The Disenfranchisement of the Chagossian People on the Future of the Chagos Archipelago

Author: Robert Beltran, LLM

March 19, 2025

Colonial History

Strategically located in the middle of the Indian Ocean, the Chagos Archipelago is 3,943 km from the coast of East Africa, 4,692 km from the Red Sea, about 1,609 km from the Southern tip of India, and 3,306 km from the Strait of Malacca. Overall, the Indian Ocean provides resources for 2.9 billion people, more than one-third of the world’s bulk cargo traffic, and two-thirds of the world’s oil shipments.[1] The U.S. and U.K. military calls the Chagos Archipelago the “Footprint of Freedom” due to its shape and the fact that it houses one of the most secretive and strategic U.S. military bases on Earth.[2] Ironically, the indigenous inhabitants of the Chagos Archipelago, called the Chagossians, have not had the freedom to return and live there since the late 1960s.[3]

[Image source: Impact Resolutions]

The Chagossians are descendants of a mix of African, Indian, and Malay people.[4] They were first brought over as enslaved peoples to the archipelago to work on the coconut plantations there.[5] Additional waves came from India, Mauritius, the Seychelles, and various parts of Africa.[6] The United Nations and a British High Court ruling in 2000 has classified the Chagossians as the indigenous inhabitants of the Chagos Archipelago.[7]

It was the French who first laid claim to the archipelago and began issuing permits for companies to establish coconut oil plantations in the 1770s.[8] They brought enslaved Africans to work in the plantations. After its defeat in the Napoleonic Wars, France formally ceded Mauritius, including the Chagos Archipelago, to Great Britain pursuant to the Treaty of Paris of 1814.[9] From then on, Britain governed the archipelago from the crown colony of Mauritius.[10] The British then brought indentured Indian laborers to work on the plantations.[11] The enslaved Africans on the plantations would not be freed until 1840, six years after the Slavery Abolition Act had outlawed slavery across the British Empire.[12] By 1903, the Chagos was administratively separated from Seychelles and was attached to Mauritius.[13]

Detachment and Military Base

The Chagos Archipelago would not gain geopolitical relevance until the mid-20th century at the height of the Cold War. Stuart B. Barber was the director of long-range planning at the U.S. Navy during the late 1950s.[14] Barber would acknowledge that he came up with the concept of a naval base in the Chagos Archipelago particularly on the atoll of Diego Garcia.[15] Barber found the atoll to be ideal for a military base, particularly its natural harbor. It had enough land for a large airstrip and its location was within striking distance of potential conflict zones.[16] Moreover, its isolation would keep it safe from an attack while still being within striking distance of Southern Africa, the Middle East, South Asia, and Southeast Asia.[17]

During the decolonization process of Mauritius, the Kennedy and Johnson administrations proposed an idea to the British government.[18] The proposal was to detach the Chagos Archipelago from Mauritius and retain the former as a British territory where the military base would be built, which the Americans would lease “without charge.”[19] The British willingly obliged in exchange for a $14 million dollar discount on its purchase of the Polaris nuclear weapons from the U.S.[20] To formalize this, the United Kingdom and Mauritius entered into the Lancaster Agreement of 1965, granting Mauritius its independence and separating the Chagos Archipelago from the latter, which was retained as a British territory.[21]

As part of the deal, the U.K. compensated Mauritius with £3 million pounds for the detachment of the Chagos Archipelago.[22] Even at the time, the deal faced tremendous backlash as it was contrary to UN General Assembly Resolution 1514 which provided that “[a]ny attempt aimed at the partial or total disruption of the national unity and the territorial integrity of a country is incompatible with the purposes and principles of the Charter of the United Nations.”[23] Nevertheless, the construction of a military base at the atoll of Diego Garcia proceeded.[24]

To ensure the security of the base, the U.S. required that the base be uninhabited and limited access to the islands.[25] Starting in 1967, the UK forcibly removed the Chagossians from the Archipelago and resettled them in Mauritius, Seychelles, and the U.K., where they struggled and lived in poverty.[26] The military base, now known as “Naval Support Facility Diego Garcia”, houses long-range bombers by the U.S. Air Force and accommodates U.S. Navy submarines.[27] The base played a significant role in the initial invasion of Afghanistan after the terrorist attacks on 9/11.[28]

 Legal Battles

The Chagossians would later on fight to return to their homeland. In 1997, the Chagossians filed a lawsuit against the British government in the British High Court challenging the  legality of their removal.[29] The High Court sided with the Chagossians,  ruling that their removal from the islands was illegal and that they had the right to return home.[30] However, the House of Lords overturned the ruling in a 3-2 decision in 2008.[31]

[Image credit: The Associated Press via The Independent]

In the U.S., the Chagossians also filed a lawsuit in federal court against the U.S. government.[32] The lawsuit alleged the U.S. government of harm, including forced relocation, cruel, inhuman, and degrading treatment, and genocide.[33] In 2004, the U.S. District Court for the District of Columbia dismissed the case, ruling that it raised a political question and that, since the matters on foreign affairs are vested in the executive branch of government, judicial interference would violate the separation of powers.[34] 

Mauritius also made its legal claims over the Chagos Archipelago in international courts. Initially, they brought a case against the U.K. with the Permanent Court of Arbitration (PCA) in 2011, pursuant to the United Nations Convention on the Law of the Sea (UNCLOS).[35] The issue disputed was whether the establishment by the U.K. of a “Marine Protected Area” (MPA) over the Chagos Archipelago was in accordance with the UNCLOS.[36] The establishment of a MPA of the Chagos Archipelago effectively banned the fishing and other extracted activities within 640,000 km of the archipelago on the ground of environmental protection.[37] This, in effect, prevented anyone from getting close to the archipelago. Unsurprisingly, an exception was granted to people on the military base to fish.[38]

In 2015, the PCA ruled that the Chagos MPA “was not in accordance with the provisions of the Convention, the Tribunal has taken no view on the substantive quality or nature of the MPA or on the importance of environmental protection.”[39] In other words, the MPA was not per se illegal, but the U.K. could rectify the issue by consulting  with Mauritius in establishing the MPA to give due regard to the latter’s rights.[40] The PCA narrowed its decision-making process to how the MPA was established rather than its legality and merit as a marine protected area around the Chagos Archipelago.[41]

In June 2017, the United Nations General Assembly (UNGA) voted to refer the dispute between the U.K. and Mauritius to the International Court of Justice (ICJ).[42] The final vote at the UNGA was 94 in favor of the referral and 15 against the referral.[43] In 2019, the ICJ, in an advisory opinion, held that the U.K.’s administration of the Chagos Archipelago was illegal and it was instructed to end its administration of the islands as “rapidly as possible.”[44] The ICJ ruled that the decolonization of Mauritius was not complete because of the unlawful detachment of the Chagos Archipelago.[45] It further stated that the detachment was not the “free and genuine expression of the people concerned.”[46] In 2021, the International Tribunal on the Law of the Sea (ITLOS) reiterated the advisory opinion of the ICJ on a collateral issue in a maritime dispute between Mauritius and the Maldives.[47] The dispute involved the Chagos Archipelago because Mauritius used it as a baseline to determine the extent of its exclusive economic zone.[48] The Maldives raised a jurisdictional question on the ground that the sovereignty over the Chagos Archipelago was still in dispute, which the ITLOS shot down.[49]

New Deal

Initially, the U.K. government refused to recognize the ICJ’s advisory opinion on the grounds of its non-binding nature. They determined that the settlement ought to be settled bilaterally between the U.K. and Mauritius.[50] However, in 2022, the new Conservative government of Prime Minister Liz Truss initiated negotiations to hand over the Chagos Archipelago to Mauritius, with the notable exception of Diego Garcia.[51] The negotiations were stopped when Rishi Sunak took over as Prime Minister.[52] In October 2024, the newly elected Labour government led by Prime Minister Keir Starmer announced a deal to handover the Chagos Archipelago to Mauritius while allowing American and British militaries to remain at Diego Garcia on a 99-year lease.[53] Furthermore, the U.K. would pay Mauritius £9 billion as part of the deal.[54] Coincidentally, Mauritius elected a new government, and their new Prime Minister, Navin Ramgoolam, criticized the duration of the 99-year lease on Diego Garcia.[55] Currently, the deal is on hold to give the new Trump administration an opportunity to examine the deal.[56]

Nevertheless, the initial announcement of the deal was met with criticism on many fronts. Former Foreign Secretary James Cleverly, who led the negotiations under the Truss premiership, criticized the deal as “weak, weak, weak.”[57] The new Leader of the Opposition, Kemi Badenoch called it an “immoral surrender.”[58] The leader of Reform UK and the Brexit movement, Nigel Farage, said the Chagos deal could seriously fracture the U.S. – U.K. Special Relationship.[59] Even Labour Member of Parliament Peter Lamb, who represents Crawley where most Chagossians live in the U.K., opposes the deal, putting him at odds with his own party.[60] Mr. Lamb laments the fact that his Chagossian constituents were not consulted by the government on the deal. Furthermore, he also states that he has not heard of a single Chagossian constituent who favors Mauritian sovereignty over the Chagos Archipelago.[61]

One reason for this is the fact that Mauritius has suggested that only those Chagossians who have a Mauritian passport would be allowed to return to the islands, excluding Chagossians in the U.K. and the Seychelles.[62] Former Maldives President Mohamed Nasheed criticized the deal, calling it “unacceptable,” especially since the Maldives itself has a claim on one of the atolls at the Chagos Archipelago.[63]

In November 2024, Chagossians in the U.K. held a rally in London protesting the deal.[64] Jean Francois Nellan, a spokesperson for the Chagossian Voices, a Chagossian grassroots organization, stated that they “have a right for self-determination, this is what we’ve been asking. Do a referendum and ask us if we want to be British or Mauritian.”[65] The British Foreign Office claimed that the deal with the Mauritian government respected the interest of the Chagossian people.[66] Frankie Bontemps, the acting chair of Chagossian voices, said that whenever they asked about the negotiations, they were told that what was happening couldn’t be disclosed  as it was a discussion between the U.K. and Mauritian governments.[67] 

Mr. Bontemps, whose mother was born in Diego Garcia, gave birth to him in Mauritius.[68] In 2006, he moved to the U.K. Mr. Bontemps said that Chagossians were treated as second class citizens in Mauritius.[69] Many Chagossians actually feel that Mauritius sold them out for their independence back in the 1960s.[70] Now, Mr. Bontemps feels like history is repeating itself with the U.K. – Mauritius deal.[71]

The Right to Self-Determination

As for the ICJ’s pronouncement in its advisory opinion to garner the “free and genuine expression of the people concerned,” the “people concerned” are unequivocally the Chagossians. Their “free and genuine expression” has not been heard in the territorial dispute between the U.K. and Mauritius. The right to self-determination is deeply embedded in customary international law.[72] Nevertheless, the right has been reinforced several times by numerous international treaties such as the U.N. Charter and the International Covenant on Civil and Political Rights (ICCPR).[73] 

For better or worse, the U.K. has been selective in affording the right to self-determination to the inhabitants of its remaining overseas territories. In 2002, the government of Gibraltar, a British Overseas Territory, held a referendum on a proposal by the U.K. government to share sovereignty over the territory with Spain.[74] The proposal was rejected in a landslide by the inhabitants of Gibraltar.[75] In 2013, the Falkland Islands held a referendum on whether or not they supported the continuation of their status as a British Overseas Territory.[76] Again, in a landslide, the inhabitants of the Falklands voted to remain a British Overseas Territory.[77] On the other hand, the U.K. handed over the sovereignty of Hong Kong to the People’s Republic of China (PRC) in 1997 without holding a referendum on what the people of Hong Kong actually wanted.[78] Today, the PRC has all but eroded civil liberties in Hong Kong.[79]

In essence, two questions must be answered for the Chagossians: Was the Chagos historically part of Mauritius? And do the Chagossians, as indigenous people, have a right to self-determination, independent of any state? On the first question, Mauritius was terra nullius, or “no man’s land”, until European explorers inhabited it. The first recorded visit was made by Arabs in the 10th century but there is no evidence of their inhabitation of the island.[80] The Portuguese visited the island in the 16th century.[81] It was the Dutch who can be said to have first colonized the island in 1638.[82] In fact, the Dutch were the ones who named it Mauritius after Prince Maurice of Nassau, the Prince of Orange.[83] The Dutch inhabited Mauritius until 1710.

France took possession of the island in 1715, renaming it the “Isle de France.”[84] As mentioned, the island that we now know as Mauritius was ceded by France to Great Britain in 1814 under the Treaty of Paris which included the Chagos Archipelago.[85] Mauritius only became an independent state in 1968.[86] As an independent state, it never included the Chagos Archipelago, which it received in compensation from the British as part of the Lancaster Agreement.[87] In other words, Mauritius itself never possessed or exercised sovereignty over the Chagos Archipelago.[88] Thus, it is not accurate to state that Mauritius has a vested right over the Chagos Archipelago.

On the second question, the answer is an unequivocal yes. Chapter 1, Article 1, Part 2 of the U.N. Charter states that “to develop friendly relations among nations based on respect for the principle of equal rights and self-determination of peoples, and to take other appropriate measures to strengthen universal peace.”[89] Both Article 1’s of the ICCPR and the International Covenant on Economic, Social, and Cultural Rights provide that “[a]ll peoples have the right of self-determination.[90] By virtue of that right, they can freely determine their political status and freely pursue their economic, social, and cultural development.”[91]

All three provisions speak about the right to self-determination of “peoples.” Currently, there is no universally recognized definition of “peoples” in international law. This means there is no distinction of what kind of people have the right to self-determination. It doesn’t matter whether it’s indigenous people or stateless people. It means all kinds of people have a right to self-determination without exception and that includes the Chagossians.

Conclusion

In summary, it cannot be said that the Chagos Archipelago has always been a part of Mauritius. However, the Chagossians have a right to self-determination as the indigenous inhabitants of the Chagos Archipelago. Hence, the only way to settle the sovereignty of the Chagos Archipelago is to hold an international referendum involving the Chagossians on the future of their homeland. It is the responsibility of the U.K., Mauritius, and the Seychelles to collaborate together and allow the Chagossians in their populations to determine the status of their homeland.

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Glossary

• Archipelago - an expanse of water with many scattered islands.

• Atoll - a coral island consisting of a reef surrounding a lagoon.

• Baseline – in the context of the law of the sea, it is the line (or curve) along the coast from which the seaward limits of a state's territorial sea and certain other maritime zones of jurisdiction are measured, such as a state's exclusive economic zone.

• Charter of the United Nations – the foundational treaty of the United Nations signed by member states on June 26, 1945. It lays down the purposes, governing structure, and overall purpose of the UN system.

• Customary International Law - refers to international obligations arising from established international practices, as opposed to obligations arising from formal written conventions and treaties.

• Decolonization – the retreat of an occupying power at a given territory and the subsequent independence and formation of a new country within that given territory.

• Disenfranchisement – the state of being deprived of a legal right or privilege, especially the right to vote.

• Exclusive Economic Zone – under the 1982 U.N. Convention on the Law of the Sea, it is an area of the ocean extending up to 200 nautical miles (370 km) immediately offshore from a country’s land coast in which that country retains exclusive rights to the exploration and exploitation of natural resources.

• Genocide – under Article 2 of the 1948 United Nations Convention on the Prevention and Punishment of the Crime of Genocide defines genocide as "any of the following acts committed with intent to destroy, in whole or in part, a national, ethnical, racial or religious group, as such: killing members of the group; causing serious bodily or mental harm to members of the group; deliberately inflicting on the group conditions of life calculated to bring about its physical destruction in whole or in part; imposing measures intended to prevent births within the group; [and] forcibly transferring children of the group to another group."

• Geopolitical – adjective of a study of the influence of such factors as geography, economics, and demography on the politics and especially the foreign policy of a state.

• Grassroots organizations - are groups of people pursuing common interests, largely on a volunteer and not-for-profit basis.

• House of Lords – the upper house of the Parliament of the United Kingdom.

• Indentured - required by contract to work for another for a certain period of time.

• Indigenous - of, relating to, or descended from the earliest known inhabitants of a place and especially of a place.

• International Court of Justice - the primary judicial body of the United Nations.

• Jurisdictional - the power, right, or authority of a court or tribunal to hear a case, and to render a decision over the said case and the parties involved.

• Maritime - connection with human activity at sea.

• Permanent Court of Arbitration – a non-UN governmental organization established by the Convention for the Pacific Settlement for International Disputes in 1899 to facilitate arbitration and other forms of dispute resolution between states.

• Referendum – the principle or practice of submitting to popular vote a measure passed on or proposed by a legislative body or by popular initiative.

• Sovereignty – the power over a population in a given territory that is recognized by other states.

• Stateless people – someone who is not recognized as a citizen by any country.

• Strait - a comparatively narrow passageway connecting two large bodies of water.

• Terra Nullius – a Latin term which translates to “no man’s land” or land belonging to no one. In international law, it refers to the concept of a land or territory with no owner and which can be freely claimed by anyone.

• Treaty – a legally binding agreement between two or more countries.

• United Nations General Assembly - the main policy-making organ of the United Nations.

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Footnotes/Sources

[1] Nitya Labh, Why Diego Garcia Matters, Foreign Policy (May 30, 2024), https://foreignpolicy.com/2024/05/30/diego-garcia-us-uk-chagos-military-base/#:~:text=The%20detachment%20was%20motivated%20by,threat%20during%20the%20Cold%20War.

[2] Alice Cuddy, What I found on the secretive tropical island they don’t want you see, BBC (Sept. 29, 2024), https://www.bbc.com/news/articles/ckdg7jjlx2go

[3] Id.

[4] Peter Trudgill, Chagrin of the Chagossians, The New Eurpoean (Nov. 20, 2024), https://www.theneweuropean.co.uk/chagrin-of-the-chagossians/

[5] Id.

[6] Id.

[7] Briefing The Rights of Chagossians to Self-Determination, Chagossian Voices (Jan. 2023), https://chagossianvoices.org/wp-content/uploads/2023/12/07Jan-2023-Briefing-on-Chagossian-Self-determination.pdf

[8] Mohamed Rehan, Mauritius alleges Maldives attempting control over 99 percent of overlapping area, The edition (Oct. 26, 2022), https://edition.mv/news/26131

[9] “That’s When the Nightmare Started” UK and US Forced Displacement of the Chagossians and Ongoing Colonial Crimes, Human Rights Watch (Jan. 15, 2023)

[10] Christian Nauvel, A Return from Exile in Sight? The Chagossians and Their Struggle, 5 Nw. J. Int'l Hum. Rts. 96 (2007).

http://scholarlycommons.law.northwestern.edu/njihr/vol5/iss1/4

[11] “That’s When the Nightmare Started”, Human Rights Watch (Feb. 15, 2023), https://www.hrw.org/report/2023/02/15/thats-when-nightmare-started/uk-and-us-forced-displacement-chagossians-and

[12] Jack Blackburn, A brief history of the Chagos Islands — and why they still matter, The Times (Oct. 03, 2024), https://www.thetimes.com/uk/politics/article/chagos-islands-map-uk-mauritius-k7cqtc9k8

[13] Mohamed Rehan, Mauritius alleges Maldives attempting control over 99 percent of overlapping area, The edition (Oct. 26, 2022), https://edition.mv/dh_maaenboodhoo/26131

[14] David Vine, “Inexcusable Inhuman Wrongs”: US, UK Must Deliver Long Overdue Justice at Diego Garcia, Just Security (Mar. 23, 2023), https://www.justsecurity.org/85592/inexcusably-inhuman-wrongs-us-uk-must-deliver-long-overdue-justice-at-diego-garcia/

[15] Id.

[16] Id.

[17] David Vine, The Truth About the U.S. Military Base at Diego Garcia, truthdig (June 15, 2015), https://www.truthdig.com/articles/the-truth-about-the-u-s-military-base-at-diego-garcia/

[18] Id.

[19] Id.

[20] Sam Bull, UK To Return Chagos Islands — But Secretive US Base Will Remain, Responsible Statecraft (Oct. 09, 2024), https://responsiblestatecraft.org/us-military-base-diego-garcia/

[21] Supra note 11.

[22] Supra note 11.

[23] Prof James Kerr-Lindsay, Britain’s Chagos Blunder?, YouTube (Oct 11, 2024), https://www.youtube.com/watch?v=nbrJB8V9m1c

[24] Id.

[25] Raisina Debates, Chaos over Chagos: Is the sovereignty dispute coming to an end?, Observer Research Foundation (May 03, 2023), https://www.orfonline.org/expert-speak/chaos-over-chagos-is-the-sovereignty-dispute-coming-to-an-end

[26] Haroon Siddique, Chagos islanders must get full reparations for forced exile, says NGO, The Guardian (Feb. 15, 2023), https://www.theguardian.com/world/2023/feb/15/chagos-islanders-full-reparations-exile-colonial-crime-human-rights-watch-trial

[27] Diego Garcia, Naval History and Heritage Command U.S. Navy Seabee Museum, https://www.history.navy.mil/content/history/museums/seabee/explore/online-reading-room/historic-topics0/diego-garcia.html

[28] Supra note 2.

[29] Vine, David. "The Impoverishment of Displacement: Models for Documenting Human Rights Abuses and

the People of Diego Garcia." Human Rights Brief 13, no. 2 (2006): 21-24, 32.

[30] Supra note 17.

[31] Supra note 17.

[32] Supra note 29.

[33] Supra note 29.

[34] Supra note 29.

[35] Award in the matter of the Chagos Marine Protected Area Arbitration, Permanent Court of Arbitration (Mar. 18, 2015), https://files.pca-cpa.org/pcadocs/MU-UK%2020150318%20Award.pdf

[36] Notice of Arbitration in the Dispute Concerning The ‘Marine Protected Area’ Related to the Chagos Archipelago, 1982 United Nations Convention on the Law of the Sea (Dec. 20, 2010), https://pcacases.com/web/sendAttach/1791

[37] Marine Protected Area, British Indian Ocean Territory, https://www.biot.gov.io/environment/marine-protected-area/

[38] John Vidal, Chagos islands: UK experts to carry out resettlement study, The Guardian (Mar. 13, 2014), https://www.theguardian.com/world/2014/mar/13/chagos-islands-uk-experts-resettlement-study

[39] Supra note 37.

[40] Supra note 37.

[41] Supra note 37.

[42] Chagos legal status sent to international court by UN, BBC (June 22, 2017), https://www.bbc.com/news/uk-40376673

[43] Id.

[44] Stephen Allen, The Chagos Advisory Opinion and the Decolonization of Mauritius, American Society of International Law, Volume: 23 Issue:2 (Apr. 15, 2019), https://www.asil.org/insights/volume/23/issue/2/chagos-advisory-opinion-and-decolonization-mauritius

[45] U.N. Court Tells Britain to End Control of Chagos Islands, Home to U.S. Air Base, The New York Times (Feb. 25, 2019), https://www.nytimes.com/2019/02/25/world/asia/britain-mauritius-chagos-islands.html

[46] Id.

[47] Andrew Harding, UN court rules UK has no sovereignty over Chagos islands, BBC (Jan. 28, 2021), https://www.bbc.com/news/world-africa-55848126

[48] Press Release Dispute Concerning Delimitation of the Maritime Boundary Between Mauritius and Maldives In the Indian Ocean, International Tribunal For The Law Of The Sea, ITLOS/Press 313 (Jan. 28, 2021), https://www.itlos.org/fileadmin/itlos/documents/press_releases_english/PR_313_EN.pdf

[49] Id.

[50] Owen Bowcott, Corbyn condemns May’s defiance of Chagos Islands ruling, The Guardian (May 1, 2019), https://www.theguardian.com/world/2019/may/01/corbyn-condemns-mays-defiance-of-chagos-islands-ruling

[51] Matthew Parris, We’ve lost interest in our dependencies, The Spectator (Nov. 12, 2022), https://www.spectator.co.uk/article/weve-lost-interest-in-our-dependencies/

[52] UK drops plans to hand Chagos Islands back to Mauritius, Modern Diplomacy (Dec 7, 2023), https://moderndiplomacy.eu/2023/12/07/uk-drops-plans-to-hand-chagos-islands-back-to-mauritius/

[53] Alistair Smout, Michael Holden, and Villen Anganan, UK cedes Chagos Island sovereignty to Mauritius, retains Diego Garcia airbase, Reuters (Oct. 3, 2024), https://www.reuters.com/world/britain-agrees-chagos-island-sovereignty-deal-with-mauritius-2024-10-03/

[54] Dan Bloom, UK waits nervously for Trump to back Chagos Islands deal, Politico (Feb. 4, 2025), https://www.politico.eu/article/uk-waits-donald-trump-back-chagos-islands-deal/

[55] Villen Anganan, Mauritius PM queries duration of lease deal for Chagos military base, Reuters (Jan. 18, 2025), https://www.reuters.com/world/mauritius-pm-queries-duration-lease-deal-chagos-military-base-2025-01-18/

[56] David Mercer, Alice Cuddy, and James Landale, UK’s Chagos deal on hold to allow Trump review, BBC (Jan. 15, 2025), https://www.bbc.com/news/articles/cwyp3750y3po

[57] Maia Davies & Rachel Hagan, Chagossians criticize lack of say in UK deal to hand over islands, BBC (Oct. 4, 2024), https://www.bbc.com/news/articles/cy78ejg71exo

[58] David Hughes, Starmer: Chagos deal necessary to give legal certainty for Diego Garcia base, The Independent (Feb. 5, 2025), https://www.the-independent.com/news/uk/keir-starmer-kemi-badenoch-james-cleverly-diego-garcia-mauritius-b2692795.html

[59] Rhiannon James, Chagos Islands deal could dangerously fracture UK and US relationship – Farage, The Independent (Feb. 04, 2025), https://www.independent.co.uk/news/uk/nigel-farage-government-donald-trump-chagos-islands-keir-starmer-b2692135.html

[60] Dominic Penna, Labour MP condemns Chagos deal as ‘worst thing’ party has ever done, The Telegraph (Feb 10, 2025), https://www.telegraph.co.uk/news/2025/02/10/labour-mp-peter-lamb-condemns-chagos-deal-worst-thing/

[61] Britain should not hand the Chagos Islands to Mauritius, The Economist (Oct. 9, 2024), https://www.economist.com/leaders/2024/10/09/britain-should-not-hand-the-chagos-islands-to-mauritius

[62] Id.

[63] Nasheed says UK says UK ceding Chagos to Mauritius unacceptable, Atoll Times (Oct. 4, 2024), https://atolltimes.mv/post/news/10035

[64] Lucinda Adam, Hundreds protest against Chagos Islands deal, BBC (Nov. 13, 2024), https://www.bbc.com/news/articles/crln9np2dz8o

[65] Id.

[66] Id.

[67] Noah Keate, Britain’s handover of the Chagos Islands is pleasing nobody, Politico (Feb. 6, 2025), https://www.politico.eu/article/britain-chagos-islands-uk-handover-keir-starmer-military-base-white-house-africa/

[68] Id.

[69] Id.

[70] Sovereignty, Chagossian Voices, https://chagossianvoices.org/sovereignty/

[71] Supra note 67.

[72] self determination (international law), Legal Information Institute, Cornell Law School.

[73] Id.

[74] Patrick Wintour, Giles Tremlett, Gibraltar votes out joint rule with Spain, The Guardian (Nov. 8, 2002), https://www.theguardian.com/politics/2002/nov/08/uk.gibraltar

[75] Id.

[76] Falklands referendum: Voters choose to remain UK territory, BBC (Mar. 12, 2013), https://www.bbc.com/news/uk-21750909

[77] Id.

[78] No Hong Kong Referendum, The Washington Post (July 18, 1984), https://www.washingtonpost.com/archive/national/1984/07/19/no-hong-kong-referendum/1734f015-6732-40b6-ad40-4eefcba0a07d/

[79] Kanis Leung, Hong Kong’s plan for a new national security law deepens fears over eroding civil liberties, The Associated Press (Feb. 28, 2024), https://apnews.com/article/hong-kong-national-security-law-china-7be1fcea908ddb1b2537ec41f6fd4220

[80] Background Notes: Mauritius, U.S. Department of State Archive Bureau of African Affairs (Dec. 1999), https://1997-2001.state.gov/background_notes/mauritius_9912_bgn.html#:~:text=The%20French%20claimed%20Mauritius%20in,base%20during%20the%20Napoleonic%20wars.

[81] Id.

[82] Id.

[83] Id.

[84] Id.

[85] Supra note 9.

[86] History of Mauritius, mauritiusnow.com, https://mauritiusnow.com/history-of-mauritius/#:~:text=Mauritius%20gains%20independence%20(1968),Minister%20on%2012%20March%201968.

[87] Eliot Wilson, The Chagos Islands agreement: first thoughts, The Ideas Lab Substack (Oct. 05, 2024), https://theideaslab.substack.com/p/the-chagos-islands-agreement-first

[88] Id.

[89] Chapter 1, Article 1, Part 2, U.N. Charter, https://www.un.org/en/about-us/un-charter/full-text

[90] Article 1 of the International Covenant on Civil and Political Rights, https://treaties.un.org/doc/publication/unts/volume%20999/volume-999-i-14668-english.pdf; Article 1 of the International Covenant on Economic, Social, and Cultural Rights, https://treaties.un.org/doc/treaties/1976/01/19760103%2009-57%20pm/ch_iv_03.pdf

[91] Id.