Arson

Last updated

The remains of Kyoto Animation Studio 1 after being set ablaze by an arsonist Kyoto animation arson attack 1 20190721.jpg
The remains of Kyoto Animation Studio 1 after being set ablaze by an arsonist

Arson is the act of willfully and deliberately setting fire to or charring property. Although the act of arson typically involves buildings, the term can also refer to the intentional burning of other things, such as motor vehicles, watercraft, or forests. The crime is typically classified as a felony, with instances involving a greater degree of risk to human life or property carrying a stricter penalty. Arson which results in death can be further prosecuted as manslaughter or murder. A common motive for arson is to commit insurance fraud. [1] [2] [3] In such cases, a person destroys their own property by burning it and then lies about the cause in order to collect against their insurance policy. [4]

Contents

A person who commits arson is referred to as an arsonist, or a serial arsonist if arson has been committed several times. Arsonists normally use an accelerant (such as gasoline or kerosene) to ignite, propel, and direct fires, and the detection and identification of ignitable liquid residues is an important part of fire investigations. [5] Pyromania is an impulse control disorder characterized by the pathological setting of fires. [6] Most acts of arson are not committed by pyromaniacs. [6]

Etymology

The term derives from Law French arsoun (late 13th century), from Old French arsion, from Late Latin ārsiōnem "a burning," (acc.) from the verb ardēre, "to burn." [7] [8] [9]

The Old English term was bærnet, lit. "burning"; and Edward Coke has indictment of burning (1640). Arsonist is from 1864. [10]

English common law

English Common Law defines arson as "the malicious burning of the dwelling of another." [11]

This definition has four elements:

Malicious
For purposes of common law arson, "malicious" refers to intention of starting the fire. Fires can be started on purpose or on accident. In either case, there are legal examples which charge the guilty person with arson whether their intention was to start a fire or not. "Malicious" in this case is describing the intention of the arsonist as ill-intentioned and intending to cause harm or death.
Burning
According to common law charring to any part of dwelling was sufficient to satisfy this element. No significant amount of damage to the dwelling was required. Any injury or damage to the structure caused by exposure to heat or flame is sufficient.
Of the dwelling
'Dwelling' refers to a place of residence. The destruction of an unoccupied building was not considered arson: "... since arson protected habitation, the burning of an unoccupied house did not constitute arson." At common law a structure did not become a residence until the first occupants had moved in, and ceased to be a dwelling if the occupants abandoned the premises with no intention of resuming their residency. [12] Dwelling includes structures and outbuildings within the curtilage. [13] Dwellings were not limited to houses. A barn could be the subject of arson if occupied as a dwelling.
Of another
Burning one's own dwelling does not constitute common law arson, even if the purpose was to collect insurance, because "it was generally assumed in early England that one had the legal right to destroy his own property in any manner he chose". [14] Moreover, for purposes of common law arson, possession or occupancy rather than title determines whose dwelling the structure is. [13] Thus a tenant who sets fire to his rented house would not be guilty of common law arson, [13] while the landlord who set fire to a rented dwelling house would be guilty.

Degrees

Many U.S. state legal systems and the legal systems of several other countries divide arson into degrees, depending sometimes on the value of the property but more commonly on its use and whether the crime was committed in the day or night.

Many statutes vary the degree of the crime according to the criminal intent of the accused. Some US states use other degrees of arson, such as "fourth" and "fifth" degree, [15] while some states do not categorize arson by any degree. For example, in the state of Tennessee, arson is categorized as "arson" and "aggravated arson."

Insurance Fraud

A common motive for arson is to commit insurance fraud. In such cases, a person destroys their own property by burning it and then lies about the cause in order to collect against their insurance policy.

An example of insurance fraud being the motivating factor for an act of arson is the case for Operation Firebird. [16] A married couple and 4 co-conspirators were arrested and convicted with arson and insurance fraud after a string of home, business, and warehouse fires which took place between 2014 and 2018 were exposed as acts of arson. Using chicken left in boiling frying oil, the convicted criminals would make fire seem like a cooking accident. Then, the group committed insurance fraud by filing insurance claims for the cost of the building, as well as, smoke-damaged goods to claim fire damages for insurance payouts. The group's scheme claimed a reported $4 million and ended when authorities were tipped off of on where the location of the next planned incident would take place. Police then performed an investigation dubbed Operation Firebird with the San Jose Fire Department. According to a 2019 Press Release from the California Department of Insurance, Tyler and Kim Chen, Ha Nguyen, Sandy Ngo, Duyen Pham, and Trang Huynh were all convicted with various degrees of arson and insurance fraud.

Tyler Chen was convicted with five separate counts of arson and two separate counts of insurance fraud in Santa Clara County in 2018. Tyler Chen's wife, Kim Chen, was convicted with two counts of insurance fraud in Santa Clara county. [17]

By region

United States

A U.S. World War II era arson poster. The image seen above was created out of fear of arson attacks during World War II. Once the war ended, Smokey Bear made his debut because fire safety was more of a concern than acts of arson. Smokey Bear in poster from 1944. THE SABOTEUR'S FAVORITE WEAPON IS ARSON - NARA - 515637.jpg
A U.S. World War II era arson poster. The image seen above was created out of fear of arson attacks during World War II. Once the war ended, Smokey Bear made his debut because fire safety was more of a concern than acts of arson.
Smokey Bear in poster from 1944. Smokeybear1944.jpg
Smokey Bear in poster from 1944.

In the United States, the common law elements of arson are often varied in different jurisdictions. For example, the element of "dwelling" is no longer required in most states, and arson occurs by the burning of any real property without consent or with unlawful intent. [18] Arson is prosecuted with attention to degree of severity [19] in the alleged offense. First degree arson [20] generally occurs when people are harmed or killed in the course of the fire, while second degree arson occurs when significant destruction of property occurs. [21] While usually a felony, arson may also be prosecuted as a misdemeanor, [22] "criminal mischief", or "destruction of property." [23] Burglary also occurs, if the arson involved a "breaking and entering". [24] A person may be sentenced to death if arson occurred as a method of homicide, as was the case in California of Raymond Lee Oyler and in Texas of Cameron Todd Willingham.

After the Great Chicago Fire in 1871, the United States started a National Fire Prevention Week in order to educate the people on ways to prevent fires, minimize their damages, and hopefully drastically decrease casualties. [25] Fire Prevention Week campaigns includes various information on safe cooking practices pertaining to grilling, microwaving, and cooking on a stove.

During World War II arson was a much higher concern in the United States. There was a severe lack of firefighters due to the fact most of the men were overseas to fight the war. There were few men left behind to help combat forest fires. For example, during WW II in Eldora, Iowa a fire chief reported that his regular membership shrank from 21 to 9 men and their fire fighting force recruited retired members and new members to fill the missing positions during the war. [26] Although there were few attempts to burn U.S. forests, it continued to be a big concern due to the potential detrimental effects. This concern for arson attempts led to the rise of Smokey Bear who was the face of fire prevention and fire safety measures. [27] [28] Although the intention of Smokey Bear's persona is to encourage fire safety, Smokey shares a message of fire prevention which includes accidental fires that can sometimes be legally charged as arson.

In New York, arson is charged in five degrees. Arson in the first degree is a Class A-1 felony and requires the intent to burn the building with a person inside using an explosive incendiary device. In New York, the criminal charge of arson includes a maximum sentence of 25 years to life. [29]

In California, a conviction for arson of property that is not one's own is a felony punishable by up to three years in state prison. Aggravated arson, which carries the most severe punishment for arson, is punishable by 10 years to life in state prison. A well-known example of arson which took place in California is the Esperanza Fire. Raymond Lee Oyler was ultimately convicted of murder and sentenced to death for a 2006 fire in southern California that led to the deaths of five U.S. Forest Service firefighters; he was the first U.S. citizen to receive such a conviction and penalty for wildfire arson. [30]

Some states, such as California, prosecute the lesser offense of "reckless burning" when the fire is set recklessly as opposed to willfully and maliciously. The study of the causes is the subject of fire investigation. A recent example of a reckless burning offense is the El Dorado fire which took place in 2020 in California. This fire was caused by a gender reveal party which utilized a smoke bomb which is categorized as unsafe pyrotechnics. The El Dorado fire burned over a 71-day period, destroyed 20 structures and resulted in one firefighter fatality, for which the couple hosting the party were charged with involuntary manslaughter. [31] The Esperanza Fire ultimately resulted in the death of firefighter Charles "Charlie" Morton, who became trapped while attempting to fight the fire. The DA of California considered arson charges for the family members as they were deemed negligent with regard to fire safety. [32]

England

Cars damaged by arson in Millwall, Tower Hamlets, London, during the 2011 England Riots Sherwood Gardens Riots 03.jpg
Cars damaged by arson in Millwall, Tower Hamlets, London, during the 2011 England Riots

In British law, arson was a common law offence (except for the offence of arson in royal dockyards) [33] dealing with the criminal destruction of buildings by fire. The common law offence was abolished by s.11(1) of the Criminal Damage Act 1971. [34] The 1971 Act makes no distinction as to mode of destruction except that s.1(3) requires that if the destruction is by fire, the offence is charged as arson; s.4 of the Act provides a maximum penalty of life imprisonment for conviction under s.1 whether or not the offence is charged as arson. In Hong Kong, the common law offence was abolished by s 67 of the Crimes Ordinance 1971 (Part VIII of which, as amended by Crimes (Amendment) Ordinance 1972, [35] mirrored the English Criminal Damage Act 1971). [36] Like the English counterparts, 63 of the 1972 Ordinance provides a maximum penalty of life imprisonment, and s 60(3) of the Ordinance requires that if the damage is by fire the offence should be charged as arson.

Myanmar

In the Burmese legal system, arson is considered "mischief by fire" under sections 435 and 436 of the Myanmar Penal Code and punishable by fine and imprisonment. [37] The statutes were last amended on 1 July 2016, and made arson on houses and buildings punishable with up to 20 years in prison. [37]

The Burmese military has long used arson as a weapon of war against civilians. [38] [39] From the 2021 Myanmar coup d'état to August 2022, military forces committed arson on 28,434 houses in the country. [40]

Scotland

While the Scottish legal system has no offence known as arson statutorily defined, there are many offences that are used to charge those with acts that would normally constitute arson in other nations. Events constituting arson in English and Welsh law might be dealt with as one or more of a variety of offences such as wilful fire-raising, culpable and reckless conduct, vandalism or other offences depending on the circumstances of the event. The more serious offences (in particular wilful fire-raising and culpable and reckless conduct) can incur a sentence of life imprisonment.

Ireland

Ireland differentiates how it charges arson not by degree but rather by what is being destroyed and if anyone was harmed. [41] For example, while the sentence for setting fire to a building can be life imprisonment, the sentence for setting fire to goods in a building can only be up to fourteen years.

A notable historical act of arson in Ireland is the burning of Wildgoose Lodge, which resulted in the arrest, sentencing, and execution of 18 men, many of whom were innocent. [42] More recently, the 2023 Dublin riot involved instances of arson, with many such acts targeting vehicles.

Notable arsonists

See also

Related Research Articles

In criminal law, mens rea is the mental state of a defendant who is accused of committing a crime. In common law jurisdictions, most crimes require proof both of mens rea and actus reus before the defendant can be found guilty.

Robbery is the crime of taking or attempting to take anything of value by force, threat of force, or by use of fear. According to common law, robbery is defined as taking the property of another, with the intent to permanently deprive the person of that property, by means of force or fear; that is, it is a larceny or theft accomplished by an assault. Precise definitions of the offence may vary between jurisdictions. Robbery is differentiated from other forms of theft by its inherently violent nature ; whereas many lesser forms of theft are punished as misdemeanors, robbery is always a felony in jurisdictions that distinguish between the two. Under English law, most forms of theft are triable either way, whereas robbery is triable only on indictment. The word "rob" came via French from Late Latin words of Germanic origin, from Common Germanic raub "theft".

Burglary, also called breaking and entering (B&E) and housebreaking, is the act of illegally entering a building or other areas without permission, typically with the intention of committing a further criminal offence. Usually that offence is theft, larceny, robbery, or murder, but most jurisdictions include others within the ambit of burglary. To commit burglary is to burgle, a term back-formed from the word burglar, or to burglarize.

<span class="mw-page-title-main">Mischief</span> Class of criminal offense

Mischief or malicious mischief is the name for a class of criminal offenses that is defined differently in different legal jurisdictions. While the wrongful acts will often involve what is popularly described as vandalism, there can be a legal differentiation between vandalism and mischief. The etymology of the word comes from Old French meschief, which means "misfortune", from meschever, "to end badly".

<span class="mw-page-title-main">Theft Act 1968</span> United Kingdom legislation

The Theft Act 1968 is an act of the Parliament of the United Kingdom. It creates a number of offences against property in England and Wales.

An attempt to commit a crime occurs if a criminal has an intent to commit a crime and takes a substantial step toward completing the crime, but for reasons not intended by the criminal, the final resulting crime does not occur. Attempt to commit a particular crime is a crime, usually considered to be of the same or lesser gravity as the particular crime attempted. Attempt is a type of inchoate crime, a crime that is not fully developed. The crime of attempt has two elements, intent and some conduct toward completion of the crime.

Capital murder refers to a category of murder in some parts of the US for which the perpetrator is eligible for the death penalty. In its original sense, capital murder was a statutory offence of aggravated murder in Great Britain, Northern Ireland, and the Republic of Ireland, which was later adopted as a legal provision to define certain forms of aggravated murder in the United States. Some jurisdictions that provide for death as a possible punishment for murder, such as California, do not have a specific statute creating or defining a crime known as capital murder; instead, death is one of the possible sentences for certain kinds of murder. In these cases, "capital murder" is not a phrase used in the legal system but may still be used by others such as the media.

Malice is a legal term which refers to a party's intention to do injury to another party. Malice is either expressed or implied. For example, malice is expressed when there is manifested a deliberate intention to unlawfully take away the life of a human being. Malice is implied when no considerable provocation appears, or when the circumstances attending the killing show an abandoned and malignant heart. Malice, in a legal sense, may be inferred from the evidence and imputed to the defendant, depending on the nature of the case.

In criminal law and in the law of tort, recklessness may be defined as the state of mind where a person deliberately and unjustifiably pursues a course of action while consciously disregarding any risks flowing from such action. Recklessness is less culpable than malice, but is more blameworthy than carelessness.

<span class="mw-page-title-main">Malicious Damage Act 1861</span> United Kingdom legislation

The Malicious Damage Act 1861 is an Act of the Parliament of the United Kingdom of Great Britain and Ireland. It consolidated provisions related to malicious damage from a number of earlier statutes into a single Act. For the most part these provisions were, according to the draftsman of the Act, incorporated with little or no variation in their phraseology. It is one of a group of Acts sometimes referred to as the Criminal Law Consolidation Acts 1861. It was passed with the object of simplifying the law. It is essentially a revised version of an earlier consolidation Act, the Malicious Injuries to Property Act 1827, incorporating subsequent statutes.

John Leonard Orr is an American convicted serial arsonist, mass murderer, and former firefighter. A fire captain and arson investigator in Glendale, California, Orr was convicted of serial arson and four counts of murder; he is believed to have set nearly 2,000 fires in a 30-year arson spree, most of them between 1984 and 1991, making him the most prolific serial arsonist in American history.

Property crime is a category of crime, usually involving private property, that includes, among other crimes, burglary, larceny, theft, motor vehicle theft, arson, shoplifting, and vandalism. Property crime is a crime to obtain money, property, or some other benefit. This may involve force, or the threat of force, in cases like robbery or extortion. Since these crimes are committed in order to enrich the perpetrator they are considered property crimes. Crimes against property are divided into two groups: destroyed property and stolen property. When property is destroyed, it could be called arson or vandalism. Examples of the act of stealing property is robbery or embezzlement.

Wilful fire-raising is a common law offence under Scots law applicable to deliberately starting fires with intent to cause damage to property.

<span class="mw-page-title-main">Criminal damage in English law</span> United Kingdom legislation

Criminal damage in English law was originally a common law offence. The offence was largely concerned with the protection of dwellings and the food supply, and few sanctions were imposed for damaging personal property. Liability was originally restricted to the payment of damages by way of compensation.

<span class="mw-page-title-main">Rattlesnake Fire</span> 1953 wildfire in Northern California

The Rattlesnake Fire was a wildfire started by an arsonist on July 9, 1953, in Powder House Canyon on the Mendocino National Forest in northern California. The wildfire killed one Forest Service employee and 14 volunteer firefighters from the New Tribes Mission, and burned over 1,300 acres (530 ha) before it was controlled on July 11, 1953. It became and remains to this day a well-known firefighting textbook case on fatal wildland fires.

<span class="mw-page-title-main">Scottish criminal law</span>

Scots criminal law relies far more heavily on common law than in England and Wales. Scottish criminal law includes offences against the person of murder, culpable homicide, rape and assault, offences against property such as theft and malicious mischief, and public order offences including mobbing and breach of the peace. Scottish criminal law can also be found in the statutes of the UK Parliament with some areas of criminal law, such as misuse of drugs and traffic offences appearing identical on both sides of the Border. Scottish criminal law can also be found in the statute books of the Scottish Parliament such as the Sexual Offences (Scotland) Act 2009 and Prostitution (Scotland) Act 2007 which only apply to Scotland. In fact, the Scots requirement of corroboration in criminal matters changes the practical prosecution of crimes derived from the same enactment. Corroboration is not required in England or in civil cases in Scotland. Scots law is one of the few legal systems that require corroboration.

<span class="mw-page-title-main">Criminal law of the United States</span>

Criminal law is a system of laws that is connected with crimes and punishments of an individual who commits crimes. In comparison, civil law is where the case argues their issues with one entity to another entity with support of the law. Crimes can vary in definition by jurisdiction but the basis for a crime are fairly consistent regardless.

Life imprisonment is one of the five principal punishments stipulated in Article 33 of the Criminal Law of the People's Republic of China. In the Criminal Law, there are 87 penalties for life imprisonment.

The 2011–2012 Los Angeles arson attacks were a series of fires started on December 29, 2011, in Los Angeles, California. It was the worst case of arson reported in the area since the 1992 Los Angeles riots. Harry Burkhart, then 24, who was wanted in Germany on suspicion of burning down his home, was charged in Los Angeles in January 2012 with 28 counts of arson of property and nine counts of arson of an inhabited structure. Prosecutors said that Burkhart was "motivated by rage against Americans" and sought to terrorize as many people as possible when he torched dozens of cars, homes and garages late at night, when most residents were sleeping, to inflict maximum fear and damage.

On December 24, 2001, arsonists set fire to the Woodbine Building Supply Company building in Toronto, Ontario, Canada, causing an explosion and leading to one of the largest fires in the city's history. The arsonists were conspiring with John Magno, co-owner of the store, who desired to destroy the struggling business to collect a fraudulent insurance claim and clear the site for construction of a condominium development. The fire led to the evacuation of over 50 homes on Christmas morning, and the death of one of the arsonists. After many years of sitting as an idle lot, it was replaced by a condo building, Carmelina Condominiums, completed in 2015.

References

  1. ↑ "Arson". FindLaw. Archived from the original on January 5, 2019. Retrieved January 4, 2019.
  2. ↑ arson Archived February 10, 2008, at the Wayback Machine . Dictionary.com. The American Heritage Dictionary of the English Language , Fourth Edition. Houghton Mifflin Company, 2004. Accessed: January 27, 2008
  3. ↑ "StackPath". December 13, 2010. Archived from the original on January 27, 2021. Retrieved November 23, 2020.
  4. ↑ Zalma, Barry (January 8, 2014). "Fraud Proved – Lie About Cause Of Fire Sufficient to Support Guilty Verdict". LexisNexis. Archived from the original on January 5, 2019. Retrieved January 4, 2019.
  5. ↑ Almirall, José R.; Furton, Kenneth G., eds. (2004). Analysis and interpretation of fire scene evidence. Boca Raton: CRC Press. ISBN   978-0849378850. OCLC   53360702.
  6. 1 2 Burton, Paul R.; McNiel, Dale E.; Binder, Renée L. (November 2012). "Firesetting, arson, pyromania, and the forensic mental health expert" (PDF). Journal of the American Academy of Psychiatry and the Law. 40 (3): 355–365. PMID   22960918. Archived (PDF) from the original on January 5, 2019.
  7. ↑ "arson". Online Etymology Dictionary. Archived from the original on June 1, 2019. Retrieved June 2, 2019.
  8. ↑ Various. Chambers's Twentieth Century Dictionary (part 1 of 4: A-D). Library of Alexandria. ISBN   9781465562883. Archived from the original on January 25, 2022. Retrieved October 24, 2020– via Google Books.
  9. ↑ "Definition of arson - Dictionary.com". www.dictionary.com. Archived from the original on June 1, 2019. Retrieved June 1, 2019.
  10. ↑ Murray, James Augustus Henry; Craigie, Sir William Alexander; Onions, Charles Talbut (December 2, 1888). "A New English Dictionary on Historical Principles". www.books.google.com. Archived from the original on November 13, 2023. Retrieved November 13, 2023.
  11. ↑ Black's Law Dictionary (9th ed.). 2009. Arson. At common law, the malicious burning of someone else's dwelling house or outhouse that is either appurtenant to the dwelling house or within the curtilage.
  12. ↑ Boyce & Perkins, Criminal Law, 3rd ed. (1992) at 280, 281.
  13. 1 2 3 Boyce & Perkins, Criminal Law, 3rd ed. (1992) at 281.
  14. ↑ Braun, William C. (1952). "Legal Aspects of Arson". Journal of Criminal Law and Criminology. 43 (1): 53.
  15. ↑ Nagel, Ilene H. (1983). "The Legal/Extra-Legal Controversy: Judicial Decisions in Pretrial Release". Law & Society Review. 17 (3): 481–516. doi:10.2307/3053590. JSTOR   3053590. Archived from the original on December 1, 2019. Retrieved September 24, 2019.
  16. ↑ "Ringleader of family arson crew pleads guilty in $4 million Operation Firebird insurance fraud case". www.insurance.ca.gov. Retrieved March 5, 2024.
  17. ↑ Chan, Nicholas (November 19, 2019). "Couple Pleads Guilty in $4M Arson, Insurance Fraud Case". San Jose Inside. Retrieved March 5, 2024.
  18. ↑ See U.S. v. Miller, 246 Fed.Appx. 369 (C.A.6 (Tenn.) 2007); U.S. v. Velasquez-Reyes, 427 F.3d 1227, 1230–1231 and n. 2 (9th Cir.2005).
  19. ↑ "Campus Crime: Crime Codes and Degree of Severity". California State University, Monterey Bay. Archived from the original on December 24, 2008. Retrieved May 10, 2008.
  20. ↑ See U.S. v. Miller, 246 Fed.Appx. 369 (C.A.6 (Tenn.) 2007)
  21. ↑ Garofoli, Joe (September 1, 2007). "Suspect in Burning Man arson decries event's loss of spontaneity". San Francisco Chronicle . p. A8. Archived from the original on April 25, 2008. Retrieved May 11, 2008.
  22. ↑ "Reason for Referral". Nebraska Commission on Law Enforcement and Criminal Justice. Archived from the original on May 3, 2008. Retrieved May 11, 2008.
  23. ↑ "Man accused of arson pleads to misdemeanor charges". The Salina Journal . January 25, 2008. Archived from the original on December 22, 2008. Retrieved May 11, 2008.
  24. ↑ 3 Charles E. Torcia, Wharton's Criminal Law § 326 (14th ed. 1980)
  25. ↑ Lessons from History The Chicago Fire of 1871 , retrieved March 5, 2024
  26. ↑ "The International Fire Service and World War II - Fire Engineering: Firefighter Training and Fire Service News, Rescue". December 7, 2017. Retrieved March 25, 2024.
  27. ↑ "The cultural history of Smokey Bear". theaggie.org. Retrieved March 5, 2024.
  28. ↑ "How Fear of a WWII Invasion Gave Rise to Smokey Bear". History. August 9, 2019. Retrieved March 5, 2024.
  29. ↑ "New York Arson Laws".
  30. ↑ "Getting Tough on Arson". Utne Reader. January–February 2011. p. 13.
  31. ↑ "Father in gender-reveal that sparked fatal 2020 California wildfire has pleaded guilty". AP News. February 11, 2024. Retrieved March 25, 2024.
  32. ↑ Rokos, Brian (January 11, 2022). "Doomed El Dorado firefighter's last words: trapped in a 'corner'". San Bernardino Sun. Retrieved March 27, 2023.
  33. ↑ William Blackstone (1765–1769). "Of Offenses against the Habitations of Individuals [Book the Fourth, Chapter the Sixteenth]". Commentaries on the Laws of England. Oxford: Clarendon Press (reproduced on The Avalon Project at Yale Law School). Archived from the original on May 3, 2008. Retrieved June 1, 2008..
  34. ↑ "Criminal Damage Act 1971". Archived from the original on December 8, 2009. Retrieved March 24, 2010.
  35. ↑ "Legco.gov.hk" (PDF). Archived (PDF) from the original on March 7, 2021. Retrieved June 15, 2016.
  36. ↑ "Hklii.hk". Archived from the original on February 25, 2021. Retrieved June 15, 2016.
  37. 1 2 "The Penal Code". Myanmar Law Information System. July 1, 2016.
  38. ↑ Mirza, Atthar; Moriarty, Dylan. "'Burn it all down': How Myanmar's military razed villages to crush a growing resistance". Washington Post. Retrieved March 15, 2023.
  39. ↑ "Satellite Data Raise Fears Myanmar's Army Setting Towns Ablaze". Human Rights Watch. November 3, 2021. Retrieved March 15, 2023.
  40. ↑ Sai, Ko (August 29, 2022). "Over 28,000 Homes Torched by Myanmar Junta Forces Since Coup". The Irrawaddy. Retrieved March 15, 2023.
  41. ↑ Book (eISB), electronic Irish Statute. "electronic Irish Statute Book (eISB)". www.irishstatutebook.ie. Retrieved March 5, 2024.
  42. ↑ Muirí, Réamonn Ó (1986). "The Burning of Wildgoose Lodge: A Selection of Documents". Journal of the County Louth Archaeological and Historical Society. 21 (2): 117–147. doi:10.2307/27729616. ISSN   0070-1327. JSTOR   27729616.
  43. ↑ Bosworth 1987, pp. 26–27.

Works cited

Further reading

This page is based on this Wikipedia article
Text is available under the CC BY-SA 4.0 license; additional terms may apply.
Images, videos and audio are available under their respective licenses.