“So That the Strong Should Not Harm the Weak”

(fl. 1792–1750 B.C.)

“See that proper justice is done.”
— HAMMURABI to Sin-iddinam, Provincial Governor of Yamutbal1


Lofty Anu, the great god of the skies. Shamash, the great sun god, patron of justice. Marduk, the chief son of Ea, local deity of the city of Babylonia, and the god of fifty names. These once common now esoteric gods of the Babylonians go unworshipped, demoted from the altar and pedestal, and known but to few academics and museum curators. True, their names retain the power to evoke an air of mystery. But it is no longer the mystery of reverence that comes with touching divinity. There is nothing in the ring of their names that takes us to heaven like the smell of incense, the pealing of bells, or the chant of monks. Rather, it is a mundane mystery, a curiosity, somewhat more like being piqued by a strange implement at an antique store whose purpose wholly escapes you. If they were ever alive in the hearts of men, the gods of the Babylonians, though legion, are certainly now dead. The Babylonian Nietzsche, if ever there was one, is victor.

Monumental Justice

Hammurabi's Face?

It is these forgotten gods and the many others in the Babylonian pantheon that the great king of the Babylonians, Hammurabi worshipped. Hammurabi,2 who ruled Babylonia between 1792 and 1750 B.C., was the general of armies, conqueror of the lands between two great rivers, digger of canals, builder of walls, repairer of temples. Nothing but rubble remains of these works of the great Hammurabi “of whom no footing now on earth appears.”3 One of Hammurabi’s monuments, however, has lasted the onslaught of time. Hammurabi was also the dispenser of justice for his people. In the thirty-eighth year of his forty-two year reign—about five centuries before Moses—he promulgated his famous list of judgments that we know, if not altogether accurately, as the “Code of Hammurabi.”

Known to history as one of the great ancient lawgivers, Hammurabi is best known to us through his famous “code”. Hammurabi collected the “just verdicts” (dînât mêšarim) that were revealed to him by the great sun god, Shamash, who—because he saw all things from his vantage point in the sky—was god of law, order, and justice. As a Babylonian hymn to Shamash put it:

Your rays grasp everything that is hidden,
And the behavior of humans is revealed by your light! . . . .

. . . .

Perched on the highest mountains you inspect the world
And from the midst of heaven, you balance the universe. . . .4

Hammurabi's Steele at the Louvre

This great collection of judgments is now in diaspora, away from the natural fertile soils and steady heat of the land between two rivers, Mesopotamia—current day Iraq. Its home is in Paris, at the Louvre Museum, where it rests after being found in 1901 by a French archaeological expedition in the Persian mountains of Iran. Around 1120 B.C., Shutruk-Nahhunte, the sukkalmah or king of Elam, had the stele with Hammurabi’s “laws” carried off from the temple of Shamash at Sippar where Hammurabi had it erected. Shutruk-Nahhunte set it in Susa, his capital—not as a living symbol of justice and order—but as a trophy of his victory over the Babylonians many centuries after Hammurabi died. Shutruck-Nahhunte surely thought it a fitting payback for Hammurabi’s defeat of his distant predecessor, Siwe-palar-huppak, in 1764 B.C.

Hammurabi's "Code"

Nestled between an explanatory prologue and an epilogue full of warning to those temerarious enough to tamper with his dictates, the so-called “Code of Hammurabi” is etched upon a stele of black diorite almost eight feet high and seven feet in circumference at its base. The Code is composed of 282 just verdicts carved in densely-packed cuneiform text.5 Crowning the stele is a bas relief of King Hammurabi and the sun-god Shamash, god of justice, seated on his throne. About this sculptured scene, Martha Roth tells us:

There are varied interpretations of this scene: that the god is dictating the laws to the king; that the king is offering the laws to the god; that the king is accepting or offering the emblems of sovereignty of the rod and ring; or—most probably—that these emblems are the measuring tools of the rod-measure and robe measured used in temple building . . . . Whatever its details, the broad message the illustration communicated to even the most illiterate must have been clear: King Hammurabi and the god of justice Shamash work together to protect the people of Babylonia.6

Hammurabi on His Throne

The breadth of the subjects treated by these 282 “laws” is striking. The code opens with penalties for witchcraft and spells (§§ 1, 2) and judgments regarding false witness and judges that tamper with testimony or justice (§§ 3-5). The code treats of numerous criminal matters, including theft (§§ 6-8), stolen property (§§ 9-12), continuance of trial for lack of witnesses (§ 13), kidnapping (§ 14), escape and kidnapping of slaves (§§ 15-20), and burglary, brigandage, and looting (§§ 21-25). The code contains precepts covering social relations in civil society and the administration of government (§§ 26-41). The agricultural flavor of Babylonian society is clearly manifest in those provisions that address the cultivation of land, the relations between landowner and farm laborer (§§ 42-52), the maintenance of canals, the responsibility for damages caused to crops by careless farmers (§§ 53-56) or shepherds and their sheep (§§ 57, 58), and matters involving land and orchards (§§ 59-65). Though chiseled off from the original stele by Shutruk-Nahhunte, the next provisions dealt with loans and house-renting.7 Next, the “code” deals with interest, relations between merchants and with agents (§§ 100-107), the wine business (§§ 108-111), transportation of goods (§ 112), debts (§§ 113-119), and grain storage and deposits (§§ 120-126). Following these, focus is given to the family and relations between the sexes, including slander against women, adultery, rape, unchastity, incest, marriage, dowries, separation, divorce, concubinage, and women’s property (§§ 127-164). Principles of inheritance as they concerned children, wives, widows, concubines, slaves, and others are then detailed (§§ 165-184), as are judgments regarding adoption and foster-children (§§ 185-193). Standards regarding wrongful death and personal injury are treated by the code (§§ 194-214), as are the fees, duties, and liability of physicians and veterinarians (§§ 215-225), wrongful branding of slaves (§§ 226-227), the rights and duties of home builders, (§§ 228-233), ship-builders (§ 234), and boatmen and ships (§§ 235-240). The remaining precepts return to agricultural topics, covering oxen (§§ 241-249), injuries caused by goring oxen (§§ 250-252), and the hiring of persons, animals, wagons, and boats and ships (§§ 253-277). Finally, the last provisions of the “code” deal with servants, the slave-trade, and rebellious slaves (§§ 278-282).

As a lawmaker, Hammurabi’s judgments are not substantively innovative. He stood on the shoulders, if not of giants, at least of other kings. We know of many lawgivers that existed before him such as Urukagina or Uru-inimgina of Lagash (2351-2340 B.C.), Ur-Nammu (2112-2095 B.C.) and his son, Shulgi (2094-2047 B.C.), kings of Ur, and Lipit-Ishtar king of Isin (1934-1924 B.C.).8 Hammurabi’s importance is not as a reformer or revolutionary, as his decisions appear to have been well within Sumerian and Akkadian customs.9 Rather, Hammurabi’s importance comes from the manner in which he universalized these customs across his empire and stiffened the punishments associated with breaches; thereby, he unified the “black headed races” (as he referred to his people) during his reign.

Cuneiform Text of Hammurabi's Code

Politically and historically, Hammurabi’s rule had great effect. Prior to Hammurabi, the history of Mesopotamia was one of squabbling city-states ruled by petty kings who competed among themselves in chronic wars for an ephemeral superiority that seemed to last but one or two or at best three generations. After Hammurabi, the region’s history is characterized by stable territorial states governed from a single capital city. One ruler with one law and great energy, he ruled a society of many gods and diverse peoples, and this was to be the model for the future. After Hammurabi, “no competing city-states were ever to emerge again,” van de Mieroop tells us. Indeed, the Babylonian empire was to exist in one form or another—ruled by various Babylonian, Kassite, Assyrian, or Chaldean dynasties—until its fall to the Persian empire and Cyrus the Great in 539 B.C. “This was the most lasting consequences of Hammurabi’s rule in political terms.”10

The "Code" as a Work of the Science of Justice

Since its discovery in 1901, Hammurabi’s Code has been commonly misunderstood. Confusingly, the form of Hammurabi’s “laws are . . . somewhere between the formulations of rules and accounts of actual cases judged by the king.”11 Moreover, the laws are commonly construed out of their historical context. And for both these reasons, the real import of the code is missed. In fact, Hammurabi’s Code is not a “code” at all. Nor does contain “laws” as we moderns use the term.

If a code is defined as a complete system of positive law or a systematic collection or revision of laws on a particular topic,12 then Hammurabi’s list of laws cannot be considered a code. It does not cover all the law, and though it covers many topics, it covers these but superficially and incompletely.13 At best, therefore, the “code” is more “a type of anthology,” rather than a code.14

Additionally, whether the law is defined as a rule of reason or a command of the sovereign enforced by sanction, Hammurabi’s precepts cannot be considered laws.15 Hammurabi’s code is not cited in Babylonian judicial decisions that have been preserved, and does not appear to have been considered binding precedent on Babylonian courts or judges.16 Historically, therefore, the code appears to be an anthology of just verdicts or judgments of the King, and not laws intended to govern uniformly.17 Indeed, to consider the statements on the Code of Hammurabi “laws” is anachronistic. The French Assyriologist Bottéro tells us that the Babylonians were a “people whose knowledge was entirely expressed by the concrete.”18 The Babylonians had few words to describe abstract concepts, and there is no term for the notion that we understand—either in a scientific sense or a juridical sense—as “law.”19 “[I]n their vocabulary there is not a single word to indicate ‘principle,’ ‘law,’ or ‘concept’ in any field.”20

How, then, are we to understand Hammurabi’s Code if not as a code of laws? “What Hammurabi wanted to collect in his ‘Code,’ Bottéro explains, “was a selection of . . . the most just decisions, the wisest, the most sagacious, the most worthy of an experienced ruler.”21 Understood contextually, the “code” appears to be an effort by Hammurabi to apply scientific principles—as the Babylonians understood science—to those of his judgments he saw as just. It is more like a “treatise, with examples, on the exercise of judicial power.”22 In Mesopotamia, to judge was to decide, assign, or impose a destiny on the litigant, without recourse to an abstract rule of reason. The judgment did not necessarily look into the merits and demerits of the litigant, as it was “not an act of logic or of morality, but of power.”23 This is common in early civilizations where the inchoate rules of decision have not even reached the stage of custom, and meddlesome gods rule the world of men by arbitrary will. As the historian of ancient law, Maine, tells us with regard to the ancients:

The only authoritative statement of right and wrong is a judicial sentence after the facts, not one presupposing a law which has been violated, but one which is breathed for the first time by a higher power into the judge’s mind at the moment of adjudication.24

Outside of the arbitrary will of Shamash, the god of justice whom Hammurabi believed inspired his judgments, there was no rule, no order, no reason in the nature of justice which could be divined by the Babylonian mind:

The king’s command is sure as that of Shamash,
His command cannot be rivaled nor his utterance altered.

. . .

Like Shamash, the king loves justice and hates evil.25

Historically, the understanding of the Code of Hammurabi must begin with an awareness of the grammatical and logical form that these judgments take. Each one of these judgments or verdicts in the Code of Hammurabi is composed of two clauses. The first states certain general facts and is introduced by the particle if (šumma).26 Following the first clause, the judgment is given.27 For example, take § 247:

If a man hire an ox and destroy its eye: he shall pay silver to the owner of the ox to the extent of one-half its value.28

The form of Hammurabi’s judgments is identical to the form of statements found in the many surviving divination, medical, mathematical, and other scientific treatises of ancient Babylonia, all of which are composed of lists of phenomena or omens tied to predictions or prognoses. All of the statements in these treatises—regardless of subject matter—bear the identical grammatical and logical form as the Code of Hammurabi:

  • If a man’s chest-hair curls upwards: he will become a slave.29
  • If the gallbladder [of the sacrificial sheep] is stripped hepatic duct: the army of the king will suffer of thirst during a military campaign.30
  • If the north wind sweeps the face of heaven until the appearance of the new moon: the harvest will be abundant.31
  • If a man, while walking, suddenly falls forward with dilated eyes and is unable to restore them to their normal condition, and if he is himself incapable, at the same time, of moving his arms and legs: an attack of ‘epilepsy’ has started.”32

The Babylonians were rigorous empiricists. In all their sciences they observed natural phenomena, tried to identify causal links between them, and studiously recorded them in treatises and lists. These dealt with many topics— lexicography, grammar, divination, mathematics, and medicine, all of which used the if/then conditional format.33 Despite their empirical spirit, the Babylonians were extremely hampered by an inability to form abstract concepts. Their mental horizons were bounded by a post hoc ergo propter hoc logical fallacy over which they never leaped,34 and so the Babylonians went from omen to oracle, from symptom to disease, from fact to judgment, addicted to lists of one-to-one relationships, without once recognizing the existence of any scientific, moral, or juridical law behind them. For this reason, “[a]ll their sciences,” including jurisprudence, “were structured not according to axioms that were revealed and demonstrated, according to laws that were deduced and articulated, but they were based on the accumulations of concrete and individual cases that were enumerated in the way of Lists.”35 Nowhere in any of the Babylonian’s numerous surviving treatises or lists, or for that matter, in their literature, “do we encounter an utterance of such a principle or of such a law, taken by itself in abstraction and with formal universality. We see in them nothing but an enumeration of indefinite litanies of cases: hypotheses followed each by an exact judgment that one has to express based on them.”36 In their jurisprudence just like in everything else, the first fact is connected to the second, not by abstract rule, but by custom, traditional social coercion, the command of the king, or the will of the gods.37

The Mesopotamians of old never crossed this threshold [abstraction to universal concepts] . . . . It was the Greeks who have taken us further, to the universal concepts, the absolute formulations, that allow us the clear perception and the distinct expression of the principles and the laws in all their abstraction.38

In summary, the Code of Hammurabi appears to be an attempt to apply a scientific methodology—as the Babylonians understood it—to the judgments of the king and the justice thereby wrought. In the Babylonian mind, therefore, the “code” was a “work of science devoted to the exercise of justice.39 Because it there was no notion of law, it was a science devoted to the exercise of power, a science—not of reason—but of the application of custom, coercion, command, or the will of the gods to the resolution of civil disputes and the maintenance of order.

An Eye for an Eye and a Tooth for a Tooth

Perhaps one of the single greatest concepts found in Hammurabi’s code, and which retains vitality today though certainly in a different form, is the principle of proportional retribution. This was the reasoning behind the so-called lex talionis.40

  • § 196—If a man destroy the eye of another man, they shall destroy his.
  • § 196—If one break a man’s bone, they shall break his bone.
  • § 200—If a man knock out a tooth of a man of his own rank, they shall knock out his tooth.

These precepts were carried out of Babylon by a Hebrew named Abram, rich in cattle, silver, and gold, who received a command from Yahweh to leave Ur of the Chaldeans in Babylon and go to the land of Canaan, to dwell by the oaks of Mamre, Gen. 12:1-3; 13:18, whence they found their analogy, by the mystery of revelation, in the laws of Moses, where most of us have learned them:

When a man causes a disfigurement in his neighbor, as he has done It shall be done to him, fracture for fracture, eye for eye, tooth for tooth; as he has disfigured a man, he shall be disfigured.

Lev. 24:19-20; see also Exodus 21:23-25; Deut. 19:21.

At first glance, the lex talionis sounds barbaric, but it represented a great stride in the law against the “law” of feud and vengeance, which often resulted in greater punishment than befit the crime. Under Hammurabi’s vision of justice, punishment was to fit the wrong, be proportional to the wrong, and was to be applied, at least to those within each caste, evenly. We may be reminded:

But if the old form of the lex talionis, an eye for an eye or a tooth, sounds too barbaric today, may we not reformulate the retributive theory and put it thus: Everyone is to be punished alike in proportion to the gravity of his offense or to the extent to which he has made others suffer?41

Seventeen centuries later, a greater lawgiver than either Hammurabi or Moses, Jesus of Nazareth, was to teach that justice was but the irreducible minimum how we should treat our fellows, and that there are times where mercy, forgiveness, and love compel us to go beyond the proportionally just. As grace builds on nature, mercy and love build upon justice. “You have heard that it was said, ‘An eye for an eye and a tooth for a tooth.’ But I say to you, Do not resist an evildoer. But if anyone strikes you on the right cheek, turn the other also” (Matthew 5:38-39). Had Hammurabi not existed and promulgated his just verdicts, would we have been recipients of this sublime doctrine?

The Prologue & Epilogue and the End of Law

Hammurabi on
Supreme Court Frieze

Though the specific judgments of Hammurabi may interest the historian and entertain the layman and even the courts with their quaintness,42 they have little practical meaning for us today. Like all positive law, their significance ebbed with the tide in the affairs of men. What is of interest is Hammurabi’s notion of the law’s end found in the prologue and epilogue of the Code. These lasting and unchanging principles wax in hymnic-epic cadence, law in poetry, redolent of the lilt of the Gilgamesh. It is this aspect of Hammurabi’s jurisprudence which remains as vivid today in the second millennium after Christ as it did in Babylon in second millennium before Christ.

What is the end of the law according to Hammurabi?

Anu and Bel called me, Hammurabi, the exalted prince, the worshiper of the gods, to cause justice to prevail in the land, to destroy the wicked and the evil, to prevent the strong from oppressing the weak, to go forth like the Sun over the Black Head Race, to enlighten the land and to further the welfare of the people. . . .When Marduk sent me to rule the people and to bring help to the county, I established law and justice in the land and promoted the welfare of the people.43

Hammurabi's Profile at
the U.S. House of Representatives

It is a tradition that runs deep in our heritage, that Laws that contradict these purposes, that is, laws that promote injustice, encourage or insulate moral evil, or are against the common good—though they may be found in the books and enforced by established government—may not be laws in the fullest, strictest sense of the word. They are, as St. Thomas would put it, perversions of law, more like violence than laws. They are, as Martin Luther King—acting in the Augustinian and Thomistic tradition—put it in his Letter from Birmingham Jail, not laws in the true sense at all. When St. Thomas and King wrote about law in that spirit, they wrote within the tradition of Hammurabi.

Hammurabi's Contribution

If the law is defined as James Boyd White defined it, “an art essentially literary and rhetorical in nature, a way of establishing meaning and constituting community in language,”44 then the Code of Hammurabi takes on a significance beyond history, one that gives meaning and constitutes the human community across the ages. It is here that the perennial quality and noble vision of Hammurabi’s code remains even for us moderns. On the level of fundamentals, the law at the time of the ziggurat is the same as the law at the time of the skyscraper. It is in the deep furrows of the law’s soil—in the area of fundamental or natural law—and not in law’s annual fruits—the positive law, that Hammurabi’s seminal and lasting contribution may be found. Indeed, we are heirs, through the filter of the Hebrews and the Greeks indirectly through the Hittites and the Cretans, to much of the Sumerian-Akkadian or Babylonian civilization, of which Hammurabi is a symbol.45 That is why “we cannot understand anything of the past without going back to Mesopotamia, and without refusing to stop in Greece or in Israel on this road.”46 It does us well to stop and ponder this. Law ought never be so parochially modern as to forget its root “by the rivers of Babylon.” Psalm 137:1.


Bottéro , Jean (trans., Zainab Bahrani and Marc Van de Mieroop). Mesopotamia: Writing, Reasoning, and the Gods. Chicago: University of Chicago Press, 1992.

Foster, Benjamin R., trans. From Distant Days: Myths, Tales, and Poetry of Ancient Mesopotamia. Bethesda, CDL Press, 1995.

Harper, Robert Francis. The Code of Hammurabi King of Babylon. Chicago: University of Chicago Press, 1904.

Johns, C. H. W. The Oldest Code of Laws in the World. Union, N.J.: The Law Book Exchange, Ltd. 2000.

van de Mieroop, Marc. King Hammurabi of Babylon. Oxford: Blackwell Publishing, 2005.

Roth, Martha T. Mesopotamian Legal Traditions and the Laws of Hammurabi, 71 CHI.-KENT L. REV. 13, 23-24 (1995).

VerSteeg, Russ. Law in the Ancient World. Durham: Carolina Academic Press 2002.

Wooley, C. Leonard. The Sumerians. New York: Norton 1965.



1 Marc van de Mieroop, King Hammurabi of Babylon (Oxford: Blackwell Publishing , 2005), 94 (citing W. H. Van Soldt, Letters in the British Museum (Leiden: E. J. Brill, 1994), Part 2, 10).

2 The name Hammurabi is most likely a combination of the Amorite word for family (hammu) with the Akkadian adjective for great (rabi). Some scholars argue that it should be read as being of entirely Amoritic origin—‘Ammurapi—in which case it means “the kinsman heals.” Van der Mieroop, op. cit., 2-3.

3 Edmund Spencer, “The Ruines of Time.”

4 Jean Bottéro (trans., Zainab Bahrani and Marc Van de Mieroop), Mesopotamia: Writing, Reasoning, and the Gods (Chicago: University of Chicago Press, 1992), 210 (quoting W. G. Lambert, Babylonian Wisdom Literature, pp. 126ff.; J. Seux, Hymnes et priers aux dieux et d’Assyrie, pp. 51ff.).

5 Translations of the Code may be found in C. H. W. Johns, The Oldest Code of Laws in the World (Union, N.J.: The Law Book Exchange, Ltd. 2000) and in Robert Francis Harper, The Code of Hammurabi King of Babylon (Chicago: University of Chicago Press, 1904). In addition to a translation, Harper’s work has the text of the original cuneiform in addition to its transliteration. It is available on line in PDF format at http//oll.libertyfund.org.

6 Martha T. Roth, Mesopotamian Legal Traditions and the Laws of Hammurabi, 71 CHI.-KENT L. REV. 13, 23-24 (1995).

7 C. H. W. Johns, op. cit., 17.

8 See C. Leonard Wooley, The Sumerians (New York: Norton 1965), 69-70, 91, 173-74; Russ VerSteeg, Law in the Ancient World (Durham: Carolina Academic Press 2002), 7-12.

9 Mieroop, op. cit., 109.

10 Mieroop, op. cit., at 39.

11 Mieroop, op. cit., 102; cf. C. Leonard Wooley, op. cit., 91.

12 See BLACK’S LAW DICTIONARY (7th Ed. 1999) 250 (s.v. “code”).

13 Bottéro, op. cit., 161.

14 Ibid.

15 Ibid.

16 Bottéro, op. cit., 163-64.

17 Bottéro, op. cit., 164.

18 Bottéro, op. cit., 271.

19 Bottéro, op. cit., 31, 178-79.

20 Bottéro, op. cit., 135.

21 Bottéro, op. cit., 165.

22 Bottéro, op. cit., 167.

23 Bottéro, op. cit., 278.

24 Maine, Ancient Law, (New York: Henry Holt & Co. 1906), 7.

25 Benjamin R. Foster, trans., From Distant Days: Myths, Tales, and Poetry of Ancient Mesopotamia (Bethesda, CDL Press, 1995), 382.

26 Grammatically, the introductory clause, which contains the general facts upon which the judgment or verdict is based, is referred to as the protasis.

27 The word “then” being implied. The second clause, which consists of the judgment or verdict, is known as the apodasis.

28 Harper, op. cit., 87.

29 Bottéro, op. cit., 128 (citing VAT 7525, i: 19f., in Archiv für Orientforschung 18 (1957f): 63).

30 Bottéro, op. cit., 128 (citing Cuneiform Texts . . . in the British Museum, 28, pl. 28: 12b.)

31 Bottéro, op. cit., 130 (citing Zeitschrift für Assyriologie 48 (1936): 309:6f).

32 Bottéro, op. cit., 170 (quoting R. Labat, Traité akkadien de diagnostics et de pronostics médicaux, pp. 190f., XXVI: 16f.)

33 Bottéro, op. cit., 169.

34 Bottéro, op. cit., 172.

35 Bottéro, op. cit., 39.

36 Bottéro, op. cit., 177.

37 Bottéro, op. cit., 172.

38 Bottéro, op. cit., 178.

39 Bottéro, op. cit., 179.

40 Lex talionis is Latin for lex (law) and talio (like).

41 Morris R. Cohen, Reason and Law 53 (1961).

42 A Westlaw search of federal and state cases for “Hammurabi /s Code” retrieved over 100 documents, all dating from after 1901 when the steel was discovered in Susa and shortly thereafter translated into English. The Code of Hammurabi has been cited most frequently in the context of justifying punitive damages, laws of restitution and victim compensation, adoption laws, laws against usury, and the principle that the punishment should be proportionate to the crime, and minors should be treated differently from adults. The Code has also been cited as an early example of medical malpractice, suretyship and pledgeship, riparian rights, workers’ compensation, spousal protection, and both testate and intestate inheritance. Oddly, the fundamental principles contained in the prologue and epilogue, which are perhaps more important, have been ignored by the courts.

43 Harper, 'op. cit., 3, 9.

44 James Boyd White, When Words Lose Their Meaning: Constitutions and Reconstitutions of Language, Character, and Community (Chicago: University of Chicago Press 1984), xi.

45 Bottéro, op. cit., 28.

46 Bottéro, op. cit., 28.

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