Compensation for loss of livelihood Farmers whose land leases have been terminated and their land plots transferred to agricultural enterprises, such as cotton producing companies (so-called clusters), have not been materially compensated for loss of livelihood, instead receiving usually verbal assurances of full-time employment with cotton producing companies to whom the land plots were transferred. Compensation for agricultural land withdrawn for state or public needs was regulated by Cabinet of Ministers decree no. 911 of 16 November 2019.33 However, this resolution has almost entirely lost its force following its revision in February 2023.34 Furthermore, when so-called “voluntary” land lease terminations have been secured, farmers automatically forego any rights they may have had to compensation. Compensation following a land seizure is also referenced under Cabinet of Ministers resolution no. 97, 29 May 2006.35 According to article 26, paragraph 2 of the resolution: ‘Compensation of losses to landowners, land users, lease holders, and owners of land plots and losses of agricultural and forestry production is carried out in accordance with the land legislation of the Republic of Uzbekistan’, thus deferring the regulation of compensation for farmland to the Land Code. Article 37 of the Land Code, amended on 29 June 2022, relating to the withdrawal of land plots for public needs with compensation, states: ‘Withdrawal of land plots or parts thereof owned by individuals and legal entities respectively on the right of lifetime hereditary possession, permanent possession, permanent use, fixed term (temporary) use or lease for public needs with compensation shall be carried out in an order established by law.’ 18 A False Sense of Legality International human rights law Although there is no general human right to land, there is growing consensus among the international community that such a right should be anchored in international human rights law.36 According to the UN, ‘Land is not a mere commodity, but an essential element for the realization of many human rights’ and is a ‘cross-cutting issue that impacts directly on the enjoyment of a number of human rights’. 37 For many people, land is a source of livelihood, and is central to economic rights. Land is also often linked to peoples’ identities, and so is tied to social and cultural rights. Given the fundamental nature of access to land and land tenure as a prerequisite for the enjoyment of other human rights, the abuse of land rights, including the arbitrary and illegal termination of land leases, may constitute an indirect violation of human rights. In 2012, the Food and Agriculture Organization (FAO) of the UN developed a set of guidelines that ‘set out the principles and internationally accepted standards for practices for the responsible governance of tenure’. The guidelines also include indicators to assess the governance of land tenure, including protections from the ‘arbitrary loss of tenure rights, including through forced evictions’. According to the FAO: ‘The governance of tenure is a crucial element in determining if and how people, communities and others are able to acquire rights, and associated duties, to use and control land, fisheries and forests.’