28. The view was stated that the purpose of the optional protocol would determine whether only one, or both procedures, would be needed. The examination of individual complaints, in an approach similar to other existing individual complaints procedures, was seen as the principal purpose of an optional protocol. The view was expressed that only justiciable provisions should fall under the individual complaints procedure, whereas violations of the provisions of the Convention of a more general nature could be addressed, for example, in the framework of the reporting procedure. Element 7 29. With respect to this element, the question of who should have standing to submit a communication was discussed, and whether this should be extended to a person or group having sufficient interest in the matter. 30. Some delegations were of the view that individuals as well as groups should have standing, along the lines of the International Convention on the Elimination of All Forms of Racial Discrimination, as well as of some regional procedures. Standing for groups would be needed in cases of major violations. The language could be specified to read: "groups or organizations with specific interest in women". It was proposed that "groups" could be more specific, such as "groups of persons", or "groups of individuals", or "groups acting on behalf of individuals". Other delegations referred to the example of the first Optional Protocol to the International Covenant on Civil and Political Rights, which granted standing to individuals only. The view was expressed that only victims themselves should have standing. 31. It was stated that, owing to the quasi-judicial nature of the procedure, an approach that allowed groups of victims to file complaints would not be favoured. The comparison to national judicial processes was made, which also did not allow such group complaints. At the same time, the important role of organizations in assisting victims in filing complaints was stressed. The distinction between the victim having the right to complain, and the person, group, or representative who may file a complaint on the person’s behalf, would need to be made clear. In this view, other procedures, such as the communications procedure of the Commission on the Status of Women, were considered more appropriate for widespread or systematic violations. 32. Many delegations stated that the term "organization" needed clarification. Any difference to "groups" would need to be elaborated. If "organization" meant "non-governmental organizations", then it should be so stated, in which case it might be merged with "groups". At the same time, a requirement to have groups file on behalf of their members was also proposed. The Commission was cautioned against broadening the categories of persons who might submit complaints, as the Committee might be flooded with communications, and possible financial implications were noted. On the other hand it was stated that allowing groups to complain could reduce the cost, as the Committee might receive one collective complaint instead of many separate complaints from individuals. Other delegations argued that the inclusion of a third category of "organizations" was called for to address the systematic nature of discrimination and gender-based violence, and would be an innovative element. 33. With regard to the standing criteria of a person or group "having a sufficient interest", many delegations found this to be too vague and broad a formulation. Some delegations found such a provision to be inappropriate. The -110-