A/72/128 need for adequate and accessible housing of persons with disabilities by implementing necessary programmes and budgetary allocations while also meeting the immediate obligation to accommodate individual needs. The requirement of reasonable measures in both contexts should be seen as a rigorous standard to be met, never as a defence for inaction. 42 48. The Special Rapporteur also emphasizes that reasonable accommodation in housing is often linked to systemic patterns of discrimination and imbalances in power “which result in a society being designed well for some and not for others”. 43 The Supreme Court of Canada warned that reasonable accommodation claims should not be allowed to shield systemic discriminatio n from scrutiny or leave in place imbalances in power that have led to the neglect of the needs or perspectives of marginalized groups in the design of policies. 44 It is important to ask, in each individual case, not only what is required by the individual person with a disability to ensure equality, but also why the housing system created the need for individual accommodation in the first place. Requests for modifications of buildings or housing policies are usually only made because those requirements were not adequately considered when buildings or policies were designed in the first place. Persons with disabilities must be empowered to challenge housing, planning and zoning, social protection and justice systems that fail to meet their needs and thus deny them access to adequate housing. IV. Key components of adequate housing 49. In its general comment No. 4 (1991) on the right to adequate housing, the Committee on Economic, Social and Cultural Rights identified key factors to be considered in determining if housing is adequate. The following is a consideration of those factors as they apply to persons with disabilities. 1. Security of tenure 50. Security of tenure is a cornerstone of the right to housing. Persons with disabilities are less likely to enjoy security of tenure and often experience catastrophic results owing to displacement and forced eviction. They often lose not only their physical home but also a network of support and contacts, without which they may not survive. 51. The obligations of both public and private housing providers with respect to security of tenure must be interpreted and applied in the light of the overriding obligation to ensure the right of persons with disabilities to live in adequate and secure housing within the community, with access to services and support. States must ensure legal protection against forced evictions in all forms of housing tenure, from ownership and formal rental agreements to informal settlements. 45 No eviction should be permitted that would result in the loss of housing or necessary forms of support for persons with disabilities. 46 Where relocation is unavoidable or agreed to by those affected, alternative housing must be provided that meets all requirements __________________ 42 43 44 45 46 17-11724 Committee on Economic, Social and Cultural Rights, general comment No. 3 (1990) on the nature of States parties’ obligations, paras. 9-11. Shelagh Day and Gwen Brodsky, “The duty to accommodate: who will benefit?”, Canadian Bar Review, vol. 75 (1996). Ibid. Guiding principles on security of tenure for urban poor, See A/HRC/25/54. Communication No. 5/2015, Ben Djazia and Bellili v. Spain, views adopted on 20 June 2017, para. 16.5; Committee on Economic, Social and Cultural Rights, general comment No. 7 (1997) on forced evictions, para. 16; Basic principles and guidelines on development based evictions and displacement, A/HRC/4/18, annex I, paras. 54-56. 15/23