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Penalization of people living in poverty 2011, para. 66
- Paragraph text
- Across developing and developed countries, release on bail pending trial is subject to increasingly stringent and onerous conditions which require individuals to, for example, demonstrate their connections with the community, have a fixed address or permanent employment, report regularly to police or make a cash deposit or post a bond as guarantee. These requirements are impossible for the poorest and most marginalized to meet in the vast majority of cases and, as a result, they are more likely to remain in detention pending a trial. This dramatically increases the likelihood that they will ultimately be convicted: not only does it put them in a vulnerable position whereby they will be more inclined to accept unfair "plea deals" or to make admissions of guilt in order to secure a swifter release, it contributes to the deterioration of the detainees' appearance and demeanour, impedes their ability to liaise with lawyers or obtain character witnesses and causes them to lose their employment or social housing, thereby creating a disincentive for the court to give a suspended or community service sentence.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- Persons on the move
- Year
- 2011
Paragraph
Taxation and human rightss 2014, para. 70
- Paragraph text
- Natural resources can be a vital source of revenue that the State can use to comply with its human rights obligations. The financial and social benefits of natural resource exploitation are, however, increasingly bypassing people in producing countries. In most countries, extractive industries generate few jobs directly and have only weak links to local markets. Far from bringing benefits, the exploitation of natural resources has been frequently linked to human rights abuse and encroachment on lands and livelihoods of communities, mass evictions, pollution and environmental degradation, which may result in violations of rights to health, food, housing and water. The right of people to participate in decisions regarding natural resources is often violated, especially where the land, territory and resources of indigenous peoples is concerned.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Economic Rights
- Environment
- Person(s) affected
- All
- Year
- 2014
Paragraph
The right to participation of people living in poverty 2013, para. 60
- Paragraph text
- From a human rights perspective, effective access to public information is a precondition for exercising other human rights. Exercise of the right to participation depends on transparency and access to complete, up-to-date and comprehensible information. People must have the capacity and opportunity to use the information, understand their entitlements and be able to evaluate the quality of the services, policies or programmes in question. Transparency is essential to ensure rights holders are fully aware of the aims and scope of the process, the other actors involved and their role and level of influence.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2013
Paragraph
The UN responsibility for the cholera outbreak in Haiti 2016, para. 36
- Paragraph text
- Third, the contention that receipt of the claims would "necessarily involve a review of political and policy matters" is self-serving and unjustified. The claims are far from being "political" in the sense defined by the Secretary-General in 1995 as those targeting actions or decisions of political organs, nor are they rambling denunciations (see A/C.5/49/65). In terms of policies, it is true that waste management and other such internal policies might need to be reviewed, but if that prospect is enough to trigger non-receivability, it would become effectively impossible ever to claim damages from the United Nations.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
Marginality of economic and social rights 2016, para. 40
- Paragraph text
- Many books have now been written extolling the virtues of involvement by the courts in enforcing economic and social rights in various countries around the world, but justiciability is by no means the whole story. Indeed, it might be argued that the focus on justiciability has become the tail that is wagging the analytical dog. Rights holders can seek accountability through many means, including: (a) sharing information with the media; (b) using community or peer pressure; (c) collecting and publishing data; (d) complaining to an authoritative body or person; and (e) evaluating and reporting. However, most of these methods assume that, at the end of the day, there will be a mechanism in place to which the claim can ultimately be brought for vindication in the absence of self-correction by the duty holder.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
The UN responsibility for the cholera outbreak in Haiti 2016, para. 51
- Paragraph text
- Given the extent to which there is agreement on this legal framework, the puzzle is why the current position of the United Nations remains so very distant from the outcome that these principles seem to require. In essence, there are two reasons. The first is the determination to abide by the unpublished legal opinion that declares the claim not to be of a private character. For the reasons explained above, this opinion should be reconsidered and revised. The second reason is the failure to openly acknowledge and clearly address a range of background considerations which have fuelled fears that have apparently deterred the various actors from seeking to resolve the problem in a principled manner. The report turns now to examining those matters.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
The right to participation of people living in poverty 2013, para. 39
- Paragraph text
- To fully respect dignity and autonomy, participatory processes must be meaningful for those living in poverty and they should be able to exert influence over the final outcome. They should be included in all stages of the relevant decision-making processes so that they have the chance to set priorities or question the agenda in fundamental ways.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Poverty
- Social & Cultural Rights
- Person(s) affected
- All
- Year
- 2013
Paragraph
The World Bank and human rights 2015, para. 70
- Paragraph text
- No outsider can prescribe an ideal recipe for the Bank to follow in adopting a human rights policy. There are many options and paths that could reasonably be taken. The Bank is a very special organization and it will need a carefully tailored policy that takes adequate account of the many concerns that will undoubtedly be expressed. Most of all, there needs to be a transparent discussion, based on carefully thought-through proposals.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2015
Paragraph
The right to participation of people living in poverty 2013, para. 48
- Paragraph text
- Appropriate mechanisms for coordinating participation must be developed; these should be participatory themselves. In terms of the inclusion and identification of participants, programmes must be targeted to ensure the involvement of all stakeholders who may be or perceive themselves to be affected by the policy, decision or programme in question. The principles of non-discrimination and equality necessitate that participants must be identified in a transparent and proactive way. This should include undertaking a stakeholder analysis or mapping to identify vulnerable or disadvantaged groups with a stake in the outcomes of the decision; ensuring that the most marginalized groups and communities are identified and engaged from the outset, taking into account the obstacles they face; and dedicating resources to reach out to them.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2013
Paragraph
The World Bank and human rights 2015, para. 75
- Paragraph text
- Diverse civil society actors also needs to think through in a more systematic and nuanced way what exactly they would like to see from a human rights initiative. In the view of the Special Rapporteur, it is debatable whether some of the roles that the Bank has been called upon to undertake in the past are appropriate. The Bank cannot be expected to carry the burden of the expectations of every human rights demand that might be made in a given situation. There are limits to what can reasonably be expected of it and there are legitimate questions related to its mandate and the respective roles that should be played by different actors. Placing unreasonable demands on the Bank merely reinforces the fears of those who are currently resisting change in that area.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- N.A.
- Year
- 2015
Paragraph
Taxation and human rightss 2014, para. 18
- Paragraph text
- The right to self-determination, enshrined in both the International Covenant on Economic, Social and Cultural Rights and the International Covenant on Civil and Political Rights, expressly encompasses the rights of peoples (not the State or Government) to freely dispose of their natural wealth and resources. Considering that many natural resources are finite and non-renewable, this right needs to be protected with special care, taking into account the rights of future generations. At the very least, a State's population has a right to enjoy a fair share of the financial and social benefits that natural resources can bring. This requires ensuring participation, access to information and high standards of transparency and accountability in decision-making about the use of natural resources. Where indigenous peoples are involved, States have additional and specific obligations, including ensuring free, prior and informed consent in any decisions regarding the use of their lands.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Economic Rights
- Governance & Rule of Law
- Social & Cultural Rights
- Person(s) affected
- Ethnic minorities
- Year
- 2014
Paragraph
Human rights based approach to recovery from the global economic and financial crises, with a focus on those living in poverty 2011, para. 25
- Paragraph text
- At the core of the human rights framework is an overarching requirement that all States take into consideration the principles of participation, transparency and accountability in the design, implementation and evaluation of State policies. Human rights are important not only in the outcome of State policies but also in the process by which they are formulated and implemented. These principles are integral both to ensuring effectiveness in the adopted policy and responding to the obligations of States with regard to the rights to take part in public life, to seek and receive information and to have access to effective remedies in cases of violation.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2011
Paragraph
The right to participation of people living in poverty 2013, para. 24
- Paragraph text
- There is no doubt that initiating and sustaining meaningful and effective participatory processes requires time, patience, resources and planning. However, it is not a simple policy option that policymakers can choose not to implement. States (all branches at the local, national and international levels) have a legal obligation to implement inclusive, meaningful and non-discriminatory participatory processes and mechanisms, and to engage constructively with the outcomes. With political will, all States are in a position to improve the enjoyment of this right. The practices of some States, United Nations agencies and civil society organizations has shown that it is possible for States to create or support participatory mechanisms that succeed in empowering disadvantaged members of the public and improving policy. Experience shows that the benefits and opportunities outweigh the risks and challenges.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2013
Paragraph
The right to participation of people living in poverty 2013, para. 26
- Paragraph text
- These norms have been further developed by human rights monitoring bodies, who have emphasized that participation should be understood broadly and requires concrete political, legal and institutional actions. Electoral participation is just one specific expression of the right to participation (A/HRC/18/42, para. 5); although free and fair elections are a crucial component, they are not enough to ensure that those living in poverty enjoy the right to participation in key decisions affecting their lives (E/C.12/2001/10, para.12). According to the Human Rights Committee, the right to participation in the conduct of public affairs covers "all aspects of public administration, including the formulation and implementation of policy at international, national, regional and local levels" (CCPR/C/21/Rev.1/Add.7, para. 5). The right to participation necessitates participatory mechanisms with a legal basis, providing for "access to appropriate information, adequate support, feedback … and procedures for complaints, remedies or redress" (CRC/C/GC/12, para. 48). Participation should not be a one-off event, but requires a long process of intensive dialogue regarding the development of policies, programmes and measures in all relevant contexts (ibid., para. 13). For example, the Committee on Economic, Social and Cultural Rights has said that participation in decision-making processes must be an integral component of any policy, programme or strategy related to the rights to health and water (E/C.12/2000/4, para. 54, and E/C.12/2002/11, para. 48). The right is not limited to participation in formal political institutions, but also in civil, cultural and social activities (A/HRC/18/42, Annex, para. 5); for example, the right to take part in cultural life is also an essential element of the right to participation, and States must adopt concrete measures to ensure enjoyment of this right (E/C.12/GC/21, para. 39).
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Poverty
- Person(s) affected
- All
- Year
- 2013
Paragraph
The right to participation of people living in poverty 2013, para. 20
- Paragraph text
- This report focuses on the intrinsic value of participation as a fundamental right to which individuals are inherently entitled by virtue of their humanity. This right to take part and exert influence in decision-making processes that affect one's life is inextricably linked to the most fundamental understanding of being human and the purpose of rights: respect of dignity and the exercise of agency, autonomy and self-determination. The right to participation imposes concrete obligations on States voluntarily assumed in several binding human rights instruments.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2013
Paragraph
Marginality of economic and social rights 2016, para. 55
- Paragraph text
- Despite these impressive reporting figures, in half of the concluding observations the Committee recommended that measures be taken to ensure the "direct applicability" of the Covenant in the domestic legal order. In slightly less than half of the concluding observations, the Committee also recommended that the State concerned seek to raise awareness of the justiciability of the rights. And in almost every concluding observation (27), the Committee recommended that legislation be enacted or amended in order to implement Covenant obligations.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- N.A.
- Year
- 2016
Paragraph
The UN responsibility for the cholera outbreak in Haiti 2016, para. 67
- Paragraph text
- The Special Rapporteur has argued above that the major concerns that appear to underlie the abdication approach can all be addressed satisfactorily without jeopardizing any core interests of the United Nations or its Member States. But the case to be made in favour of action is actually much stronger than that conclusion might suggest. Thus, before outlining what a constructive and responsible approach might look like, it is important to highlight the positive reasons which argue strongly for an urgent change of policy.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
Social protection and old age poverty 2010, para. 73
- Paragraph text
- States must remove administrative barriers that prevent older people from accessing social pensions, such as requiring identification documents for registration when such documents are costly or may not exist in countries where many people are not registered at birth. Administrative requirements often affect women disproportionately as they are less likely to have identity cards and have been registered at birth. There are alternative ways to assess and record ages based on local knowledge and personal references. Furthermore, the establishment of social pensions can be used as an opportunity to improve data collection and registration.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Person(s) affected
- Older persons
- Women
- Year
- 2010
Paragraph
Access to justice for people living in poverty 2012, para. 9
- Paragraph text
- The right to equality before the courts and tribunals and the right to a fair trial consist of a complex set of rules and practices that include the right to a fair and public hearing within a reasonable time and respect of the principles of equality of arms and presumption of innocence, among others. While the rules regarding due process are included in several provisions of international human rights treaties, of particular relevance is article 14 of the International Covenant on Civil and Political Rights, which provides that "all persons shall be equal before the courts and tribunals" in criminal and civil cases and creates an obligation upon States to ensure that everyone has access to "a fair and public hearing by a competent, independent and impartial tribunal established by law" in "the determination of any criminal charge against him or of his rights and obligations in a suit at law".
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2012
Paragraph
The right to participation of people living in poverty 2013, para. 34
- Paragraph text
- The United Nations Declaration on the Rights of Indigenous Peoples, although not legally binding, developed further the importance of free, prior and informed consent in matters of fundamental importance for the rights, survival and dignity of indigenous peoples, based on their right to self-determination. "Free" means without coercion, intimidation or manipulation; "prior" implies in advance of the activity or decision being made, with sufficient time for indigenous peoples to undertake their own decision-making processes; "informed" necessitates provision of objective, accurate and complete information relating to the activity, presented in a manner and form understandable to indigenous peoples (A/HRC/18/42, Annex, para. 25).
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Social & Cultural Rights
- Person(s) affected
- Ethnic minorities
- Year
- 2013
Paragraph
Marginality of economic and social rights 2016, para. 45
- Paragraph text
- Second, even when economic and social rights are both constitutionally recognized and justiciable, there are many factors that can limit the resulting outcomes. Lawyers might not invoke such rights, a lack of resources and the absence of legal aid might make it impossible for many violations of economic and social rights to be litigated and potential applicants might be denied standing to sue. Even when cases get to court, the judiciary might not be independent, the judicial culture might not be amenable to scrutinizing the sort of issues raised by economic and social rights and the remedies available might be so weak as to deter such litigation.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2016
Paragraph
The UN responsibility for the cholera outbreak in Haiti 2016, para. 29
- Paragraph text
- The claimants challenged the non-receivability finding and requested either mediation or a meeting to discuss the matter. In July 2013, the Under-Secretary-General wasted no words in dismissing such requests: "In relation to your request for the engagement of a mediator, there is no basis for such engagement in connection with claims that are not receivable. As these claims are not receivable, I do not consider it necessary to meet and further discuss this matter." Left with no further recourse within the United Nations, the claimants filed a class action suit in October 2013 with the United States District Court for the Southern District of New York. In January 2015, the court ruled that the defendants were immune from suit, a finding upheld on 19 August 2016 in Georges v. United Nations by the Court of Appeals for the Second Circuit.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
Human rights based approach to recovery from the global economic and financial crises, with a focus on those living in poverty 2011, para. 89
- Paragraph text
- A human rights-based recovery from the successive crises must be one in which all segments of society play a significant role. The human rights principles of participation, transparency and accountability require States to create and maintain mechanisms by which individuals can meaningfully and effectively contribute to, provide feedback on and claim redress from policy measures that affect their enjoyment of human rights.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2011
Paragraph
The World Bank and human rights 2015, para. 18
- Paragraph text
- The next step is to demonstrate that criminal justice interventions will not violate the political prohibition. While acknowledging that "most development efforts" have a "political dimension," a narrow interpretation is adopted, according to which the Bank cannot involve "itself in the partisan politics or ideological disputes that affect its member countries". Inappropriate involvement is said to include "favoring political factions, parties or candidates in elections," or "endorsing or mandating a particular form of government, political bloc or political ideology."
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2015
Paragraph
The right to participation of people living in poverty 2013, para. 28
- Paragraph text
- Regarding the right to information, States have to make every effort to ensure easy, prompt, effective and practical access to information which might be of public interest, including by proactively making this information available and putting in place necessary procedures which enable prompt, effective, practical and easy access to information. Fees charged should not constitute an unreasonable impediment to access to information, and an appeals system should be in place to challenge failures to provide information (CCPR/C/CG/34).
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2013
Paragraph
Taxation and human rightss 2014, para. 22
- Paragraph text
- Decision-making processes regarding tax and public revenues must therefore be based on full transparency and the broadest possible national dialogue, with effective and meaningful participation of civil society and those who will be directly affected by such policies, including people living in poverty. Fiscal policies should be subjected to the scrutiny of the population during design, implementation and evaluation stages, with the various interests transparently identified. This will require capacity-building and fostering fiscal literacy in the population. The population should have access to all relevant information in an accessible and understandable format, and inclusive mechanisms should be put in place to ensure that they are actively engaged in devising the most appropriate policy options. Owing to the asymmetries of power, expertise and interests in this debate, specific measures should be taken to ensure equal access and opportunities to participate, particularly for people living in poverty.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Poverty
- Person(s) affected
- All
- Year
- 2014
Paragraph
Access to justice for people living in poverty 2012, para. 77
- Paragraph text
- Despite States' obligation to ensure that individuals facing a criminal charge have access to a free interpreter (International Covenant on Civil and Political Rights, art. 14.3 (f)), often this service is limited, unavailable or reserved for those who speak a foreign language, rather than a minority language or local dialect, and is rarely provided in civil cases. The issue of language disproportionately disadvantages women, who are not only less likely to speak the predominant language and require an interpreter, but who are also vulnerable to abuse or exploitation by interpreters, whose cultural prejudices may inform their translation.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Movement
- Person(s) affected
- Women
- Year
- 2012
Paragraph
The UN responsibility for the cholera outbreak in Haiti 2016, para. 83
- Paragraph text
- First and foremost, there should be an apology and an acceptance of responsibility in the name of the Secretary-General.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
Marginality of economic and social rights 2016, para. 19
- Paragraph text
- Closely linked to this loss of legitimacy is a loss of credibility in the eyes of rights holders. The second-class status of economic and social rights has deeply negative consequences for the potential of the human rights movement to gain the widespread support that it needs in order to establish its credibility in the eyes of the literally billions of people whose fundamental needs continue to be of only minor relevance to the core human rights agenda. The fact that the movement is subject to powerful challenges at the global level is due in significant part to the perception that its overriding preoccupations do little or nothing to address the most abiding and pressing challenges confronted by a large part of humanity.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Governance & Rule of Law
- Social & Cultural Rights
- Person(s) affected
- N.A.
- Year
- 2016
Paragraph
Taxation and human rightss 2014, para. 21
- Paragraph text
- Many human rights treaties emphasize the right to participation. In particular, article 25 of the International Covenant on Civil and Political Rights includes the right of all people to take part in the conduct of public affairs, a right that covers all aspects of public administration and the formulation and implementation of policy at international, national, regional and local levels. Effective and meaningful participation is in turn dependent on the right to seek, receive and impart information.
- Body
- Special Rapporteur on extreme poverty and human rights
- Document type
- Special Procedures' report
- Topic(s)
- Civil & Political Rights
- Equality & Inclusion
- Governance & Rule of Law
- Person(s) affected
- All
- Year
- 2014
Paragraph