Such violence is not the only obstacle in the way of a fair vote.
Shielding them with high tariff walls would place a huge obstacle in the way of reform.
The main obstacle in the way of more flexibility has been the Japanese finance ministry.
Ofcom and Jeremy Hunt are also likely to erect a second obstacle in the way of the takeover.
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"The core holding of Roe is that a state cannot place an obstacle in the way of a woman who wants to abort before viability, " DiPippa said.
But there could still be one big obstacle in the way of such a neat resolution: Devlet Bahceli, the Nationalist leader and also a deputy prime minister.
So, you might say that the largest obstacle in the way of Mr Osborne announcing an even slower deficit reduction plan next week isn't the financial market, but the chancellor's lack of confidence in his own side.
Rising inflation could prove to be an important obstacle in the way of a self-sustaining recovery, with its effects more likely to be seen in the second half of the year, according to equity strategist Mark Lamkin.
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Erdogan had previously suggested the deaths "could be an internal settling of scores, or it could be an initiative that was taken to create an obstacle in the way of the new honest steps we are taking, " according to the Anatolian news agency.
"This could be an internal settling of scores, or it could be an initiative that was taken to create an obstacle in the way of the new honest steps we are taking, " said Turkish Prime Minister Recep Tayyip Erdogan, according to the semiofficial Anatolian news agency.
Liverpool have the added incentive of knowing victory may just put an obstacle in the way of United's attempt to claim a record 19th title and overhaul their own record - although that will not register for a second in the minds of Dalglish and his players.
The nuclear issue is not the only obstacle standing in the way of improved relations.
The lawsuit is just the latest potential obstacle standing in the way of the tie-up between the two major air carriers.
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The prime minister may be proving more pragmatic and focused than expected, but many an obstacle lies in the way.
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Why are they clamoring to give even more power and control to the state, instead of seeking to free themselves from the very obstacle that stands in the way of any genuine economic progress?
There are no legal restrictions in most of the countries today on preaching Islam, but since their grandeur and authority is established in the world, it has led to developing a universal feeling which forms a greater obstacle than the greatest legal binding in the way of free propagation of Islam.
Perhaps the biggest obstacle Mr Bratton faces is the gang violence that is endemic in Los Angeles in a way it has never been on the East Coast.
There is no easy answer, but there is this to say about the Senate experience of the 1960s and 1970s: When confronted by the obstacle of the filibuster in that era, those with a cause went about overcoming the filibuster the hard way.
Obstruction in the way of preaching Islam does not mean only a legal obstacle, but greater power or domination of a non-Muslim state against Muslims is by itself a great obstacle in the propagation of Islam.
But the governor's main obstacle to re-election, if she chooses to run in 2008, will be the way she entered office in 2004.
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Dunham may say that the company is not for sale, but getting McClendon out removes a big obstacle in a way of a hostile takeover.
Another obstacle to the spread of on-board devices may be the availability of hand-held ones, in the same way that carphones have largely given way to mobile phones.
Ljubicic, who upset Britain's Andy Murray on his way to the semi-finals in Beijing last week, proved far less of an obstacle to Djokovic who always had control of the contest.
In a previous post, you read about how self-centeredness is an obstacle to all communication, extending all the way from social conversations to our focus, presentations.
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