Universal-Womens-accesss-to-justice-Publications-Practitioners-Guide-Series-2016-ENG

68 PRACTITIONERS GUIDE No. 12
is also a breach of the right not to be subjected to torture and
ill-treatment for which the State is responsible. 181
The obligation to fulfil: States must take a variety of
measures to ensure human rights in practice
The obligation to fulfil human rights means that the State must
adopt appropriate measures aimed at the full realization of
human rights. The jurisprudence of certain treaty bodies and
mechanisms uses the “fulfil” terminology. 182 The Human Rights
Committee has characterized the obligation in the following
terms: that States must “adopt legislative, judicial,
administrative, educative and other appropriate measures in
order to fulfil their legal obligations”, noting that “it is
important to raise levels of awareness about the Covenant not
only among public officials and State agents but also among
the population at large”. 183
The CEDAW Committee has added that the obligation to fulfil
requires that States parties “take a wide variety of steps to
ensure that women and men enjoy equal rights de jure and de
facto, including, where appropriate, the adoption of temporary
special measures in line with Article 4, paragraph 1, of the
Convention and General Recommendation 25 on Article 4,
181
M.C. v Bulgaria (2003) ECHR 651; Vertido v Philippines, CEDAW
Communication No 18/2008, UN Doc CEDAW/C/46/D/18/2008 (2010).
182
Committee on Economic, Social and Cultural Rights, General
Comment No 12, “The right to adequate food”, UN Doc E/C.12/1999/5
(1999), where the Committee defines the obligation to fulfil as the
obligation to provide and facilitate (paragraph 15); and Committee on
Economic, Social and Cultural Rights, General Comment No 14, “The
right to the highest attainable standard of health”, UN Doc
E/C.12/2000/4 (2000), where the uses the terms facilitate, provide
and promote.
183
Human Rights Committee, General Comment No 31, above note
176, paragraph 7.