Research article

‘Inhabiting the paradox’: between punitive and pedagogical rationales in prison

Author
  • Nadia P Gutiérrez Gallardo orcid logo (Arizona State University, AZ, USA)

Abstract

This article explores tensions and possibilities of education in punitive confinement contexts through social pedagogy, drawing on fieldwork conducted with incarcerated women enrolled in a university programme in Mexico. Beyond transformation narratives, the study conceptualises prison education as a paradoxical space, shaped by institutional control and re-signified by students as a site of resistance. Through qualitative research, it analyses how women construct identities in the face of carceral logics that infantilise and stigmatise students, conditioning their education. By framing education in punitive confinement contexts as a fugitive pedagogical practice situated against confinement, the article highlights how educational experiences open cracks in the punitive order where rights are reclaimed, subjectivities are reconfigured and ‘education as anti-fate’ emerges. This article argues that liberatory education in prison entails inhabiting a paradox: it requires navigating the contradictions between pedagogy and punishment, and sustaining practices that defy institutional erasure while affirming dignity, autonomy and the right to imagine. In this liminal terrain, social pedagogy becomes a political and ethical commitment to resist the normalisation of confinement and cultivate spaces where justice is not deferred but enacted.

Keywords: prison, education, social pedagogy, higher education, incarcerated women

How to Cite: Gutiérrez Gallardo, N. P. (2026) ‘“Inhabiting the paradox”: between punitive and pedagogical rationales in prison’. International Journal of Social Pedagogy, 15 (1), 7. DOI: https://doi.org/10.14324/111.444.ijsp.2026.v15.x.007.

Rights: 2026, Nadia P. Gutiérrez Gallardo.

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Published on
31 Mar 2026
Peer Reviewed

Introduction

My experience as a prison educator began in 2017. My approach is grounded in Freirean pedagogy and the political dimension of education in punitive confinement contexts (EPCC),1 which aims to create spaces where students and instructors can reframe their position within society. This process involves sociological imaginaries, conceptual frameworks that enable individuals to situate themselves within broader social, historical and structural contexts, opening possibilities for reimagining reality and dismantling fatalism. Education in prison (EIP) is not only a teaching-learning process but a fundamental right that reclaims dignity (Scarfó, 2018).

However, as the years went by, I realised that punitive rationality in the prison system resists any educational praxis that attempts to escape its rationale of domination. I recall discussing daily life in prison with students back in 2019. One of the discussion prompts addressed governmentality in prison. This question caused silence and tension that left my teaching partner and I unsettled. Its impact was such that the prison’s assistant director asked us about it, as several students had reported feeling uncomfortable and unsure about continuing the course. We realised we needed to pay attention to topics perceived as ‘dangerous’ for their potential to disrupt order (Gutiérrez and Santoyo, 2023). I learned that, once we leave the prison, much of what happens inside is beyond our control, yet our actions might still be used to justify disciplinary measures, even if we do not agree with them. I understood that being a teacher in prison means sustaining practices that resist structural violence while striving to build a horizon of dignity, humanisation and liberation through socio-educational engagement.

Therefore, my understanding of EPCC has become more nuanced. It no longer centres solely on ‘transformation’, as this notion – while powerful – can also be problematic. In carceral contexts, speaking of education as transformative may unintentionally imply an overwhelming expectation: is it truly possible to modify structural violence, the systemic logic of prison or the punitive logic? Such discourse might reproduce medical-psychiatric-curative narratives that pathologise incarcerated individuals by constructing them as ‘abnormal’ subjects in need of correction (Foucault, 1995).

Education in prison may generate change at individual, institutional and structural levels. Yet we must ask whether the goal is to ‘transform’ intersectional oppressions or to abolish them. One of EPCC’s contributions lies in distinguishing transformation from other forms of resistance: rejecting violence, affirming ungovernable modes of existence and creating spaces to imagine more inclusive and just futures. It is about sustaining practices that interrupt what is given, resist what is oppressive and foster possibilities – practices that, if only for a moment, offer liberation from the violence, oppression and pain of confinement.

This pedagogical practice, however, clashes with the punitive logic of the institution (Herrera and Frejtman, 2010), creating challenges for educators and students. How are identities constructed within a space structured to erase them? What tensions emerge between the punitive logic and a socio-educational one? How can social pedagogy develop practices that challenge control and disciplinary frameworks while recognising incarcerated women as students?

This analysis extends beyond the subjective level to examine how the institution’s conception of education as ‘social reintegration’ (Gaete and Acuña, 2022) affects students’ access to the university space, putting at risk their right to education. In this context, studying was seen as resistance – a way for women to assert their rights and identity, challenge carceral logic and create spaces of symbolic ‘escape’. Moreover, knowledge empowered them to demand rights and reaffirm their identity as students.

The analysis of education in punitive confinement must be situated within the broader penitentiary context of Mexico. According to the National Survey of Imprisoned Population (ENPOL) conducted by the Instituto Nacional de Estadística y Geografía (INEGI, 2021),2 there are approximately 220,500 people incarcerated nationwide, of whom 94.3 per cent are men and 5.7 per cent are women. The largest populations are concentrated in the State of Mexico (34,100), Mexico City (26,500) and Jalisco (13,400). Most incarcerated individuals are between 30 and 39 years old (36.1 per cent). Although 69.1 per cent have completed basic education, only 22 per cent are enrolled in educational programmes. In contrast, 77 per cent of those not enrolled cite barriers such as lack of time, documentation or educational offerings – factors reported most frequently by women. Nationally, the prison infrastructure comprises 325 penitentiary centres (14 federal, 261 state and 50 for adolescents) with a total capacity of 230,168 spaces, revealing a system under constant pressure and structural crisis. These data highlight the intersection between social inequality, gender and educational exclusion that defines the Mexican carceral landscape, underscoring the need to analyse education in prison not only as a pedagogical endeavour but as a sociopolitical practice within a context marked by carceral expansion, institutional precariousness and educational inequity.

The article is organised into five sections. First, I offer an overview of research that has contributed to defining EPCC, and I highlight its impact on students, including their ability to defend themselves against injustice. This section also explores EPCC and social pedagogy. The second section presents the conceptual framework needed to understand punitive and liberatory logics. The third section outlines the methodological approach, while the fourth section focuses on students’ experiences. The last section presents conclusions and reflections on the liberatory possibilities of EPCC.

Literature review

EPCC has gained relevance recently, particularly in Latin America, where educational initiatives are being framed as tools for rehabilitation and acts of resistance. At its core, EPCC grapples with the complex intersections of pedagogy, punishment, and justice. Within Latin America, Argentina stands as the leading country in the development of critical and socio-pedagogical research on education in punitive confinement contexts. Since the early 2000s, scholars such as Berenstein (2021), Bustelo (2020), Manchado (2012, 2023, 2024), Pérez (2022), Scarfó (2011), Suárez and Frejtman (2012), Tejerina (2016), Ojeda (2013) and Umpierrez and Sosa (2023) have consolidated a robust field of enquiry grounded in popular education and critical pedagogy, framing education in prison as a space of encounter, collective reflection and resistance. These contributions have influenced studies across Uruguay, Chile, and Brazil, which explore how educational practices can foster dignity and humanisation within carceral institutions (Baraldo et al., 2016; Gaete and Acuña, 2022; Marrero, 2020).

In Mexico, research on higher education in prisons remains scarce and fragmented, often limited to local initiatives or institutional reports (Fregoso and Rojas, 2021). One of the few comprehensive studies, Meanings, Beliefs, Perceptions, and Expectations of University Students in Confinement by Díaz and Ariosto (2010), shows that education allows incarcerated students to ‘be something else’, shifting symbolically from prisoner to student. Yet, as Díaz and Ariosto note, this transformation does not replace one identity with another but entails navigating a ‘double condition’ of both prisoner and student. Building on this, Ariosto (2014) highlights higher education as a transformative and identity-constructive practice continually threatened by prison dynamics. In Mexico, the main programmes operate under the auspices of the Universidad Autónoma de la Ciudad de México (UACM) and the Universidad Autónoma de Baja California (UABC). The former, known as PESCER, has faced persistent political conflicts that have limited critical knowledge production about its pedagogical and social impacts.

This fragmented landscape underscores the need to expand research on education in punitive confinement across Mexico and Latin America, connecting emerging initiatives with the theoretical and methodological contributions developed in the Southern Cone to build a more comprehensive and comparative regional field. Within this broader effort, scholars worldwide have offered valuable insights into how carceral education operates as both a site of resistance and a mechanism of control. They have explored how carceral education can offer dignity, hope, and identity reconstruction, yet these possibilities unfold within institutions founded on control, exclusion, and violence. This literature review examines the field through its tensions. Drawing on critical and social pedagogies, particularly in Latin America and Europe, it identifies three core tensions: education as liberation versus education as control; individual transformation versus structural oppression; and inclusion versus exclusion.

Education as liberation versus education as control

EIP is often framed as a transformative force capable of restoring dignity, nurturing critical thought and enabling prisoners to reclaim their voices. From this perspective, education becomes a way to resist institutional violence and the dehumanising logic of confinement. Studies grounded in social pedagogy echo this promise, highlighting educational institutions as agents of transformation that challenge narratives of punishment and ‘reintegration’, while providing tools for autonomy and the exercise of rights (Behan, 2021; Costelloe, 2014; Lucas, 2020; Manchado, 2023; Marrero, 2020; Parchuc, 2019; Rubin, 2023; Umpierrez and Sosa, 2023). These contributions insist that EIP should become a means for (des)subjectivation and social transformation.

This potential contradicts the prison’s function as a space of discipline and control. This constitutes one of the central tensions of EPCC: education offers liberation, but it can be instrumentalised by institutions. This is illustrated through the contrast between ‘simulation pedagogy’, a model that replicates institutional power under the guise of inclusion, and a ‘pedagogy of encounter’ that cultivates relational, subjectivating and dignifying practices (Suárez and Frejtman, 2012). Drawing from educational experiences in Buenos Aires, this distinction reveals how seemingly emancipatory spaces may reproduce carceral logics, infantilise students and reinforce hierarchies. In response, pedagogies grounded in dialogue and mutual recognition propose that knowledge be co-constructed rather than transmitted, and where speech becomes a form of resistance to silence and dehumanisation (Suárez and Frejtman, 2012).

The idea of pedagogical territories offers a powerful lens for understanding how educational spaces can be carved out in, against and despite confinement (Bustelo, 2020). Emerging through collective narration and shared reflection, these spaces create openings for symbolic repositioning and critical agency Yet their autonomy remains fragile. Embedded within institutions that regulate space, time and access, these territories risk being reabsorbed by the structures they seek to contest (Bustelo, 2020). This tension extends beyond prison walls. Universities and other institutions involved in EIP are not exempt from the contradictions of carceral logics. Rather than standing outside systems of inequality and punishment, they are entangled in them. Higher education programmes must interrogate their own complicity in exclusionary practices even when promoting inclusion and reintegration (Manchado, 2024).

In some cases, the university legitimises the prison, presenting education as benevolence. When universities align with prison administrations or depoliticise the curriculum, they risk becoming instruments of soft control, extending the reach of carceral power under the guise of pedagogy (Manchado, 2024). Yet there are counterexamples that demonstrate the potential for radical engagement. Both the Centro Universitario Devoto (CUD) in Argentina and the Punta de Rieles prison in Uruguay exemplify how EIP can become a vehicle for dignity, autonomy and collective transformation. At CUD, housed in the Devoto prison and affiliated with the University of Buenos Aires, academic engagement is intertwined with political organisation, enabling students to resist punitive logics, reclaim their voices and build advocacy networks (Bustelo, 2020; Ceballos, 2022; Colombero, 2020; Hennig, 2023). Similarly, Punta de Rieles reimagines incarceration through a self-managed, community-orientated model where education is a right, embedded in a project of collective governance and humanisation (Baraldo et al., 2016).

These initiatives resonate with the ideas of Makarenko (1951), who, in his work with juvenile offenders in the Soviet Union, argued that EIP must be rooted in collective responsibility, meaningful work and the belief in people’s capacity for transformation. Rather than treating prisoners as passive recipients of discipline, Makarenko envisioned them as co-constructors of their development and a more just social order. CUD and Punta de Rieles embody practices that disrupt punitive norms and foreground education as subjectivation, solidarity and reparation. Yet, their radical possibilities remain precarious, contingent on political will, institutional autonomy and sustained structural support, without which their emancipatory promise risks being absorbed by the systems they seek to subvert.

Individual transformation versus structural oppression

Social pedagogy invites us to shift focus from individual outcomes to structural critique. Although many studies celebrate the role of EIP in identity reconfiguration and emotional healing, this occurs within institutions marked by exclusion and violence. International research shows that education can help incarcerated individuals construct ‘student identities’ that contrast with the stigmatised ‘prisoner identity’, allowing them to imagine alternative life paths (Berenstein, 2021; Carrigan and Maunsell, 2014; Duguid and Pawson, 1998). At the same time, educational progress is constrained by a punitive infrastructure that reinforces hierarchies and pathologises prisoners. Spaces that allow access to speech and narrative can play a critical role in helping prisoners reconstruct their life stories not as objects of penal control, but as active agents (Berenstein, 2021). Through practices such as narrative workshops, re-signification is encouraged, transforming not only students’ self-understanding but also their relation to confinement and broader structures social exclusion (Bustelo, 2020).

The connection between social pedagogy and EIP remains underexplored in current literature, with only incipient attempts to establish this link (F. T. Añaños, personal communication, 6 March 2025). The most explicit efforts come from Spain, where scholars advocate for an approach that redefines EIP as a fundamental right oriented towards human development, autonomy and reintegration (Del Pozo Serrano et al., 2013; García-Vita and Melendro Estefanía, 2013; Nicolás López et al., 2024). These initiatives position socio-educational intervention as an alternative to strengthen democratic values and dignity (Burgos-Jiménez et al., 2023; Del Pozo Serrano and Añaños-Bedriñana, 2013).

However, this pedagogical promise is constrained by structural tensions. Social pedagogical practices in prison remain entangled in ‘resocialisation’ discourses that risk subordinating education to correctional goals. Recent studies highlight how prison-based socio-pedagogical practices are mediated by welfare-oriented frameworks and control strategies, thereby limiting their emancipatory potential. In Latin America, even when not explicitly framed as social pedagogy, practices in prisons can be interpreted as part of this field, emphasising their relevance to struggles for autonomy and humanisation. Understanding EPCC as a distinct field within social pedagogy (F. T. Añaños, personal communication, 6 March 2025) reframes these practices not as isolated or remedial, but as part of a larger project of social transformation.

The structural violence of the prison system limits educational transformation. Students often inhabit a ‘dual condition’, where their identities are overshadowed by their role as prisoners (Ariosto, 2014). Within carceral logics, academic achievement is conditioned by systems of reward and punishment, valued more as evidence of compliance than as the exercise of a right. These contradictions become stark in the experiences of incarcerated women, who navigate layers of exclusion: patriarchal expectations, criminalisation and educational marginalisation (Giacomello, 2013). In such contexts, claiming a student identity becomes liberating, a transgressive act that provokes institutional resistance or punishment (Gutiérrez, 2020).

Inclusion versus exclusion: who gets to be a student?

While EIP is frequently presented as a means of inclusion – restoring rights, providing different life trajectories – it remains marked by exclusion. Access is uneven, framed as a reward for compliance and burdened by stigma. This paradox is evident when deciding who participates in EIP, under what terms and how that participation is institutionally understood.

An example of this contradiction is found in the experiences of incarcerated women. As research in Santa Martha Acatitla reveals, they often face suspicion or outright resistance. Their engagement with learning is read not as self-betterment, but as defiance of normative gender roles (Gutiérrez, 2020). These dynamics stem from the expectations placed on them to be docile, caregiving and disengaged from public life (Fregoso and Rojas, 2021). Education becomes a space where these expectations are resisted at the cost of further marginalisation. The paradox is sharp: education is meant to empower, yet women are frequently penalised, rendering educational inclusion a source of deeper exclusion, as I will show in the findings section.

The issue of inclusion is complicated by institutional arrangements. In Mexico, only two in-person higher education programmes operate inside prisons, one which is PESCER. Despite its progressive mandate, it has faced political tensions, leading to a lack of systematic evaluation, especially regarding gendered impacts. Access remains limited and critical reflection on the programme’s effectiveness is still emerging.

Inclusion through EIP is often shaped by bureaucratic, disciplinary and symbolic constraints. Participation in programmes is frequently contingent on ‘good behaviour’, reinforcing reward systems rather than advancing universal access or educational justice. When education is a privilege rather than a right, its transformative potential is diminished (Umpierrez and Sosa, 2023). This perpetuates hierarchies, since only those who comply with institutional expectations are granted the role of student. This contradiction invites a rethinking of what educational inclusion in prisons actually entails. Does it mean expanding access, recognising diverse identities and narratives or challenging who is seen as deserving of education at all? Without addressing these layered exclusions – based on gender, race, class, behaviour and institutional fit – prison education risks deepening the very inequalities it claims to challenge.

Conceptual framework

EPCC is not a neutral practice. Its meaning is shaped by national, institutional and historical configurations of punishment, justice and social control (Behan, 2021). EPCC is a socio-educational field that exists within, against and despite prison, situated within the carceral logic, but in tension with it. To theorise this space, I draw from prison studies and social pedagogy, while grounding the discussion in Latin America.

From a Foucauldian perspective, EIP has historically worked as a corrective device in the machinery of discipline aimed at the transformation of the ‘deviant’ subject (Hoyos and Marcelín, 2024). This works as ‘useful punishment’ (Pavarini, 2009), which constructs education as a therapeutic or curative intervention. Learning becomes entangled with narratives of abnormality and reformation, and the prisoner is rendered an object of correction. This framework omits structural and racialised conditions of criminalisation, depoliticising incarceration and justifying its permanence (Gutiérrez et al., 2023). The result is a pedagogical field defined by adaptation to carceral norms. A central element of this apparatus is what authors have called the ‘re ideologies’,3 discourses of re-socialisation, re-education, re-insertion, re-generation and re-habilitation that sustain the illusion of correction while concealing the exclusionary and punitive nature of the prison (Daroqui, 2007; Gaete and Acuña, 2022). These ideologies serve to depoliticise punishment, neutralise critique and reinforce the idea that the prisoner is inherently deficient.

This logic becomes more complex with the rise of neoliberal rationalities. In many Latin American contexts, prisons function as spaces of exclusion and abandonment (De Giorgi, 2006; Wacquant, 2009). The discourse of ‘reintegration’ persists but is often a hollow ideological promise used to sustain carceral legitimacy while limiting access to education. Contemporary incarceration increasingly aligns with a logic of disposability: a space where populations are marked as surplus, not to be transformed, but managed or neutralised (Slokar, 2020).

That is the conflict of EPCC. On the one hand, EIP is framed by institutions as a rehabilitative tool, a means to reintegrate individuals into the normative social order; on the other, educators and students may re-signify educational spaces as acts of resistance, constructing alternative subjectivities and restoring dignity within dehumanising conditions. These two logics co-exist in conflict. The result is a negotiation where the liberatory potential of education is threatened by efforts to instrumentalise it (Hennig, 2023).

To navigate this tension, I turn to social pedagogy as a framework that does not deny the structural violence of confinement but insists on the political and ethical dimensions of education. Social pedagogy imagines education as accompaniment, an effort to sustain relationships of care, dialogue and critical reflection in hostile environments (Núñez, 1999; Silva Balerio, 2016). These ephemeral and fugitive territories in (against and despite) confinement (Bustelo, 2020), where students can reimagine their place in the world and exercise agency in defiance of silencing, are carved out within institutions designed to suppress them.

We can conceive socio-educational practices as those that extend the pedagogical terrain beyond formal, with the goal of ‘creatinglearning and personal development scenarios within institutions that were not created for that purpose … transmuting and perverting the institutional program designed to deliver pain’ (Silva Balerio, 2016, p. 31). Social pedagogy helps us grasp one of the deepest meanings of EPCC: to teach is to bridge (Anzaldúa, 2002), to construct a fugitive space embedded in prison but not reducible to it: it seeks liberation from the violence of confinement. Although fleeting due to the limited duration of the educational experience, is always potent, as its effects may transcend the institution, shape subjectivity and inform political practice.

As Silva Balerio (2016) argues, this is an intermediate zone where practices and interventions promote rights, foster support, and resist punitive domination. Its plasticity allows for the reconstruction of cultural meanings and the formation of supportive relationships that reduce vulnerability and counteract institutional abandonment. It becomes a space of resistance, capable of generating cultural defences to confront the ‘invasive and devastating effects of the punitive system’ (Silva Balerio, 2016, p. 33).

Methodological approach

This research is grounded in a qualitative framework that privileges the experiences and meaning-making processes of incarcerated women who pursue higher education (Borsotti, 2006; Denzin and Lincoln, 2000; Reguillo, 1998; Reynaga, 1998). Rather than approaching EIP as a neutral intervention, I adopt a standpoint rooted in situated epistemologies (Haraway, 1991; Rockwell, 2009) that recognises the prison as a site epistemic tension and political struggle. I positioned myself as a participant-observer in the field, inhabiting the classroom, walking the corridors, and sharing time with students in a space marked by surveillance, regulation and institutional violence. My role was relational and ethically committed to the participants and the process (Gentile, 2013; Reguillo, 1998; Taylor and Bodgan, 1987). The methodological design was developed through a set of qualitative windows (ventanas cualitativas) that articulated different strategies of inquiry: semi-structured interviews, thematic guide, participant observation and field diary. These windows, grounded in the life-history perspective (Atkinson, 2001; Bertaux, 2005), ensured a multilayered and ethically attentive engagement with participants’ experiences. The process involved identifying, coding and analysing information through successive readings, using the content analysis technique (Bardin, 1996) to trace thematic patterns and refine categories. This technique enabled a rigorous yet interpretive engagement with the narratives, combining systematic organisation and the analytical reconstruction of meaning. Through successive cycles of reading, coding and categorisation, the process advanced from surface-level description to the identification of latent structures and thematic regularities. In line with Bardin’s (1996) framework, content analysis operated as a hermeneutic exercise of translation, transforming lived experiences into analytically coherent categories while striving to preserve the ethical and contextual integrity of participants’ voices.

For two months, I engaged with six students enrolled in a law degree through the PESCER programme. Our encounters were structured through three 90-minute, semi-structured interviews.These were designed to elicit narrative reflections on the participants’ educational experiences, which I conceptualise, following Schlosser (2008), as ‘identity moments’. These are not fixed turning points, but events that reconfigure their understanding of themselves and their place in the world. Participants were selected based on their voluntary willingness to narrate their educational experiences and their current enrolment in the UACM law programme through PESCER. Participation was guided by informed consent, emphasising confidentiality and the right to withdraw at any time.

To support this process, I developed a guide informed by work on narrative and life history methods (Atkinson, 2001; Bertaux, 2005), organised around six themes: educational background inside and outside prison, personal and family histories, work trajectories and future aspirations. I invited participants to explore moments of rupture, continuity and resistance. I also kept a detailed field journal and conducted participant observation as complementary strategies for deepening the analysis and enabling data triangulation.

The analytical process incorporated triangulation as a strategy to strengthen validity and interpretive depth. This was achieved through the convergence of three sources of information: semi-structured interviews, participant observation, and the researcher’s field diary. Each provided complementary perspectives on how women narrated their educational experiences and constructed student identities within confinement. The interviews captured their personal accounts; observation allowed attention to embodied and relational dynamics during classroom interactions; and the field diary recorded the contextual, emotional, and reflexive dimensions of the encounters. Triangulation thus unfolded throughout the research process – from data collection to interpretation – allowing findings to emerge from the interplay between lived experience, situated reflection and socio-educational analysis. The process concluded with the consolidation of categories cross-verified across these three sources, ensuring coherence and credibility in the interpretation of the results.

The analytical process not only engaged with interpretive categories but was continuously grounded in the empirical narratives of participants. Quotations and lived accounts were not illustrative but constitutive of the analysis, allowing theoretical reflection to emerge from empirical density. This approach ensured balance between conceptual elaboration and the lived complexity of women’s experiences, maintaining fidelity to the material conditions and affective dimensions that gave shape to their voices.

The analysis was structured through a system of categories and macro-categories derived from these narrative axes. Drawing from the theoretical framework and a map of categories I elaborated (Figure 1), I identified four central analytical anchors (anclajes): motivation; studying as resistance; pedagogical bond; and future horizon. Each represents a cluster of meanings that link individual trajectories to broader socio-educational processes within punitive confinement. The coding process was iterative and interpretive, progressively grouping narrative segments and reclassifying them as consolidated themes. For this article, I focus on the studying as resistance anchor.

Figure 1
Figure 1

Diagram of the study’s analytical framework, including a map of analysis categories showing how school trajectories, motivation and present strategies interact with identity formation, self-affirmation and recognition by others among university students in reclusion 

A critical component of this research was the creation of a dialogical space that broke from the authoritarian routines of the prison. Encounters with the participants were built on mutual respect, care and the recognition of their knowledge, voices and silences. Participation was voluntary and informed consent was obtained. I aimed to maintain a horizontal dynamic that challenged extractivist tendencies in prison research and fostered reciprocal recognition (Skliar, 2011). The anonymisation of participants was ensured through the use of pseudonyms. The names that appear in this article do not correspond to the real identities of the women I interviewed. This choice preserves confidentiality while maintaining the narrative integrity of their voices.

The data was analysed using thematic content analysis (Bardin, 1996), paying attention to the ways in which participants articulated their student identities through narratives of dignity, rupture and self-determination. I focused on the conditions of meaning production in prison. This dimension is critical, as it highlights the capacity of education to foster forms of symbolic resistance and affirm identity. This interpretive process integrated the theoretical and empirical dimensions of the study, maintaining coherence between categories, objectives and results.

Findings

The women’s narratives reveal the paradoxical condition of being simultaneously students and prisoners. Their educational experiences unfold within a gendered space that disciplines femininity and punishes defiance. As explored in previous research on identity anchoring in confinement (Gutiérrez, 2020), studying law becomes both an act of self-assertion and transgression – a process of estar siendo abogadas (becoming lawyers) that reclaims autonomy and challenges the docility expected of imprisoned women. Within this double condition, education functions as both recognition and resistance: it affirms their intellectual and moral agency while exposing the contradictions of a system that grants knowledge as a privilege rather than a right.

The findings are organised around three analytical lines that illuminate how women experience studying within punitive confinement: (1) the redefinition of education as a space of symbolic freedom and resistance; (2) the institutional and bureaucratic barriers that transform learning into a conditional privilege; and (3) the stigmatisation and denial of the student identity. While this research project centres on the lived experience of studying in prison, the exploration of participants’ educational trajectories prior to incarceration remains an open and pending area for further enquiry. Future work will extend these analyses to understand how earlier schooling experiences shape the meanings that education acquires inside confinement.

Between punishment and fleeing: the classroom as a threshold of symbolic freedom

Educational practices within confinement constitute a contested terrain between two antagonistic rationalities. On the one side, prison administrations instrumentalise education as a mechanism of control and behavioral adjustment; on the other, students can resignify the classroom as a space for autonomy, dignity and political subjectivation. In this context, attending university becomes a tactical act of resistance against institutional violence. As Alicia recounts:

Just by being in school, you avoided a lockdown, a fight, problems in your cell, you get spared from many things. You also stop doing a lot of things and don’t experience the [prison] environment. I’m completely detached from everything going on inside the prison.

Even when institutions attempt to restrict access to the university space, students develop strategies to reopen it and maintain it as a site of appropriation. Alicia describes a revealing scene: ‘Even if they don’t want us to, we sneak in … we make up a big story about needing to finish our thesis.’ This ‘big story’ is a situated strategy that subverts the rules of confinement, a gesture that dramatises the legality of using the classroom and reconfigures it into a self-managed refuge.

This exemplifies a pedagogy that perverts the institutional programme designed to generate pain (Silva Balerio, 2016): students inhabit the place and infuse it with new meanings, transgress it and make it fertile. It also reaffirms the relational nature of these spaces which, contested and defended by the students, are reconfigured as fugitive territories within the prison but not absorbed by it.

This scene reveals a form of quiet political agency where the continuity of the university experience depends on the creative and affective will of those who embody it. In the face of closure, they open. In the face of regulations, they narrate. In the face of punishment, they study. It is a situated tactic that reclaims educational space as their own. Beyond the tactical gestures of evasion, these narratives illustrate how the participants’ position as law students carries a symbolic inversion of power. Studying law, the very system that once condemned them, becomes an act of reclaiming interpretive authority over justice and legality. Their engagement with legal language and reasoning produces a double movement: it confronts the punitive order that confines them and simultaneously expands their epistemic agency. This dynamic echoes Foucault’s reflections on counter-conduct (Lemos, 2022) and connects to social pedagogy’s emancipatory tradition, where learning transforms dependence into self-determination (Silva Balerio, 2016; Skliar, 2017; Meirieu, 2008). Thus, the students’ narratives are not only testimonies of resistance but also reflections of a juridical and epistemic reappropriation from within confinement. Karen expresses it clearly, ‘It’s a way to escape everything in here’. Jessica confirms that going to university is ‘like a lifesaver that keeps you from drowning’.

This image of the university as a lifesaver captures not only the emotional and psychological relief that education provides but also the strategic significance of the classroom as a tactical fugitive space. Within the carceral environment – marked by surveillance, routine and degradation – attending class becomes a defiant gesture. It allows students to construct an alternative temporality not dictated by institutional routines but by their own rhythms of learning, reflection and self-construction. The classroom functions as a space within-but-against the prison: a liminal zone where other kinds of interactions and subjectivities become possible. In choosing to study, students interrupt the carceral narrative imposed on them and engage in bridging practices, acts of symbolic displacement that allow them to ‘be elsewhere’ even while physically confined.

Jessica’s metaphor reveals how this displacement operates affectively: the university becomes an anchor to something beyond the prison, a tether to their future selves, to dignity and agency. In the classroom they are asserting an identity that the institution seeks to suppress. They are swimming against the current of punitive logic, clinging to something that keeps them afloat. This refusal to drown, to be fully consumed by the prison’s logic defines the fugitive dimension of their education.

This shift in meaning is echoed by participants as they all agree that studying became a way to escape the prison. It meant becoming absent from prison dynamics. The classroom is a buffer against violence or isolation, a site of active disassociation from the rhythms, conflicts and surveillance that structure prison life:

I used to think that there was no peace or privacy in this place, but it’s not true. I come here and I can have privacy. I listen to music, turn on my computer, write, do homework or projects to help others. (Jessica)

From such subtle maneuvers, Jessica manages to inhabit a different space that transforms the oppressive everyday life of prison into a more liberating routine. In doing so, she inoculates herself against the effects of confinement, momentarily abandoning the imposed identity of ‘prisoner’ by anchoring herself in being a student.

Barriers to access: education as a privilege rather than a right

The prison’s structure imposes barriers that transform access to education into a conditional privilege. Incarcerated women must navigate a bureaucratic regime that demands participation in state-sanctioned ‘rehabilitative’ activities, many of which reinforce gender stereotypes and lack educational value. These include therapy, job training and workshops, referred to by participants as ‘courses’. Most see little value in learning to knit or make beaded bracelets. As Caro notes, ‘it’s mandatory to take these courses as part of the “rehabilitation treatment”. If we don’t attend, we lose privileges like having a TV or receiving visits. I don’t even like them’.

This arrangement exemplifies what I call puntitis4 (scoring points): a bureaucratic logic in which progress and access are evaluated by accumulating signatures, credits and attendance. Under this regime, education is stripped of its critical and emancipatory value and redefined as another item to check off in the performance of rehabilitation. Puntitis operates as a disciplinary technology that recodes rights into rewards and learning into metrics; it reflects how prisons instrumentalise pedagogical practices, not to foster critical learning, but to simulate rehabilitation through standardised indicators of conformity.

Education is thus transformed into currency. Students are caught between conflicting institutional demands. Karen shares how prison staff prioritise course attendance over university participation, creating tension between the roles of prisoner and student:

We submitted a proposal to both the previous director and the current one, asking for support for those who attend classes. The director forwarded our proposal to the council, asking them to excuse us from other activities … and they refused.

The overlapping schedules force students into impossible choices. Many are compelled to leave university classes halfway through to attend a workshop, only to return afterwards, an everyday choreography between their identities as students and prisoners. This institutional strategy fails to meet standards of educational accessibility, adaptability and affordability (Scarfó, 2018), thus obstructing education as a right and reducing it to a conditional favour. Some students resort to informal arrangements, relying on the goodwill of staff. Alicia shares: ‘I talk to her [the woman in charge of a workshop] when I feel it’s too much, and I ask, “Can you cut me some slack with attendance?”, and I know she helps me out because she gets it.’

But these favours are not guaranteed. Laura notes, ‘Usually they don’t follow through, and then you have to prove that you’re attending classes’. In these negotiations, women end up performing compliance just to secure basic acknowledgment. As Alicia adds, ‘Even if the craft I turn in is ugly, I have to do it to fulfill the requirement’. This small acts of negotiation blur into the paradox of reinforcing the carceral logic they are trying to resist. By continually positioning students as dependent and infantilised subjects, the institution hinders their ability to act with autonomy and dignity. Carmen underscores this contradiction: ‘The coordinator let us justify extracurriculars if we came to him … He supports me, but I have to ask him for favours.’

In this scenario, education is not seen as a right, but as a transaction to be negotiated. Puntitis thus becomes not merely a bureaucratic flaw, but an ideological device that reshapes education into a conditional, depoliticised practice. It sustains carceral logic by framing learning as a privilege contingent on submission, docility and productivity. Puntitis is aligned with the re ideologies that cast prisoners as subjects to be corrected, hollowing out education’s liberatory potential and repurposing it to serve the prison’s punitive and normalising functions. Yet, through small acts of resistance – strategic negotiation, dignified refusal and the assertion of their academic identities – these women insist on their right to learn. Their presence in the university classroom is an act of refusal. A practice of fugitive pedagogy that unsettles carceral logic from within.

Stigmatisation and the denial of the student identity

Despite their academic commitment, incarcerated women who pursue education are met with scepticism, infantilisation and institutional resistance. While this research did not aim to compare the study of law inside and outside prison, the narratives reveal distinctive dimensions of what it means to ‘be a law student’ within confinement. In this context, studying law acquires a paradoxical character: it is both an academic pursuit and a daily act of resistance against institutional control. The women’s engagement with legal knowledge is deeply situated, they study the very system that criminalised them, reclaiming it as a language for self-defence and collective agency.

While the construction of professional identity was not an explicit objective of this research, the women’s narratives revealed how studying law in confinement reshaped their sense of self and agency. As I analysed in my master’s thesis, these students experience an ‘estar siendo abogadas’ (becoming lawyers) as a form of reclaiming their humanity and defending autonomy (Gutiérrez, 2020). Their learning is not only cognitive but existential: ‘coming to the university also gives you the possibility of being able to defend yourself before the authorities of the very same system … today we make our demands according to the laws’ (Carmen). This self-defensive engagement with the law subverts its punitive function, transforming legal knowledge into a strategy of resistance. Beyond self-defence, the women extend this practice to others, as Caro describes: ‘I gave her a few articles and told her, “file this one, this one, and that one” … I was telling her how to write it’. Through these acts, studying law becomes a relational practice, a means to accompany and empower peers. For Laura, assisting others ‘it boosts your self-esteem and makes you want to move forward, to say: yes, I can’. These statements reveal a double recognition process: first, affirming their own capacity and right to be heard, and second, being recognised by others as knowledgeable and capable. The women’s juridical subjectivity thus emerges not from institutional validation, but from embodied acts of learning, defending and caring. In this sense, studying law inside prison is unique: it entails navigating the paradox of mastering the language of power to subvert it, transforming the carceral space into a site of both legal and affective self-determination.

Yet this emergent agency exists in tension with the institutional conditions that continually misrecognise them. Rather than being recognised as students exercising their right to learn, they are perceived as suspicious, deviant or undeserving. It reflects what I conceptualise as a triple-intensified punishment that heightens their vulnerability: being a woman, a criminal and a student. Each identity carries structural stigma; together, they intersect to amplify the institutional violence and exclusion these women endure, reinforcing the notion that their place is not in the classroom but in feminine activities that perpetuate gender norms within a predominantly male system (Giacomello, 2013). As Laura reflects, ‘They say I’ve done nothing all day … that I’ve just been lazy, but university classes are long and intense. Today, for example, class runs from 9 to 3, and I don’t have time to do anything else’.

Her account reveals how institutional frameworks fail to recognise the labour of studying. In this evaluative regime, university coursework is reduced to one tick box among many, and fulfilling it often means falling short of other mandated activities. The result is disciplinary sanctions and stigmatisation. Academic commitment is not only devalued but reframed as idleness. The student identity clashes with an institutional logic that insists incarcerated women remain first and foremost docile subjects of correction.

Labels function as mechanisms of control (Juliano and Freixas, 2008). Failing to recognise the participants as students, while labelling them as ‘lazy’, serves as a reminder to all incarcerated women of why they are there: for transgressing the gender mandate that confines all women to a single social destiny. Participants resist the triple-intensified punishment on a daily basis. Alicia’s experience underscores how entrenched this gendered logic is:

I went to the prison authorities and told them I was working on my thesis and needed support for my food sale stand. And they said: ‘We’ll check if that’s true.’ Later, another officer said, ‘I thought you were working in the library just for fun’.

Such responses reflect a patriarchal carceral culture that cannot reconcile incarcerated women with the figure of the intellectual. Carmen articulates the labour this disbelief demands: ‘Women here have to be clever to find ways to escape the status they impose on us.’ These tactics of navigation are not merely survival strategies; they are acts of dignified disobedience, a resistance that constitutes a fugitive educational practice that defies the logic of the institution. Within these precarious spaces, the classroom becomes a site of counter-subjectivation and dignified refusal.

At the same time, the unequal distribution of resources between male and female facilities reinforces the gendered logics of punishment. As Karen notes, ‘In the men’s prison, if you’re enrolled in the university programme, it counts for other requirements. Here, it doesn’t’. And Alicia adds: ‘Men can use USB drives. We can’t. They get more support.’

This disparity reveals how institutions reproduce gender-based inequalities symbolically and materially. Women’s educational labour is not only delegitimised but made structurally more difficult. Their struggle to be seen as students and not as wayward or manipulative bodies speaks to the heart of the contradiction that defines EPCC, where the promise of ‘transformation’ is undermined by the systems that claim to enable it. Nevertheless, through their tactics, students are able to sustain some form of liminal liberation within incarceration.

In sum, access to education is not only bureaucratically restricted but symbolically contested. The tension between being a ‘prisoner’ and a ‘student’ is not merely semantic: it is a battle over recognition, dignity and the right to imagine another future. Within this contested terrain, social pedagogy must not only accompany but actively sustain the struggle for fugitive spaces of learning. It must recognise them as political and intimate: temporary sanctuaries where the carceral logic is suspended – if only briefly – and the possibility of becoming otherwise – social pedagogy as anti-fate (Núñez, 1999) – takes root.

These findings reveal how the meanings of studying in confinement are not merely empirical descriptions but enactments of broader theoretical concepts. The re-signification of education within prison embodies a situated agency: a politics of meaning that emerges under constraint (Bustelo, 2020) and resonates with Butler (2004) and Strauss’ (1977) notion of recognition as a condition for subjectivity. The women’s narratives also actualise Freire’s idea of education as praxis: they learn, reflect and act on the structures that define their existence. By connecting these theoretical lenses to the lived experiences of law students, the analysis underscores how education in prison functions as a socio-pedagogical act of resistance, self-determination and dignification within the logics of punishment.

This analysis underscores the socio-educational dimension of the findings. Beyond describing individual experiences, it interprets the women’s narratives as pedagogical processes that produce social meaning, relational transformation and collective agency within punitive structures. Following Núñez (1999) and Silva Balerio (2016), the results reveal how social pedagogy operates as a praxis of accompaniment and critical awareness, transforming institutional spaces into contexts of learning, care and resistance. The classroom emerges as a socio-educational territory that reconfigures the relationship between knowledge, power and justice: it cultivates the capacity to act, think and resist collectively within a system designed to isolate. In this sense, the women’s experiences exemplify how social pedagogy enables education to function as both a personal and political practice of emancipation, generating meaningful bonds (Gutiérrez, 2020) that sustain dignity and humanisation even under coercive conditions.

The students often articulated expectations that exceeded the institutional purpose of ‘reintegration’. Their questions, about justice, law and the meaning of freedom reveal a critical stance towards the carceral order itself. As Carmen noted, ‘The university taught us that everything must have a foundation. It gives you a lot to defend yourself; not like my friends at the flea market defend themselves, but to defend yourself peacefully, in accordance with the law’. These reflections illuminate how learning becomes a relational and political act: students do not merely adapt to educational structures but reinterpret them as spaces to ask, to contest and to imagine. Within confinement, such questioning transforms education from a disciplinary mechanism into a collective practice of thinking and feeling otherwise.

These findings align with multidisciplinary studies that examine how education in confinement reshapes the relationship between punishment, subjectivity and social inclusion. In Argentina, Suárez and Frejtman (2012) describe prison education as a field of tensions between pedagogical and punitive logics, while Bustelo (2020) identifies pedagogical territories as fragile yet transformative spaces where incarcerated people reclaim themselves as subjects of knowledge. Comparative research from Uruguay, Chile and Spain further highlights how gender and institutional hierarchies shape access to learning and recognition. Situating the experiences of Mexican women law students within this Latin American dialogue reveals that prison classrooms function as territories for alternative forms of resistance and being.

Conclusion

The tension that arose when my colleague and I let a seemingly simple question slip – one that could have had serious consequences for the students, for us and for the programme – revealed the logic of fear that governs prison operations and shapes the relationships within them (Ferreccio, 2017). The intense emotions that followed – especially fear – were shared by everyone involved and made this logic palpable.

From that moment on, I realised that participating in educational experiences in prison means inhabiting the paradox of being in an extremely oppressive space facing a system defined by suffering, violence and oppression, while striving to cultivate fugitive pedagogical territories in (against and despite) confinement (Bustelo, 2020). Tactical projects that enable fleeting moments of resistance to the oppression of punishment, and that open the possibility of generating spaces of encounter, where the bond between teachers and students allows speech to unblock the affliction of confinement (Manchado, 2012).

However, the conversations I had with the law students show how the tensions they experience are embedded in this paradox, because they shape their educational experience and affect the construction of their identities. One of the most persistent is the contradiction between being a student and a prisoner: their academic identity is constantly delegitimised, subordinated or called into question, forcing them to inhabit a ‘dual condition’ in which being recognised as rights-bearing subjects becomes a daily struggle. Added to this is the tension between education as a right and education as a privilege, since access to university classes is conditioned by logics of punishment and reward.

Moreover, their commitment is met with suspicion: they are stigmatised as manipulative, dishonest or lazy by gender norms that expect passivity and docility. Their presence in the classroom becomes an act of resistance that, paradoxically, exposes them to punishment. Studying becomes a practice of dignity, subversion and liberation, but also a source of constant risk and tension. Within this complex and contested field, how can we envision learning situations that cultivate autonomy, freedom and self-realisation, defined as core principles of social pedagogy? What should be the meaning of education in a context of confinement?

While it is true that schools and modern education reproduce the hegemonic social order (Bourdieu and Passeron, 1990) and that they share with prisons the aim of producing docile bodies (Foucault, 1995), I argue that social pedagogy, particularly in its intimate relationship with liberatory pedagogy, allows us to recognise that EIP has historically been instrumentalised in the service of control, discipline and the reproduction of punitive logics, without this implying a renunciation of disputing it as a field of political action and resistance. Even within coercive environments, the potential remains to open spaces for educational experiences that challenge, empower and resist the oppression of confinement: territories inhabited within, against and despite imprisonment.

It is also important to recognise, as Silva Balerio (2016) warns, that intra- and extramural education ‘cannot do everything’, but neither is it a useless tool for promoting change. It is not about placing blind faith in the transformative power of education, nor about falling into a paralysing pessimism that views it as a device for discipline and the reproduction of the status quo. Rather, it is about embracing the contradictory nature of EPCC, acknowledging that it can hold experiences of liberation and resistance that strive for a different future, grounded in a political commitment to social justice and equity. The struggle for truly liberatory education in confinement cannot be limited to securing its formal existence; it must also entail a radical challenge to the power structures that condition and constrain it.

The findings of this study reaffirm the dialogic relationship between theory, method and lived experience. The theoretical framework of social pedagogy provided a lens to interpret the students’ narratives not as isolated experiences, but as socio-educational processes that emerge within, against and despite punitive confinement. Methodologically, the life history and qualitative windows approach made it possible to capture these contradictions in motion, how students construct meaning, negotiate control and sustain dignity through everyday pedagogical acts. This synergy between framework and method demonstrates that understanding EPCC requires an epistemology grounded in experience: one that recognises knowledge production in prison as a political, ethical and affective process of existence.

Thus, I propose to think of EPCC as a way of creating spaces of autonomy, critical thinking and subjective reconstruction, where incarcerated people can (re)build (other) identities beyond the imposed criminalisation and stigmatisation. Through practices grounded in horizontal dialogue and the co-construction of knowledge, EPCC can become a tool for resistance and the affirmation of rights (Hennig, 2023). However, this possibility is constantly threatened by the prison system, which imposes administrative and symbolic barriers to accessing and developing meaningful educational processes. We, therefore, inhabit a paradoxical tension inherent to the school within the prison (Suárez and Frejtman, 2012). Although education programmes cannot eradicate punitive rationality, they can cultivate territories where dignity and radical care prevail.

We might find here the meaning of EPCC: that of inhabiting the paradox as an inevitable experience of educating within carceral contexts where two seemingly irreconcilable forces converge: education, a practice orientated towards freedom, human development and autonomy, and the prison, whose functioning is based on control, punishment and fear. Inhabiting the paradox does not mean denying this contradiction but rather living within it: teaching and studying with the awareness of being immersed in a system that restricts the emancipatory horizons of education (Gaete and Acuña, 2022). Inhabiting the paradox means not only confronting the conflict but also sustaining it as a condition for creating and persisting in meaningful educational practices. Ultimately, it means inhabiting the in-between of punitive and pedagogical logics, without fully resolving their tensions, but affirming the commitment to recognise the other as a subject. This is a liminal space of liberatory struggle and radical imagination, resonating with abolition feminism’s refusal to escape contradiction. As Davis et al. (2022) emphasise, transformation does not require the erasure of paradoxes; rather, it emerges through upholding immediate needs and long-term visions, supporting incarcerated communities while working to dismantle the systems that confine them.

Taken together, the framework, objectives and results form an integrated argument about the liberatory potential of education in confinement. The theoretical lens of social pedagogy helped trace the tensions between punitive and pedagogical rationalities, while the qualitative methodology grounded this analysis in participants’ lived realities. The results demonstrate how education functions as a fugitive and relational practice that challenges control and affirms subjectivity. These findings not only validate the study’s objectives – namely, to analyse how women construct student identities within carceral spaces – but also extend them, showing that education in prison operates as both method and resistance, a site where theory materialises in everyday practice.

Núñez (2007) proposes thinking of social education as that which has the potential to challenge predetermined social trajectories by offering individuals the possibility of constructing their own unique and singular paths: ‘education as anti-fate’. Perhaps this is the greatest struggle and potential of EPCC: to open up the possibility of inhabiting anti-fate not only for women in prison – for whom the sentence seems to have been predetermined by the despotic selectivity of the penal system – but also for a world in which it might be possible to imagine that the fate of difference is no longer prison. Ultimately, EPCC should not respond to the mandate to correct but to the imperative to resist, refuse and liberate.

Notes

  1. The term Education in Punitive Confinement Contexts (EPCC) emerged in Argentina with the 2006 National Education Law 26.206, which integrated prison education into the national education system. This brought visibility to an excluded field and transferred its oversight from the prison system to the Ministry of Education. Argentina’s approach redefines EPCC as a right and a political act. Scholars like Parchuc (2019), Bustelo (2020), Manchado (2012, 2023, 2024), Umpiérrez and Salvadé (2020), and Scarfó (2011, 2018) define EPCC as a pedagogical process aimed at subjectivation, resistance and identity reconfiguration. EPCC embraces a political and ethical dimension, conceiving education as a counter-hegemonic practice. It enables prisoners to reimagine their futures, build alternative identities and exercise agency. Its value lies in its ability to dignify, include and recognise them as rights-bearing subjects capable of imagining other worlds. I use the term EPCC in this context, alternating with ‘education in prison’ (EIP).
  2. There are no comprehensive or regularly updated nationwide statistical databases for the Mexican penitentiary system. The ENPOL 2021 survey constitutes the most recent and systematic effort conducted by INEGI, an autonomous public body responsible for regulating and coordinating the National System of Statistical and Geographical Information. Due to the opacity and fragmentation of available data, several scholars have characterised the penitentiary system as a ‘black box’ (Cisneros, 2014; Gutiérrez, 2019).
  3. Zaffaroni (2015) identifies, under the notion of ‘re ideologies’, the concepts associated with a treatment-oriented logic and defines them as absurdities, arguing that the idea of ‘re-’ is incompatible with the notion of ‘deterioration’.
  4. I am grateful to Citlalli Santoyo, who helped me find this term.

Declarations and conflicts of interest

Research ethics statement

The author conducted the research reported in this article in accordance with IRB standards.

Consent for publication statement

The author declares that research participants’ informed consent to publication of findings – including photos, videos and any personal or identifiable information – was secured prior to publication.

Conflicts of interest statement

The author declares no conflicts of interest with this work. All efforts to sufficiently anonymise the author during peer review of this article have been made. The author declares no further conflicts with this article.

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