Comparative analysis of state and civil society discourse on the implementation of the United Nations’ convention on the rights of the child in North Africa

ABSTRACT In the face of continuing children’s rights abuses across North Africa, the need for governments to engage non-state actors in human rights implementation is explicit in the United Nations’ convention on the rights of the child (UNCRC). Hitherto, this has largely escaped scholarly attention. It is a lacuna addressed in this paper, which presents a theoretically informed analysis of the role of civil society as a political space for promoting children’s rights in six countries with particular reference to Egyptian and Sudanese policy and practice. Critical discourse analysis of state and civil society submissions to the second-cycle United Nations’ Universal Periodic Review provides insight into UNCRC implementation. The findings show key contrasts in the salience and framing of a range of issues including: violence against children, education, health, forced marriage and discrimination. The wider significance of this is manifold: it offers an original transferable methodology, highlights the formative role of discourse and underlines a pronounced asymmetry in the power of government and civil society. Furthermore, the Egyptian and Sudanese case studies reveal key implementation pathologies applying to authoritarian and (post-)conflict states.


Introduction
Notwithstanding the fact that all countries in the region have ratified the United Nations' convention on the rights of the child (UNCRC), North African states generally have a poor record in upholding human rights for children and young people. 1 Whilst the conditions of children across the region vary between states, overall, recent accounts paint a bleak picture. One noted that, 'countless children suffer from rights violation in the fields of protection, education, survival and development, and health' (Abdul-Hamid 2011, 3). Another observed that, 'across the region, laws relating to children are outdated, and enforcement of children's rights is too often weak or non-existent … Shockingly, governments in some countries are simply unable or unwilling to adequately protect children' (Parker, Patel, and Watson 2015, 3).
Whilst the need for governments to engage non-state actors in human rights implementation is explicit in the UNCRC, it has largely escaped scholarly attention. To address this lacuna, critical discourse analysis is used to compare government and civil society organisations' (CSOs) issue-salience and framing in reports submitted to the second-cycle United Nations' Universal Periodic Review (UPR) 2011-2015. This is of pivotal importance in shaping UNCRC implementation, notably determining which Convention articles are prioritised and how they are addressed. Such a method allows a theoretically informed analysis of the role of civil society as a political space for promoting children's rights. In the following discussion, aggregate analysis across six countries (Algeria, Egypt, Libya, Morocco, Sudan and Tunisia) is presented to provide a snapshot of the regional situation. The problem of 'frame dissonance' between ruling elites and CSOs is then illustrated with reference to two case studies; an authoritarian regime (Egypt) and a (post-)conflict state (Sudan).
Accordingly, the principal research aims are to further understanding of: (1) what issues states and CSOs prioritise in their discourse on UNCRC implementation and (2) In terms of framing, whether states' UPR discourse complementsor contrasts withthat of CSOs. The six states selected for study constitute a purposive sample (Palys 2008) designed to reflect a broad cross section of the history, demographics, politics and law of North Africa as a unit of regional analysis. This follows long-established practice amongst practitioners and academics alike (cf. International Bureau for Children's Rights 2007; Karshenas and Moghadam 2009;Pellicer and Wegner 2009;UNICEF 2011). The current case selection is also founded on the children's rights issues facing these countries. These are extensive and include: structural obstacles, gaps in legislation, limited state capacity and resource issues (see Gerbaka and Almuneef 2014, 160-161); deficiencies in monitoring (UNCRC 2012a, 6); inadequate data collection, limitations in health care, failings in the welfare of disabled children, problems tackling economic and sexual exploitation, and the physical and mental abuse of children (Bouhlila 2011;UNCRC 2011aUNCRC , 2012Zayed and Ali 2012;Gobrial 2012;Sabbe et al. 2013;Ali, Aziem, and Nagla 2014;El-Nawawy and Khamis 2014;Yefet 2015).
Hitherto, studies of human rights in North African have necessarily prioritised aspects of jurisprudence (e.g. Berger 2003;Ibrahim 2012;Nmehielle 2011;Oder 2011). As noted, a key lacuna attaches to contemporary understanding of civil society's role in rights implementation. 'Civil society' here is defined as the associational activities involving non-governmental organisations, charities, pressure groups, community groups, campaigning organisations and social movements (Keane 1988). North Africa presents a propitious research context because of 'the pre-uprising, region-wide growth of civil society' (Hinnebusch 2015, 211). For this reason, it is argued that analysis of CSOs' input to rights implementation is as important as legal analyses because it is the key to knowledge transfer, policy responsiveness and effective practiceas well as a means to uphold government accountability and legitimacy.
Although often overlooked in the academic literature, co-working and engagement with civil society is an obligation placed on states under Articles 4, 42 and 44 of the UNCRC: inter alia, 'cooperation with civil society organizations, including non-governmental organizations [is required] … in the planning and monitoring of the implementation of the Convention and the Optional Protocols' (2015,4). This participatory approach is also evident in the African Charter on the Rights and Welfare of the Child (inter alia: governments must secure 'the meaningful participation of non-governmental organizations, local communities and the beneficiary population in the planning and management of a basic service programme for children ',Article 14).
In response, administrations across the region have espoused civil society engagement. For example: 'civil society … [is] a fundamental actor in a participatory democracy' (Government of Algeria 2012, 16); and our aim is to extend ' … support for national civil society and non-governmental organizations so that they in turn can contribute to the promotion of and protection of human rights in the Sudan' (Government of the Sudan 2011, 22). 2 As Olowu (2013, 27) observes, taken together the combination of human rights instruments and government rhetoric on civil society participation, 'hold the promise of dramatically increasing the capacity of African countries and peoples to work together in critical issues of democratization, human rights , sustainable regional peace and stability. [However …] The challenge remains how to galvanize them' (emphasis added).
To explore these issues, the remainder of this paper is structured thus: following an outline of the research context and related aspects of social theory, the study methodology is described. Attention then moves to the findings. First, with aggregate, regional analysis of UPR submissions; followed by critical analysis of the nature and significance of the dissonance across selected frames with reference to Egypt and Sudan. The concluding discussion summarises the main findings and their implications; including reflection on the pathologies preventing the full realisation of the UNCRC in authoritarian and (post-)conflict contexts.

Research context: children's rights in North Africa
The UNCRC is the cornerstone of children's rights in North Africa. Many of its provisions have subsequently been reaffirmed in the Arab League of Nations 2010 Marrakesh Declaration. 3 Further rights extend from the earlier Arab Charter on Human Rights (circa 2004). 4 In turn, these are complemented by provisions in the constitutions of individual counties. 5 In some cases, the latter are notable for their ambition (e.g. Article 28 of the Libyan Constitution of 2014 -'in all cases, all legislations and policies of the State shall be based on the best interest of the child'). Yet, as Tobin (2005, 86) cogently observes, such 'constitutional recognition of children's rights offers no guarantees with respect to the enjoyment of the rights'. Moreover, as the following analysis reveals, there is deep uncertainty over monitoring and enforcement. In cases such as Egypt, it is authoritarian rule and exclusive governing practices that constitute the biggest threat to effective implementation. In others, problems include: a dearth of monitoring and baseline data, inadequate resources and, limited state capacity. A further key challenge relates to social attitudes. In other words, the disposition of individuals and groups towards the rules, norms and values collectively constituting human rights instruments. These matter because they determine the extent to which the provisions of the UNCRC and other treaties are adopted or resisted (see, for example, Cohrs et al. 2007;Diaz-Veizades et al. 1995). It is a point emphasised by Kaime (2005, 221) who notes, whilst 'the Convention on the Rights of the Child has been almost universally ratified … implementation depends to a large extent on the level of cultural legitimacy accorded to children's rights norms in a society'.
As noted, the conditions facing children vary across the region. For example, female genital cutting is nearly universal in Egypt and Sudan but practically non-existent elsewhere; child marriage is widespread in Sudan, yet rare in Tunisia. In addition, there are specific issues relating to: violence against children in Algeria, 6 in Libya the majority of displaced families are women and children, 7 in Morocco, there has been slow progress in adopting a comprehensive Children's Codecompounded by poor enforcement of existing legislation 8 ; and in Tunisia, enrolment in early childhood education remains lowparticularly for poor families and those living in rural areas. 9 Against this backdrop, the regional assessment offered by United Nations' monitoring bodies is one of widespread rights violations and policy failure. It is a view supported by the testimony of international observers. For example, UNICEF notes that: North Africa continue[s] to be plagued by violence against children: Some 89 per cent of children are subject to physical or psychological punishment, 3.5 million women aged between 20 and 24 were married before they turned 18, and female genital mutilation affects 96 per cent of women in Egypt … and 89 per cent in Sudan. 10 In turn, the malaise is reflected in the region's international human rights rankings. Four of the six countries studied here feature in the bottom third of the 180 + UN-recognised states. Lamentably, Sudan, Libya and Algeria languish in the bottom quintile (IHRRI 2014).
Accordingly, the current analysis of civil society perspectives of UNCRC implementation is timely because, whilst a surface reading would suggest that North African states' accession to various human rights treaties and protocols is evidence of progress (2012b), 11 the following presents a more critical assessment. It points to a 'disconnect' between state discourse and the everyday lives of children and young people. As noted, to explore this further, following aggregate regional analysis, the later frame analysis of the UPR discourse in this article centres on Egypt and Sudan. As the ensuing discussion reveals, these countries were selected to complement the regional perspective.
The case of Egypt illustrates the social and political shifts that have taken place in the region. Thus, almost a quarter of a century ago, it was noted that, a budding civil society has recently begun to manifest heretofore-latent energy, and is now competing with other social forces (most notably a rising wave of Islamic activism) for a share of the public space that the state used to occupy. (Khalifa 1995, 160) Today, whilst the revolutionary turmoil associated with the 'Arab Spring' has had markedly different outcomes across North African states (Erdag  2015;Greffrath and Duvenhage 2014;Hinnebusch 2015), Abdel Fattah el-Sisi's ousting of Mohammed Morsi during the Egyptian uprising of 2013 has meant that state repression again characterises contemporary governance. As Abdelrahman (2012, 262) describes it, the country is presently subject to 'a predictable mix of repression, occasional symbolic concessions and violence'. It is a troubled context in which, 'the military, [is] the effective ruler of the country, [and] the battle to suppress revolutionary demands is not only about maintaining its control of a substantial part of the economy [but also … ] its long-earned privileges' (Abdelrahman 2012, 262). In short, it is a place where, 'state elites are using organized violence to formalize a new narrower ruling coalition and to break their opponents, to proactively restructure Egypt's political arena and reregulate state-societal relationships' (Stacher 2015, 268). The selection of Egypt as a case study therefore affords the opportunity to explore UNCRC implementation in the context of an authoritarian regime, albeit one with 'the minimal concession of occasional and symbolic electoral participation' (Abdelrahman 2012, 263). It is an arena deserving of scholarly attention for, as Stork (2012, 484) observes: the most problematic areas of conflict around what international human rights law requires and what Egypt's emerging rulers will tolerate lie in the domains of speech and belief, freedom of religion, cultural expression, and of course the rights of women in the face of entrenched and even reinvigorated patriarchy. Extant work has highlighted the need for further research on children's rights in (post-)conflict settings (Maslen and Islamshah 2000;Wyness 2016). In order to respond to this rejoinder, Sudan was selected as the second case study. The country has been subject to one of the continent's longest series of modern-era conflicts. The first north-south civil war endured from 1955 to 1971, and the second from 1983 to 2005. Following South Sudan's independence in 2011, a new civil conflict began in December 2013 (Johnson 2013). At the time of writing, a fragile peace treaty (signed in 2015) is on the verge of collapse. Sudan therefore presents a challenging context for UNCRC implementation. This is because governmentality is severely undermined in the (post-)conflict environment owing to a raft of factors including: violence, limited institutional capacity, political infighting and ethnic divisions (Curless and Rodt 2013;Lyman 2013). It is also because, as Naomi Pendle observes, ongoing remedial measures to address this malaise, including 'attempts to strengthen the state, inadvertently interrupt local power relations between groups' (2014,227). In this way, they provoke factional backlashes, thereby fuelling yet further political tension, conflict and instability.

Social theory
Co-working between CSOs and government in UNCRC implementation is supported by social theory on knowledge exchange and democracy. A key example is complementarity theory (Klijn and Skelcher 2007). This emphasises how politicians attempt to cope with complexity by using civil society networks to increase involvement in policy implementation, thereby not only strengthening input legitimacy but also policy efficacy through the pursuit of shared goals. In turn, such co-working is echoed in the deliberative democracy paradigm. This is concerned with the shaping of public policy. As Jean Cohen (1997, 70) explains, 'not simply a form of politics, democracy, on the deliberative view, is a framework of social and institutional conditions that facilitates free discussion among equal citizensby providing favourable conditions for participation, association, and expression'. Lastly, Habermas' Theory of Communicative Action, (1994, 7-8) makes a further, powerful statement that validates the current attention to rights discourse and the deliberative input of civil society. Notably, when he notes that, 'an autonomous basis in civil society, a basis independent of public administration and marketmediated private commerce, is assumed as a precondition for the praxis of civic self-determination'. In sum, the prevailing policy framework and social theory both underline that sole attention to state accounts of UNCRC implementation offers but a partial view. Accordingly, following an outline of the methodology, the remainder of the discussion explores civil society discourse alongside that of state elites.

Methodology
The present attention to policy discourse is apposite because of what is termed 'frame alignment' in the policy literature (Snow et al. 1986). This underlines the way that the probability of successful collaborative policy implementation increases at the point at which the frames of key policy actorssuch as government and civil societyare aligned ('frame resonance'). This has two componentsthe level of attention to individual topics ('issue-salience') and the meanings attached to these references ('framing').
In methodological terms, the present analysis offers a transferable discourse-based approach to studying rights implementation. To this end, the second-cycle UN Universal Periodic Review (UPR) constitutes a rich and unique data set, one that informs understanding of the role of civil society as a political space for resistance to child oppression and realisation of rights. The UPR emerged in the wake of the 2006 UN General Assembly resolution (60/251) (Cochrane and McNeilly 2013). According to its proponents, it is not designed to be an elite or technocratic exercise. Rather, it provides the opportunity for each state to set out the actions they have taken to advance human rights; it also makes provision for civil society input. This matters to understanding and addressing the multiple and inter-connected issues facing children across North Africa. Specifically, the UPR allows for non-governmentalor, civil society organisations (NGO or CSOs) to submit formal written submissions to the Review. The UN policy guidance is unambiguous, 'the UPR should ensure the participation of all relevant stakeholders, including non-governmental organizations' (OHCHR 2011, 7).
Critical discourse analysis is here employed to examine the UPR submissions. This 'is a type of discourse analytical research that primarily studies the way social-power-abuse, dominance, and inequality are enacted, reproduced, and resisted by text and talk in the social and political context' (Vliegenthart, Walgrave, and Meppelink 2001, 352). Its use here is supported by diverse strands of social theory including the literature on social constructivism (Kukla 2000) and the interpretive school of policy analysis (Yanow 1999). These place emphasis on beliefs, values, interpretations and knowledge relevant to addressing a given policy issue (Eden and Ackermann 2004). The epistemological grounding of the present attention to civil society accounts is standpoint theory. Specifically, the notion of 'situated knowledge' (Stoetzler and Yuval-Davis 2002). This argues that the first-hand accounts, in this case from organisations representing children and young people affected by oppression and discrimination in the communities in which they reside, are a valuable complement to administrative studies, case law and institutional analyses.
The discourse analysis was operationalised by examining issue-salience and framing in 110 reports by CSOs submitted to the UPR 2011-2015, as well as states' National Reports submitted over the same period. Examination of issue-salience was done using content analysis (Krippendorff and Bock 2008) or, measuring the frequency of key words, ideas or meanings in the policy documents. A particular type of content analysis derived from electoral studies was used. This divided the texts (electronic copies of the UPR reports) into 'quasi-sentences' (or, 'an argument which is the verbal expression of one political idea or issue ' Volkens 2001, 96). Dividing sentences in this way controlled for long sentences that contained several policy ideas. To do this, electronic copies of UPR submissions were coded and the number of references to each topic ('quasi-sentences') was logged into a database. The topics were derived from the key frames in the UNCRC (e.g. education, health, child labour, legislation, violence/abuse, child marriage, citizenship, equality etc.). The nett effect was to produce a breakdown of the level of attention to (and thus indicator of prioritisation of) given topics amongst competing issues and agendas in political discourse. The underlying rationale for studying issue-salience and framing lies in the literature on political agenda-setting (Cf. Cobb and Howard Ross 1997). As Vliegenthart, Walgrave and Meppelink (2011, 369) explain, 'the basic premise of the agenda-setting approach is that political decision making requires political attentiontaking the form of resources, time, personnel, etc.and that shifts in attention are a precondition for policy change' (emphasis added). Of key importance here is whether political elites are true to their UPR rhetoric and listen to CSOs when deciding which issues should be prioritised in fulfilment of their UNCRC obligations. This is a prerequisite for responsive implementation that listens to the demands of the communities in which the region's children and young people reside.
Aside from the frequency with which topics were referred to in the texts, attention also centred on 'framing' or, the language used by policy actors. Effectively, this is a 'schemata of interpretation' (Goffman 1974, 27). It tells us about the inherent meanings and messages in the textas well as criticality in relation to policy ideas. Thus, as Snow et al. (1986, 470) note, 'by rendering events or occurrences meaningful, frames function to organize experience and guide action, whether individual or collective' (emphasis added) (see also McAdam, McCarthy, and Meyer 1996, 6). In summary, the present paper makes an original contribution by examining human rights implementation as a two-stage process. Specifically, (1) the level of attention that state elites place on particular topics and the way that they frame their discourse and (2) CSOs' response.

State and civil society discourse on human rights treaty implementation
(a) Aggregate analysis of the submissions to the UPR Aggregate, regional comparison of government and CSOs' submissions to the UPR reveals significant differences across policy frames (Table 1). In other words, compared to CSOs, states are placing different emphasis on policy issues in fulfilment of UNCRC obligations. Contrary to the synergies predicted by complementarity theory, this disjuncture applies to all six states in the region. Greatest variance was evident in the case of Sudan. In social theory terms, the data reveal widespread 'frame dissonance'. This is a policy pathology for it suggests conflict in agenda-setting and rights implementation. Furthermore, it points to a state-led approach to human rights policy. Against this regional backdrop, the frame dissonance is explored further in relation to our two case studies.
(b) Critical analysis of state and civil society discourse across selected frames As noted, attention now turns to explore UPR rights framing in state and civil society discourse across selected frames in relation to Egypt and Sudan.
Violence and abuse At a regional level, 'violence and abuse towards children' is the first-ranked frame in the civil society discourse (accounting for just under a quarter of quasi-sentences, 24.2%), compared to a lowly fifth-ranked in the state discourse (6.8%). Notwithstanding governments' obligations under Article 19 of the UNCRC (inter alia, 'States Parties shall … protect the child from all forms of physical or mental violence' etc.), extant studies point to the prevalence of child abuse across the region (cf. Kudrati et al. 2008). It is particularly severe in Egypt where recent analysis suggests that it affects 37.8% of young males and 21.2% of females (Aboul-Hagag and Hamed 2012, 92). It is also a widespread and enduring problem in Sudan. Recent research reveals it is acute in the case of street children, with the overwhelming majority subject to abuse (Belay 2015, 68).
In the case of both Egypt and Sudan, textual analysis of the UPR data reveals key aspects of the disjuncture to lie in state elites' and CSOs' conceptualisation of the issue. The state discourse tends to be generalised, lacking in specifics and overly descriptive of institutional measures. For example: 'the Violence against Women and Children Unit of the Ministry of Justice was established pursuant to a presidential decree in 2005' (Government of the Sudan 2011, 18). In contrast, civil society discourse is highly critical of the perceived failure to translate rhetoric into outcomes. States' inability to uphold the (albeit) limited child abuse laws in the two territories features prominently. For example: 'millions of Egyptian children are subjected to physical and sexual violence, mistreatment, and exploitation … while the security apparatus neglects to provide the necessary protection to prevent such crimes or to criminally prosecute those responsible' (Forum of Egyptian Independent Human Rights Organizations 2011, 4). A further example alludes to a: culture of social stigma and blaming the victims … [Noting] many victims of harassment and sexual assault (especially those who are traditionally vulnerable such as 'street children') have reported that they have been sexually abused by members of the police upon attempts to report incidents involving sexual violence. (Egyptian Initiative for Personal Rights 2011, 6) The current analysis also shows the problem extends beyond poor law enforcement and relates to basic efficacy in public administration and welfare provision. This is particularly evident in the discourse of Sudanese CSOs. For example, training of child protection officer[s] in the south will be highly required … for instance in Magwi County the child protection officer was one [in number] and could not be two [places] at on[c]e. The reality on the ground is that, we have a number of child protection actors but they all lack institutional capacity. (Human Rights Forum in Juba South Sudan 2011, 3) In response, a key trope in the Egyptian and Sudanese CSOs' discourse is the call for increased government support. For example, 'to tackle abuse the state shall allocate a separate budget within the available resources, for the protection of child rights' (Coalition of NGOs for the UPR-Egypt 2011, 7).
Legislation At a regional level, legislation to uphold child rights (UNCRC, Article 3) is the frame commanding greatest attention in state reports. It accounts for just under a third (31%) of all references. Yet, textual analysis shows governments' discourse is dominated by rote-like listing of enactments that, the authorities claim, further children's rights. For example, 'pursuant to Act No. 12 of 1996 as amended by Act No. 126 of 2008, the Government offers fully integrated care to children (social, educational, health, cultural and developmental)' (Government of Egypt 2014, 17). Whilst a surface reading would suggest that this augers well, the current analysis reveals CSOs' excoriating criticism. Inter alia, states' response is viewed as largely instrumental and lacking effectiveness.
The law on child abuse illustrates this. CSOs widely lament that, for example, in Egypt, corporal punishment of children is currently lawful, despite recommendations to prohibit it by the [UN] Committee on the Rights of the Child and other treaty monitoring bodies … we make a specific recommendation that legislation is enacted in Egypt which explicitly prohibits all forms of corporal punishment, without exception, in all settings including the home. (Global Initiative to end corporal punishment all children, Egypt, 2012, 8) A similar malaise affects Sudan. As CSOs complain, 'corporal punishment is lawful in the home in Northern Sudan, where provisions against violence and abuse in the Child Act (2010), the federal Interim Constitution (2005) and other laws are not interpreted as prohibiting all corporal punishment in childrearing' (Global Initiative, Sudan 2011, 3).
A further core stand of the discourse centres on the need for states to ensure consistency between domestic laws and international obligations. For example: the government must 'undertake legislative reforms to implement Sudan's international human rights obligations [there are … ] over 60 laws in need of harmonization with international human rights standards' (Redress Trust and the Sudanese Human Rights Monitor 2010, 8).
The disparity between state and civil society discourse on child rights legislation also needs to be weighed in the context of the repressive nature of the regime that has emerged in Egypt. At first sight its propensity to emphasise rights legislation in the UPR might appear counterintuitive. However, an explanation can be found in earlier work by Hafner-Burton, Tsutsui and Meyer (2008, 116, emphasis added). They note that, regimes that are less constrained by domestic forces are more likely to ratify human rights treaties as symbolic commitment, because these sovereigns are free to entertain high levels of decoupling between policy and practice, while constrained [i.e. democratically accountable] governments are more reluctant to incite domestic (and foreign) oppositions and interest groups.

Education
As a broad international literature attests, education is widely viewed as a key arena for children's rights, one that is covered by Article 28 of the UNCRC. Yet, manifold problems and shortcomings apply to rights promotion in schooling across the region. Egypt is no exception. As Assaad and Caroline (2015, 21) observe, the policy of free education, designed to promote opportunities for children, has led to a distorted system where there is substantial inequality in succeeding in basic education depending on a child's family circumstances … The current system is clearly not meeting its goals of providing equitable and adequate education for children.
At the heart of the problem is a disjuncture in state and civil society policy framing. Much of the government discourse centres on the genuine advances that have been made in extending access to education. For example: 'since 2004, the Sudan has experienced positive developments and genuine progress with respect to the provision of education for all' (Government of the Sudan 2011, 19). In contrast, the CSOs highlight multiple problems. Foremost is the failure to connect education policy with other social welfare measures. For example: in Sudan, poverty has led many families not to be able to provide basic needs for their children and there is no support from the government … Many children end up not continuing their education and joining the work force in their early age. (Human Rights Committee Ghazal State 2011, 4) and the decrease in quality of education disproportionately impacts rural areas and vulnerable households, as reflected in academic achievement … children from poor households constituted only 3-5 per cent of achievers in the preparatory stage, and only 0.5 per cent in the general secondary education stage. (Egyptian Centre for Economic and Social Rights 2011, 6) A further key strand in the discourse is concerned with education's formative role in challenging the oppressive social attitudes that underpin rights abuses in Egypt, Sudan and elsewhere. CSOs repeatedly call on government to embed rights awareness in the school curriculum. For example, to teach human rights at all levels of education … a comprehensive programme carried out in cooperation between National Council for Human Rights, Egyptian government and the civil society for raising awareness of the children in schools, youth centers and libraries. This shall be achieved by using interactive methods in addition to games and arts. (Coalition of NGOs for the UPR-Egypt 2011, 5)

Discrimination
Analysis of the UPR data reveals key contrasts in state and civil society discourse related to tackling discrimination (UNCRC Article 2). In particular, the state discourse is often declaratory in nature. For example, 'education is a right for every citizen and that the State must guarantee access to education, without discrimination as to religion, race, ethnicity, gender or disability' (Government of the Sudan 2011, 18). Furthermore, it is overly descriptive and often content to merely list or describe administrative, legal and/or institutional provisions (e.g. 'the Constitution guarantees equality before the law, equality of rights, freedoms and public responsibilities, and equality of opportunity for all citizens', Government of Egypt 2014, 14). In contrast, the civil society discourse is highly critical of states' deficient policy response.
The foregoing disparity matters. Not least because it highlights governing elites' failure to pay due attention to 'intersectionality'. This term refers to discrimination issues related to children's multiple, simultaneous identities and characteristics (something that is implicit in Article 2 'States Parties shall take all appropriate measures to ensure that the child is protected against all forms of discrimination', see, for example, Taefi 2007, my emphasis). Instead, the UPR data reveal governments' tendency towards a reductive approach, one that treats all children and young people alike. In response, as the following illustrations reveal, civil society discourse is critical of state failure to fight the multiple forms of discrimination facing children and young people across 'protected characteristics' (i.e. on the basis of age and ethnicity, or age and genderand so on).
Gender equality is a key example. As existing research underlines, 'the rights of women in the Arab MENA countries are still being violated. The extent varies from one country to the other, but this problem is real and widespread' (El-Masri 2012, 942). In Egypt and Sudan, it is particularly acute (Johansson-Nogués 2013; Tønnessen 2011). The UPR data underline this. They show CSOs highlighting how gender inequality affects children and young people across multiple policy areas, including compulsory-phase education. For example, in Sudan, 'the girl child has been [of] deprived her right to education and freedom of expression … Many girls still do not attend school because their parents are afraid of them meeting people who might drive them from their traditions' (SABA, SEEMA and SORD 2011, 8). Whilst in Egypt, a leading CSO demanded that the state: ensure all children can enjoy the right to free primary education, without discrimination, by improving the quality of public education. In particular, strengthen efforts, including through the fairer distribution of resources, to reduce disparities in education on the basis of gender. (Egyptian Center for Economic and Social Rights 2014, 3) On disability, extant work underlines how disabled children in Egypt and Sudan often 'fac[e] several challenges to meet their basic needs in society, cope with their disabilities and overcome barriers that prevent them from living a normal life … their rights have been ignored' (Zidan 2012, 766). The problem is particularly acute for children with intellectual disabilities (Gobrial 2012). In sum, the 'major challenge is the lack of access to services … limited financial resources … social stigma, and negative social attitudes' (Hadidi and Al Khateeba 2015, 527). The current analysis offers a civil society perspective on this malaise. Inter alia, it reveals a worrying disjuncture between state and NGO discourse related to UNCRC Article 23 ('a mentally or physically disabled child should enjoy a full and decent life, in conditions which ensure dignity, promote self-reliance and facilitate the child's active participation in the community'). As with a number of preceding frames, the state discourse often overly descriptive, giving significant attention to a straightforward listing the various enactments related to disabled children. For example, 'Articles 80, 81 and 83 guarantee the rights of certain groups in society: children, persons with disabilities' (Government of Egypt 2014, 8). Crucially, it often does little more than express general policy aspirations without detailing the means by which they might be achieved.
In contrast, CSOs' discourse underlines the widespread discrimination facing disabled children. It is highly critical of governments' policy records, pointing to state failings across a range of welfare services and criminal justice. For example, people with disability have opted for education but lack of sufficient support left them far behind, [in consequence … ] children are unable to attend education due to lack of support … [they] have been deprived of their right to [a] basic service like education. (Civil Society Human Rights Forum Juba 2012, 3) The discourse also included powerful accounts of state failure to help disabled children caught up in the recent political turmoil in Egypt and conflict in Sudan. For example, after demonstrations and political clashes [in Cairo and Alexandria] children with physical or mental disabilities also were detained. While in detention, children are denied adequate health care, and the state has failed to establish a strategy for their rehabilitation and reintegration into society. (Forum of Egyptian Independent Human Rights Organizations 2011, 3).
In the case of Sudan, the discourse detailed how, the disabled are neglected and side-lined … some are used as source of money to the families by keeping them on roadsides as beggars and in the evening they are taken home. Some have made camps by roadsides as their permanent homes … No initiative so far has been done to [help] these disabled.
Health UNCRC Article 24 asserts, 'the right of the child to the enjoyment of the highest attainable standard of health and to facilities for the treatment of illness and rehabilitation of health'. However, the present analysis paints a troubling picture. In the face of deep-set problems in both Egypt and Sudan, state discourse is again often largely instrumental, over-generalised and lacking in specifics (e.g. 'children [have a] right to a name, identity documents, free compulsory vaccination, [and] health care', Government of Egypt 2014, 7). Yet, as Boutayeb and Helmert (2011, 5) note, in Egypt, 'health services all show unjustifiable gaps between rural and urban; poor and rich; developed and deprived regions; and illiterate and educated women'. Child malnutrition 'remains a significant problem … but has received little attention from the policy makers' (Akhmat et al. 2014, 667). This is reiterated the UNCRC's assessment of Egypt: 'child mortality remains high in rural areas […] children continue to die from diarrhoea and respiratory diseases; a significant number of children continue to suffer from anaemia; [and …] malnutrition among children under the age of five is increasing' (UNCRC 2011b, para. 62-63).
The present analysis confirms the endurance of policy failure in health. It reveals that only the Sudanese UPR report gives child malnutrition more than a passing reference. Yet, even here, the necessary policy details are lacking. For example, recently, policies that constitute core guidelines for improving the welfare and quality of life of children as well as for protecting their survival and developmental rights are ongoing. Survival and development of children are major objectives of these policies, which aims at reducing moderate to severe malnutrition in children. (Government of the Sudan 2011, 24) In contrast, civil society discourse is caustic in its response. It places particular emphasis on the intersection of child poverty and health, and highlights repeatedly the need for greater state action to address the plight of destitute and homeless children. For example, demanding that the government 'develop a National Street Children Strategy for prevention, withdrawal and reintegration of street children' (Coalition of NGOs for the UPR-Egypt 2011, 6). On malnutrition, it points to state failings in the training of health professionals. For example, in Egypt, 'no comprehensive training on breastfeeding has been put in place … information provided to health professionals on optimal breastfeeding practices remains very insufficient' (International Baby Food Action Network 2014, 2).
Female genital mutilation (FGM) is a further key health issue afflicting both countries (Rasheed, Abd-Ellah, and Yousef 2011). As a Sudanese CSO notes: 'it reinforces the inequality suffered by girls and women and is a violation of universally recognized human rightsincluding the rights to bodily integrity and to the highest attainable standard of physical and mental health' (Izza Peace Foundation 2010, 12). Despite this, as CSOs protest in their UPR submissions, the rescinding of a resolution issued by the Sudanese Council of Ministers in 2009 means that, 'certain types of female genital cutting/mutilation are not criminal offences' (Redress Trust and the Sudanese Human Rights Monitor 2010, 3). The UNICEF (2016b, 40) has also repeated its concern about this lack of legal protection and demanded that 'areas such as criminalizing FGM and child marriage still need to be harmonised with international legal instruments'. Overall, the civil society discourse in the two countries emphasises governments' lack of political will and inadequate resources. In the latter regard, as one NGO noted: 'Egypt continues to spend less on healthcare when compared to similar countries … with only 4.02%

Participation in decision-making
Further evidence of dissonance between state and civil society framing is apparent in the discourse on children and young people's participation in decision-making. This matters for not only does it inform an understanding of the current state of democracy, it also tells us about young people and contemporary notions of citizenship in the region. Reflecting on the contemporary situation in Sudan, Ensor and Reinke (2014, 73) conclude, 'overall, the actions taken to promote the welfare of children … risk reinforcing the denial of their agency. Paradoxically, normative protectionist efforts are restricting children's participation … [leading to] Youth's marginalisation from mainstream economic life, political acknowledgment, and civic responsibility'.
It is in this context that the present analysis shows governments readily evoke the language of UNCRC Article 12 (inter alia: 'when adults are making decisions that affect children, children have the right to say what they think should happen and have their opinions taken into account'). For example, government in Egypt alludes to: 'consultation with a large number of representatives of Egyptian civil society and non-governmental organizations, through meetings held at the National Council for Human Rights, in order to learn their views on the status of human rights' (Government of Egypt 2014, 31). Highlighting the disparity between rhetoric and reality, the civil society discourse offers a markedly different view. CSOs are forthright in their condemnation. For example, alluding to 'severely restricted options for participation and representation in policymaking' (Association for Education Support and Development et al 2014, 7); and noting that 'children in Egypt suffer from many serious problems including … lack of children's participation in decision making' (Alliance of Egyptian NGOs 2012, 5). In Sudan, the CSO discourse emphasises how children's marginalisation and exclusion not only apply to public decision-making but extend to the familial sphere: [parents] are afraid that educated girls will argue with them, and want more control over their lives. Even worse, say the parents, a young girl often does not have a say in whether and whom she will marry. It is the parents, who make the decision. The girl is frequently subordinate to her partner in big family decisions. (Generation in Action and, Green Star Initiatives 2010, 3) Child marriage As Louis Mikhail (2002) notes, child marriage (proscribed under UNCRC Articles 1, 2, 3, 6 and 12) involves economic transactions, lack of freedom, and the violation of a child's right to consent in ways that are often exacerbated by social and economic factors. However, extant studies reveal that it is a widespread practice in both Egypt and Sudan (see Hussein and Manthorpe 2007). In Sudan, Scott et al. (2014, 777) note how: menstruation is often considered the main criteria for marriage by customary courts in South Sudan. [And that …] From a health and human rights standpoint, early marriage leads to numerous negative health and social consequences, including early pregnancy, high burden of infectious diseases, high maternal mortality and low educational attainment.
The current analysis shows a significant difference in state and CSOs' prioritisation of the issue (Table 1). In both Egypt and Sudan, the state UPR discourse alludes to government policy interventions that are unequal to the scale of the task. For example, the Egyptian Government reports that, 'the Ministry of Social Solidarity has organized seminars to educate women about … early marriage … The initiative is directed at people who attend rural development centres for women, women's clubs and women's residential and guidance centres' (Government of Egypt 2015, 26). Yet, as Sabbe et al. (2015) highlight, it is not only the scale of the response that is inadequate, but also the monitoring and enforcement of existing laws. The failings are compounded by the fact that even the latter offer incomplete protection, a problem that has been condemned by the UN Committee on the Rights of the Child: an 'incorrect determination of childhood [i.e. the statutory age of adulthood, sometimes as low as 12 years] throughout much of Sudan has serious implications for the protection of children's rights, particularly in relation to juvenile justice and early marriage ' (2010, 27-28). More recently, the latest UN assessment suggests little, if any, progress. It alludes to the 'significant extent of child marriage, especially in rural areas [of Sudan]'. In particular, it points to legal failings and blames the 'the lack of restrictions on this practice within the 2010 Child Act' (UNICEF 2016a, 36).
The civil society discourse is also clear on the deep-set and pervasive nature of the problem. One NGO noted how, 'the continuing the encouragement of early marriages amount[s] to a violation of Sudan's obligations with respect of the CRC' (Christian Solidarity Worldwide 2011, 2). Another described how, 'the early marriage phenomenon [in Egypt] widely prevail[s], and has reached more than 1 million girls … Consequently, the deaths among the girls under the age of 18 [has] increased in Upper Egypt due to early pregnancy and childbirth' (Egyptian Association for Community Participation Enhancement 2012, 4). The principal policy demand from CSOs is a tightening of existing laws. For example, 'we call upon the State Party [Egypt] to increase the minimum age of marriage for both genders … and criminalise early marriages for females below 18 years of age' (Feminist and Women's Groups in Egypt 2012, 1). The civil society discourse also alludes to the economic drivers underpinning early marriage. For example, 'in Egypt, girls under 18 are often forced into prostitution and early marriage for financial profit' (Forum of Egyptian Independent Human Rights Organizations 2011, 3). In addition, CSOs highlight the need for a flexible policy response to address geographical variations in child marriage, one that is linked to changing social attitudes and local traditions. For example, 'violations of these rights [of consent] particularly among the cattle owner[s] in the south … early and force[d] marriage in some part of South Sudan is rampart and still continuous to deprives women right to free choice of their spouse' (Civil Society Human Rights Forum Juba 2012, 3). The CSO discourse also underlines the scale of the policy challenge. In particular, noting how the practice is often ingrained in traditional culture: 'girl compensation is a cultural norm in Sudan. Many of the girls compensated to other families committed suicide due to rights violation in their new families' (Generation in Action, and Green Star Initiatives 2010, 4).

Child labour
Child labour is a further key rights concern (UNCRC, Article 32), one that intersects with range of other rights issues (Assaad, Deborah, and Nadia 2010, 79). As in the wider region, it is a pervasive problem in both Egypt and Sudan. As Berenger and Audrey (2016, 23) observe, 'in Sudan, poverty has also been identified as a main driver of the prevalence of girls' labour'. This is also confirmed by Egyptian labour market research. This also highlights how levels of child labour are linked to economic prosperity and adult earnings, with child labour highest amongst offspring of illiterate parents (Wahba 2005). Its complex causes mean that it demands a sophisticated policy response. Something the present analysis of states' UPR discourse suggests is lacking. For example: 'to combat child labour the Government has set up centres for working children. These function through a social association which provides developmental care in order to limit the negative effects of child labour' (Government of Egypt 2015, 22). In response, CSOs are highly critical of existing policy and practice, as well as the fact that institutional measures are not equal to the scale of the challenge. For example, one alluded to 'unofficial estimates that put the number of child workers in Egypt at 2.7 million' (Forum of Egyptian Independent Human Rights Organizations 2011, 10). Others highlight the necessity of a 'step-change in resources and political will to tackle widespread economic and social exploitation' (Egyptian Centre for Economic and Social Rights 2012, 2).

Child soldiers
As recent work by Carano and Bailey (2012, 253) highlights, 'the forceful induction of children as child soldiers is an abhorrent violation of human rights'; one that is proscribed under UNCRC Article 38. However, existing analysis suggests that 15,000-16,000 children have been involved in the conflict in South Sudan (Anon 2016, 20836). This has terrible consequences for the children themselves, their families and society as a whole (Ryan 2012). In an attempt to address the problem, the Government of Sudan has adopted a number of legal measures such as ratifying the CRC Optional Protocol on the Involvement of Children in Armed Conflict, and passing the Defense Forces Law 2010 (Amendment 2013), and National Service Law (Amendment 2013). All prohibit recruitment of children under 18 years. Notwithstanding this, the latest report by the UN notes the continuing practice of 'children being abducted for use by armed forces' (UNICEF 2016a, 82). Indeed, amongst the armed parties listed by the UN are the Sudan government security forces themselves. In addition to abduction, contemporary analysis shows poverty driving children to join the combatants: 'it is very disturbing that while many children are forcibly recruited into armed conflicts, others actually volunteer, due to their nightmarish alternatives' (Carano and Bailey 2012, 253).
Against this backdrop, the current analysis highlights a critical disjuncture between state and civil society discourse in the post-conflict context of Sudan. Whilst the government alludes to 'a disarmament, demobilization and reintegration plan [that has …] demobilized and reintegrated large numbers of child soldiers from the Darfur' (Government of the Sudan 2011, 42), CSOs' UPR submissions point to a raft of issues and shortcomings. These include the inadequacy of government resources directed at the problem and poor monitoring procedures. For example, emphasis should be made by all warring parties in different locations of Sudan to abandon and combat military conscription of children or abusing children by using them as child soldiers. DDR Commission in both South and North Sudan should be strengthened to help achieve these noble goals. (Iza Peace Foundation 2010, 4)

Discussion
Complementarity theory underlines how political elites attempt to cope with complexity by using civil society networks to increase involvement in policy implementation, thereby not only strengthening input legitimacy but also policy effectiveness through greater criticality, use of 'situated knowledge' and the pursuit of shared objectives. Such thinking underpins the participatory clauses in the UNCRC. However, notwithstanding governments' espousal of civil society engagement across the six North African states, the present analysis paints a different picture. It reveals a significant disjuncture between government and CSOs' discourse. This is in stark contrast to the notion of complementarity which asserts: 'governance networks when predicated on the basis of deliberative and other democratic practices … engender both a democratic ethos and consensual decision-outcomes that transcend and accommodate partial preferences' (Klijn and Skelcher 2007, 16, my emphasis).
Instead, the current data show that government is prioritising aspects of policy and framing issues of children's rights in ways that contrast with the discourse of CSOs. Moreover, textual analysis shows states' reports often to be over-generalised, declaratory and lacking necessary detail on developing measures to uphold key aspects of the UNCRC. In short, rather than the sought-after participatory model of human rights implementation that might be anticipated from governments' rhetoric, the current study data show that a state-centric, bureaucratic model characterises practice in the region. This is principally founded on government policy elites pressing ahead with their own priorities, as opposed to joint authorship of policy founded on broad-based civil society input.
The frame analysis provides particular insight into the ill-effects of child rights implementation in authoritarian (Egypt) and (post-)conflict (Sudan) contexts. Specifically, textual analysis of the UPR data (as set out in Section 5b above) reveals the factors, or pathologies, that arrest progress in the implementation of the UNCRC, namely: jurisprudence, education, faith, freedom of expression, and governance and political instability ( Table 2). The wider significance of this to contemporary analysis of child rights is in underlining the need for greater cognisance of the role of civil society linked to political context. Specifically, from a conceptual perspective, work in this area needs to draw upon two strands of theory: 'authoritarian resilience' (Nathan 2003) and 'transitology' (O'Donnell, Schmitter, and Whitehead 1990). The former underlines how the authoritarian regimes may endure through ruling elites' suppression of discontent and their capacity to adapt. Whilst transitology is concerned with how the rise of organised civil society contention may boost state-building in post-conflict societies, as well as undermine repressive practices in authoritarian contexts, thereby transforming the observance of human rights.
The current analysis resonates with both strands of thinking. On the one hand, there is limited evidence of transitology. The most obvious example is the fact that both Egypt and Sudan have finally ratified the UNCRC and taken faltering steps to embed some aspects of the Convention in domestic practices and legal codes. Crucially, however, the present analysis provides far more evidence of the endurance of implementation failure in relation to the UNCRC. In the case of Egypt, this takes the form of authoritarian resilience. It manifests itself in constraints on CSOs' freedom of expression and the regimes' rhetoric. The latter gives the appearance of rights-based action, yet suppresses opposition and any challenge to the political elite's dominant position. In the case of Sudan, political insecurity associated with conflict has undermined the capacity of state institutions to deliver its commitments under the UNCRC.
In social theory terms, this disjuncture in the way states and CSOs frame their UPR discourse resonates with the notion of 'performativity' and the tension between legitimacy and legitimation. 'Performativity' here is the 'reiteration of a norm or set of norms, and to the extent that it acquires an act-like status in the present, it conceals or dissimulates the conventions of which it is a repetition' (Price and Shildrick 1999, 241). In other words, through their submissions to the UPR, the two case-study North African states appear to embrace civil society engagement and the promotion of child rights in a  (ISHR 2014, 2); ' … websites have been regularly banned. In July 2008, authorities banned "YouTube" for containing video clips revealing the beating and torture inflicted upon children under the framework of detentions of some rebel groups' (Cairo Institute for Human Rights Studies 2012, 7) Education 'military involvement in education and juvenile recruitment: following the 25th January revolution all schools are required to add to the curriculum a subject of which the title has been translated as "Militarist Upbringing"' (IFOR 2014, 2); 'The decrease in quality of education disproportionately impacts rural areas and vulnerable households, as reflected in academic achievement' (Egyptian Center for Economic and Social Rights 2012, 4); 'Many children end up not continuing their education and joining the work force in their early age' (NGO Human Rights Committee, Western Bahr el Ghazal State 2012, 4) Faith and freedom of expression 'ambiguity undermines the very principle of religious freedom and also reflected an increasingly prosecutorial attitude towards minorities for blasphemy and other faith-related issues, such as the arrest of two Coptic children in October 2012 for alleged contempt of religion' (Minority Rights Group International 2012, 7) Governance/political instability 'Article 32 (5) commits the state to protect the right of children however the implementation mechanism to enforce those laws are lacking. Poverty has led many families not to be able to provide basic needs for their children and there is no support from the government' (NGO Human Rights Committee, Western Bahr el Ghazal State 2012, 3) way that advances political legitimacyor, the 'public basis of justification and appeals to free public reason, and hence to all citizens viewed as reasonable and rational' (Rawls 2003, 79). Whereas, in contrast, the present critical analysis of CSO data shows this is often 'legitimation'. This term refers to 'communicative actions aimed at managing the public's perception that government actions are effective in promoting their desired ends, whether that is in fact true' (Moore 2001, 712). All of this presents a key challenge to CSOs concerned with advancing child rights across the region. Against this backdrop, the wider significance of this study can be summarised thus: (1) it offers an original transferable methodology, (2) highlights the formative role of discourse; (3) underlines a pronounced asymmetry in the power of government and civil society; (4) reveals a disjuncture in civil society and state framing of child rights implementation and (5) as the analysis of Egypt and Sudan reveals, it shows how specific pathologies prevent the full realisation of the UNCRC in authoritarian and post-conflict contexts. In consequence, notwithstanding the specificities of each North African state, this suggests CSOs in the region need to adapt their action repertoires (or means by which they challenge political elites) in order secure greater progress in the realisation of children's rights ahead of the upcoming third cycle UPR. Notes 8. https://www.gov.uk/government/uploads/system/uploads/attachment_data/ file/415910/AHRR_2014_Final_to_TSO.pdf, p. 98. 9. http://www.ohchr.org/EN/countries/MENARegion/Pages/TNIndex.aspx. 10. Accessed January 4, 2016. http://www.unicef.org/media/media_57288.html. 11. For example: 'The Committee notes as positive the legal reforms undertaken to harmonize the legislation with the provisions of the Convention' (UNCRC 2012, p. 3, para. 11).