State responsibility for eliminating violence against women 2013, para. 16
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One of the debates within the context of due diligence is whether it is an obligation of conduct/means or an obligation of result. The general opinion is that it is one of conduct, however, failure of conduct will likely constitute failure of result. Thus it can be argued that it is the type of conduct which is important. Treaties that establish obligations to protect against rights violations often require States to take appropriate measures, without explicitly defining what measures are appropriate. Similarly, due diligence standards require States to exercise whatever diligence is due; they do not define such diligence.
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Non-negotiated soft law
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Special Rapporteur on violence against women, its causes and consequences