148 Human rights in practicetransformation, 185 which may result in conflicting approaches and widely diverging outcomes depending on the approach taken, which may not produce true citizens of the world.186 In legal education, human rights law may form part of constitutional/public law, regional systems, for example EU law, or public international law. How_ ever, the subject is often optional or confined to postgraduate studies. Many law students still leave university without having developed a clear understanding of human rights and human rights law. This is a particularly acute problem in countries where lawyers and activists are faced with human rights violations, or their legacy, but may lack the knowledge and requisite skills that would help them deal with the issues arising in such contexts. The staple response of international actors has been to provide human rights training for officials, judges and lawyers, such as in the case of Iraq following the end of the Saddam Hussein regime. Carefully designed training programmes that meet actual needs, address gaps in knowledge and enhance the skills of participants can be useful measures in such circumstances.187 However, training has often been used as a poorly designed short-cut measure where external actors with limited under-standing of the situation and needs of participants share largely theoretical knowledge. Such training is often attractive for organisers, trainers and fenders who can claim successful project implementation; meanwhile, participants enjoy the opportunity to travel and frequently receive handsome per dienas. For these reasons, there is a risk that training lacks a sense of focus, i.e. that it is not an integral part and means of a broader, organically developed long-term strategy but becomes an end in its own right. The larger impact of such training beyond evaluation by its participants is often not clear, particularly where officials receive training but the structural conditions facilitating violations remain in place.188 To be effective, developing and implementing human rights training should therefore be an integral element of a carefully designed strategy that identifies realistic objectives, including follow up and sustainability. The focus on training also risks masking deeper structural problems. Legal education in countries marked by years of dictatorship or conflict often 185 Gerber, above note 181. See for an analysis of, and case study (India) on, various models of human rights education [global citizenship, coexistence andtransformative action], M. Bajaj, Human Rights Education: Ideology, Location, and Approaches, (2011) 33 Human Rights 481. 186 See on the potential of such education, U. Baxi, Human Rights Education: The Promise of the Third Millennium? in G. J. Andreopoulos and R. P. Claude (eds.), Human Rights Education for the Twenty-first Century (University of Pennsylvania Press, 1997), 142-54. 187 See www.Imiamightseducation.infoi, and ww-w.ohchnorgienfpublicationsresourcesipages/ trainingeducation.aspx for the main UN websites. See also International Human Rights Network, What is effective training?, online at www.ihrnetwork.orgifiles/7.0/020Whato/o2Ois %20Effectiveo/o20Tra
ining.PDF. 188 See for an interesting case study on the political question of whether to conduct human rights training in repressive systems, D. Kinley and T. Wilson, Engaging a Pariah: Human Rights Training in l3urma/Myanmar, (2007) 29 Human Rights Quarterly 368. 149Strategies declines markedly, resulting in a noticeable gap in knowledge and skills between the older and younger generations. Training is a means to narrow this gap but cannot by itself replace good university education. Support for human rights work, from fenders and from other universities, adds an important financial and moral dimension that can act as a welcome boost for universities and lecturers who often work in extremely difficult circumstances. Evaluating approaches in this regard should form part of broader reflections on how capacity can be generated from within countries on a sustainable basis.The conflict in Darfur, Sudan (2003 and ongoing as of 2015) has been 0,,-,:o, characterised by massive human rights violations that have been attributed primarily to the government of Sudan and the Janjaweed (militias) but also to rebel groups. The UN and the AU responded by undertaking a number of fact- uf, j finding missions and inquiries, issuing resolutions and, in the case of the UNSC, .5,:_c_w-L-:,.= referring the situation to the Prosecutor of the ICC in 2005.2 The UN and AU also .v-c-=1 worked together to provide protection on the ground through the AU/UN Hybrid Mission in Darfur (UNAMID), whose presence the government of Sudan agreed to in 2007.3 In 2008 the ICC applied for an arrest warrant against Sudans President Al-Bashir (which was issued in 2009), which triggered considerable debate and opposition by the Arab League, the AU and others.4 The AU made a renewed ( effort to resolve the crisis in 2009 through the AU High-Level Panel on Darfur, which was mandated to examine the situation in depth and submit recommendations to the Council on how best the issues of accountability and combating impunity, on the one hand, and reconciliation and healing, on the other, could be effectively addressed.5 The situation constituted a major challenge for national and international NGOs and other human rights actors who worked in an environment characterised by constant flashpoints. This included the crisis in Darfur, majorI See in particular, Report of the International Commission of Inquiry on Darfur, 2005, and 3. Flint and A. de Waal, A New History of a Long War, 2nd edn (Zed Books, 2008). 2 UNSC resolution 1593 (2005). See for an overview, L. Oette, Peace and Justice, or Neither? The Repercussions of the al-Bashir Case for International Criminal Justice in Africa and Beyond, (2010) 8 Journal of International Criminal Justice 345, at 347-50. See for a critical assessment, F. Griinfelci and W. N. Vermeulen in cooperation with J. Krommendijk, Failure to Prevent Gross Human Rights Violations in Darfur: Warnings to and Responses by International Decision Makers (2003-2005) (Brill, 2014). 3 TJNSC resolution 1769 (2007). 4 See Oette, above note 2,357-64. a Darfur: The Quest for Peace, Justice and Reconciliation, Report of the African Union High-Level Panel on Darfur (AUFD), PSC/AHGI2 (CCVII) (29 October 2009)