a man (see Status of women's testimony in Islam). Such countries include: Algeria (in criminal cases), Bahrain (in Sharia courts), Egypt (in family courts), Iran (in most cases), Iraq (in some cases), Jordan (in Sharia courts), Kuwait (in family courts), Libya (in some cases), Morocco (in family cases), Palestine (in cases related to marriage, divorce and child custody), Qatar (in family law matters), Syria (in Sharia courts), United Arab Emirates (in some civil matters), Yemen (not allowed to testify at all in cases of adultery and retribution), and Saudi Arabia. Such laws have been criticized by Human Rights Watch and Equality Now as being discriminatory towards women. The criminal justice system in many common law countries has also been accused of discriminating against women. Provocation is, in many common law countries, a partial defense to murder, which converts what would have been murder into manslaughter. It is meant to be applied when a person kills in the "heat of passion" upon being "provoked" by the behavior of the victim. This defense has been criticized as being gendered, favoring men, because of it being used disproportionately in cases of adultery, and other domestic disputes when women are killed by their partners. As a result of the defense exhibiting a strong gender bias, and being a form of legitimization of male violence against women and minimization of the harm caused by violence against women, it has been abolished or restricted in several jurisdictions. The traditional leniency towards crimes of passion in Latin American countries has been deemed to have its origin in the view that women are property. In 2002, Widney Brown, advocacy director for Human Rights Watch, stated that, "[S]o-called crimes of passion have a similar dynamic [to honor killings] in that the women are killed by male family members and the crimes are perceived as excusable or understandable." The Office of the United Nations High Commissioner for Human Rights (OHCHR) has called for "the elimination of discriminatory provisions in the legislation, including mitigating factors for 'crimes of passion." In the United States, some studies have shown that for identical crimes, men are given harsher sentences than women. Controlling for arrest offense, criminal history, and other pre-charge variables, sentences are over 60% heavier for men. Women are more likely to avoid charges entirely, and to avoid imprisonment if convicted. The gender disparity varies according to the nature of the case. For