[Joint Open Letter] Mongolia: Stop Reprisals Against Mongolian Human Rights Defender Sukhgerel Dugersuren
18 August 2022 4:38 pm

We, the undersigned civil society organizations, stand in solidarity with Mongolian human rights defender Sukhgerel Dugersuren and strongly condemn the criminalization and smear campaigns against her, which we identify as an attempt to prevent her from conducting her crucial work in defense of human rights and the environment.

We urge the Mongolian government to ensure Sukhgerel can safely defend human rights without fearing reprisals and that all charges against her are dismissed.

We call on all the international institutions and actors active in the country – including development banks, UN bodies and experts, EU member states and institutions, international embassies, international investors or private companies – to publicly speak out in support of Sukhgerel, use their leverage to strongly condemn reprisals, and take any action they can to ensure Sukhgerel can continue to safely carry out her work.

Who is Sukhgerel Dugersuren?

Sukhgerel Dugersuren is an internationally renowned human rights defender and the Executive Director of the Mongolian organizations Oyu Tolgoi Watch and Rivers without Boundaries Mongolia. She has a long trajectory of exposing human rights abuses and defending the rights of herder and rural communities in Mongolia. Her courageous and inspirational work is admired by scores of international and local civil society organizations, as well as UN Special Rapporteurs and experts, who have closely worked with her.

In the past decades, Sukhgerel has supported dozens of communities negatively affected by large-scale projects, such as mines and hydropower dams. She has helped these communities in denouncing the harmful impacts of these activities and bringing their grievances to the attention of the Mongolian government, development banks, and international organizations. For example, she supported complaints to the independent accountability mechanisms of the World Bank, International Finance Corporation, European Bank for Reconstruction and Development and the Asian Development Bank.

What happened and why is she being criminalized?

According to Front Line Defenders, on 2 August 2022, Mongolia’s General Intelligence Agency informed Sukhgerel that she is under investigation for committing crimes under the Mongolian Criminal Code Article 19.4, which prohibits the “illegal cooperation with foreign intelligence agency, agent.” Although no other details around the investigations have been shared, we fear Sukhgerel might be at risk of imminent arrest and we are deeply concerned for her safety.

Sukhgerel is being subject to a clear criminalisation process, where the law is used to limit civic freedoms and punish human rights defenders. The undersigned human rights organizations consider these accusations false and baseless, as they appear to be related to Sukhgerel’s support to the communities impacted by the Erdeneburen hydropower plant, funded by China’s EXIM Bank, and her legitimate requests for access to environmental information, public participation in environmental decision-making and transparency.

On 3 August 2022, during a government briefing, Mongolia’s Minister of Justice and Internal Affairs, H. Nyambaatar, stated that the construction of the Erdeneburen hydro plant had been suspended for two years, as a result of a letter from the local communities to the Chinese authorities. He also said that when development projects are interrupted by a civil society organization or person, then a task force should be established to investigate these cases as ‘sabotage’ under Criminal Code Article 19.6 and that the government could claim compensation for the lost economic opportunity. This concerning statement was shared just a few days before the visit by China’s Foreign Minister Wang Yi, to Ulan Bator on 7 and 8 August to discuss economic cooperation between the two countries and who specifically mentioned the Erdeneburen hydropower plant in his remarks.

The Mongolian Minister’s statement could be construed as a direct threat of reprisal against human rights defenders like Sukhgerel. It also sends a very chilling message to all individuals and communities peacefully raising concerns or opposing harmful projects, especially in a context where several environmental activists have already been threatened and criminalized.

Sukhgerel is also facing a worrying and orchestrated smear campaign in online media and social media. We are deeply worried about the criminalization and smear campaign against Sukhgerel, which puts her at additional risk and constitutes a threat to all human rights defenders and civil society groups in the country. We fear that as a result of these online actions other human rights defenders, and in particular the communities protesting against the harmful impacts of the Erdeneburen dam or other foreign-funded projects, might also be at risk of being criminalized.

We stand in solidarity with Sukhgerel and other human rights defenders in Mongolia, and we call on all the relevant international institutions and actors that defend international law and human rights to intervene promptly in support of their important and legitimate struggles. Sustainable development is not possible where civil society is repressed and criminalized.


What are we asking?

We call on the government and other relevant authorities in Mongolia to:

  1. Immediately investigate and unconditionally cease all attempts to target and criminalize Sukhgerel Dugersuren, as well as other human rights defenders and individuals expressing their opinion or raising concerns about development projects in the country;
  2. Guarantee in all circumstances that all human rights defenders in Mongolia are able to carry out their human rights activities without fear of reprisals and free of all restrictions, in line with Mongolia’s international human rights obligations and commitments, including its recently approved law on human rights defenders;[1]
  3. ​​​​​​​​​​​​​​​​​​​​​Publicly recognise the importance of freedom of expression, meaningful participation, unimpeded access to information on development projects and environmental impacts, and a safe environment for human rights defenders, to help ensure development projects are truly sustainable for Mongolia.

We call on all the international institutions and actors active in the country – including development banks[2], UN bodies and experts[3], EU member states and institutions[4], international embassies, international investors and private companies – to:

  1. Urge Mongolian authorities to immediately halt and dismiss all the charges against Sukhgerel Dugersuren.
  2. Urge Mongolian authorities to investigate and stop all attempts to target, criminalize and stigmatize individuals expressing concerns or their views about development projects, including Sukhgerel Dugersuren.
  3. Express serious concern about the statements made by Mongolian government officials, who publicly remarked that those opposing the Erdeneburen hydropower plant will be investigated and criminalized, and denounce the smear campaign Sukhgerel Dugersuren is facing.
  4. Publicly recognise the importance of freedom of expression, meaningful participation, unimpeded access to information on development projects and environmental impacts, and the need to ensure a safe and enabling environment for human rights defenders, by publicly stating that communities must be able to defend their right to a healthy environment and that human rights defenders are indispensable allies who should be supported.

[1] On 1st April 2021, the Mongolian parliament adopted a new law for human rights defenders, making it the first country in Asia to provide a framework of protection for people who speak out on human rights concerns and violations. This protection includes ensuring an environment in which human rights defenders are not persecuted for their work.

[2] In their policies, including the environmental and social safeguards, all the main development financial institutions (DFIs) are committed to ensure stakeholders engagement and participation. Some DFIs (including the World Bank, the International Finance Corporation and the European Bank for Reconstruction and Development) have also adopted commitments of zero tolerance for reprisals against those who share their views about DFI-funded projects, while other banks – such as the Asian Infrastructure Investment Bank – have committed to address reprisals. DFIs should also comply with the recommendations of the UN Guiding Principles on Business and Human Rights.

[3] The UN Guiding Principles on business and human rights, based on international law and human rights standards, affirm that States should ensure “that the legitimate and peaceful activities of human rights defenders are not obstructed”.

[4] The 2008 EU Guidelines on Human Rights Defenders state that HRDs are natural and indispensable “allies” in the promotion of human rights and democratization in their countries, and call on member States to take concrete actions to support human rights defenders.



  1. Abibinsroma Foundation – Ghana
  2. Accountability Counsel – United States
  3. AJI/GAPK – Brazil
  4. All African Women’s Group – United Kingdom
  5. ALTSEAN=Burma – Burma
  6. AMATE El Salvador – El Salvador
  7. Amnesty International – Sierra Leone
  8. Andrew Lees Trust – United Kingdom
  9. APIT – Portugal
  10. Arab Watch Coalition – MENA
  11. Asian Forum for Human Rights and Development (FORUM-ASIA) – Thailand
  12. Asociacion Ambiente y Sociedad – Colombia
  13. Association of Ethical Shareholders Germany – Germany
  14. Balkani Wildlife Society – Bulgaria
  15. Bank Information Center – United States
  16. Black Wimen for Wages for Housework – United States
  17. Both ENDS – Netherlands
  18. Building and Wood Workers International – Asia Pacific
  19. Business & Human Rights Resource Centre – Global
  20. Campaign of Campaigns – Mexico
  21. CEE Bankwatch Network – Czech Republic
  22. Center for International Environmental Law (CIEL) – United States
  23. Center for New Environmentally Safe Technologies – Kazakhstan
  24. Centre de Défense des Droits de l’homme et Démocratie – DRC
  25. Centre for Environmental Justice – Sri Lanka
  26. Centre for Financial Accountability – India
  27. Centre for Human Rights and Development – Mongolia
  28. Centro de Documentación en Derechos Humanos “Segundo Montes Mozo S.J.” (CSMM) – Ecuador
  29. Chirapaq/ECMIA – Peru
  30. Christian Aid – UK
  31. CIVICUS: World Alliance for Citizen Participation – South Africa/Global
  32. Coalition for Human Rights in Development – Global
  33. Coalition for Sexual and Bodily Rights in Muslim Societies (CSBR) – Indonesia
  34. Colectivo sobre Financiamiento e Inversiones Chinas Derechos Humanos y Ambiente, CICDHA – Latin America
  35. Community Empowerment and Social Justice Network (CEMSOJ) – Nepal
  36. Community Resource Centre (CRC) – Thailand
  37. Consejo Interreligioso del Perú-Religiones por la Paz – Peru
  38. Constitution Researches Foundation – Azerbaijan
  39. Corner House Research – United Kingdom
  40. DAWN (Development Alternatives with Women for a New Era) – Global
  41. Defenders Protection Initiative – Uganda
  42. Democracy Monitor PU – Azerbaijan
  43. Derecho Ambiente y Recursos Naturales (DAR) – Peru
  44. DiXi Group – Ukraine
  45. EarthRights International – United States
  46. EİTİ NGO Coalition Azerbaijan – Azerbaijan
  47. Empower Foundation – Thailand
  48. Entrepreneurship Development Foundation – Azerbaijan
  49. Environics Trust – India
  50. Environmental Defender Law Center – United States
  51. Equitable Cambodia Cambodia
  52. FIAN Germany – Germany
  53. FIDH (International Federation for Human Rights), within the framework of the Observatory for the Protection of Human Rights Defenders – France
  54. Framer Framed – The Netherlands
  55. Franciscans International – Switzerland
  56. Friends of the Earth Japan – Japan
  57. Friends of the Earth US – United States
  58. Front Line Defenders – Ireland
  59. GegenStroemung INFOE e.V. – Germany
  60. Gender and Environment Network – Mexico
  61. Global Women’s Strike/UK – United Kingdom
  62. Global Women’s Strike/US – United States
  63. Green Advocates International – Liberia
  64. HRM “Bir Duino-Kyrgyzstan” – Kyrgyzstan
  65. Human Development Center “Tree of Life” – Kyrgyz Republic
  66. Inclusive Development International – United States
  67. IndiaMatters – United Kingdom
  68. Indigenous Women Legal Awareness Group (INWOLAG) – Nepal
  69. International Accountability Project (IAP) – Global
  70. International Rivers – USA
  71. International Service for Human Rights – Switzerland
  72. International Women’s Rights Action Watch Asia Pacific (IWRAW Asia Pacific) – Malaysia
  73. isha lisha- Haifa feminist center – Israel
  74. Jamaa Resource Initiatives – Kenya
  75. Jubilee Australia Research Centre – Australia
  76. Karapatan Alliance Philippines – Philippines
  77. Kingston University – United Kingdom
  78. KKA – India
  79. Latindadd – Peru
  80. Law and Society Trust – Sri Lanka
  81. Legal Action for Women – United Kingdom
  82. London Mining Network – United Kingdom
  83. Manushya Foundation – Thailand
  84. Mines, mineral &People – India
  85. MiningWatch Canada – Canada
  86. Network Movement for Justice and Development – Sierra Leone
  87. NGO Center for Support for Economic Initiatives (SEI) – Azerbaijan
  88. NGO Consortium for promotion EITI in Kyrgyzstan – Kyrgyzstan
  89. NGO EcoMangystau – Kazakhstan
  90. NGO Forum on ADB – Asia
  91. No Business With Genocide – United States
  92. Oil Workers’ Rights Protection Organization Public Union – Azerbaijan
  93. OMCT (World Organisation Against Torture), within the framework of the Observatory for the Protection of Human Rights Defenders – Switzerland
  94. Organic Agriculture Association – Albania
  95. Otros Mundos/Chiapas – Mexico
  96. Pakistan Fisherfolk Forum – Pakistan
  97. Peace in Kurdistan – United Kingdom
  98. Persatuan Sahabat Wanita Selangor – Malaysia
  99. Phenix Center for Economic and Informatics Studies – Jordan
  100. PowerShift e.V. – Germany
  101. Protection International – Belgium
  102. Public Service of Ukraine, Poltava branch – Ukraine
  103. ReCommon – Italy
  104. Recourse – The Netherlands
  105. RhodanteA – Belgium
  106. Rural Media Network Pakistan – Pakistan
  107. Scientists for Wild River Landscapes – Germany
  108. Sierra Leone Land Alliance – Sierra Leone
  109. Society for Threatened Peoples – Germany
  110. SOMO (Stichting Onderzoek Multinationale Ondernemingen) – Netherlands
  111. Sosial Strategicall Resorch and Analiticall Invesigation Public Union – Azerbaijan
  112. Steps Without borders NGO – Mongolia
  113. Stiftung Asienhaus – Germany
  114. Studio Jonas Staal – The Netherlands
  115. Sukaar Welfare Organization – Pakistan
  116. Sustentarse – Chile
  117. Swedwatch – Sweden
  118. TKPT – Indonesia
  119. Transparet Governance PU – Azerbaijan
  120. Twerwaneho Listeners Club – Uganda
  121. Universidad Nacional José Faustino Sánchez Carrión – Perú
  122. urgewald – Germany
  123. Witness Radio – Uganda
  124. Women Empowerment Against Poverty of Nepal (WEAPoN) – Nepal
  125. Women in Action on Mining in Asia (WAMA) – Asia
  126. Women of Color/Global Women’s Strike – United States
  127. World Economy, Ecology & Development – WEED – Germany
  128. Zero Tolerance Initiative – Australia