Peace-Keeping Attempts by the Organisation of African Unity

G. J. Naldi

The International and Comparative Law Quarterly, Vol. 34, No. 3. (Jul., 1985), pp. 593-601.

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PEACE-KEEPING ATTEMPTS BY THE ORGANISATION OF

AFRICAN UNITY

WHILSTthe peace-keeping activities of the United Nations are common know-

ledge and are well documented, comparable exercises pursued recently by another
significant international body. the Organisation of African Unity (the O A U ) , have
received little attention. The purpose of this article is to examine briefly the con-
temporary peace-keeping functions of the Organisation of African Unity, with
particular reference to the continuing disputes in Chad and Western Sahara.
The search for solutions to the protracted conflicts in Chad and the Western
Sahara has led the Organisation of African Unity to exercise tangible peace-keep-
ing activities. In the former case. thisentailed the establishment of amilitary force;
in the latter case, committees have been established with the mandate of imple-
menting a negotiated settlement compatible with the right of self-determination.

A. Chad
The presence of foreign troops in the civil war that has been raging in Chad since
the 1960s gave rise to serious concern in the O A U in 1980. It was therefore felt
that the presence of an O A U peace-keeping force could help to bring some
measure of peace and stability to the unfortunate country. The O A U Assembly
approved the motion of the formation of an O A U peace-keeping force at its
18th Session at Nairobi in 1981.'
The Charter of the O A U does not provide expressly for military action by the
Organisation. However. Article 20 makes provision for a Defence Commission
and Article 2. paragraph (f), urges members to co-operate in the fields of
defence and security. It is also interesting to note that Article 52 of the Charter
of the United Nations does not preclude the existence of regional arrangements
or agencies for dealing with such matters relating to the maintenance of inter-
national peace and security as are appropriate for regional requirements, pro-
vided that they are compatible with the purposes and principles of the United
Nations. Hence a call for military action does not seem to lie beyond the implied
powers of the O A U Assembly, although such a measure may only be envisaged
in exceptional c i r c ~ m s t a n c e s . ~
The idea of an O A U force was mooted at the 31st Session of the Council of

1. For a resum6 of events in Chad at that time. see Keesing's Contemporur? Archives,
Sept. 1982, pp.31677-31680. The O A U Assembly of the Heads of States and Govern-
ments is "the supreme organ of the Organisation" which "discusses matters of common
concern to Africa with a view to co-ordinating and harmonising the general policy of the
Organisation". The Assembly is composed of. as its full name suggests, the Heads of Afri-
can States and Governments, except for the Union of South Africa, and meets at least
once a year and, when approved by a majority. in extraordinary session. Each Member
State has one vote and resolutions. except for procedural matters. requlre a two-thirds
maioritv for adoption; see Arts.Prl1 of the O A U Charter: N. J . Padelford. "The OAU"
(1964) i8 Int. o&. 521, 534.
2. In the Certain Expenses of the United l\'utions case 119621 1.C.J. Reu. 151. 168. the
International Court of justice expressed the view that the united ~ a t i o n ; possessed the
implied powers necessary for the fulfilment of its purposes. This principle, murutis mutun-
dis, could be applied by analogy to the O A U .
594 International and Comparative Law Quarterly [VOL.
34
Ministers held at Khartoum in 1 9 7 8 . ~Further talks on the subject were held by
the Defence Commission at Addis Ababa in April 1979 and the suggestion was
welcomed by the Secretary-General, Mr Edem Kodjo, at a ministerial meeting
at Monrovia in July 1979. It was explained that the proposed force would not
compose a standing army but would be based upon a procedure whereby threat-
ened States could call upon troop contingents from O A U Member state^.^ A t
its 18th Session held in Nairobi in June 1981 the Assembly approved in principle
the establishment of a pan-African defence force.5
A t the same time the Assembly considered the possibility of maintaining a
peace-keeping force in Chad and, under Resolution lOZ(XVII1) Rev. 1, an
O A U peace-keeping force for Chad was established. The then Chairman of the
OAU, President Moi of Kenya, required that two preconditions be satisfied
before the O A U force be sent to Chad: first, the force had to be invited by the
Chadian Government; and, second, Libyan troops, which had been present in
the country at the invitation of President Goukouni since 1980, had to be with-
drawn. These requirements were complied with and by 16 November 1981 all
Libyan troops had left the country. However, the O A U force was bedevilled
with problems from the outset. First, the precise mandate of the force was
unclear. According to its constituent resolution, the mandate of the force was to
"ensure the defence and security of the country whilst awaiting the integration
of Government Forces". President Moi expressed what he felt was its proper
role:
The purpose of this exercise is to enable the people of Chad to decide o n a national
government of their choice through free and fair elections supervised by the O A U
with the help of an African peace-keeping force.

Alternatively the O A U Standing Committee on Chad clarified the role of the

peace-keeping force as being to assist the government to maintain peace and
security in the country and to take measures to help it to form and organise a
united, integrated, national force. Nevertheless, in performing these functions
the force would continue to remain neutral and would not involve itself in the
internal affairs of the country. Thus, the O A U envisaged a neutral role for the
force, an aid to the establishing of negotiations.6 President Goukouni, however,
appeared to view the force as nothing more than another army with which to
continue the fighting.
Second, the O A U lacked the necessary machinery to control such an oper-
ation. Logistic and financial difficulties were encountered. Originally, six States
had volunteered to provide ~ i o o p for
s the force: Nigeria, Senegal, Benin, Togo,

3. Keesing's Contemporary Archives, Oct. 1978, p.29259. The Council of Ministers is

composed of the Foreign Ministers of the Member States and meets at least twice a year
and when requested and approved by two-thirds of its members in special session. Its func-
tions and duties include the "responsibility of preparing conferences of the Assembly" and
it is entrusted with the power to implement the decisions of the Assembly. The Council of
Ministers also "co-ordinates inter-African LO-operationin accordance with the instruc-
tions of the Assembly and in conformity with Article 2(2)"; see Arts.12-15, O A U
Charter.
4 . Keesing's Contemporary Archives, Sept. 1979, p.29846.
5. Idem, p.29842.
6. The Guardian. 29 Jan. 1982.
JULY19851 OA U Peace-Keeping Attempts 595
Guinea and Zaire. The initial number of troops was to total over 10,000 but,
after Benin, Guinea and Togo withdrew their bffer of troops, only 3,265 even-
tually arrived in Chad. The O A U force was then already receiving substantial
financial aid. The Senegalese contingent was financed by France and the USA
contributed $12,000,000 towards the costs incurred by Nigeria and Zaire. The
O A U force cost £87,000,000 a year and consequently the United Nations was
approached for financial assistance since only £270,000 was raised by the Mem-
ber States of the O A U towards the cost of the force. The United Nations Secur-
ity Council accordingly adopted Resolution 504(1982) which called on the
United Nations Secretary-General "to establish a fund for assistance to the
peace-keeping force of the O A U in Chad, to be supplied by voluntary contribu-
tions".'
The reticence of the rival Chadian forces to negotiate created further prob-
lems for the O A U force. Since no political solution was foreseeable and the war
showed no signs of abating, Nigeria withdrew half its contingent, 1,000 men.
Moreover, the peace-keeping force was becoming embroiled in hostilities while
President Goukouni accused it of worsening the situation. The progress of the
war turned against President Goukouni and on 7 June 1982 the capital N'Dja-
mena had fallen to the forces of President Habre. O n 11 June the O A U Chair-
man ordered the withdrawal of the O A U force by 30 ~ u n e It. ~appears to be
correct to conclude that the activities of the O A U in Chad resulted in abject fail-
ure."he establishment of the peace-keeping force was a costly venture that
achieved little merit and which gave rise to grave disappointment. Some States.
particularly Cameroon and Gabon, were opposed to the idea of an O A U force
and alternatively advocated United Nations involvement. But the real danger
may lie in the probability that the O A U will be unwilling or unable to dispatch
another peace-keeping force if the occasion demands. This might constitute
another blow to the already imperilled concept of African unity.

B. T h e Western Sahara

The present conflict in the ex-Spanish colony of the Western Sahara between
Morocco and the Polisario Front, the indigenous national liberation movement

7. See further Keesing's Contemporary Archives, Nov. 1980, p.30557: and Sept. 1981,
p.31055; The Guardian, 21 Jan. 1982, p.5; and 19 Feb. 1982. p.9; at its 19th Session in 1983
held at Addis Ababa. the Assembly decided that Member States would meet their share of
the costs incurred by the participating States, see Keesing's Contemporary Archives.
Vol.XXXIX, Oct. 1983, p.32420.
8. Keesing's Contemporary Archives, Sept. 1982, p.31677. Subsequently ex-President
Goukouni continued the war with considerable Libyan support which in August 1983 led
to intervention by France on President Habre's behalf. The dispute reached a stalemate
and. as a result of negotiations between France and Libya, an agreement was signed on 17
Sept. 1984 providing for the withdrawal of French and Libyan troops by 15 Nov. 1984.
However. it appears that Libya has not observed the terms of the agreement and that a
substantial Libyan armed presence remains in northern Chad; see The Guardian. 18 Sept.
1984; 22 Nov. 1984, p.10; The Times, 17 Nov. 1984, p.6; and 20 Nov. 1984, p.5.
9. It should also be noted that the O A U has made unsuccessful attempts at a political
solution, see R . M. D'Sa, "The Relationship Between the UN and O A U in the Fields of
International Peace and Security and of Economic and Social Development" (unpublished
PhD thesis, Faculty of Law, University of Birmingham, 1982, Vol.1. p.93).
596 International and Comparative L a w Quarterly [VOL.34
of the disputed territory which in February 1976 unilaterally declared the inde-
pendence of the Saharan Arab Democratic Republic (SADR). has been raging
since 1976 when Morocco and Mauritania occupied the territory in pursuit of
their territorial claims that had been dismissed by the International Court of Jus-
tice."' The mediation of the O A U has thus far met with a singular lack of suc-
cess, and Morocco's withdrawal from the Organisation in November 1984 in
protest at the admission of the SADR makes any prospect of success even less
likely." Nevertheless, the O A U has worked hard at reaching a negotiated
settlement and has advanced some eminently sensible propositions that have
unfortunately foundered on intransigence. The task of finding a solution to the
Western Sahara conflict has been delegated to two committees: the Ad Hoc
Committee, otherwise known as the Committee of Wise Men: and the Imple-
mentation Committee.

1. The Ad Hoc Committee

During the 15th Summit Session of the Assembly of Heads of State and
Government held at Khartoum from 18-22 July 1978. the Assembly adopted
Resolution 92(XV), in which it was decided to establish an ad hoc committee of
at least five heads of State. members of the O A U , under the chairmanship of the
then Chairman of the O A U . President Nimeiri of Sudan. The committee's man-
date, as defined in the resolution. was to seek a solution to the Western Sahara
dispute compatible with the right of self-determination. The committee would
also comprise President Nyerere of Tanzania, President Traore of Mali, Presi-
dent Obasanjo of Nigeria. President Houphouet-Boigny of the Ivory Coast and
President Toure of ~ u i n e a . "
Morocco and Mauritania welcomed the mediation of the Ad Hoc Committee
but the Polisario Front and Algeria considered that the Western Sahara dispute
was a decolonisation problem and therefore was properly the responsibility of
the United Nations." However, this objection would not appear to take Article
53 of the Charter of the United Nations into account.
These objections notwithstanding. the A d Hoc Committee was duly consti-

10. [I9751 I.C.J. Rep. 12. O n the Western Sahara dispute generally, see M. Barbier. Le
Conflit du Sahara Occidental (1982); J. Damis. Conflict in Northwest Africa: The Western
Sahara Dispute (1983); G . J . Naldi. Certain international Legal Aspects of the Western
Sahara Dispute (unpublished PhD thesis. Faculty of Law. University of Birmingham.
1984).
11. See The Guardian, 12 Nov. 1984. p.8; 13 Nov. 1984. p.7: The Times. 13 Nov. 1984.
p.1. Art.32 of the Charter states that membership of the Organisation shall be terminated
a year subsequent to written notification to the Administrative Secretary-General to that
effect.
12. UNGAOR. 33rd Session. 1978. Doc. Al331235, Annex 11; G . J . Naldi, "The
Organisation of African Unity and the Saharan Arab Democratic Republic" (1982) 26
J . A . L . 152, 159. The constitutional basis for the establishment of the A d Hoc Committee
would appear to lie in Art.20 of the Charter which empowers the Assembly to establish
such specialised commissions as it deems necessary. It is interesting to note that Art.19
established a Commission of Mediation, Conciliation and Arbitration for the purpose of
peacefully settling disputes among Member States. Its services have not been sought over
the Western Sahara dispute.
13. U N G A O R , 34th Session, 1979, Supp. No.23 (Doc. A/34/23/Rev.l). p.106.
JULY 198.51 O A U Peace-Keeping Attempts 597
tuted and immediately established a sub-committee entrusted with the task of
visiting the region and contacting all the parties concerned and interested in the
dispute, including the Saharan people. in order to implement the measures
necessary for restoring peace and security. The warring parties were requested
to observe an immediate cease-fire to enable the sub-committee to accomplish
its duties. lJ
As a result of the sub-committee's tour of Algeria, Mauritania, Morocco and
Spain, the Ad Hoc Committee adopted certain recommendations concerning
the exercise of the right of self-determination by the people of Western Sahara
and the modalities of its exercise. These recommendations were submitted to
the O A U Assembly at its 16th Ordinary Session held at Monrovia. Liberia. in
July 1979 which subsequently adopted them as Resolution 114 (XVI). This reso-
lution recommended, inter nlia:
1. The preparation of a proper atmosphere for peace in the area
through a general and immediate cease-fire supervised by an O A U
peace-keeping force.
2. The withdrawal of all Moroccan troops from the Western Sahara.
3. T he exercise of the right of self-determination by the people of West-
ern Sahara in a general and free referendum which will enable them
to choose one of the following options:
(a) total independence; or
(b) maintenance of the stutus quo.
4. The convening of a meeting of all the parties concerned, including the
representative of Western Sahara, to request their co-operation for
the implementation of this decision.
5 . T he establishment of a special committee of six Member States of the
O A U , known as the Implementation Committee. to work out the
modalities and to supervise the organisation of a referendum with
the co-operation of the United Nations on the basis of one person one
vote."
Recommendations 1 4 have not yet been implemented

2. The Irnplementntion Committee

The Implementation Committee, composed of representatives from Guinea.
Kenya, Mali, Nigeria, Sierra Leone, Sudan and Tanzania. was established under
Resolution 103(XVIII) 1981 with the purpose of working out, in collaboration
with the parties to the conflict, the modalities and all other details relevant to the
attainment of a cease-fire and the conduct and administration of a referendum:
and its mandate was to participate with the United Nations in taking all necess-
ary measures to guarantee the exercise by the people of Western Sahara of self-
determination through a general and free referendum.I6

14. ibid. OAU Res. AHGI93(XVI), Report of the Ad Hoc Committee on Western
Sahara, pp. 1-2 and Annex 111.
15. OAU Res. AHGI93(XVI), Annex VII.
16. See Naldi, op. cit. supra n.12, at pp.159-160; Keesing's Conrenlporary Arc1lir.e.c.
Sept. 1981, p.31055; The Guardian, 30 June 1981.
598 International and Comparative Law Quarterly 34
[VOL.
As expected, the Implementation Committee has proved unable to reach a
solution to the Western Sahara dispute. Initially both Morocco and the Polisario
Front appeared to agree on the principle of a referendum, at least in public, but
irreconcilable differences existed between them as to how it ought to be
achieved." King Hassan of Morocco told the committee that Morocco was
"ready, when the O A U is ready, to organise a peaceful, honest and unequivocal
referendum". However, Morocco remained adamant that its troops would not
withdraw from the territory before a referendum took place and has been
opposed to a United NationsiOAU peace-keeping force in the territory. Fur-
thermore, as far as Morocco was concerned, the referendum would ask only one
question:
D o you approve of the acts of allegiance which imply that you belong to the King-
dom of Morocco?'"
Morocco expressed the view that only those Sahrawis that were listed in the cen-
sus carried out by Spain in 1974 (which was rejected at the time by Morocco who
claimed that 30,00W0,000 Sahrawi refugees were living in Morocco) were
entitled to vote.
The Polisario Front naturally rejected the Moroccan proposals. It expressed
the hope that the referendum should take place in a free environment, free of
any constraints placed by Moroccan troops. It expressed itself in favour of a
United NationsiOAU peace-keeping force to ensure stability and to guarantee
free elections and further considered an international neutral administration to
be an absolute necessity. The Polisario Front suggested that the following ques-
tion be asked at the referendum:
Yes o r no to independence?
Those entitled to vote would be all Sahrawis who would be subject to scrutiny by
the proposed neutral administration to ensure that they were indigenous to the
territory .I9
The consensus resolution arrived at by the Implementation Committee in
August 1981 decided that the question to be asked at the referendum would be:
Independence or integration with Morocco?
The implementation of the cease-fire would be left to "the parties to the con-
flict". In preparation for the free elections, the Committee considered it necess-
ary that an impartial interim administration be established to collaborate with
the existing Moroccan administration. The former body would be assisted by a
joint United NationsiOAU peace-keeping force. The Moroccan administration
would remain in office until the scrutiny of the eligible voters started, when the
elections would be supervised by a team of observers who would subsequently
submit a report on the validity of the exercise to the United Nations and O A U ,
based partially on the system used in Zimbabwe in 1980. The Committee sug-

17. A meeting of the Implementation Committee in September 1983 collapsed after

Morocco refused to conduct direct negotiations with the Polisario Front. The Polisario
Front, on the other hand, insisted o n direct negotiations with Morocco as a precondition
to a referendum; see Keesing's Contemporary Archives, Vol.XXX, April 1984, p.32822.
18. TheGuardian, 26Aug. 1981,p.5.
19. Ibid.
JULY19851 OA U Peace-Keeping Attempts 599
gested further that the troops belonging to the belligerents be confined to bar-
racks or bases during the conduct of the referendum when law and order would
be maintained by the peace-keeping force. Finally, on the controversial question
of the franchise, the Committee suggested that the estimated size of the popula-
tion of Western Sahara should be based on the figures of the Spanish census of
1974, account being taken of the relevant documents provided by the United
Nations High Commission for Refugees and the rate of growth of the popula-
ti~n.~"
In February 1982 the Implementation Committee submitted the following
proposals on the organisation of the referendum: (a) that an interim adminis-
tration be appointed by the Implementation Committee vested with the legisla-
tive and administrative powers required for the organisation and conduct of a
referendum; (b) that a commissioner be appointed to head the interim adminis-
tration "at least one month before the cease-fire takes effect"; and (c) that a
joint OAUiUnited Nations commission be sent to the Western Sahara at least
one month prior to a cease-fire to make arrangements for the poll. In addition,
the Implementation Committee drew up detailed provisions for the organis-
ation of the referendum. These recommendations provide, inter nliu, that the
people of Western Sahara express themselves freely and democratically, by
secret ballot on the basis of one person one vote without discrimination on the
ground of sex, on whether they want independence or integration with
Morocco; that the commissioner be responsible for the drafting and voting
regulation, including a register of electors, voting procedures, including the
method of counting votes and tabulating results, the drawing up of electoral
boundaries, or districts, measures to prevent abuses and to ensure the security
of voters and ballots, and penalties for any electoral abuses. In addition, in
preparation for the referendum, a campaign of public information should be
undertaken to familiarise voters with the significance of the referendum, the
issues involved and the voting procedure. Consequently, the interim adminis-
tration should take measures to guarantee freedom of expression, assembly,
publication and m ~ v e m e n t . ~ '
The Implementation Committee has also adopted detailed provisions con-
cerning a cease-fire in Western Sahara. The suggestions include the stationing of
a peace-keeping force and/or a military observer group, including a civilian
police component having the necessary powers to supervise the attainment of
the cease-fire, including fixing the respective positions of each side's forces; the
confinement of troops to bases or such areas where their presence would not
constitute a psychological or any other hindrance to the conduct of a free and
fair referendum; and the exchange of prisoners of war at the direction of and
under the supervision of the commander of the peace-keeping force.22

20. AHGIIMPCIWSIDec.l(I); The Guardian, 24 Sept. 1981, p.6.

21. AHGIIMPCIWSIDec.2(11) Rev.2; see further Keesing's Contemporary Archives,
Vol.XXX, April 1984, p.32821.
22. AHGlIMPCIWXIDec.l(I1) Rev.2; the recommendations of the Implementation
Committee were adopted by the Assembly at its 19th Session in June 1983; see Keesing's
Contemporary Archives, loc. cit. supra 11.21. In turn the UN General Assembly took note
of the decision of the OAU Assembly in Resolution 38140(1983), adopted without a vote;
see Keesing's Contemporary Archives, Vol.XXX, April 1984, p.32825.
600 International and Comparative Law Quarterly [VOL.
34
All the suggestions advanced by the various committees have met with serious
difficulties ab initio. Morocco and the Polisario Front have adopted mutually
irreconcilable positions and their intransigent attitudes give little hope for a
peaceful solution.
The Polisario Front insists that, before it accepts the proposal for a referen-
dum, Morocco must comply with the precondition that it completely withdraw
its forces from the territory. Morocco has resisted this condition, and the Imple-
mentation Committee's failure to secure acceptance of the Polisario Front's
requirement has constituted an obvious impediment to any negotiations. Sym-
pathy must be expressed for this request on the part of the Polisario Front. The
presence of Moroccan troops cannot be considered as conducive to a free atmos-
phere, and should be replaced by an OAUIUnited Nations peace-keeping force.
Morocco rejects the proposed participation of an OAUIUnited Nations
peace-keeping force. The presence of such a force to maintain the peace and
supervise free and fair elections is, however, considered necessary. In addition,
the SADR's admission as an O A U member has seriously undermined the pros-
pect of further Moroccan co-operation with the Implementation C ~ m m i t t e e . ~ ~
Additional problems are encountered in that Member States of the O A U may
be reluctant, for either political or financial reasons, to establish and contribute
towards another O A U force after the problems encountered by the O A U
peace-keeping force in Chad.
Nevertheless, the O A U Assembly has continued to endorse the Implemen-
tation Committee's endeavours. A t its 19th Ordinary Session held at Addis
Ababa in June 1983 the Assembly called upon the Implementation Committee
to secure a cease-fire and to make preparations for the referendum scheduled
for December 198324and called upon the United Nations in conjunction with
the O A U to provide a peace-keeping force for the duration of the referendum.
In addition, it called upon the parties to the conflict to enter into direct negoti-
ations with a view to permitting the exercise of the r e f e r e n d ~ m . ~ '
In light of the Chad precedent, the question arises whether an O A U peace-
keeping force for the Western Sahara as envisaged by the Implementation Com-
mittee is a viable proposition. One of the fundamental principles underlying the

23. See D'Sa, op. cit. supra n.9, at p.244. It would appear that, as the war is now shift-
ing in Morocco's favour, King Hassan has declared that the status of the Western Sahara is
subject neither to negotiation nor concession; see The Guardian, 9 March 1985, p.5; The
Observer, 10 March 1985, p.15. Note Art.3, para.4, of the O A U Charter which requires
Member States to settle disputes peacefully through negotiation, mediation, conciliation
o r arbitration.
24. AHGIRes.l04(XIX). Morocco's subsequent refusal to hold the referendum by the
specified date led the O A U to seat the S A D R at its 20th Ordinary Session held at Addis
Ababa in November 1984. As previously indicated, Morocco withdrew in protest. A
number of States, including Nigeria, recognised the SADR as a result; see The Times, 14
Nov. 1984, p.6. It would appear that Morocco's action with respect to the referendum vio-
lates the principle of good faith, enshrined in Art.2, para.2, of the UN Charter.
25. Ibid. In Resolution 39140 of 5 Dec. 1984, the General Assembly, by 94 votes to
none with 42 abstentions, endorsed the activities of the O A U , including Resolution
104(XIX), and urged the parties to the conflict to undertake direct negotiations with a
view to implementing a cease-fire which would allow a referendum to be held free from
administrative and military constraints under the auspices of the O A U and UN.
JULY 19851 O AU Peace- Keeping Attempts 60 1
concept of peace-keeping is that of obtaining the consent of the host State.26
Morocco has declared its opposition to the presence of an O A U force so it
would appear that an O A U force could not be established in Moroccan-
occupied Western Sahara. Alternatively, the Polisario Front has expressed its
support for an international peace-keeping force as a means of ensuring a freely
conducted referendum. Thus, unless Morocco's opposition can be overcome,
the prospects appear dim. This seems especially so in view of Morocco's with-
drawal from the O A U . Furthermore, financing the venture would also create
virtually insurmountable problems. As has been observed, financing the O A U
peace-keeping force in Chad constituted a considerable hurdle and there seems
to be no reason why this same difficulty would not be encountered in the West-
ern Sahara.
The United Nations, however, could prove a source of aid. Indeed, the
General Assembly in Resolution 36146 of 1981 expressed, inter aliu, "the deter-
mination of the United Nations to co-operate fully with the Organisation of
African Unity in the fair and impartial organisation of the referendum (in the
Western Sahara)". For the latter purpose, this resolution requested the Sec-
retary-General to "take the necessary steps to ensure that the United Nations
participates in the organisation and conduct of the referendum and to report to
the General Assembly and the Security Council on this subject. . . . " It would
therefore appear that in principle the United Nations might be prepared to con-
tribute towards the cost of a peace-keeping exercise and the holding of a refer-
endum in the Western Sahara. Nevertheless, it seems that even these proposals
have little chance of success, although they would appear to offer the best
opportunity for a peaceful solution of the dispute.
G . J. NALDI

26. See generally J . I. Garvey, "United Nations Peace-Keeping and Host State Con-
sent" (1979) 64 A.J.I.L. 241; A . Di Blase, "The Role of the Host State's Consent with
Regard to Non-Coercive Actions by the United Nations", in A . Cassese ( E d . ) . tir~ltc,d
Nations Peace-Keeping (1978), p.55.