Country Advice
Vietnam Vietnam – VNM39416 – Vietnam Populist Party (VPP) – Attitude of Vietnamese Government to VPP members – Treatment of anti-government activists returning to Vietnam 24 October 2011
1. Please provide general information on the Vietnam Populist Party.
The Vietnam Populist Party (VPP1), in Vietnamese Đảng Vì Dân Việt Nam, is a pro- democracy political organisation based in the USA. The name of the party is also transliterated as the „For the People‟s Party‟ (FPP). The VPP is one of a number of Vietnam- focused pro-democracy groups that have formed in Vietnam and abroad in the last decade. Carlyle Thayer2 opines that although many of these organisations refer to themselves as „parties‟, the description is problematic as they lacked structure and a geographically diverse membership.3
General information about the VPP
The VPP was formed in Houston in 20064 following the merging of five pro-democracy groups under the leadership of Nguyen Cong Bang (Nguyen).5 Following its formation, the party released the New Vietnam Platform calling for “fair and free” elections in Vietnam. The group‟s public base remains in Houston, USA under Nguyen‟s direction. The VPP‟s strength, in Vietnam, including membership numbers, is difficult to measure, particularly as the VPP declines to provide information on its membership or structure citing security concerns.6
Details on the VPP‟s policies and beliefs is limited and mostly restricted to information provided by the VPP7 and associated websites maintained by the party and/or Nguyen. The
1 The party is also abbreviated as VNPP, FPP, PPP and DVD. 2 Carlyle A. Thayer is Professor of Politics, School of Humanities and Social Sciences, University College, University of New South Wales at the Australian Defence Force Academy in Canberra. 3 Thayer, C.A. 2009, „Vietnam and the Challenge of Political Civil Society‟, Contemporary Southeast Asia: A Journal of International and Strategic Affairs, Volume 31, Number 1, April, https://muse.jhu.edu/journals/contemporary_southeast_asia_a_journal_of_international_and_strategic_affairs/v031/3 1.1.thayer.pdf - Accessed 24 October 2011 4 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 5 Thayer, C.A. 2009, „Vietnam and the Challenge of Political Civil Society‟, Contemporary Southeast Asia: A Journal of International and Strategic Affairs, Volume 31, Number 1, April, https://muse.jhu.edu/journals/contemporary_southeast_asia_a_journal_of_international_and_strategic_affairs/v031/3 1.1.thayer.pdf - Accessed 24 October 2011 6 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 7 The VPP‟s full platform is available at http://www.vnpp.net/index.php?option=com_content&view=category&id=51&Itemid=40
Page 1 of 9 VPP‟s own website claims that the party is a grassroots political organisation mainly active in Vietnam.8 The party declares that its immediate goal is “a fair and free general election in Vietnam” under international supervision in order to create a multi-party democracy in Vietnam.9 The VPP advocates a non-violent campaign for “democracy, freedoms, social justice, and welfare for the poor.”10
Information on VPP activities in Vietnam is limited to reports on the arrest of VPP members and sympathisers. The party itself appears to operate on a clandestine basis in Vietnam noting on its website that “[d]ue to security reasons, VNPP‟s Coordinating Committee has withheld the names and locations of most of its officers [in Vietnam]”.11 It is noted that Nguyen has advocated a policy of retaining a low profile in Vietnam since at least the mid-2000s. In 2005 Nguyen advised the UWFA (United Workers - Farmers Association) not to take a proactive stance that would “invite repression and dampen recruitment.”12 The website further claims that the “formal leadership establishment of the organization is pending upon a party convention that is expected to be organized in Vietnam, when it becomes possible.”13
The VPP maintains a website in Vietnamese and English and also operates a radio station, Radio Hoa-Mai, to disseminate its views. Radio Hoa-Mai is based in southern California, however, it broadcasts to Vietnam using short wave radio twice weekly and programmes are available for download from the internet.
History
The VPP was formed by Vietnamese exiles based in the US city of Houston in early 2006 under the leadership of Nguyen Cong Bang.14 Information on Nguyen‟s background could only be found on the VPP website. Nguyen claims to have been born in South Vietnam in 1955 and to have fought for the ARVN (Army of the Republic of Vietnam).15 After being interned at a labour camp, Nguyen escaped and settled in the USA. Nguyen was involved with several pro-democracy groups during the 1980s and 1990s and in 1998 joined the
8 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 9 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 10 „General Policy of the VNPP‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=14:general-policy&catid=24:general- policy&Itemid=39 - Accessed 24 October 2011 11 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 12 Thayer, C.A. 2009, „Vietnam and the Challenge of Political Civil Society‟, Contemporary Southeast Asia: A Journal of International and Strategic Affairs, Volume 31, Number 1, April, p.12 https://muse.jhu.edu/journals/contemporary_southeast_asia_a_journal_of_international_and_strategic_affairs/v031/3 1.1.thayer.pdf - Accessed 24 October 2011 13 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 14 „Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011 15 „Biography of the Secretary General of the VNPP‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=27&Itemid=60 - Accessed 24 October 2011
Page 2 of 9 Vietnam Coalition Party. Nguyen claims to have left this group in March 2004 over (unspecified) disagreements on policy before forming the VPP in 2006.16
In February 2007 the VPP joined with the Vietnamese Progression Party17 (VNPP) to form the Lac-Hong Coalition.18 A contemporary report from the BBC stated that support for both parties in Vietnam was limited to a “core of democracy activists in the country‟s main cities.”19 The precise nature of this „merger‟ was not reported by sources consulted, nor is the level of continued cooperation between the two groups. The VPP continues to maintain its own website and on that basis would appear to maintain a separate existence as a political party.
Current Status
Source information on the current status of the VPP is restricted to the VNPP website and reports on the arrest of VPP members in Vietnam. No independently verifiable information could be located indicating what, if any, activities are being undertaken by the VPP in Vietnam. The Vietnamese Government has made claims that the VPP has paid members to undertake terrorist activities including bombings.
No information on membership numbers within Vietnam or the USA could be located. Information on members of the VPP is restricted to its website and NGO/press reports of individuals arrested by the Vietnamese Government and accused of being VPP members or sympathisers. Contact information details for the party (e.g. phone numbers, postal addresses) are based in Houston, USA.
2. What is the Vietnam government’s attitude towards the VPP, and in particular are members of the VPP subject to harassment etc. from the government?
Sources were located detailing harassment, in the form of prosecutions, of VPP members since its 2006 formation. In many cases gaoled dissidents were members of multiple pro- democracy groups or in some instances, different sources claimed that the dissidents belonged to different groups. These sources variously refer to the Vietnam Populist Party (VPP or VNPP) or the For the People Party (FPP). For clarity, VPP20 is used below. Prominent cases of VPP members being prosecuted include:
In July 2010 Nguyen Thanh Tam was arrested under Article 79 of the Vietnamese Criminal Code (VCC) for activities aiming to overthrow the socialist government.21
16 „Biography of the Secretary General of the VNPP‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=27&Itemid=60 - Accessed 24 October 2011 17 The Vietnamese Progression Party (Dang Thang Tien Vietnam). The party‟s name is commonly abbreviated as VNPP or VPP. This document will use VNPP. 18 Thayer, C.A. 2009, „Vietnam and the Challenge of Political Civil Society‟, Contemporary Southeast Asia: A Journal of International and Strategic Affairs, Volume 31, Number 1, April, https://muse.jhu.edu/journals/contemporary_southeast_asia_a_journal_of_international_and_strategic_affairs/v031/3 1.1.thayer.pdf - Accessed 24 October 2011 19 Hayton, B. 2007, „Vietnam dissident priest detained‟, BBC News, 24 February, http://news.bbc.co.uk/2/hi/asia- pacific/6393975.stm - Accessed 24 October 2011 20 Note that some sources refer to the Vietnam Progressive Party as the VPP. 21 „Arrest and arbitrary detention of four Vietnamese‟ 2010, Asian Human Rights Commission, 22 September, http://www.humanrights.asia/news/forwarded-news/AHRC-FUA-013-2010 - Accessed 24 October 2011
Page 3 of 9 Vietnam Human Rights Network22, a US-based NGO, stated that Tam, described as a farming rights activist, was accused of collaborating with the VPP.23
In April 2010, Pham Thi Phuong and her husband Pham Ba Huy were arrested in Ho Chi Minh City for planning “terrorist activities”. The Vietnamese Government accused Phuong, a 66 year old female, of having joined the VPP in exile after fleeing Vietnam in 2002 while being investigated for fraud offences. The prosecution claimed that Phuong received US$5000 from the VPP to illegally re-enter Vietnam for the purpose of bombing up statues in Ho Chi Minh City. A Vietnamese language BBC article cited an unnamed VPP source as claiming the money was for “leaflets and slogans.”24 No independent sources could be located to confirm or refute the claims of either the Vietnamese Government or the VPP. In September 2011 state-controlled media reported that Phuong received an 11 year gaol sentence for attempting to overthrow the government.25 No information was located on the current status of Huy although a VPP website entry dated 21 September 2011 suggested he remained in gaol.26
In February 2010, Doan Huy Chuong, Nguyen Hoang Quoc Hung, and Do Thi Minh Hanh, reportedly affiliated with the FPP and UWFA (United Workers - Farmers Association) were arrested for distributing pro-democracy pamphlets.27 The US Department of State reported that the leaflet was a joint campaign by several pro- democracy groups (the VPP is not named as participating).28 The three were convicted in October for violating Article 89 of the VCC (causing public disorder to oppose the people's government), and given gaol terms between seven and nine years.
In April 2009, VPP party members Duong Au, Phung Quang Quyen, Truong Van Kim, and Truong Thi Tam were arrested under Article 91 of the VCC (fleeing abroad to oppose the government). According to an AFP article, Vietnamese authorities accused the four of meeting with VPP officials in Cambodia and “actively opposing Vietnamese state policies, including those concerning controversial bauxite mines.”29 It is not clear from these sources whether these accusations were based on additional actions performed by the four or solely related to their membership of the VPP. They
22 See http://www.vietnamhumanrights.net/English/aboutus.htm 23 Vietnam Human Rights Network (undated), Report on Human Rights in Vietnam in 2010, p.25 http://www.vietnamhumanrights.net/English/documents/VNHRN%20REPORT%202010.pdf - Accessed 24 October 2011 24 „Đảng Vì Dân bác bỏ cáo buộc 'khủng bố‟ (Populist Party denies 'terrorist') 2010, BBC News Tieng Viet, 29 April, 'http://www.bbc.co.uk/vietnamese/vietnam/2010/04/100422_pham_thi_phuong.shtml (translated at http://translate.google.com.au/translate?u=http%3A%2F%2Fwww.bbc.co.uk%2Fvietnamese%2Fvietnam%2F2010% 2F04%2F100422_pham_thi_phuong.shtml&sl=vi&tl=en&hl=en&ie=UTF-8) Please note: Google translations can often be poor and can contain errors - as such they give only a rough indication of the contents of a document. For any further reliance on this information, a professional translations hould be obtained - Accessed 24 October 2011 25 „Vietnam jails 66-year-old woman for subversion‟ 2011, Agence France-Presse, 22 September, MSN Malaysia website http://news.malaysia.msn.com/regional/article.aspx?cp-documentid=5302036 - Accessed 24 October 2011 26 „Mrs Pham Thi Phuong sentenced to 11 years imprisonement (sic)‟ 2011, Vietnam Populist Party website, 21 September, http://www.vnpp.net/prodemocracynews/243-243 - Accessed 24 October 2011 27 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April 28 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April 29 „Vietnam jails four for links with banned party‟ 2010, AFP, 23 April, Antaranews.com website http://www.antaranews.com/en/news/1271967422/vietnam-jails-four-for-links-with-banned-party - Accessed 24 October 2011
Page 4 of 9 received sentences ranging from three to five years gaol followed by similar periods of probation.30
In 2007, Le Thi Cong Nhan, a “well-known human rights attorney”, Bloc 8406 (a collective of pro-democracy activists) cofounder, and VPP spokeswoman, was arrested in 2007 and convicted of violating Article 88 of the VCC (distribution of propaganda against the state). Nhan was released from prison in March 2010 after completing her three-year sentence.31
In May 2007, Truong Minh Duc, described by Amnesty International as a freelance journalist, Bloc 8406 supporter, and member of the VPP was arrested and sentenced to five years‟ imprisonment with three years‟ house arrest on release.32 Reporters Without Borders stated that Duc was gaoled for “taking advantage of democratic rights to act against the state‟s interests” and “receiving money from abroad to support complaints against the state” under Article 258 of the VCC.33
General attitude of Vietnamese Government to pro-democracy parties
The Vietnamese Communist Party (VCP), operating within the framework of the Vietnamese Fatherland Front (VFF), is the only permitted political party in Vietnam. All other parties, including the VPP, are illegal and banned from participating in the political process.34
The 2011 Freedom House Country Report on Vietnam stated that the Vietnamese Government continued to reject any challenge to the one-party state status quo.35 The report noted that criticism of the government continued to be “harshly” supressed, with dissidents being gaoled. Participation in the political system was only permitted through the structures of the VCP. The 2010 US DOS Human Rights Report on Vietnam observed that opposition parties were “neither permitted nor tolerated”.36
An April 2011 Human Rights Watch report noted that ill-defined national security laws were regularly used to imprison dissidents. These include “subversion of the people‟s administration” (VCC Article 79); “undermining the unity policy” (Article 87); “conducting propaganda against the government” (Article 88); “disrupting security” (Article 89); “fleeing abroad to oppose the government” (Article 91); “causing public disorder” (Article 245); and
30 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April 31 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April 32 „Viet Nam Release Prisoners of Conscience‟ 2010, Amnesty International, Junw, http://www.amnesty.org/fr/library/asset/ASA41/001/2010/fr/df03720e-a5f4-4da1-b15b- 2ef93fb67fee/asa410012010en.html - Accessed 24 October 2011 33 „Five-year jail term for freelance journalist Truong Minh Duc‟ 2008, Reporters Without Borders, 29 March, UNHCR website http://www.unhcr.org/refworld/publisher,RSF,,VNM,47f0c4abd,0.html - Accessed 24 October 2011 34 Freedom House 2011, Country Report: Vietnam, 26 May, http://www.freedomhouse.org/template.cfm?page=22&year=2011&country=8164 - Accessed 24 October 2011 35 Freedom House 2011, Country Report: Vietnam, 26 May, http://www.freedomhouse.org/template.cfm?page=22&year=2011&country=8164 - Accessed 24 October 2011 36 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April
Page 5 of 9 “abusing democratic freedoms” of speech, press, belief, religion, assembly, and association to “infringe upon the interests of the State” (Article 258).37
3. Are the activities of Vietnamese citizens in Australia monitored by the Vietnamese Embassy?
No further information on this matter was located since RRT Research Response VNM17238 (2005) concerning the monitoring activities of Vietnamese embassies in countries including Australia..
4. Do Vietnamese citizens who are known to be involved in anti-government activities abroad encounter difficulties when they return to Vietnam?
Vietnamese citizens known to be involved in anti-government activities may face difficulties when they return to Vietnam. Article 91 of the Vietnamese penal code allows for the arrest and prosecution of individuals for “fleeing abroad to oppose the government.”38 Several sources including the US Department of State and Human Rights Watch (HRW) note the use of Article 91 to detain returning dissidents, including VPP members. An April 2011 HRW report noted the February 2011 arrest of Vu Quang Thuan, the leader of the Vietnam Progressive Democratic Movement, immediately upon arriving at Ho Chi Minh City Airport.39 As noted in the response to Question 2, four VPP members were arrested and subsequently gaoled in 2009 under Article 91.40
Comments supplied to the tribunals by Carlyle Thayer in 2005 (VNM17238) drew a distinction between the treatment of Vietnamese citizens engaged in anti-regime activities compared to those who were merely critical of the Vietnamese Government.41 Thayer stated that Vietnamese who participated in anti-regime activities were likely to be interviewed by authorities when they returned to Vietnam and their relatives contacted by security officials “in a subtle form of intimidation.”42 Thayer noted that this kind of treatment was not extended to those returnees who were critical of the Vietnamese Government.
According to the 2010 US Department of State Human Rights Report for Vietnam, the Vietnamese Government cooperated with the UNHCR and other organisations to facilitate the return and protection of returning refugees.43 Nonetheless, the report stated that the Vietnamese Government refused to allow certain activists living abroad to return, and that known overseas Vietnamese political activists were denied entrance visas or were detained and deported after entering the country.44
37 „Human Rights Defender Cu Huy Ha Vu Faces Trial‟ 2011, Human Rights Watch, 2 April, http://www.hrw.org/news/2011/04/02/vietnam-release-prominent-legal-activist - Accessed 24 October 2011 38 „Human Rights Defender Cu Huy Ha Vu Faces Trial‟ 2011, Human Rights Watch, 2 April, http://www.hrw.org/news/2011/04/02/vietnam-release-prominent-legal-activist - Accessed 24 October 2011 39 „Peaceful Dissidents and Bloggers Arbitrarily Locked Up‟ 2011, Human Rights Watch, 7 April, http://www.hrw.org/node/97905 - Accessed 24 October 2011 40 United States Department of State 2010, '2009 Country Reports on Human Rights Practices', US State Department website, 11 March, http://www.state.gov/g/drl/rls/hrrpt/2009/eap/136015.htm - Accessed 12 March 41 RRT Country Research 2005, Research Response VNM17238, 24 March. 42 RRT Country Research 2005, Research Response VNM17238, 24 March. 43 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April 44 US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April
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Page 7 of 9 References „Arrest and arbitrary detention of four Vietnamese‟ 2010, Asian Human Rights Commission, 22 September, http://www.humanrights.asia/news/forwarded-news/AHRC-FUA-013-2010 - Accessed 24 October 2011
„Biography of the Secretary General of the VNPP‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=27&Itemid=60 - Accessed 24 October 2011
„Đảng Vì Dân bác bỏ cáo buộc 'khủng bố‟ (Populist Party denies 'terrorist') 2010, BBC News Tieng Viet, 29 April, 'http://www.bbc.co.uk/vietnamese/vietnam/2010/04/100422_pham_thi_phuong.shtml (translated at http://translate.google.com.au/translate?u=http%3A%2F%2Fwww.bbc.co.uk%2Fvietnamese%2F vietnam%2F2010%2F04%2F100422_pham_thi_phuong.shtml&sl=vi&tl=en&hl=en&ie=UTF-8) Please note: Google translations can often be poor and can contain errors - as such they give only a rough indication of the contents of a document. For any further reliance on this information, a professional translation should be obtained - Accessed 24 October 2011
„Five-year jail term for freelance journalist Truong Minh Duc‟ 2008, Reporters Without Borders, 29 March, UNHCR website http://www.unhcr.org/refworld/publisher,RSF,,VNM,47f0c4abd,0.html - Accessed 24 October 2011
„General Policy of the VNPP‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=14:general- policy&catid=24:general-policy&Itemid=39 - Accessed 24 October 2011
„Human Rights Defender Cu Huy Ha Vu Faces Trial‟ 2011, Human Rights Watch, 2 April, http://www.hrw.org/news/2011/04/02/vietnam-release-prominent-legal-activist - Accessed 24 October 2011
„Introduction of the Vietnam Populist Party‟ (undated), Vietnam Populist Party website, http://www.vnpp.net/index.php?option=com_content&view=article&id=15&Itemid=118 - Accessed 24 October 2011
„Mrs Pham Thi Phuong sentenced to 11 years imprisonement (sic)‟ 2011, Vietnam Populist Party website, 21 September, http://www.vnpp.net/prodemocracynews/243-243 - Accessed 24 October 2011
„Peaceful Dissidents and Bloggers Arbitrarily Locked Up‟ 2011, Human Rights Watch, 7 April, http://www.hrw.org/node/97905 - Accessed 24 October 2011
„Viet Nam Release Prisoners of Conscience‟ 2010, Amnesty International, Junw, http://www.amnesty.org/fr/library/asset/ASA41/001/2010/fr/df03720e-a5f4-4da1-b15b- 2ef93fb67fee/asa410012010en.html - Accessed 24 October 2011
„Vietnam jails 66-year-old woman for subversion‟ 2011, Agence France-Presse, 22 September, MSN Malaysia website http://news.malaysia.msn.com/regional/article.aspx?cp- documentid=5302036 - Accessed 24 October 2011
Page 8 of 9 „Vietnam jails four for links with banned party‟ 2010, AFP, 23 April, Antaranews.com website http://www.antaranews.com/en/news/1271967422/vietnam-jails-four-for-links-with-banned-party - Accessed 24 October 2011
Freedom House 2011, Country Report: Vietnam, 26 May, http://www.freedomhouse.org/template.cfm?page=22&year=2011&country=8164 - Accessed 24 October 2011
Hayton, B. 2007, „Vietnam dissident priest detained‟, BBC News, 24 February, http://news.bbc.co.uk/2/hi/asia-pacific/6393975.stm - Accessed 24 October 2011
1 http://www.vnpp.net/index.php?option=com_content&view=article&id=14:general- policy&catid=24:general-policy&Itemid=39
RRT Country Research 2005, Research Response VNM17238, 24 March.
Thayer, C.A. 2009, „Vietnam and the Challenge of Political Civil Society‟, Contemporary Southeast Asia: A Journal of International and Strategic Affairs, Volume 31, Number 1, April, p.12 https://muse.jhu.edu/journals/contemporary_southeast_asia_a_journal_of_international_and_strat egic_affairs/v031/31.1.thayer.pdf - Accessed 24 October 2011
United States Department of State 2010, '2009 Country Reports on Human Rights Practices', US State Department website, 11 March, http://www.state.gov/g/drl/rls/hrrpt/2009/eap/136015.htm - Accessed 12 March
US Department of State 2011, 2010 Country Reports on Human Rights Practices, 8 April, www.state.gov/g/drl/rls/hrrpt/2010/eap/154408.htm - Accessed 11 April
Vietnam Human Rights Network (undated), Report on Human Rights in Vietnam in 2010, p.25 http://www.vietnamhumanrights.net/English/documents/VNHRN%20REPORT%202010.pdf - Accessed 24 October 2011
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