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Both categories of displacement fall under the prohibition of forced displacement.[8] Article 49 states: Individual or mass forcible transfers, as well as deportations of protected persons from occupied territory to the territory of the Occupying Power or to that of any other country, occupied or not, are prohibited, regardless of their motive.[9] Forced displacement takes place where the individuals are compelled to move without their genuine consent, by means of force or coercion, from the area in which they are lawfully present.[10] Forcible transfer within a territory does not necessarily require physical force

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The court agreed the fee violates a state constitutional ban on passing revenue-raising measures in the final five days of a legislative session and without a 75 percent majority vote

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