Response to Call for Submissions in Connection with the ...



Response to Call for Submissions in Connection with the Convention on the Rights of the Child General Comment on the Right of the Child to the Enjoyment of the Highest Attainable Standard of Health

The Center for Reproductive Rights (the Center)[i] appreciates the opportunity to provide this submission to the Committee on the Rights of the Child (the Committee) in connection with the forthcoming General Comment on the Right of the Child to the Enjoyment of the Highest Attainable Standard of Health (Art. 24).[ii]

Acknowledging that the Committee’s General Comment No. 4[iii] does address elements of the sexual and reproductive health aspects of adolescents’ right to health, we take this opportunity to urge detailed and focused attention to this issue with respect to children as a broader category (using the Convention definition of “children” as every human being under the age of 18)[iv] to encourage the Committee to further elaborate the standards arising from the Convention in their application to all children, including adolescents.

(1) What should be the basic premises for the realization of children’s right to health?

It is essential that States adopt and implement laws, policies and regulations to fulfill children’s right to sexual and reproductive health, which promote the best interests of the child (Art. 3.1), with due regard for their evolving capacities (Arts. 5, 14.2). This is particularly crucial in view of the fact that, across the world, children and adolescents have been widely underserved by reproductive health services.[v]

All children have the right to access confidential and non-discriminatory sexual and reproductive health education, information and services.[vi] This will empower them to make informed decisions about their sexual and reproductive health, and encourage them to access care. A comprehensive understanding of sexual and reproductive health is imperative to an individual‘s ability to protect his or her health and make informed decisions about sexuality and reproduction. Thus, access to appropriate education, information and services is vital to reducing adolescent pregnancies, unwanted pregnancies, unsafe abortions,[vii] and maternal mortality rates,[viii] and to preventing the transmission and spread of sexually transmitted infections (STIs) and HIV/AIDS among young people.[ix] Moreover, States’ failure to guarantee such education, information and services for adolescents can result in violations of other rights guaranteed by the Convention, such as their right to education.

Thus, in situations in which States reinforce parental interests in the protection of vulnerable children, such interests should not undermine the respect warranted in line with their evolving capacities.[x]

(2) How can the principles of the Convention on the Rights of the Child (CRC), in particular articles 2, 3, 6 and 12, be applied to designing, implementing and monitoring interventions to address child and adolescent health challenges and what aspects are specific to a child’s rights approach to health?

Any interventions to guarantee children’s right to health must respect their autonomy and privacy in decision-making about their sexual and reproductive health.[xi] Adopting and implementing policies that adhere to this standard, particularly in situations in which children may have distinct beliefs about the morality of sexual and reproductive health services from those of their parents or spouses,[xii] will ensure that children are able to express their own views in the realization of their right to health.

While children are entitled to special care under the CRC, the “evolving capacities of the child” standard, developed also in General Comment No. 4, recognizes that many adolescents have the maturity and ability to make their own decisions and to anticipate and bear responsibility for the consequences of their decisions.[xiii] As such, the General Comment should clearly indicate that States should adopt policies to ensure that children and adolescents who are sufficiently mature can exercise judgment on their own behalf to provide informed consent to the use of sexual and reproductive health services.[xiv]

Guaranteeing children’s confidentiality is essential to safeguarding their best interests and promoting their development. Children may be deterred from accessing sexual and reproductive health care if they believe that their parents or guardians could learn about their sexual activity, use of contraception, or decision to terminate a pregnancy.[xv] Furthermore, children’s dependence on parents or guardians to pay for costly sexual and reproductive health services may impact their ability to make confidential decisions for themselves.[xvi] As such, the design of all services must incorporate specific measures to ensure confidentiality. Monitoring of the implementation of services in line with States’ obligations should also identify any problems that arise in different settings, such as where healthcare providers may disclose information about the services sought by children when they bill their parents or guardians for such services.[xvii]

Laws and policies requiring parental or spousal consent or disclosure for children’s access to such services are likely to make children reluctant to use them. As a result, they may forgo contraception, and thereby risk pregnancy or STIs.[xviii] Furthermore, children who are unable to legally terminate unwanted pregnancies without the consent of a parent or guardian may seek illegal and possibly unsafe abortion services in order to avoid disclosure to their parents. Given that unsafe abortion is a leading cause of maternal mortality and morbidity,[xix] the “[d]enial of services or of confidentiality may be a matter literally of an adolescent girl’s death, or severe and enduring injury.”[xx]

In the context of child marriage, policies and procedures must be in place to ensure married girls are able to provide informed consent to sexual and reproductive health services and to safeguard their right to confidentiality. Although child marriage is condemned under international law, in circumstances in which it still occurs, husbands may be required to consent to medical services, thus undermining the married girl’s autonomy to make decisions about her reproductive health in a confidential setting.[xxi]

In view of these obstacles to the enjoyment of the right to health, interventions to address child and adolescent health must guarantee that sufficiently mature adolescents can provide informed consent to the use of sexual and reproductive health services, rather than securing consent from their parents or spouses.[xxii] Such policies, supported by training for those who implement them, must ensure respect for adolescents’ “right to privacy and confidentiality, including with respect to advice and counseling on health matters”[xxiii]. They should also ensure that financial and bureaucratic procedures do not jeopardize adolescents’ right to confidentiality and access to sexual and reproductive health services.

By adopting these interventions and monitoring their implementation, States can ensure that the principles of promoting the best interests of the child, children’s right to life and children’s right to express their views, enshrined in the Convention and subsequent General Comments, are applied to a child’s rights approach to health.

(3) What is the normative content of article 24? What are the specific obligations of States under article 24? What are the responsibilities of non-state actors under article 24?

Article 24 incurs obligations to respect, protect and fulfill children’s right to sexual and reproductive health. The duty to respect requires States to refrain from interfering directly or indirectly with adolescents’ access to sexual and reproductive health.[xxiv] Laws or regulations that condition access to sexual and reproductive health education, information or services for children on parental consent or marital status violate the obligation to respect. Thus, States should reform laws or policies that restrict access to health services by requiring parental or spousal authorization.[xxv] Also, financial barriers that interfere with children’s access to reproductive health services, such as the high cost of contraception, amount to a violation of the State’s obligation to respect and must be eliminated.[xxvi]

The duty to protect requires States to prevent non-state actors from censoring, withholding, or intentionally misrepresenting sexuality education and information provided to adolescents.[xxvii] UN treaty-monitoring bodies (TMBs), including this Committee, have indicated that the lack of adequate and appropriate sexuality education is an obstacle to States’ obligations to guarantee the right to life, non-discrimination, education and information and have recognized that sexuality education is a means to ensuring the right to health by contributing to the reduction of the rates of maternal mortality, abortion, adolescent pregnancies, and HIV/AIDS.[xxviii] As such, TMBs have established an international obligation for States to ensure that non-state actors, including schools, provide sexuality education.[xxix] In recognizing that children may hold different conscientious and religious convictions than their parents or the societies in which they live, States should adopt measures to regulate the provision of sexuality education and sexual and reproductive health information and services to ensure children are not denied access to such education, information or services on religious or other social or cultural grounds.

In accordance with the obligation to fulfill, States should take steps to create and ensure access to comprehensive, age-appropriate sexual and reproductive health information and services through their health policies.[xxx] Moreover, as has been recognized by the European Committee of Social Rights, such policies must be designed to combat gender stereotypes and empower adolescents.[xxxi] Furthermore, States should invest in reproductive health care services that enable children to exercise their right to sexual and reproductive health. These measures are essential to tackling harmful practices, preventing early pregnancy and STIs, and enabling children to exercise their reproductive autonomy.

(4) What are the priority concerns in general and in particular regions of the world for the implementation of article 24?

A priority concern across the world is the lack of or insufficient access to sexual and reproductive health education, information and services.[xxxii] Globally, nearly half of the deaths resulting from unsafe abortion in 2003 occurred among adolescents and adults below the age of 25[xxxiii], and complications from pregnancy and childbirth are the leading causes of death for 15 to 19-year-old girls in the developing world.[xxxiv] Additionally, among young people aged 10 to 24, 111 million cases of curable STIs occur each year, and 60% of young people between the ages of 15 and 24 are unable to correctly identify the ways to prevent transmission of HIV.[xxxv]

Specifically, children confront many barriers in access to sexual and reproductive health information and services, such as laws that discriminate against them on the basis of their age by requiring parental or spousal consent for services, and the denial of sexual and reproductive health services like abortion and emergency contraception. For example, in the cases of K.L. v. Peru[xxxvi] and L.C. v. Peru[xxxvii], the Human Rights Committee (HRC) and the Committee on the Elimination of Discrimination against Women (CEDAW Committee) respectively recognized the State’s failure to ensure adolescents’ access to legal reproductive health services, including abortion. Likewise, in the case of Paulina del Carmen Ramírez Jacinto v. Mexico, the Inter-American Commission on Human Rights addressed the case of an adolescent who was raped at the age of 13, not offered emergency contraception, and prevented by state agents from obtaining a legal abortion to terminate the resulting pregnancy. As a result of her lack of access to these essential sexual and reproductive health services, Paulina was forced to carry her pregnancy to term, suffering significant financial and personal consequences, which affected her access to education and employment opportunities.[xxxviii]

Moreover, despite its fundamental importance, sexual and reproductive health education is alarmingly inadequate or completely lacking in several countries throughout the world. In some countries, sexuality education is unavailable in public schools, which is the main source of education for many children.[xxxix] Other states include inappropriate and ideologically driven content in their sexuality education courses.[xl] These courses often disseminate medically inaccurate and biased information about contraception, abortion and HIV/AIDS.[xli] Furthermore, such courses often promote abstinence-only messages, discourage condom use, and rely on gender stereotypes about sex, sexuality, and gender identity.[xlii] In addition, although delaying sexual activity among youth is one of the motives used to justify these programs, studies show that such messages are largely ineffective in achieving this goal.[xliii]

(5) Which concrete measures should be put in place to implement article 24?

In order to ensure that every child is able to enjoy the right to health, as mandated by Article 24 of the CRC, States should establish and implement effective policy frameworks, guaranteeing children’s access to comprehensive and appropriate sexual and reproductive health services, and mandate comprehensive sexuality education for them.

States must eliminate formal barriers in children’s access to services, such as parental or spousal consent requirements and financial obstacles. They must ensure that sexual and reproductive health services are geographically accessible for children, and ensure that health care providers receive appropriate training so that they understand children’s autonomy and confidentiality in decision-making about their sexuality and reproduction. For example, in K.L. v. Peru, the HRC found that the State failed to ensure K.L.’s right to the special care she needed as a minor by denying her access to legal abortion services.[xliv] In L.C. v. Peru, the CEDAW Committee held that the State’s failure to ensure L.C.’s access to legal reproductive health services for women, including abortion, was discriminatory and amounted to violations of her right to health and freedom from sex role stereotyping and prejudice.[xlv]

Furthermore, since many children are concerned about stigma or shame culturally associated with sexual activity, pregnancy, and STIs[xlvi], which may make them less willing to seek counseling and care,[xlvii] providers should be trained to work directly with children and provide information about how to protect their health without judging their choices[xlviii] or perpetuating gender stereotypes in the provision of services.

States must also introduce curricula for comprehensive sexuality education that is scientifically accurate, objective and free of discrimination. Sexuality education should be a mandatory and robust component of children’s education,[xlix] aimed at developing “the capacity of children and young people to understand their sexuality in its biological, psychological, socio-cultural and reproductive dimensions which will enable them to make responsible decisions with regard to sexual and reproductive health behavior.”[l]

The Inter-Agency International Technical Guidelines on Sexuality Education and TMBs[li] provide useful guidance on the content of sexuality education programs. Specifically, such programs should include information on reproductive rights,[lii] responsible sexual behavior,[liii] sexual and reproductive health,[liv] prevention of STIs including HIV/AIDS,[lv] prevention of teenage pregnancies,[lvi] and contraception and family planning.[lvii] Additionally, these programs should address the relationships and emotions involved in sexual experiences,[lviii] promote self-esteem, respect for the rights of others, gender equality,[lix] and avoid “reinforcing demeaning stereotypes and perpetuating forms of prejudice.”[lx]

Sexual and reproductive health education should reach all individuals. Thus, sexuality education must be delivered in formal sectors, including both public and private educational establishments, as well as through informal sectors.[lxi] By implementing programs, States can reach children outside of the school system and ensure that sexuality education curricula address the special needs of particularly marginalized adolescents, such as street children and out-of-school youth.

Finally, States should establish monitoring and accountability mechanisms to ensure that the right of the child to enjoy the highest attainable standard of health, including sexual and reproductive health, is fully implemented. The collection of data to assess the nature and extent of specific sexual and reproductive health problems among adolescents, with a view to designing effective policy and service responses to such problems is essential to achieving this. For example, by collecting data on the incidence of early marriage and the rate of maternal mortality among adolescents, States can demonstrate that adolescents that have married at an early age are less likely to access sexual and reproductive health services. As such, States can document the impact of early marriages on children’s health and lives. Consequently, they can work with young people to develop accountability mechanisms that permit the swift identification of problems in service design and delivery and appropriate measures to address them, such as providing reparations to children in circumstances in which States fail to respect, protect and fulfill their human rights obligations.

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[i] The Center for Reproductive Rights is a non-governmental legal advocacy organization in consultative status with the Economic and Social Council since 1997. Its mission is to use the law to advance reproductive freedom as a fundamental human right that all governments are legally obligated to protect, respect, and fulfill. The Center has provided international and comparative legal analysis on the reproductive rights of young people to the United Nations, other inter-governmental organizations, national governments and non-governmental organizations around the world.

[ii] Presented to the Committee on the Rights of the Child on 6 January 2011, in response to the call for submissions published at .

[iii] Committee on the Rights of the Child, General Comment 4: Adolescent health and development in the context of the Convention on the Rights of the Child, (33rd Sess., 2003), U.N. Doc. CRC/GC/2003/4 (2003) [hereinafter CRC, General Comment 4].

[iv] Convention on the Rights of the Child, adopted Nov. 20, 1989, art. 1, G.A. Res. 44/25, annex, UN GAOR, 44th Sess., Supp. No. 49, U.N. Doc. A/44/49 (1989) (entered in to force Sept. 2, 1990).

[v] Programme of Action of the International Conference on Population and Development, Cairo, Egypt, Sept. 5-13, 1994, paras. 7.41, U.N. Doc. A/CONF.171/13/Rev.1 (1995) [hereinafter ICPD Programme of Action].

[vi] Convention on the Rights of the Child, adopted Nov. 20, 1989, art. 24, para. 1, G.A. Res. 44/25, annex, UN GAOR, 44th Sess., Supp. No. 49, U.N. Doc. A/44/49 (1989) (entered into force Sept. 2, 1990) [hereinafter CRC].

[vii] ICPD Programme of Action, supra note 5, paras. 7.44 (a), (b), 7.47; Key Actions for the Further Implementation of the Programme of Action of the International Conference on Population and Development, paras. 35(b), 73(c), (e), U.N. GAOR 21st Special Sess., June 30—July 3, 1999, U.N. Doc. A/S-21/5/Add.1 (1999).

[viii] See, e.g., CEDAW Committee, Concluding Observations: Nigeria, paras. 33-34, U.N. Doc. CEDAW/C/NGA/CO/6 (2008); ESCR Committee, Concluding Observations: Bolivia, para. 43, U.N. Doc. E/C.12/1/Add.60 (2001)

[ix] ICPD Programme of Action, supra note 5, paras. 8.29(a), 8.31, 8.32; see also Further Actions and Initiatives to Implement the Beijing Declaration and Platform for Action, U.N. GAOR, para. 44, U.N. Doc. A/Res/S-23 (2000).

[x] Laura Katzive, Commentary: Protecting Married Adolescents while Respecting their Autonomy: International Standards and Targets for Future Advocacy presented at the WHO/UNFPA/Population Council Technical Consultation on Married Adolescents, Geneva (Dec. 9-12, 2003) (on file with the Center for Reproductive Rights) [hereinafter Katzive, Commentary].

[xi] In evaluating whether adolescents that request reproductive health services have the capacity to make decisions about their sexual and reproductive health care, “[a] general rule is that adolescents capable of freely choosing to be sexually active without parental control are equally capable of receiving reproductive health counseling and care without parental control.” R. Cook and B.M.Dickens, Recognizing adolescents’ ‘evolving capacities’ to exercise choice in reproductive healthcare, 70 International Journal of Gynecology and Obstetrics 13, 20 (2000) [hereinafter Cook, Evolving Capacities].

[xii] Spouses should be included in such policies, if applicable, without prejudice to the principle that the appropriate legal age for marriage is 18 and this Committee’s stance that States should enact legislation to establish the minimum age for marriage at 18 years. CRC, General Comment 4, supra note 3, para. 20.

[xiii] Id. at 15; See also CRC, General Comment 4, supra note 3, para. 32.

[xiv] R. Cook and B.M. Dickens, Adolescents and consent to treatment, International Journal of Gynecology and Obstetrics 184 (2000) [hereinafter Cook, Consent to Treatment].

[xv] Cook, Evolving Capacities, supra note 11, at 17.

[xvi] Cook, Consent to Treatment, supra note 14, at 183, 184.

[xvii]Id.

[xviii] Cook, Evolving Capacities, supra note 11, at 17.

[xix] World Health Organization, Unsafe abortion: Global and regional estimates of the incidence of unsafe abortion and associated mortality in 2008, 27 (6th ed., 2011).

[xx] Cook, Evolving Capacities, supra note 11, at 17.

[xxi] Katzive, Commentary, supra note 10, at 4.

[xxii] Cook, Consent to Treatment, supra note 14, at 184.

[xxiii] CRC, General Comment 4, supra note 4, para. 11.

[xxiv] Paul Hunt & Judith Bueno de Mesquita, University of Essex Human Rights Centre, The Rights to Sexual and Reproductive Health 10 (2007) [hereinafter Sexual and Reproductive Health].

[xxv] Committee on the Elimination of Discrimination Against Women, General Recommendation 24: Women and health, (20th Sess., 1999), para 13, U.N. Doc. A/54/38 (1999) [hereinafter CEDAW Committee, General Recommendation 24].

[xxvi] This Committee and the International Conference on Population and Development Programme of Action have emphasized the importance of providing free or low-cost contraceptive methods and services to adolescents and, especially, to low-income adolescents. Committee on the Rights of the Child, General Comment 3: HIV/AIDS and the Rights of the Child, (33rd Sess., 2003), para. 20, U.N. Doc. CRC/GC/2003/3 (2003) [hereinafter CRC, General Comment 3]; ICPD Programme of Action, supra note 5, para. 7.43.

[xxvii] Sexual and Reproductive Health, supra note 24, at 10; CRC, General Comment 3, supra note 26, para. 16.

[xxviii] See, e.g., CEDAW Committee, Concluding Observations: Nigeria, paras. 33-34, U.N. Doc. CEDAW/C/NGA/CO/6 (2008); ESCR Committee, Concluding Observations: Honduras, para. 27, U.N. Doc. E/C.12/1/Add.57 (2001); ESCR Committee, Concluding Observations: Libyan Arab Jamahiriya, para. 36, U.N. Doc. E/C.12/LYB/CO/2 (2006); CEDAW Committee, Concluding Observations: Slovakia, para. 28, U.N. Doc. CEDAW/C/SVK/CO/4 (2008).

[xxix] See, e.g., CEDAW Committee, Concluding Observations: Lithuania, para. 25, U.N. Doc. CEDAW/C/LTU/CO/4 (2008); CRC Committee, Concluding Observations: Bhutan, para. 45, U.N. Doc. CRC/C/15/Add.157 (2001).

[xxx] Sexual and Reproductive Health, supra note 24, at 10.

[xxxi] Complaint No. 45/2007, International Center for the Protection of Human Rights (INTERIGHTS) v. Croatia, European Committee of Social Rights, (2009) [hereinafter INTERIGHTS v. Croatia].

[xxxii] United Nations Population Fund, State of the World Population 2005, ch. 5 (2005) available at: (recognizing that although countries have made efforts to provide reproductive health education and services, “[m]ost projects remain small in scale, leaving the reproductive health needs of most adolescents-especially the poorest and most marginalized-neglected.”)

[xxxiii] World Health Organization, Unsafe abortion: Global and regional estimates of the incidence of unsafe abortion and associated mortality in 2003 19 (5th ed. 2007).

[xxxiv] Save the Children, Children Having Children: State of the World’s Mothers 2004 4 (2004).

[xxxv] United Nations Education, Scientific and Cultural Organization, International Technical Guidance on Sexuality Education: An evidence-informed approach for schools, teachers and health educators 2, 6 (2009) [hereinafter UNESCO, Technical Guidance].

[xxxvi] K.L. v. Peru, Human Rights Committee, Communication No. 1153/2003, U.N. Doc. CCPR/C/85/D/1153/2003 (2005).

[xxxvii] L.C. v. Peru¸ CEDAW Communication No. 22/2009, U.N. Doc, CEDAW/C/50/D/22/2009 (2009).

[xxxviii] Paulina del Carmen Ramírez Jacinto v. Mexico, Case 161-02, Inter-Am. Comm’n H. R., Report No. 21/07, OEA/Ser.L/V/II.130, doc. 22, rev. 1 (2007).

[xxxix] ESCR Committee, Concluding Observations: Moldova, para. 27, U.N. Doc., E/C.12/MDA/CO/2 (2011).

[xl] John Santelli et al., Abstinence-only education policies and programs: A position paper of the Society for Adolescent Medicine 38 Journal of Adolescent Health (2006);; INTERIGHTS v. Croatia at paras. 60-61 (“the Committee does find that certain specific elements of the educational material used in the ordinary curriculum are manifestly biased, discriminatory and demeaning, notably in how persons of non-heterosexual orientation are described and depicted … By permitting sexual and reproductive health education to become a tool for reinforcing demeaning stereotypes, the authorities have failed to discharge their positive obligation not to discriminate in the provision of such education, and have also failed to take steps to ensure the provision of objective and non-exclusionary health education.”); Special Rapporteur on the Right of Everyone to the Enjoyment of the Highest Attainable Standard of Physical and Mental Health, Rep. of the Special Rapporteur on the right of everyone to the enjoyment of the highest attainable standard of physical and mental health, Anand Grover, Mission to Poland, ¶ 25, Human Rights Council, U.N. Doc. A/HRC/14/20/Add.3 (May 20, 2010); Katarzyna Pabijanek, ASTRA Network Secretariat, Legal commitments to gender equality and SRHR issues in Albania, Macedonia, Georgia, Poland and Ukraine 14 (2009), available at

[xli] Sexuality Information and Education Council of the United States (SIECUS), In Their Own Words: What Abstinence-Only-

Until-Marriage Programs Say (2005).

[xlii] Id.

[xliii] Mathematica Policy Research, Inc., Impacts of Four Title V, Section 510 Abstinence Education Programs: Final Report 59 (2007) (finding that the surveyed abstinence programs had “no overall impact on teen sexual activity [and] no differences in rates of unprotected sex” among those who completed the programs).

[xliv] K.L. v. Peru at para. 6.5.

[xlv] L.C. v. Peru at para. 8.11, 8.15.

[xlvi] See Center for Reproductive Law and Policy & Child and Law Foundation, State of Denial: Adolescent Reproductive Rights in Zimbabwe 56-58 (2002).

[xlvii] See Id. at 58.

[xlviii] Douglas Kirby et al., Tool to Assess the Characteristics of Effective Sex and STD/HIV Education Programs 47 (2007).

[xlix] See, e.g., CEDAW Committee, Concluding Observations: Lithuania, para. 25, U. N. Doc. CEDAW/C/LTU/CO/4 (2008); CRC Committee, Concluding Observations: Ireland, para. 52, U.N. Doc. CRC/C/IRL/CO/2 (2006).

[l] INTERIGHTS v. Croatia at paras. 47-48.

[li] UNESCO, Technical Guidance, supra note 35.

[lii] See, e.g., Rep. of the Committee on the Elimination of Discrimination against Women (CEDAW), 24th Sess., Jan. 15 – Feb. 2, 2001, 25th Sess., July 2-20, 2001, Jamaica, para. 224, Nicaragua, para. 303U.N. Doc. A/56/38 (2001), GAOR 55th Sess., Supp. No. 38 (2001).

[liii] See, e.g., Rep. of CEDAW, 26th Sess., Jan. 14 – Feb. 1, 2002, 27th Sess., June 2-21, 2002, Exceptional Sess., Aug. 5-23, 2002, Estonia, para. 112, U.N. Doc. A/57/38 (2002), GAOR 57th Sess., Supp. No. 38 (2002); Rep. of CEDAW, 2001, supra note 52, Jamaica para. 224; Id., Nicaragua para. 303.

[liv] See, e.g., Rep. of CEDAW, 18th Sess., Jan. 19- Feb. 6, 1998, 19th Sess., June 22 – July 10, 1998, Dominican Republic, para. 349, U.N. Doc. A/53/38 (1998), GAOR 53rd Sess., Supp. No. 38 (1998); Rep. of CEDAW, 16th Sess., Jan. 13 -31, 1997, 17th Sess., July 7-25, 1997, Saint Vincent and the Grenadines, para. 147, U.N. Doc. A/52/38/Rev.1 (1997), GAOR 52nd Sess., Supp. No. 38 (1997).

[lv] CEDAW Committee, Concluding Observations: Cape Verde, para. 30, U.N. Doc. CEDAW/C/CPV/CO/6 (2006); CEDAW Committee, Concluding Observations: Ghana, para. 32, U.N. Doc. CEDAW/C/GHA/CO/5 (2006).

[lvi] See, e.g., CEDAW Committee, Concluding Observations: Mauritius, para. 31, U.N. Doc. CEDAW/C/MAR/CO/5 (2006); CEDAW Committee, Concluding Observations: Philippines, para. 28, U.N. Doc. CEDAW/C/PHI/CO/6 (2006).

[lvii] See, e.g. Rep. of CEDAW, 20th Sess., Jan. 19-Feb. 5, 1999, 21st Sess., June 7-25, 1999, Belize, para 56–57, U.N. Doc. A/54/38/Rev. 1 (1999), GAOR 54th Sess., Supp. No. 38 (1999); CEDAW Committee, Concluding Observations: Bosnia and Herzegovina, para. 36, U.N. Doc. CEDAW/C/BIH/CO/3 (2006); CEDAW Committee, Concluding Observations: Cuba, para. 28, U.N. Doc. CEDAW/C/CUB/CO/6 (2006).

[lviii] Sue Alford et al., Advocates for Youth, Science & Success in Developing Countries: Holistic Programs that Work to Prevent Teen Pregnancy, HIV & Sexually Transmitted Infections 13, 28 (2005).

[lix] Population Council, Addressing Gender and Rights in Your Sex/HIV Education Curriculum: A Starter Checklist (Eleanor Timreck, Deborah Rogow, & Nicole Haberland, eds., 2007); Deborah Rogow & Nicole Haberland, Sexuality and Relationships Education: Toward a Social Studies Approach, 5 Sex Education 333 (2005).

[lx] INTERIGHTS v. Croatia at para. 48.

[lxi] ICPD Programme of Action, supra note 5, para. 11.9.

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