The Work of PREN

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ELEPHANT MANAGEMENT IN SOUTH AFRICA THE SUBMISSION BY THE EMS FOUNDATION AND ANIMAL LAW REFORM SA TO DEFF HIGH LEVEL PANEL

SUBMITTED ON THE 15TH JUNE 2020

MINISTER BARBARA CREECY AND CHAIRPERSON ADVISORY COMMITTEE HIGH LEVEL PANEL

The submission also relates to the Management, Breeding, Hunting, Trade, Handling and related matters to the ELEPHANT, LION, LEOPARD AND RHINOCEROS

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EXCERPT FROM THE SUBMISSION:

Component II: Elephants in Captivity – General (page 110 – 117)

  1. Elephants are highly social and have the largest social network of any mammal yet studied other than humans. There is a vast amount of research on elephant biology and behaviour which show that humans and elephants share the same attributes – once thought unique to humans.
  2. The susceptibility of elephants to Post Traumatic Stress Disorder demonstrates that among all species, elephants are extremely vulnerable to suffering in a captive setting.
  3. What we have learned about elephants means that we are confronting very real ethical issues in relation to our current policies and legislation that affects them.
  4. Globally there is huge concern for the well-being of elephants in captivity, particularly in relation to abuses attributable to the captive elephant industry, including:
    1. Capture of juvenile elephants from wild family groups.
    2. Cruel training and controlling methods – which typically involves the use of physical and psychological punishment.
    3. The conditions in which elephants are kept.
    4. The safety of people handling them.
  5. Several high profile cases illustrate these concerns, particularly in relation to ‘training’.
  6. The captive elephant industry has a history of cruel, abusive and domination training and deaths of handlers.
  7. The use of elephants in the elephant back safari industry is not only highly detrimental to elephants, but it also increases the risk of injury for personnel as well as the general public.
  8. In SA the training and keeping of elephants in captivity persists without adequate monitoring or control.
  9. As far back as 2005 a number of local and international animal protection organisations warned that South Africa can ill afford a rapidly growing captive elephant industry sliding out of control – but this is precisely what has happened.
  10. Once captured, elephants used in the elephant back safari industry and circuses are subjected to absolute control, social and physical deprivation, and in many cases, psychological and physical violence.
  11. Early trauma, chronic stress, and deprivation are common to elephants in captivity. The added stress and trauma exerted by such practices as beating, negative reinforcement, chaining, physical abuse, and social isolation further undermine elephant well-being that transmits laterally (among other elephants) and vertically (across generations). The experience of elephants in captivity is equivalent to that of many human prisoners and victims of torture.
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A TURNING POINT FOR THE RIGHTS OF ALL NON HUMAN ANIMALS HELD CAPTIVE IN ZOOS

VICTORY FOR KAVAAN

AN OPEN LETTER ADDRESSED TO:

Mr Owais Awan Advocate for the Petitioner H. No 168, Hill Road Pakistan Medical Co-operative Housing Society (PMCHS) Sector E-11/2
Islamabad
owais.awan014@gmail.com

Mr Dr. Anis-Ur-Rehman
Chairman of Islamabad Wildlife Management Board Office of IWMB
Murghazar Zoo
Islamabad
docman56@hotmail.com

Ms. Mishael Ali Khan
Founder of Friends of Islamabad Zoo (FIZ) House No. 31-A
Street 23, Sector F-6/2
Islamabad
mishaelali@gmail.com

c/o Kevin Schneider
Executive Director Nonhuman Rights Project kschneider@nonhumanrights.org

8 June 2020

Dear Advocate, Chairpersons and Directors,

On behalf of the Pro-Elephant Network (PREN), a collective of global Elephant scientists, researchers and activists, we congratulate you on your stupendous and historic victory in the High Court of Islamabad.

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The world is delighted and thrilled at the Order given by Hon’ble Chief Justice C.J. Athar Minallah, High Court of Islamabad, Pakistan when he recognized the right to life of non-human animals and directed that Elephant ‘Kaavan’ of the Marghazar Zoo and the Black Bear, must be immediately moved to a sanctuary. This, alongside the required move of all the other animals from the zoo in due course into more appropriate facilities, is an extremely welcome move.

Elephant Kaavan reflects the fate of other Asian Elephants in captivity, which have been ‘gifted’ as a token of diplomatic exchange and appreciation. Elephant Kaavan, who was given by Sri Lanka in 1985, has, consequently, been suffering and in distress for over three decades. His fate was followed keenly by many animal welfare groups all over the world, as he remained confined to a small enclosure in a zoo.

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VICTORY FOR THE RIGHTS OF KAAVAN AND ALL NON-HUMAN ANIMALS HELD CAPTIVE IN ZOOS

CONGRATULATIONS TO THE LEGAL TEAM

AN OPEN LETTER ADDRESSED TO:

To Mr Imran Khan
Reader of His Lordship Hon’ble Chief Justice Mr. Athar Minallah Court Room No.1, Islamabad High Court, Sector G-10 Islamabad
imran.khanihc@gmail.com

c/c Mr Owais Awan Advocate for the Petitioner H. No 168, Hill Road Pakistan Medical Co-operative Housing Society (PMCHS) Sector E-11/2
Islamabad
owais.awan014@gmail.com

c/c Dr. Anis-Ur-Rehman, Chairman of Islamabad Wildlife Management Board Office of IWMB Murghazar Zoo Islamabad docman56@hotmail.com

8 June 2020

On behalf of the listed Members of the Pro-Elephant Network (PREN), a global community of elephant scientists, researchers and activists, we congratulate you on your outstanding victory in the Hon’ble High Court of Islamabad, where the rights of non-human animals have been recognised in a ground breaking Judgment.

Your historic presentation of the case of Elephant Kaavan, deprived of life and freedom for 35 years, and the hard work it entailed has gone to make this legal battle with few, if any, precedents.

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PREN NETWORK SUPPORTS THE ASIA FOR ANIMALS COLLATION’S APPEAL TO CEASE THE USE OF ELEPHANTS IN THE DAM SEN CIRCUS, VIETNAM

The Asia for Animals Coalition in collaboration with Animals Asia have appealed against the cruel use of animals in Vietnam’s circuses for years.  Investigators have recently discovered that Dam Sen Circus has gone back on their word almost a year ago to stop using macaques in performances and again are using them and a host of other animals in their shows.  Therefore, we are writing to them again to ask them to cease these cruel activities.

A COPY OF THE LETTER, ADDRESSED TO: 

Mr Nguyen Quoc Anh

General Director
Phu Tho Tourist Service Joint Stock Company Number 15 Road 2
Lu Gia Plaza Building
Ward 15, District 11,
Ho Chi Minh City
Vietnam

Re: The continued use of wild animals in Dam Sen circus

Dear Mr Nguyen Quoc Anh,

25th March, 2020

We are writing on behalf of the ​Asia for Animals Coalition​, representing international animal welfare and conservation organizations. We express our deep concern with regards to the continued use of wild animals within the animal circus at the Dam Sen Tourist Park in Ho Chi Minh City.

Our investigations have revealed that Dam Sen Tourist Park is again using macaques and pythons, together with some other animals, after nearly one year of not using wild animals in their circus performances.

This decision goes against the global trend of a dismissal of animal circuses, where over 57 countries and regions have issued a complete or partial ban of all animals for circus performances.1 Within Vietnamese communities, there are more and more people speaking up for animals and expressing their opposition to animal performances.

We believe that continuing the animal circus performances will have negative impacts on Dam Sen Tourist Park’s reputation. In addition, Dam Sen is registering to become a member of the South

According to data from Animal Defenders International updated to January 2020 East Asian Zoos and Aquariums Association, whose policy does not accept the use of wild animals in circuses.

Scientists warn that wildlife can transmit diseases to humans. In light of the increasing spread of the Coronavirus (COVID-19), I am sure you will agree that your performing wild animals currently pose a threat of disease transmission to the trainers, performers and audiences of the shows.

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TRANSLOCATION OF TWO ELEPHANT MALE CALVES FROM DUBLIN ZOO IN IRELAND, TO SYDNEY ZOO IN AUSTRALIA – PART TWO

PREN’S RESPONSE TO CORRESPONDENCE RECEIVED:

21ST FEBRUARY 2020

Mr. Michael Daly
Director, the Zoological Society of Ireland Phoenix Park, Dublin 8
Dublin, Ireland
director@dublinzoo.ie

Mr. Leo Oosterweghel Director, Dublin Zoo Dublin Zoo,
Phoenix Park Dublin 8 Ireland DO8 AC98 info@dublinzoon.ie

c/o The Hon Richard Bruton
Minister of Climate Action and Environment 29-31 Adelaide Rd
Dublin D02 X285  minister.bruton@dccae.gov.ie

c/o The Hon Sussan Ley MP Minister for the Environment PO Box 6022 House of Representatives Parliament House Canberra ACT 2600 minister@environment.gov.au

c/o The British and Irish Association of Zoos and Aquariums (BIAZA) c/o Chief Executive Dr Madelon Willemsen Madelon.Willemsen@biaza.org.uk c/o the Chair of the Elephant Welfare Group c/o the Senior Manager Animal Care and Conservation

Nicky Needham Nicky.Needham@biaza.org.uk

c/o The Zoo and Aquarium Association (ZAA) c/o President Mr Al Mucci PO Box 538 Mosman NSW 2088 Australia admin@zooaquarium.org.au

Dear Mr. Oosterweghel:

Reply to your letter of the 13th of February 2020 – Elephant Male Calves from Dublin to Sydney

Thank you very much for your prompt response to our letter of 11 February and your openness to further dialogue.

PREN is a group of experts in the biology, behaviour, conservation and welfare of elephants, concerned for the well- being of elephants everywhere. Many of our members work directly with captive elephants.

In the spirit of your letter we would like to respectfully ask a number of questions about the proposed export of the two young bull elephants to Sydney Zoo. We would like to further understand the rationale and processes leading to this export, about which we have significant concerns.

  • Does Dublin Zoo feel any long-term responsibility for the stewardship of these bulls, or do you feel that your responsibility ends with the completion of the export? Have contingencies been considered, under which they might need to be relocated elsewhere in the future?
  • Would you explain how Sydney Zoo was chosen as the best recipient of these animals? The zoo opened to the public only a few weeks ago, is relatively small, and is privately operated. How was it decided that this zoo has sufficient experience, adequate facilities, and reliable financial security to provide for the welfare of elephants and other animals in the long-term?
  • Could you also please explain why the elephants are being moved at the relatively young age of 5 or 6 years old? Wild elephants would not leave their natal group at this age and would be able to experience a process of gradual social separation from their mothers, aunts and siblings, so imperative to their social learning and adjustment. When male elephants leave their families, they join a society of other, older males. We would like to understand why it is felt necessary to move the elephants now, and to a zoo with no other males. Is it the policy of Dublin Zoo to continue with such removals of male elephants, in the event of successful breeding in future? Is it acceptable that male elephant calves, produced at a ratio of at least 50% of captive births, will always be considered as “surplus” to requirements, making the continuation of such exports inevitable?
  • Can you explain how the decision that the move to Sydney is in the “best interest of the elephants” and “will enable the elephants to thrive and become socially well-adjusted adults”, when for the foreseeable future it is likely they will not enjoy the company of any other elephants, let alone their natal group? At best they may develop some relationship with the 63+ year old female Saigon, but this outcome or its longevity cannot be assured and, given her age and poor health, it most unlikely. In any case, such a grouping does not represent any naturally observed social situation.
  • We note that Sydney has recently been subject to excessive heat, smoke pollution from bush fires and flooding rains, and that a number of zoos elsewhere in Australia were affected adversely. The intensity and extent of these events are directly linked to climate change; this is not a matter of conjecture, it is the scientific consensus. Australia is frequently described as being on the “front-line” of climate change and will experience weather conditions of growing severity in coming years. Was this heightened risk considered in the decision to move the young elephants to Australia? What steps will be taken to protect the elephants from progressively more extreme conditions as they develop?
  • It would seem that there are many zoos in Europe and North America that might be more experienced and better prepared to hold additional bull elephants, especially given the shortage of breeding bulls. Some zoos are dedicated as “bulls only” facilities. It would also seem that the two young bulls would have a greater chance of maturing appropriately in the presence of other young and older elephants in a zoo with greater experience and more extensive holding areas. This is particularly important as young bull elephants require the leadership of older ones, so as not to become socially disorientated and unruly. Which other zoos were considered as homes for these two elephants?
  • We have seen that you consulted Mr. Alan Roocroft in planning to move the elephants. You describe him as, “the world’s leading expert on elephants”, but Mr. Roocroft is not an elephant biologist and has not studied elephants in the wild. Were any biologists familiar with the natural behaviour and needs of elephants consulted and, if not, why not? Did Mr. Roocroft produce a report for Dublin Zoo and if so, is it a public document that can be viewed?We do appreciate your willingness to engage with us on these matters, as we remain concerned about the future of these two young bulls and the imperatives that have driven the process of decision making about their future. We look forward to your response to the points we have raised in this letter, in the spirit of ongoing discussion.

Yours sincerely,

Dr Marion Garai
Elephant Specialist Advisory Group

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PREN LETTER TO IATA REGARDING LIVE ELEPHANT EXPORT

February 13, 2020

Mr. Alexandre de Juniac Director General and CEO dejuniaca@iata.org

Mrs. Andrea Gruber Head, Special Cargo  grubera@iata.org

800 Place Victoria PO Box 113 Montreal – H4Z 1M1 Quebec – Canada

33, Route de l’Aeroport PO Box 416
1215 Geneva – 15 Airport Switzerland

CITES Decision Regarding Transport of African elephants from Zimbabwe and Botswana

Dear Mr. de Juniac and Mrs. Gruber:

We write to inform you of a decision adopted by the parties to the Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) restricting the transport of live, wild caught elephants from Zimbabwe and Botswana soley to countries within the species natural and historical range in Africa, with limited exceptions. We respectfully request that the International Air Transport Association (IATA):

(1) update the 46 edition of its Live Animal Regulations accordingly with an addendum, and revise any other relevant rules, guidance and standards; and

(2) inform its members and strategic partners, including exporters, importers, transport companies and carriers, of this decision as appropriate.

CITES regulates international trade in endangered and threatened animals and plants through the listing of species on one of three Appendices. African elephants in Zimbabwe, Namibia, South Africa, and Botswana are listed on CITES Appendix II, which limits trade to avoid uses that are incompatible with species’ survival. The listing of elephants in Zimbabwe and Botswana includes an annotation(1) allowing live elephants to be exported to “appropriate and acceptable

1 Annotations define which commodities are covered by the listing or are excluded from it.

destinations.” Pursuant to this annotation, Zimbabwe has captured live baby elephants from the wild and exported to zoos and entertainment facilities in China and elsewhere (2)

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PREN LETTER TO SAUDI AIRLINES CARGO REGARDING EXPORT OF ELEPHANTS FROM ZIMBABWE

February 13, 2020

Mr. Sami Bin Ali Sindi Director General samibinalisindi@saudia.com

Dr. Ghassan bin Abdulrahman Al-Shebl Chairman, Board of Directors ghassanbinabdulrahmanalshebl@saudia.com

Mr. Jaan Albrecht Chief Executive Officer jaanalbrecht@saudia.com

Mr. Per Hojland Executive Director, Cargo Operations perhojland@saudia.com

Mr. Rainer Mueller Regional Director rainermueller@saudia.com

SAUDIA AIRLINES P.O. BOX 620
JEDDAH 21231 Kingdom of Saudi Arabia

Saudia City, Al Rawdah Street, Al Khalidiah District JEDDAH 23421- 2229
Kingdom of Saudi Arabia

Saleh N. Al-Jasser
Minister of Transport
Riyadh, King AbdulAziz road P.O. Box 12628
Kingdom of Saudi Arabia  PRTMINISTER@MOT.GOV.S

CITES DECISION REGARDING TRANSPORT OF AFRICAN ELEPHANTS FROM ZIMBABWE AND BOTSWANA

Dear Mr. Sindi, Dr. Al-Shebl, Mr. Albrecht, Mr. Hojland, Mr. Mueller, and Mr. Al-Jasser:

On October 24, 2019 SAUDI Airlines, via its subsidiary, SAUDIA Cargo, shipped 32 live, wild-caught African elephants from Victoria Falls Airport in Zimbabwe (1) to China on flight number SV3049 (2). We write to inform you of a decision approved by the parties to the

(1) Roland Oliphant, Young elephants flown out of Zimbabwe after being ‘secretly’ removed from national park, The Telegraph, Oct. 24, 2019. Available at: https://www.telegraph.co.uk/news/2019/10/24/young-elephants-flown-zimbabwe-secretly- removed-national-park/

(2) Zim Baby Elephants: from the comfort of the jungle to ‘steel prisons’ in China, The Standard, Nov. 10, 2019. Available at: https://www.thestandard.co.zw/2019/11/10/zim-baby-elephants- comfort-jungle-steel-prisons-china/

Convention on International Trade in Endangered Species of Wild Fauna and Flora (CITES) that restricts future shipments of this nature. Specifically, the transport of live, wild-caught elephants from Zimbabwe and Botswana is now limited solely to countries within the species’ natural and historical range in Africa, with certain narrow exceptions. We respectfully request that SAUDIS Airlines adopt a policy consistent with the CITES decision, which at a minimum prohibits the shipment of live, wild-caught African elephants to countries outside the species’ natural and historical range. Such a policy could include narrow exceptions when such transfer will provide demonstrable in-situ conservation benefits for African elephants, or in the case of temporary transfer in emergencies as determined by the CITES Secretariat.

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TRANSLOCATION OF TWO ELEPHANT MALE CALVES FROM DUBLIN ZOO IN IRELAND TO SYDNEY ZOO IN AUSTRALIA

11TH FEBRUARY 2020

OPEN LETTER ADDRESSED TO:

Mr. Michael Daly
Director, The Zoological Society of Ireland Phoenix Park, Dublin 8 Ireland
director@dublinzoo.ie

Mr. Leo Oosterweghel Director, Dublin Zoo Dublin Zoo,
Phoenix Park Dublin 8 Ireland D08 AC98 info@dublinzoo.ie

The Hon Richard Bruton
Minister of Climate Action and Environment 29-31 Adelaide Rd
Dublin D02 X285  minister.bruton@dccae.gov.ie

The Hon Sussan Ley MP Minister for the Environment PO Box 6022 House of Representatives Parliament House Canberra ACT 2600 minister@environment.gov.au

The British and Irish Association of Zoos and Aquariums (BIAZA) c/o Chief Executive Dr Madelon Willemsen Madelon.Willemsen@biaza.org.uk c/o the Chair of the Elephants Welfare Group c/o the Senior Manager Animal Care and Conservation

Nicky Needham Nicky.Needham@biaza.org.uk

The Zoo and Aquarium Association (ZAA) c/o President Mr Al Mucci P.O. Box 538 Mosman NSW 2088 Australia admin@zooaquarium.org.au


Honourable Ministers and Directors,

Translocation of two Elephant Male Calves from Dublin to Sydney

Together, as the Pro Elephant Network, composed of forty research scientists, NGOs, academics, and elephant professionals, we are writing to you concerning the welfare of two bull elephant calves who may be transferred from the Dublin Zoo to the Sydney Zoo in Australia.

We observe that the Dublin Zoo has been focusing on breeding elephants. We note that this repeated breeding has resulted in the serious dilemma facing zoos generally: males are produced that are often surplus to the genetic requirements of any long-term breeding programme. Furthermore, zoos are not equipped either to provide for the natural development of bulls or to guarantee their welfare across their entire life spans. Elephants in zoos are generally deprived of their basic biological needs, compared to their wild counterparts, but bull elephants lead particularly impoverished lives.

We believe that the elephants proposed to be sent to Australia are still youngsters of around six years in age, and they should be guaranteed the opportunity to mature into socially well-adjusted adults.

The BIAZA elephant management guidelines, recommended that “Young animals should be kept within their family group for several years and should not be transferred” . These young bulls will not be allowed this opportunity at the Sydney Zoo as they will be denied the company of other elephants of appropriate age and social experience.

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ELEPHANTS PLAYING POLO IN NEPAL

23RD DECEMBER 2019

AN OPEN LETTER ADDRESSED TO: 

Honorable Prime Minister Mr K P Sharma Oli

Director General Department of National Parks and Wildlife Conservation Gopal Prakash Bhattarai

Honourable Minister of Forests and Environment Shakti Bahadur Basnet

Honourable Minister of Culture, Tourism and Civil Aviation Yogesh Bhattarai 

Nepal Tourism Board 

NEPAL ELEPHANT POLO TOURNAMENT

Recent news about the organization of an Elephant polo tournament in Nepal has drawn our attention and concern. The undersigned international Elephant experts representing various fields respectfully ask that you stop this year’s Elephant Polo event and ensure such activities will be discontinued in the future. The reasons for our concerns are as follows:

Background

Indian Rulers (Aristocrats) and Western colonists established Elephant Polo in the early 20th century as a form of entertainment. The game was introduced in Nepal in 1982 as a way to increase tourism. In the game, nine Elephants (4 from one side, 4 from another side, and one referee), are each ridden by a mahout and a player. The mahout forces the Elephant to run after the ball, threatening pain and punishment if the Elephant does not respond accordingly.

Elephant Polo has been permanently discontinued in Thailand and Sri Lanka following exposure of abusive treatment prior to and during the event. The official Elephant Polo games held in Nepal and hosted by Tiger Tops were discontinued in 2017.

In December 2018 an Elephant polo tournament was held in Sauraha, drawing international criticism and exposing the abusive treatment of the Elephants. Despite this, the Elephant owners are now contemplating another Elephant Polo game.

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STOP THE TRANSFER OF FOUR JUVENILE ELEPHANTS FROM UPPER ASSAM TO GUJARAT

FREN CALLS ON THE PRIME MINISTER OF INDIA

 

OPEN LETTER 16TH DECEMBER 2019

ADDRESSED TO: SHRI NARENDRA MODI, PRIME MINISTER OF INDIA, SHRI PRAKASH JAVADEKAR, MINISTER FOR ENVIRONMENT, FOREST AND CLIMATE CHANGE, SHRI SIDDHANTA DAS IFS, DIRECTOR GENERAL OF FOREST AND SPECIAL SECRETARY MINISTRY OF ENVIRONMENT, FOREST AND CLIMATE CHANGE, SHRI NOYAL THOMAS IFS, INSPECTOR GENERAL OF FORESTS MINISTRY OF ENVIRONMENT, FOREST AND CLIMATE CHANGE 

Pro Elephants Network (PREN) is a global community of elephant experts, elephant protection organisations and academics that embraces expertise from a wide variety of disciplines including the fields of science, conservation, animal welfare, non-human rights, advocacy, business, economics, social justice and the law. As Members of this group, we are deeply concerned about elephant welfare and the practice of capturing wild elephants for captivity.   

We call on the Prime Minister and Government of India to stop the transfer of four juvenile elephants from Tinsukia, Upper Assam, to the Jagganath Temple at Ahmedabad in Gujarat.     

We make this very urgent request based on the following:    

• The elephants — Rupsing, Joymati, Babulal and Rani – are suspected to have been illegally taken from the wild. For three of the elephants, there is no record of them being captive born until December 30, 2018. One male juvenile has a bullet injury on his left foreleg, suggesting violent capture.    

• The Jagganath Temple reportedly lacks adequate infrastructure and management for the elephants currently in their care. Reports and photo documentation shared by concerned members of the public show the elephants begging and used for wedding processions.1     

• The elephants would be taken from their natural home range and forced to live in a very different climate in Gujarat, which is extremely hot and offers little access to water. Elephants require a large amount of water for their health and well-being, including access to water for daily bathing.   

• In captivity the young elephants’ physical, psychological, and social needs cannot be sufficiently met, which will cause poor health, mental distress, and lifelong suffering.2 Under current law, as captives these elephants would have virtually no protection against neglect, overwork, and abuse.   

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