressed in optimal concentrations.

THE EMBRYOLOGY

The development of the reproductive tract is sub-divided into formation of the internal and external genitalia. In both categories, the structures are bipotential with the capacity to form either male or female genitalia. Which it is, depends on genes and hormones.

THE GONADS

The structure which forms the gonads is termed the genital ridge, a region where the kidneys and adrenal glands also form. Until about five to six weeks of human gestation, the tissue forming the gonad is indeterminate on histological examination as being neither a testis or an ovary. The gonad is bipotential at this stage. A key gene which is present only on the Y (male) chromosome becomes expressed in the gonad if the egg at conception has been fertilised by a male bearing sperm (see Figure 1 and later in the text). Thereafter, the gonad becomes histologically distinguishable as a testis by cells that make testosterone (the male hormone) and other specialised cells that in later postnatal life make sperm. The bipotential gonad develops as an ovary when a female bearing sperm fertilises the egg and the Y chromosome-related key gene is absent.

Summary

INTRODUCTION

The legal status of intersex persons of Australia is complicated by the very structure of the Australian legal system. Australia is a federal system, with competence for areas of law divided according to the Constitution. However, the regulation of sex and gender identity falls across several different areas of competence, leaving a patchwork of inconsistent, and at times contradictory, laws.

While states and territories have competence in the area of registration of births – and thus the registration of sex on the birth certificate – the commonwealth holds competency in relation to marriage (and its definition), and the issuance of passports. As such, it is possible for individuals to have two documents used to establish legal identity – the passport and the birth certificate – declaring a different gender. This situation is complicated even further by the fact that different states and territories have established different rules concerning the registration of sex on the birth certifcate, as well as how an individual can register a change of gender.

This chapter will attempt to summarise the key features of these various laws, starting with the registration of an intersex child on a birth certificate in different states and territories, then go on to discuss how the birth certificate can be changed at a later date. It will then move to recognition of intersex as a status on a federal level, and the consequences of conflicts between these differing regimes.

It must be recognised that most of the laws in this regard are drafted with transgender individuals in mind, rather than being intended to address the specific context of intersex individuals. Although this is starting to change, with the Australian Capital Territory (ACT) and South Australia leading the way, many states still do not have any legal recognition or protection of intersex individuals. In the absence of more specific and appropriate laws in this regard, the more general transgender mechanisms will be examined to consider whatever imperfect protection can be provided to intersex individuals.

Summary

The Maltese Gender Identity, Gender Expression and Sex Characteristics Act, 2015 (the 2015 Act) has been described as ‘the most expansive, ground-breaking and comprehensive bill of its kind’. This chapter will analyse this Act to assess how it has impacted upon the status of intersex people in Malta.

Over the past few decades discourse about intersex has been divided into two types of discussions: deliberations aimed at achieving recognition of intersex identity which may differ from that recorded at birth, and debates about medical management. While these may seem to be two disparate aims at their core, they concern questions of dignity, respect and the realisation of human rights. It is by addressing simultaneously both sides of the discussions that the 2015 Act earns its praise.

THE PROVISIONS IN THE LEGISLATION

The 2015 Act is ambitious in its aim. It unequivocally states that it will enable both the recognition of a person's gender identity and protect the bodily integrity of people.

THE RIGHT TO GENDER IDENTITY

The 2015 Act states unambiguously that all people have a right to gender identity. This is defined in Article 2 as

each person's internal and individual experience of gender, which may or may not correspond with the sex assigned at birth, including the personal sense of the body (which may involve, if freely chosen, modification of bodily appearance and/or functions by medical, surgical or other means) and other expressions of gender, including name, dress, speech and mannerism.

In Article 3 the legislation outlines the four component elements of this right:

Summary

This chapter is intended to give a short overview of the situation of transsexual and intersex persons in Germany, and particularly on how the German Government currently approaches the topic.

LEGAL SITUATION IN GERMANY

INTERSEX PERSONS

German law currently only differentiates between two legal genders/sexes: male and female. The official rationale for the Civil Code of 1896 states: ‘Today's science does not recognise intersex persons.’ Therefore, every child had to be registered as male or female. The possibility of leaving the legal designation of sex open in a child's birth certificate only came into existence at the end of 2013, when section 22(3) of the Act on Civil Status (Personenstandsgesetz) was amended. The child in question then does not have a sex in the legal sense. Adults also have the possibility of correcting their sex designation to ‘no information on sex’. Registrars may carry out this correction; but, as a rule, it is done by the court. Only a certificate from a doctor is required. Assigning a sex-neutral first name in the same procedure is not possible. However, at the end of 2017, the Federal Constitutional Court held that these provisions were in violation of the Basic Law (the German Constitution). The gist of the decision is that that there must be a positive recognition of a legal gender which is not ‘female’ or ‘male’, and not recording any information on the legal gender is insufficient. The Court suggested that, alternatively, civil status registers could stop recording the legal gender of any person. As a result of this decision, the legislature must enact new provisions by 31 December 2018 at the latest.

Some figures may be of interest here: it is estimated that there are approximately 8,000 to 10,000 people in Germany (82.2 million inhabitants as of 31 December 2015) with variations in their sexual characteristics. Despite this, from 2013 to January 2016, the possibility of leaving the sex registration open on the birth certificate was made use of just 12 times.

Intersentia

Refine listing

Refine listing

Actions for selected content:

Save Search

7719 results in Intersentia

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary

Summary