International Court of Justice Advisory Opinion on Western Sahara
Encyclopedia
One of the main functions of the International Court of Justice
(ICJ) is to provide Advisory Opinions - non-binding legal interpretations admitted by United Nations
organs. In the summer of 1975, the court considered two questions regarding the disputed territory of Western Sahara
(then Spanish Sahara
). In 1969, Spain returned the region of Ifni to Morocco.
had largely decolonized its foreign holdings, including much of Spanish Morocco
, but had retained the Spanish Sahara. In 1958, the Moroccan Army of Liberation fought the Spanish forces in the Ifni War
. After support from France, Spain regained control of the region but returned the regions of Tarfaya, and Tantan to Morocco. Morocco continued to demand the return the remaining regions, Ifni, Saguia el-Hamra and Rio De Oro and several other regions
(Mauritania, part of Algeria & part of Mali) colonized by France. During the 1960s, Morocco succeeded in getting Spanish Sahara to be listed on the list of territories to be decolonized, and on December 20, 1966, United Nations General Assembly Resolution 2229 called on Spain to hold a referendum
on self-determination
in the region.
After initially resisting all claims by Morocco and Mauritania (which also started laying claims to parts of the region), Spain
announced on August 20, 1974, that a referendum
on self-determination
would be held in the first six months of 1975 and took a census of the region in order to assess the voting population.
Morocco
declared it cannot accept a referendum which would include an option for independence and renewed its demands for the reintegration of the remaining provinces of Saguia el-Hamra
and Rio de Oro
to the country's sovereignty. In Mauritania, a smaller movement existed to overtake some amount of the territory, partitioning it with Morocco.
Algerian-Moroccan relations had been strained since Algeria's independence in 1962, culminating in the Sand war
, and a lack of normalized relations. Algeria, after initially supporting Morocco and Mauritania in their demands , started in 1975 to support the independence of the territory. The Algerian official position was that it supported the right of self-determination of the people of the former Spanish colony. The Polisario Front
, created in 1973, a national liberation movement
known as Polisario (Spanish: "Frente Popular de Liberación de Saguia el-Hamra y Río de Oro" English: "Popular Front for the Liberation of Saguia el-Hamra and Rio de Oro") was formed in 1973 to expel the Spaniards. They engaged in several low-level acts of property destruction, mostly localized around the Fosbucraa
conveyor belt, which exported the rich phosphate
s to the Atlantic Ocean
.
On September 17, 1974, King Hassan II
announced his intention to bring the issue to the ICJ. In December, Spain agreed to delay the referendum pending the opinion of the court. They gave their support to ICJ submission on the grounds that it be a non-binding, advisory opinion, rather than a "contentious issue", where the ruling would oblige the interested states
to act in a particular manner.
On December 13, the United Nations General Assembly
voted on submission, resulting in UN General Assembly Resolution 3292, affirming it and defining the wording of the questions to be submitted. Algeria was among the nations voting in favor, and several Third World
nations abstained.
And, should the majority opinion be "no", the following would be addressed:
In the meantime, Morocco and Mauritania jointly agreed to not contest the issue of partition or sovereignty. On January 16, 1975, Spain officially announced the suspension of the referendum plan, pending the opinion of the court. From May 12 through to May 19, a small investigative team made of citizens from Cuba
, Iran
, and Côte d'Ivoire
was sent into the region to assess public support for independence. They also performed inquiries in Algeria, Mauritania, Morocco, and Spain.
In the summer, the questions were submitted by King Hassan II and Spain. Algeria, Mauritania, Morocco, and Spain were all given permission to present evidence at the hearings (the Polisario was locked out as only internationally recognized states have a right to speak - Algeria largely represented the Sahrawis). Twenty-seven sessions were held in June and July before the Court called the proceedings final.
The arguments presented by Morocco and Mauritania were essentially similar: that either one had a sovereign right over the territory. In the case of Morocco, the kingdom of Morocco claimed the allegiance of a variety of tribes in surrounding territory. The modern Moroccan monarchy is derived from this kingdom . In the case of Mauritania, there was no clearly defined state that existed at the time. Instead, Mauritania argued that a similar entity existed which they called "bilad Chinguetti
". Spain argued against Moroccan sovereignty, citing the relationship that Spanish explorers and colonizers had established with the sultan, none of which ever recognized his authority over the region. Algeria also defended the position that the Sahrawis were a distinct people, and not under the subjection of Morocco or Mauritania.
sent by the General Assembly to tour the region and investigate the political situation published its findings, showing that the Sahrawi population were "overwhelmingly" in favor of independence
from both Spain and Morocco/Mauritania. These findings were submitted to the Court, who published their opinion the next day.
For the former question, the Court decided by a vote of 13 to three that the court could make a decision on the matter, and unanimously voted that at the time of colonization (defined as November 28, 1884), the territory was not terra nullius (that is, the territory, did belong to someone).
For the latter question, the Court decided by a vote of 14 to two that it would decide. It was of the opinion, by 14 votes to two, that there were legal ties of allegiance between this territory and the Kingdom of Morocco. Furthermore, it was of opinion, by 15 votes to one, that there were legal ties between this territory and the "Mauritanian entity". However, the Court defined the nature of these legal ties in the penultimate paragraph of its opinion, and declared that neither legal tie implied sovereignty or rightful ownership over the territory. These legal ties also did not apply to "self-determination through the free and genuine expression of the will of the peoples of the Territory."(ICJ Reports (1975) p. 68, para. 162)
While Morocco and Mauritania found in the answers to the two questions a recognition that their claims are legitimate and historically based, Algeria and the Polisario Front focused on the penultimate paragraph that stated that the court's decision was not to hinder the application of self-determination through the ongoing Spanish referendum.
King Hassan II declared the organisation of a peaceful march
to force Spain to start negotiations on the status of the territory, to which Spain finally agreed. A round of talks between Spain, Morocco and Mauritania were held in Madrid and culminated in a tripartite agreement, becoming known as the Madrid Accords
On November 16, 1975, where Spain formally ceded the administration of the northern two thirds of the territory to Morocco, while the southern third was to be administrated by Mauritania. Algeria protested the agreement, and president Boumedienne retaliated by expelling all Moroccans living in Algeria . The text of the Madrid Accords have never been made public record.
In consequence, the Court's decisions were largely disregarded by the interested parties. On October 31, 1975 the first Moroccan troops invaded Western Sahara from the north-east. Algeria sent its troops into the territory of Western Sahara to help in the logistic of the evacuation of the Sahrawi refugees who have been bombarded by Moroccan air forces, which led to the first and last direct military confrontation between units of the Moroccan armed forces and the Algerian national army in Amgala
in 1976. The Algerian army suffered hundreds of deaths and more than a hundred soldiers were made prisoners by the Moroccan army. Diplomatic intervention from Saudi Arabia
and Egypt
prevented the situation from escalating further.
Spain's last soldier departed the territory on February 26, 1976. The next day, the Saharawi Arab Democratic Republic was declared by Polisario representatives. Morocco intensified their military presence in the region, and by the end of the year, Mauritania and Morocco had partitioned the territory. Mauritania was too weak militarily and economically to compete against Polisario, though, and were forced to renounce their claims in 1979. Morocco immediately annexed that territory in addition. To this day, most of Western Sahara is administered by Morocco, but its sovereignty has not been recognized by the UN or any country. At the same time, 81 governments
have recognized the Sahrawi Republic
as the legitimate government of Western Sahara.
International Court of Justice
The International Court of Justice is the primary judicial organ of the United Nations. It is based in the Peace Palace in The Hague, Netherlands...
(ICJ) is to provide Advisory Opinions - non-binding legal interpretations admitted by United Nations
United Nations
The United Nations is an international organization whose stated aims are facilitating cooperation in international law, international security, economic development, social progress, human rights, and achievement of world peace...
organs. In the summer of 1975, the court considered two questions regarding the disputed territory of Western Sahara
Western Sahara
Western Sahara is a disputed territory in North Africa, bordered by Morocco to the north, Algeria to the northeast, Mauritania to the east and south, and the Atlantic Ocean to the west. Its surface area amounts to . It is one of the most sparsely populated territories in the world, mainly...
(then Spanish Sahara
Spanish Sahara
Spanish Sahara was the name used for the modern territory of Western Sahara when it was ruled as a territory by Spain between 1884 and 1975...
). In 1969, Spain returned the region of Ifni to Morocco.
Background
Since its accession to independence in 1956, Morocco has considered Spanish Sahara to be part of its pre-colonial territory, and SpainSpain
Spain , officially the Kingdom of Spain languages]] under the European Charter for Regional or Minority Languages. In each of these, Spain's official name is as follows:;;;;;;), is a country and member state of the European Union located in southwestern Europe on the Iberian Peninsula...
had largely decolonized its foreign holdings, including much of Spanish Morocco
Spanish Morocco
The Spanish protectorate of Morocco was the area of Morocco under colonial rule by the Spanish Empire, established by the Treaty of Fez in 1912 and ending in 1956, when both France and Spain recognized Moroccan independence.-Territorial borders:...
, but had retained the Spanish Sahara. In 1958, the Moroccan Army of Liberation fought the Spanish forces in the Ifni War
Ifni War
The Ifni War, sometimes called the Forgotten War in Spain , was a series of armed incursions into Spanish West Africa by Moroccan insurgents and Sahrawi rebels that began in October 1957 and culminated with the abortive siege of Sidi Ifni.The war, which may be seen as part of the general movement...
. After support from France, Spain regained control of the region but returned the regions of Tarfaya, and Tantan to Morocco. Morocco continued to demand the return the remaining regions, Ifni, Saguia el-Hamra and Rio De Oro and several other regions
Greater Morocco
Greater Morocco is a label historically used by some Moroccan anti-colonial political leaders protesting against Spanish and French rule, to refer to wider territories historically associated with the Moroccan Sultan...
(Mauritania, part of Algeria & part of Mali) colonized by France. During the 1960s, Morocco succeeded in getting Spanish Sahara to be listed on the list of territories to be decolonized, and on December 20, 1966, United Nations General Assembly Resolution 2229 called on Spain to hold a referendum
Referendum
A referendum is a direct vote in which an entire electorate is asked to either accept or reject a particular proposal. This may result in the adoption of a new constitution, a constitutional amendment, a law, the recall of an elected official or simply a specific government policy. It is a form of...
on self-determination
Self-determination
Self-determination is the principle in international law that nations have the right to freely choose their sovereignty and international political status with no external compulsion or external interference...
in the region.
After initially resisting all claims by Morocco and Mauritania (which also started laying claims to parts of the region), Spain
Spain
Spain , officially the Kingdom of Spain languages]] under the European Charter for Regional or Minority Languages. In each of these, Spain's official name is as follows:;;;;;;), is a country and member state of the European Union located in southwestern Europe on the Iberian Peninsula...
announced on August 20, 1974, that a referendum
Referendum
A referendum is a direct vote in which an entire electorate is asked to either accept or reject a particular proposal. This may result in the adoption of a new constitution, a constitutional amendment, a law, the recall of an elected official or simply a specific government policy. It is a form of...
on self-determination
Self-determination
Self-determination is the principle in international law that nations have the right to freely choose their sovereignty and international political status with no external compulsion or external interference...
would be held in the first six months of 1975 and took a census of the region in order to assess the voting population.
Morocco
Morocco
Morocco , officially the Kingdom of Morocco , is a country located in North Africa. It has a population of more than 32 million and an area of 710,850 km², and also primarily administers the disputed region of the Western Sahara...
declared it cannot accept a referendum which would include an option for independence and renewed its demands for the reintegration of the remaining provinces of Saguia el-Hamra
Saguia el-Hamra
Saguia el-Hamra, in Arabic الساقية الحمراء, al-Saqiyah al-Hamra'a , is, with Río de Oro, one of the two territories that formed the Spanish province of Spanish Sahara after 1969. Its name comes from a waterway that goes through the capital....
and Rio de Oro
Río de Oro
Río de Oro , is, with Saguia el-Hamra, one of the two territories that formed the Spanish province of Spanish Sahara after 1969; it was originally taken as a Spanish colonial possession in the late 19th century...
to the country's sovereignty. In Mauritania, a smaller movement existed to overtake some amount of the territory, partitioning it with Morocco.
Algerian-Moroccan relations had been strained since Algeria's independence in 1962, culminating in the Sand war
Sand War
The Sand War or Sands War occurred along the Algerian-Moroccan border in October 1963, and was a Moroccan attempt to claim the Tindouf and the Béchar areas that France had annexed to French Algeria a few decades earlier.- Background :...
, and a lack of normalized relations. Algeria, after initially supporting Morocco and Mauritania in their demands , started in 1975 to support the independence of the territory. The Algerian official position was that it supported the right of self-determination of the people of the former Spanish colony. The Polisario Front
Polisario Front
The POLISARIO, Polisario Front, or Frente Polisario, from the Spanish abbreviation of Frente Popular de Liberación de Saguía el Hamra y Río de Oro is a Sahrawi rebel national liberation movement working for the independence of Western Sahara from Morocco...
, created in 1973, a national liberation movement
National Liberation Movement
A national liberation movement is an organization engaged in a war of national liberation.National Liberation Movement may also refer to:* Movement of National Liberation, a leftist party founded by former Mexican President Lázaro Cárdenas...
known as Polisario (Spanish: "Frente Popular de Liberación de Saguia el-Hamra y Río de Oro" English: "Popular Front for the Liberation of Saguia el-Hamra and Rio de Oro") was formed in 1973 to expel the Spaniards. They engaged in several low-level acts of property destruction, mostly localized around the Fosbucraa
Bou Craa
Bou Craa is a town in the Saguia el-Hamra region of northern Western Sahara, south and slightly east of the city of El Aaiún. It is inhabited almost entirely by employees of the Moroccan-controlled Bou Craa phosphate industry...
conveyor belt, which exported the rich phosphate
Phosphate
A phosphate, an inorganic chemical, is a salt of phosphoric acid. In organic chemistry, a phosphate, or organophosphate, is an ester of phosphoric acid. Organic phosphates are important in biochemistry and biogeochemistry or ecology. Inorganic phosphates are mined to obtain phosphorus for use in...
s to the Atlantic Ocean
Atlantic Ocean
The Atlantic Ocean is the second-largest of the world's oceanic divisions. With a total area of about , it covers approximately 20% of the Earth's surface and about 26% of its water surface area...
.
On September 17, 1974, King Hassan II
Hassan II of Morocco
King Hassan II l-ḥasan aṯ-ṯānī, dial. el-ḥasan ettâni); July 9, 1929 – July 23, 1999) was King of Morocco from 1961 until his death in 1999...
announced his intention to bring the issue to the ICJ. In December, Spain agreed to delay the referendum pending the opinion of the court. They gave their support to ICJ submission on the grounds that it be a non-binding, advisory opinion, rather than a "contentious issue", where the ruling would oblige the interested states
Sovereign state
A sovereign state, or simply, state, is a state with a defined territory on which it exercises internal and external sovereignty, a permanent population, a government, and the capacity to enter into relations with other sovereign states. It is also normally understood to be a state which is neither...
to act in a particular manner.
On December 13, the United Nations General Assembly
United Nations General Assembly
For two articles dealing with membership in the General Assembly, see:* General Assembly members* General Assembly observersThe United Nations General Assembly is one of the five principal organs of the United Nations and the only one in which all member nations have equal representation...
voted on submission, resulting in UN General Assembly Resolution 3292, affirming it and defining the wording of the questions to be submitted. Algeria was among the nations voting in favor, and several Third World
Third World
The term Third World arose during the Cold War to define countries that remained non-aligned with either capitalism and NATO , or communism and the Soviet Union...
nations abstained.
Submission
UN General Assembly Resolution 3292 requested that the International Court give an advisory opinion on the following questions:And, should the majority opinion be "no", the following would be addressed:
In the meantime, Morocco and Mauritania jointly agreed to not contest the issue of partition or sovereignty. On January 16, 1975, Spain officially announced the suspension of the referendum plan, pending the opinion of the court. From May 12 through to May 19, a small investigative team made of citizens from Cuba
Cuba
The Republic of Cuba is an island nation in the Caribbean. The nation of Cuba consists of the main island of Cuba, the Isla de la Juventud, and several archipelagos. Havana is the largest city in Cuba and the country's capital. Santiago de Cuba is the second largest city...
, Iran
Iran
Iran , officially the Islamic Republic of Iran , is a country in Southern and Western Asia. The name "Iran" has been in use natively since the Sassanian era and came into use internationally in 1935, before which the country was known to the Western world as Persia...
, and Côte d'Ivoire
Côte d'Ivoire
The Republic of Côte d'Ivoire or Ivory Coast is a country in West Africa. It has an area of , and borders the countries Liberia, Guinea, Mali, Burkina Faso and Ghana; its southern boundary is along the Gulf of Guinea. The country's population was 15,366,672 in 1998 and was estimated to be...
was sent into the region to assess public support for independence. They also performed inquiries in Algeria, Mauritania, Morocco, and Spain.
In the summer, the questions were submitted by King Hassan II and Spain. Algeria, Mauritania, Morocco, and Spain were all given permission to present evidence at the hearings (the Polisario was locked out as only internationally recognized states have a right to speak - Algeria largely represented the Sahrawis). Twenty-seven sessions were held in June and July before the Court called the proceedings final.
The arguments presented by Morocco and Mauritania were essentially similar: that either one had a sovereign right over the territory. In the case of Morocco, the kingdom of Morocco claimed the allegiance of a variety of tribes in surrounding territory. The modern Moroccan monarchy is derived from this kingdom . In the case of Mauritania, there was no clearly defined state that existed at the time. Instead, Mauritania argued that a similar entity existed which they called "bilad Chinguetti
Chinguetti
Chinguetti is a ksar or medieval trading centre in northern Mauritania, lying on the Adrar Plateau east of Atar.Founded in the 13th century, as the center of several trans-Saharan trade routes, this tiny city continues to attract a handful of visitors who admire its spare architecture, exotic...
". Spain argued against Moroccan sovereignty, citing the relationship that Spanish explorers and colonizers had established with the sultan, none of which ever recognized his authority over the region. Algeria also defended the position that the Sahrawis were a distinct people, and not under the subjection of Morocco or Mauritania.
The Opinion
On October 15, a UN visiting missionUnited Nations visiting mission to Spanish Sahara
To assist in the decolonization process of the Spanish Sahara , a colony in North Africa, the United Nations General Assembly in 1975 dispatched a visiting mission to the territory and the surrounding countries, in accordance with its resolution 3292 .- Purpose of the visiting mission :The mission...
sent by the General Assembly to tour the region and investigate the political situation published its findings, showing that the Sahrawi population were "overwhelmingly" in favor of independence
Independence
Independence is a condition of a nation, country, or state in which its residents and population, or some portion thereof, exercise self-government, and usually sovereignty, over its territory....
from both Spain and Morocco/Mauritania. These findings were submitted to the Court, who published their opinion the next day.
For the former question, the Court decided by a vote of 13 to three that the court could make a decision on the matter, and unanimously voted that at the time of colonization (defined as November 28, 1884), the territory was not terra nullius (that is, the territory, did belong to someone).
For the latter question, the Court decided by a vote of 14 to two that it would decide. It was of the opinion, by 14 votes to two, that there were legal ties of allegiance between this territory and the Kingdom of Morocco. Furthermore, it was of opinion, by 15 votes to one, that there were legal ties between this territory and the "Mauritanian entity". However, the Court defined the nature of these legal ties in the penultimate paragraph of its opinion, and declared that neither legal tie implied sovereignty or rightful ownership over the territory. These legal ties also did not apply to "self-determination through the free and genuine expression of the will of the peoples of the Territory."(ICJ Reports (1975) p. 68, para. 162)
Results
The opinion of the Court was interpreted differently by the different parties, and each focused on what it sees as supporting its claims.While Morocco and Mauritania found in the answers to the two questions a recognition that their claims are legitimate and historically based, Algeria and the Polisario Front focused on the penultimate paragraph that stated that the court's decision was not to hinder the application of self-determination through the ongoing Spanish referendum.
King Hassan II declared the organisation of a peaceful march
Green March
The Green March was a strategic mass demonstration in November 1975, coordinated by the Moroccan government, to force Spain to hand over the disputed, autonomous semi-metropolitan Spanish Province of Sahara to Morocco.-Background:...
to force Spain to start negotiations on the status of the territory, to which Spain finally agreed. A round of talks between Spain, Morocco and Mauritania were held in Madrid and culminated in a tripartite agreement, becoming known as the Madrid Accords
Madrid Accords
The Madrid Accords, also called Madrid Agreement or Madrid Pact, was a treaty between Spain, Morocco, and Mauritania to end the Spanish presence in the territory of Spanish Sahara, which was until the Madrid Accords' inception a Spanish province and former colony. It was signed in Madrid on...
On November 16, 1975, where Spain formally ceded the administration of the northern two thirds of the territory to Morocco, while the southern third was to be administrated by Mauritania. Algeria protested the agreement, and president Boumedienne retaliated by expelling all Moroccans living in Algeria . The text of the Madrid Accords have never been made public record.
In consequence, the Court's decisions were largely disregarded by the interested parties. On October 31, 1975 the first Moroccan troops invaded Western Sahara from the north-east. Algeria sent its troops into the territory of Western Sahara to help in the logistic of the evacuation of the Sahrawi refugees who have been bombarded by Moroccan air forces, which led to the first and last direct military confrontation between units of the Moroccan armed forces and the Algerian national army in Amgala
Amgala
Amgala is an oasis in Western Sahara. It is situated between Tifariti, Smara and Meharrize, close to the east of the Moroccan Wall, in the POLISARIO-held part of Western Sahara.Its population was estimated in 2,000 inhabitants in 1975....
in 1976. The Algerian army suffered hundreds of deaths and more than a hundred soldiers were made prisoners by the Moroccan army. Diplomatic intervention from Saudi Arabia
Saudi Arabia
The Kingdom of Saudi Arabia , commonly known in British English as Saudi Arabia and in Arabic as as-Sa‘ūdiyyah , is the largest state in Western Asia by land area, constituting the bulk of the Arabian Peninsula, and the second-largest in the Arab World...
and Egypt
Egypt
Egypt , officially the Arab Republic of Egypt, Arabic: , is a country mainly in North Africa, with the Sinai Peninsula forming a land bridge in Southwest Asia. Egypt is thus a transcontinental country, and a major power in Africa, the Mediterranean Basin, the Middle East and the Muslim world...
prevented the situation from escalating further.
Spain's last soldier departed the territory on February 26, 1976. The next day, the Saharawi Arab Democratic Republic was declared by Polisario representatives. Morocco intensified their military presence in the region, and by the end of the year, Mauritania and Morocco had partitioned the territory. Mauritania was too weak militarily and economically to compete against Polisario, though, and were forced to renounce their claims in 1979. Morocco immediately annexed that territory in addition. To this day, most of Western Sahara is administered by Morocco, but its sovereignty has not been recognized by the UN or any country. At the same time, 81 governments
Foreign relations of Western Sahara
Western Sahara, formerly the Spanish colony of Spanish Sahara, is a disputed territory claimed by both the Kingdom of Morocco and the Polisario Front...
have recognized the Sahrawi Republic
Sahrawi Arab Democratic Republic
The Sahrawi Arab Democratic Republic is a partially recognised state that claims sovereignty over the entire territory of Western Sahara, a former Spanish colony. SADR was proclaimed by the Polisario Front on February 27, 1976, in Bir Lehlu, Western Sahara. The SADR government controls about...
as the legitimate government of Western Sahara.
See also
- Baker PlanBaker PlanThe Baker Plan is a United Nations initiative to grant self-determination to Western Sahara...
- History of Western SaharaHistory of Western SaharaThe history of Western Sahara can be traced back to the times of Carthaginian explorer Hanno the Navigator in the 5th century BC. Though few historical records are left from that period, Western Sahara's modern history has its roots linked to some nomadic groups such as the Sanhaja group and the...
- List of International Court of Justice cases
- United Nations visiting mission to Spanish SaharaUnited Nations visiting mission to Spanish SaharaTo assist in the decolonization process of the Spanish Sahara , a colony in North Africa, the United Nations General Assembly in 1975 dispatched a visiting mission to the territory and the surrounding countries, in accordance with its resolution 3292 .- Purpose of the visiting mission :The mission...
Further reading
- The International Court of Justice and the Western Sahara dispute by George Joffe, 1986 (Scanned document)
- Tony Hodges (1983), Western Sahara: The Roots of a Desert War, Lawrence Hill Books (ISBN 0-88208-152-7)
- Anthony G. Pazzanita and Tony Hodges (1994), Historical Dictionary of Western Sahara, Scarecrow Press (ISBN 0-8108-2661-5)
- Toby Shelley (2004), Endgame in the Western Sahara: What Future for Africa's Last Colony?, Zed Books (ISBN 1-84277-341-0)
- Erik Jensen (2005), Western Sahara: Anatomy of a Stalemate, International Peace Studies (ISBN 1-58826-305-3)