It is important to note that the forcible dimension in the term forcible displacement: [...] is not restricted to physical force, but may include threat of force or coercion, such as that caused by fear of violence, duress, detention, psychological oppression or abuse of power against such person or persons or another person, or by taking advantage of a coercive environment.15 Even in cases of “consent” of the victim to leave, case law of the International Criminal Tribunal for the former Yugoslavia had a clear position on this, asserting that consent may be rendered “valueless” given the actual context in which it takes place.16 For instance, this would be the case if individuals or groups find themselves within a coercive environment and/or being subject to systematic discrimination.17 In such a scenario, the displacement would still clearly be considered a forced transfer. The determination as to whether a transferred person has a genuine choice must be made in the context of all relevant circumstances. In non-international armed conflict, however, the protection against displacement is less explicit, but the Practice Relating to Rule 129 makes it clear that parties may not order the displacement of civilian populations, in whole or in part, for reasons related to the conflict. International human rights law Numerous human rights protections, laid out within key legal instruments, have direct or indirect implications for the issue of preventing displacement. These include: the right to life, right to health, right to food, right to adequate housing, freedom from discrimination and the right to development. Furthermore, the final report of Special Rapporteur on The Human Rights Dimensions of Population Transfer to the Sub-Commission on Prevention of Discrimination and Protection of Minorities, concluded that, ”[…] the right to live and remain in one’s homeland, i.e. the right not to be subjected to forcible displacement, is a fundamental human right and a prerequisite to the enjoyment of other rights.”18 In addition, the report emphasized that: 15 The Rome Statute Elements of Crimes, Article 6(e). 16 See Kristic case, Judgment – Part III, para. 530. 17 For an explanation of the regulations as related to ethnic or political minorities who might have suffered discrimination or persecution (not by the occupying power) on such accounts and might therefore leave the occupied territory, see Commentary to the GC IV, at 279. 18 E/CN.4/Sub.2/1997/23, section 12, available at: http://www.unhchr.ch/huridocda/huridoca. nsf/%28Symbol%29/E.CN.4.Sub.2.1997.23.En?OpenDocument. 10