Myanmar’s Democratic Transition 265 registration cards and were permitted to vote in the May 2008 referendum on the new Constitution13 and in the 2010 general election.14 3 Recent Conditions for Rohingya In 1991 and 1992, over 250,000 Rohingya refugees fled into the Cox’s Bazar area of Bangladesh following a violent campaign by the border security force, NaySat Kut-Kwey Ye (NaSaKa).15 NaSaKa’s purpose was to secure the border with Bangladesh and quell a Rohingya insurgency movement thought to consist of a few hundred guerilla fighters. By 1996, many of the refugees were repatriated, with the United Nations Refugee Agency (UNHCR) maintaining two camps in Bangladesh sheltering 28,000 refugees. Over 200,000 Rohingya unregistered refugees still subsist in the Cox’s Bazar region, with thousands more in Egypt, Pakistan, Saudi Arabia, Malaysia, Thailand, Indonesia, the United Arab Emirates, and Japan.16 A lengthy 2010 study conducted by the Irish Centre for Human Rights determined that ‘there exists substantial material to support the conclusion that crimes against humanity are currently being committed against the Rohingya minority group in North Arakan State.’17 June and October 2012 saw some of the worst inter-communal violence in Arakan in years, resulting in around 200 deaths and 150,000 persons displaced. 13 14 15 16 17 Irish Centre for Human Rights, Crimes against Humanity in Western Burma: The Situation of the Rohingyas (National University of Ireland, 2010) 27. IRIN, ‘Myanmar: What Next for the Rohingyas?’ IRINNews (29 March 2012) <www .irinnews.org/report/95190/myanmar-what-next-for-the-rohingyas> accessed 20 October 2013. Reports of murder, rape, destruction of property, and forced labour are well-documented. Human Rights Watch, ‘Burma: The Rohingya Muslims: Ending a Cycle of Exodus?’ (1 September 1996); Human Rights Watch, ‘Burma: Rape, Forced Labor and Religious Persecution in Northern Arakan’ (May 1992) 7-21; Amnesty International, ‘Union of Myanmar (Burma): Human Rights Violations against Muslims in the Rakhine (Arakan) State’ (May 1992) Doc. ASA 16/06/92. Crimes against Humanity in Western Burma (n 13) 27. Rohingya refugees began fleeing to some of these countries in the 1980s. Ibid 146. Article 7 of the Rome Statute of the International Criminal Court defines crimes against humanity as ‘any of the following acts when committed as part of a widespread or systematic attack directed against any civilian population, with knowledge of the attack.’ Acts enumerated include but are not limited to murder, enslavement, deportation or forcible transfer of population, rape, persecution, and enforced disappearance. Rome Statute of the International Criminal Court, Art. 7 (2002). Myanmar is not a party to the Rome Statute. tilburg law review 19 (2014) 261-275