Tag: reproductive freedoms

When States effectively ban contraception – the international legal framework

(reading: 25 minutes; post-graduate level)

Monthly oral contraception pills on a yellow background; photo by Karola, courtesy of Pexels

The United Nations considers access to birth control to be a universal human right, but that right is increasingly denied even in democratic States. According to the World Health Organization (WHO), education and information on sexual and reproductive health, combined with access to contraception, have been proven to reduce teenage pregnancies, unsafe abortions, maternal morbidity and mortality, and the transmission of STDs.[i] Policies that effectively ban contraception choices violate international human rights law. Therefore, this paper examines a case study on the international legal findings by the United Nations Committee on the Elimination of Discrimination against Women that may shed light on the declining situation for women and adolescents of the United States of America and elsewhere. As women’s rights to sexual and reproductive healthcare are increasingly threatened, knowledge sharing is essential.

“HHS is aligning the program with President Trump’s pro-life and pro-family agenda.”
Emily Hilliard, a spokesperson for the United States Department of Health and Human Services

The impacts of the United States’ increasing interference on contraception can be foreseen through the case study of a situation in the Philippines from between 2004 – 2012. The rhetoric of the public policy planning is alarmingly similar to the current U.S. Administration’s. Under a multi-party democracy with an elected president and legislature, women and girls in the Philippines were effectively denied access to contraception and comprehensive information on sexual and reproductive health rights (SRHR), including family planning.

Case study: inquiry concerning the Philippines

In 2008 the Committee on the Elimination of Discrimination against Women received a joint submission from NGOs in the Philippines related to legislative acts imposed by concurrent mayors of Manila. A decentralization of health services, family planning and population development in the Philippines allowed the Manila City Council to enact legislation by ordinance, while the mayor had the authority of executive orders.

“Executive Order No. 003 recalled the sanctity of life including the protection of the life of the mother and the unborn, as enshrined in the Constitution, and declared that the City of Manila would take an ‘affirmative stand on pro-life issues’ (…).” “The Order also provided that the City would ‘promote responsible parenthood and uphold natural family planning not just as a method but as a way of self-awareness in promoting the culture of life while discouraging the use of artificial methods of contraception like condoms, pills, intrauterine devices, surgical sterilization, and other’.”[ii]

While Executive order No. 003 did not expressly prohibit the use of contraceptives, the implementation of the policies in practice severely limited access, which effectually resulted in their banning in Manila. The situation was worsened by the subsequent mayor, who continued its implementation and issued Executive Order No. 030, which imposed a funding ban on modern contraception.

Both mayors who imposed these executive orders were Catholic.

Makati, Metro Manila, Philippines; photo by Sean Yoro; courtesy of Unsplash

The CEDAW Committee considered the complaint information received “to be reliable and indicative of grave or systemic violations”[iii] according to international standards. As such, they conducted a confidential inquiry through the assistance of relevant NGOs to investigate the availability of contraceptives in Manila. They found evidence women and girls were provided with information on ‘natural family planning’ but were given misinformation about modern methods of contraception even though listed as Essential Medicines by the World Health Organization.[iv]

By excluding access to the full range of sexual and reproductive health services and commodities between 2007-11, women in Manila experienced damaging impacts on their health and lives. In particular, the executive orders “had detrimental consequences for economically disadvantaged women and drove them further into poverty by depriving them of an opportunity to control the number and spacing of their children.”[v] The multiple pregnancies adversely affected women’s mental and physical health, increased their exposure to STDs including HIV/AIDS, and “contributed to tension with their husbands or partners and fostered domestic violence.”[vi]

Executive Order Nos. 003 and 030 negatively affected women as

“such implementation over many years had a severe impact on their health and on their access to adequate health care services. The Committee observes that the lives and health of many women were put at risk, given that they were compelled to have more children than they wanted or than their health permitted them to have. The Committee particularly takes note of the potentially life-threatening consequences of unplanned and/or unwanted pregnancies as a direct consequence of the denial of access to the full range of contraceptive methods, as well as of the strict criminalization of abortion without any exemptions provided for in the State party’s legislation. Complications resulting from unsafe and illegal abortions are a prominent cause of maternal death in Manila, as acknowledged by the State party. It is therefore evident for the Committee that the failure of the State party to provide the full range of sexual and reproductive health services, commodities and information resulted in unplanned pregnancies, unsafe abortions and unnecessary and preventable maternal deaths.”[vii]

The Committee also found that “adolescent girls were exposed to an increased risk of unwanted pregnancies and pregnancy-related injuries or death following unprotected or coerced sex, to which they are particularly vulnerable.”[viii]

In the Manila case, the CEDAW Committee clarified that

“distinctive health features that differ for women in comparison to men include biological factors such as women’s reproductive functions. Given that such factors have a bearing on women’s reproductive health needs, the Committee considers that substantive equality requires that States parties attend to the risk factors that predominantly affect women. Given that only women can become pregnant, lack of access to contraceptive is therefore bound to affect their health disproportionately. (…) Women in Manila primarily bore the consequences of and were disproportionately disadvantaged by the inability to gain access to and use the full range of reproductive health services, including modern methods of contraception.”[ix]

The CEDAW Committee found the Republic of the Philippines in violation of the CEDAW Convention, Articles 2 (d), 2 (f) and Article 12.

The prohibition of discrimination and the right to health

According to Article 2 of CEDAW

States Parties condemn discrimination against women in all its forms, agree to pursue by all appropriate means and without delay a policy of eliminating discrimination against women and, to this end, undertake:

(a) To embody the principle of the equality of men and women in their national constitutions or other appropriate legislation if not yet incorporated therein and to ensure, through law and other appropriate means, the practical realization of this principle;

(…)

(d) To refrain from engaging in any act or practice of discrimination against women and to ensure that public authorities and institutions shall act in conformity with this obligation;

(…)

(f) To take all appropriate measures, including legislation, to modify or abolish existing laws, regulations, customs and practices which constitute discrimination against women

The Convention on the Elimination of Discrimination against Women (CEDAW) provides for family planning services, in Article 12, para. 1.

1. States Parties shall take all appropriate measures to eliminate discrimination against women in the field of health care in order to ensure, on a basis of equality of men and women, access to health care services, including those related to family planning.

The Committee on the Elimination of Discrimination Against Women distributed General Recommendation No. 24: Article 12 of the Convention (women and health) in 1999. It clarified the obligations of the State, including

13. The duty of States parties to ensure, on a basis of equality of men and women, access to health-care services, information and education implies an obligation to respect, protect and fulfil women’s rights to health care. States parties have the responsibility to ensure that legislation and executive action and policy comply with these three obligations. They must also put in place a system that ensures effective judicial action. Failure to do so will constitute a violation of article 12.[x]

Furthermore,

17. The duty to fulfil rights places an obligation on States parties to take appropriate legislative, judicial, administrative, budgetary, economic and other measures to the maximum extent of their available resources to ensure that women realize their rights to health care. Studies such as those that emphasize the high maternal mortality and morbidity rates worldwide and the large numbers of couples who would like to limit their family size but lack access to or do not use any form of contraception provide an important indication for States parties of possible breaches of their duties to ensure women’s access to health care. [xi]

A group of children playing a traditional game on streets of Philippines. Photo by Grace; courtesy of Pexels.

Whiles those obligations cited under the Manila investigation by the CEDAW Committee are owed under the Convention, there are other international human rights and domestic legal obligations that may also apply.

Similar rights and fundamental freedoms, such as the prohibition of discrimination, frequently fall under multiple treaties because human rights are both interdependent and interrelated. Many obligations will be owed by several UN Member States, depending on the treaties they have each ratified; their domestic law should reflect those human rights accordingly.

Health rights and reproductive freedoms

Access to contraception is anchored in international human rights lawunder the right to health, which is found in Article 12 of the International Covenant on Social, Economic and Cultural Rights (ICESCR).

ICESCR – Article 12

1. The States Parties to the present Covenant recognize the right of everyone to the enjoyment of the highest attainable standard of physical and mental health.

2. The steps to be taken by the States Parties to the present Covenant to achieve the full realization of this right shall include those necessary for:

(a) The provision for the reduction of the stillbirth-rate and of infant mortality and for the healthy development of the child;

(b) The improvement of all aspects of environmental and industrial hygiene;

(c) The prevention, treatment and control of epidemic, endemic, occupational and other diseases;

(d) The creation of conditions which would assure to all medical service and medical attention in the event of sickness.

The Economic and Social Council (ECOSOC) – Committee on Economic, Social and Cultural Rights (CESR) is tasked with the interpretation of the International Covenant on Economic, Social and Cultural Rights (ICESCR). The Committee provides clarity on the normative content of Article 12 in its General Comment No. 14 as follows.

(8.) The right to health is not to be understood as a right to be healthy. The right to health contains both freedoms and entitlements. The freedoms include the right to control one’s health and body, including sexual and reproductive freedom, and the right to be free from interference, such as the right to be free from torture, non-consensual medical treatment and experimentation. By contrast, the entitlements include the right to a system of health protection which provides equality of opportunity for people to enjoy the highest attainable level of health.[xii]

Furthermore, the State is bound to the principle of non-discrimination, including discrimination according to sex and gender. Specifically,

“States are under the obligation to respect the right to health by, inter alia, (…) abstaining from imposing discriminatory practices relating to women’s health status and needs. (…) In addition, States should refrain from limiting access to contraceptives and other means of maintaining sexual and reproductive health, from censoring, withholding or intentionally misrepresenting health-related information, including sexual education and information, as well as from preventing people’s participation in health-related matters.”[xiii]

The Committee on Economic and Social Rights interprets Article 12.2 (a), The right to maternal, child and reproductive health, as follows.

14. “The provision for the reduction of the stillbirth rate and of infant mortality and for the healthy development of the child” (art. 12.2 (a))¹⁰ may be understood as requiring measures to improve child and maternal health, sexual and reproductive health services, including access to family planning, pre- and post-natal care,¹¹ emergency obstetric services and access to information, as well as to resources necessary to act on that information.”

Photo by Reproductive Health Supplies Coalition; courtesy of Unsplash

The United Nations Office of the High Commissioner (OHCHR) also recognized that “sexual and reproductive health is an integral part of the right to health”[xiv] when they published General Comment No. 22 on the right to sexual and reproductive health (article 12 of the International Covenant on Economic, Social and Cultural Rights) in 2016.

Under the normative content of the right to sexual and reproductive health, the OHCHR stated that “Essential medicines should also be available, including a wide range of contraceptive methods, such as condoms and emergency contraception, medicines for abortion and for post-abortion care, and medicines, including generic medicines, for the prevention and treatment of sexually transmitted infections and HIV.”[xv]

Furthermore, “Unavailability of goods and services due to ideologically based policies or practices, such as the refusal to provide services based on conscience, must not be a barrier to accessing services. An adequate number of health-care providers willing and able to provide such services should be available at all times in both public and private facilities and within reasonable geographical reach.”[xvi] This is applicable not only to contraception, but also to abortion and post-abortion care. Policy making based on ideology alone runs counter to human rights.

Freedom of religion serves atheists too

Often referred to as the ‘separation of church and State’ in domestic law, international law prohibits discrimination on the basis of religion or beliefs – this includes the protection of those who choose no religion. This provision is found in the International Covenant on Civil and Political Rights (ICCPR) (1966).

ICCPR – Article 18

1. Everyone shall have the right to freedom of thought, conscience and religion. This right shall include freedom to have or to adopt a religion or belief of his choice, and freedom, either individually or in community with others and in public or private, to manifest his religion or belief in worship, observance, practice and teaching.

2. No one shall be subject to coercion which would impair his freedom to have or to adopt a religion or belief of his choice.

3. Freedom to manifest one’s religion or beliefs may be subject only to such limitations as are prescribed by law and are necessary to protect public safety, order, health, or morals or the fundamental rights and freedoms of others.

4. The States Parties to the present Covenant undertake to have respect for the liberty of parents and, when applicable, legal guardians to ensure the religious and moral education of their children in conformity with their own convictions.

Article 18 protects theistic, non-theistic and atheistic beliefs, as well as the right not to profess any religion or belief. The terms belief and religion are to be broadly construed.
General Comment No. 22 by the United Nations Human Rights Committee (1993)

Freedom of religion also entails the right to have no religion at all. In 1993 the United Nations Human Rights Committee (UNHRC) adopted General Comment No. 22 to clarify the scope of Article 18 of the ICCPR.

2. Article 18 protects theistic, non-theistic and atheistic beliefs, as well as the right not to profess any religion or belief. The terms belief and religion are to be broadly construed.

(…)

5. The Committee observes that the freedom to “have or to adopt” a religion or belief necessarily entails the freedom to choose a religion or belief, including, inter alia, the right to replace one’s current religion or belief with another or to adopt atheistic views, as well as the right to retain one’s religion or belief. Article 18 (2) bars coercions that would impair the right to have or adopt a religion or belief, including the use of threat of physical force or penal sanctions to compel believers or non-believers to adhere to their religious beliefs and congregations, to recant their religion or belief or to convert. Policies or practices having the same intention or effect, such as for example those restricting access to education, medical care, employment or the rights guaranteed by article 25 and other provisions of the Covenant are similarly inconsistent with article 18 (2). The same protection is enjoyed by holders of all beliefs of a non-religious nature.

Manila, Philippines. Photo by Mike Mijares; courtesy of Pexels.

‘Natural family planning’, which was promulgated in the Executive Orders 003 and 030 in Manila, is central to Catholic teaching. However, under Article II of the 1987 Constitution of the Republic of the Philippines, Declaration of Principles and State Policies Principles, “The separation of Church and State shall be inviolable.”[xvii] The CEDAW Committee found that despite the inviolability of Church and State “the Church has considerable influence on policy making. Religion has been relied upon as the basis for sexual and reproductive health policies, including at the level of local government units”.[xviii]

Likewise, the First Amendment of the Constitution of the United States of America states that “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof”.[xix] The United States Courts (.gov) website, reads “Today, what constitutes an ‘establishment of religion’ is often governed under the three-part test set forth by the U.S. Supreme Court in Lemon v. Kurtzman, 403 U.S. 602 (1971). Under the ‘Lemon’ test, government can assist religion only if (1) the primary purpose of the assistance is secular, (2) the assistance must neither promote nor inhibit religion, and (3) there is no excessive entanglement between church and state.”[xx]

In 2009 the Republic of the Philippines adopted an Act providing for a comprehensive women’s human rights instrument – the Magna Carta of Women (Republic Act No. 9710). The Act incorporated elements of the Universal Declaration of Human Rights such as the principle of non-discrimination, and much of the CEDAW Convention, into the Philippine national framework.

Section 3 of the Magna Carta of Women affirms a general principle of international law, which is that because human rights are interdependent and interrelated “the fulfillment of one right often depends, wholly or in part, upon the fulfilment of others”[xxi]. Unfortunately, the Philippine government failed to fully implement the Act, specifically on family planning provisions from Section 17 – Women’s Right to Health, and to monitor for compliance. Essentially, human rights were violated by integrating religious doctrine into public policy.

Freedom of expression and the right to receive information

States have an obligation to provide comprehensive information on healthcare, including contraception methods, their effectiveness and side effects. Campaigns of misinformation and disinformation by the State may be a human rights violation.

The World Health Organization states that “people must have guaranteed access to sexuality education, including information about contraceptives, that enables them to decide freely and responsibly the number and spacing of their children, as well as access to specific educational information to help ensure the health and well-being of families”.

The International Declaration of Civil and Political Rights (ICCPR), Article 19, provides for the fundamental freedom of expression. The clause on the right to receive information is found within Article 19, para. 2.

2. Everyone shall have the right to freedom of expression; this right shall include freedom to seek, receive and impart information and ideas of all kinds, regardless of frontiers, either orally, in writing or in print, in the form of art, or through any other media of his choice.

Photo by Vitaly Gariev; courtesy of Unsplash

Freedom of expression and the right to seek and receive information, according to Article 19 of the ICCPR, combined with the right to health, was expressed in the Committee on Economic, Social and Cultural Rights’ (CESR) General Comment No. 14: The right to the highest attainable standard of health.

8. (…) States should refrain from limiting access to contraceptives and other means of maintaining sexual and reproductive health, from censoring, withholding or intentionally misrepresenting health-related information, including sexual education and information, as well as from preventing people’s participation in health-related matters.”[xxii]

The Philippine Magna Carta of Women, which took effect on September 15, 2009, provides the right for women and girls to receive information related to their sexual and reproductive health.

“All people have the right to participate in and access information relating to the decision-making processes that affect their lives and well-being.”[xxiii]

That statement is consistent with the World Health Organization and the United Nations’ own statements and recommendations.

State responsibility and the devolution of powers in domestic law

As the primary subjects of international law, the nation State bears responsibility for all acts and omissions that violate international agreements – not the sub-national levels of government whether provincial, territorial, regional or local. As clarified in the International Law Commission’s Responsibility of States for Internationally Wrongful Acts (2001), General Commentary, “The State is treated as a unity, consistent with its recognition as a single legal person in international law.”[xxiv] Therefore, the Philippines bears responsibility for all acts and omissions by its sub-national government entities, including the City of Manila. So too does the United States of America, for example, over any of its sub-national States. This principle runs throughout international law.

A map of the United States’ terrain, and neighbouring States.

See CEDAW’s General Comment No. 28, paragraph 39, on the devolution of powers.

39. “…The decentralization of power, through devolution and delegation of Government powers in both unitary and federal States, does not in any way negate or reduce the direct responsibility of the State party’s national or federal Government to fulfil its obligations to all women within its jurisdiction. In all circumstances, the State party that ratified or acceded to the Convention remains responsible for ensuring full implementation throughout the territories under its jurisdiction. In any process of devolution, States parties have to make sure that the devolved authorities have the necessary financial, human and other resources to effectively and fully implement the obligations of the State party under the Convention. The Governments of States parties must retain powers to require such full compliance with the Convention and must establish permanent coordination and monitoring mechanisms to ensure that the Convention is respected and applied to all women within their jurisdiction without discrimination. Furthermore, there must be safeguards to ensure that decentralization or devolution does not lead to discrimination with regard to the enjoyment of rights by women in different regions.”[xxv]

Findings of human rights violations are attributed to the State under whose jurisdiction the violations occurred. This was affirmed in the Magna Carta of Women under Section 3.

States and other duty-bearers are answerable for the observance of human rights. They must comply with the legal norms and standards enshrined in international human rights instruments in accordance with the Philippine Constitution. Where they fail to do so, aggrieved rights-holders are entitled to institute proceedings for appropriate redress before a competent court or other adjudicator in accordance with the rules and procedures provided by law.[xxvi]

The tacit acceptance or official endorsement of violations of international law, as attributable to the State, was confirmed by the International Court of Justice in the case of United States Diplomatic and Consular Staff in Tehran, United States v Iran (1979).[xxvii]

A comparative analysis of the international legal framework between the Philippines and the United States

Consent to jurisdiction is a primary consideration in international law. Each nation State will have differing legal obligations which are dependent on their consent through the ratification of treaties, conventions and other legal instruments. This is notwithstanding customary international law, general principles of international law, and jus cogens, which are non-derogable norms.

The Philippines ratified the Convention on the Elimination of Discrimination against Women (CEDAW) on August 5, 1981, and its corresponding optional protocol on November 12, 2003. In accordance with Articles 8 and 9 of the CEDAW Optional Protocol , the Philippines accepted the Inquiry procedure on November 12, 2003. Previous to that, the Philippines ratified the International Covenant on Civil and Political Rights on October 23, 1986, and the International Covenant on Economic, Social and Cultural Rights on June 7, 1974. The Philippines has ratified eight out of nine core international human rights treaties[xxviii] and four out of a possible five optional protocols; the optional protocols provide the United Nations treaty bodies jurisdiction over complaints of alleged human rights abuses in violation of their corresponding treaties.

The United States of America signed the CEDAW on July 17, 1980, but failed to ratify the Convention and its optional protocol, so it is not a member party. Similarly, the U.S.A signed the International Convention on Economic, Social and Cultural Rights on October 5, 1977, but never ratified that Covenant either. The United States has ratified only three of the nine core human rights treaties and zero out of five optional protocols. The U.S.A. did however ratify the International Covenant on Civil and Political Rights (ICCPR) on June 8, 1992,[xxix] but unfortunately did not ratify either of its two optional protocols, which would have given the United Nations Human Rights Committee jurisdiction to hear complaints from individuals on civil and political rights abuses. Effectively, this means that protection from human rights abuses in the United States is reliant mostly on domestic remedies. However, customary international law, general principles of international law and jus cogens may be applicable under specific circumstances.

An overwhelmed mother sits in the park with her unhappy five children of various ages. (AI generated)

Conclusion

In April 2026 United States’ President Donald Trump released new guidance intended to overhaul family planning services, prioritizing childbirth over contraception.[xxx] Then in July of 2026 the Trump Administration gutted funding for 53 programs intended and proven to reduce teen pregnancies, because they were allegedly ‘normalizing sexual activities for minors’[xxxi]. These acts and omissions are likely to have dire consequences on the population of women and girls in the United States, undermining their rights to non-discrimination, the right to privacy and bodily autonomy, the right to health, the right to receive information, the right to education and the right to work. These human rights abuses will generally deepen gender inequality unless addressed.

The global rolling back of women’s rights continues. And while nation States may bear the legal responsibility, it is women, girls and gender diverse persons that bear the impact.

– August 2026

Additional resources:

See the World Health Organization’s Model List of Essential Medicines – 24^th List (2025); 22. Medicines for Reproductive health and Perinatal Care; pages 54 – 55 includes (22.1) Contraceptives and (22.4) Medicines for medical abortion: mifepristone – misoprostol.

https://www.who.int/publications/i/item/B09474

See the World Health Organization’s Fact sheet on Emergency Contraception; Nov. 9, 2021; https://www.who.int/news-room/fact-sheets/detail/emergency-contraception and on Abortion; Dec. 8, 2025; https://www.who.int/news-room/fact-sheets/detail/abortion

[i] Family planning/contraception methods; published July 3, 2025; World Health Organization; https://www.who.int/news-room/fact-sheets/detail/family-planning-contraception (accessed Aug. 16, 2026)

[ii] Para. 2, Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.

[iii] Ibid, para. 3.

[iv] Ibid; Para. 8.

[v] Ibid; para. 13.

[vi] Ibid; para. 13.

[vii] Ibid; para. 33;

[viii] Ibid, para. 34.

[ix] Para. 32; General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.

[x] Para. 13; General recommendation No. 24: Article 12 of the Convention (women and health); 1999; Committee on the Elimination of Discrimination Against Women.

[xi] Ibid, para. 17. Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.

[xii] Para. 8, General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.

[xiii] Ibid. Para. 34.

[xiv] Para. 1; General comment No. 22 (2016) on the right to sexual and reproductive health (article 12 of the International Covenant on Economic, Social and Cultural Rights); 2016; United Nations Office of the High Commissioner; E/C.12/GC/22.

[xv] Ibid, Para. 13; footnote 15 (Essential medicines are defined by WHO as “those that satisfy the priority health care needs of the population” and that “are intended to be available within the context of functioning health systems at all times in adequate amounts, in the appropriate dosage forms, with assured quality, and at a price the individual and community can afford”. See Committee on Economic, Social and Cultural Rights general comment No. 14; and WHO, Model List of Essential Medicines, 19th ed. (2015).)

[xvi] Ibid, Para. 14; footnote 16 (International Planned Parenthood Federation – European Network v. Italy, complaint No. 87/2012 (2014), resolution adopted by the Committee of Ministers of the Council of Europe on 30 April 2014.)

[xvii] Constitution of the Republic of the Philippines; February 1987; https://elibrary.judiciary.gov.ph/thebookshelf/showdocs/3/353

[xviii] Findings of fact; para. 7; Summary of the inquiry concerning the Philippines under article 8 of the Optional Protocol to the Convention on the Elimination of All Forms of Discrimination against Women; Committee on the Elimination of Discrimination against Women; April 22, 2015; CEDAW/C/OP.8/PHL/1.

[xix] Constitution of the United States; https://constitution.congress.gov/constitution/amendment-1/

[xx] First Amendment and Religion; United States Courts website; https://www.uscourts.gov/about-federal-courts/educational-resources/about-educational-outreach/activity-resources/first-amendment-and-religion (Accessed July 29, 2026)

[xxi] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, paras. 2-3.

[xxii] Para. 8, General Comment No. 14 – Substantive issues arising in the implementation of the International Covenant on Social, Economic and Cultural Rights; 2000; United Nations Economic and Social Council, Committee on Economic, Social and Cultural Rights, E/C.12/2000/4.

[xxiii] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, paras.

[xxiv] General Commentary – Chapter I – General Principles – [82] (6); ILC (2001) Responsibility of States for Internationally Wrongful Acts. International Court of Justice https://www.icj-cij.org/node/202882

[xxv] Para. 23 (39) CEDAW/C/OP.8/PHL/1

[xxvi] An act providing for the Magna Carta of Women; Republic Act No. 9710, Aug. 14, 2009. Section 3, para. 6.

[xxvii] Case concerning United States diplomatic and consular staff in Teheran (United States of America v. Iran); International Court of Justice; 29 November 1979. https://www.icj-cij.org/case/64

[xxviii] UN Treaty Body Database; Ratification Status for the Philippines; https://tbinternet.ohchr.org/_layouts/15/TreatyBodyExternal/treaty.aspx (Accessed August 4, 2026)

[xxix] UN Treaty Body Database; Ratification Status for the United States (accessed August 5, 2026)

https://tbinternet.ohchr.org/_layouts/15/TreatyBodyExternal/treaty.aspx

[xxx] Mary Zeigler; Trump Is Going After Birth Control. Here’s Why. April 25, 2026; Politico. https://www.politico.com/news/magazine/2026/04/25/birth-control-maha-abortion-trump-00889738

[xxxi] Trump administration cancels grants aimed at reducing teen pregnancies; NPR July 7, 2026; Selena Simmons-Duffin on Morning Edition. https://www.npr.org/2026/07/07/nx-s1-5875464/trump-administration-cancels-grants-aimed-at-reducing-teen-pregnancies

2026-08-31
When abortion is legal but inaccessible: an analysis under international law

Women’s reproductive freedoms are rapidly regressing and facing increasing restrictions around the globe. Women in the United States, Poland and Malta are dying due to restrictive laws and lack of accessibility. And according to the European Citizens’ Initiative, My Voice, My Choice: For Safe and Accessible Abortion more than 20 million women in the EU do not have access to safe, affordable abortion. Conversely, in Canada abortion is legal and covered by primary healthcare. However, on July 25th, 2025, women’s advocacy organizations across the nation sounded the alarm in a Joint Statement to the new Liberal Prime Minister Mark Carney warning of the regressive impact that proposed austerity measures will have on women’s rights and gender equality. The budget for the Women and Gender Equality (WAGE) Department proposed 80%^[i]less funding over each of the next four years as compared with the 2025-26 budget. The impact will be felt not just in the WAGE Department, but in local feminist organizations, women’s shelters, sexual assault services and more, including abortion facilitation services. Canadian women living in rural and remote areas often lack the means of access to safe, legal abortions due to the unavailability of the necessary healthcare services in their regions; the scope of this impact will likely be extended given the circumstances. In the context of reduced accessibility and austerity measures, what legal arguments might women’s rights advocates depend upon? The following is a legal analysis of the international human rights obligations pertinent to the situation in Canada, which may also apply to other States with the same obligations.

The Right to Health – Art. 12 of the International Convention on Economic, Social and Cultural Rights (ICESCR)

The ICESCR provides for the right to the “highest attainable standard of physical and mental health”^[ii].

Article 12

1. The States Parties to the present Covenant recognize the right of everyone to the enjoyment of the highest attainable standard of physical and mental health.

2. The steps to be taken by the States Parties to the present Covenant to achieve the full realization of this right shall include those necessary for:

(a) The provision for the reduction of the stillbirth-rate and of infant mortality and for the healthy development of the child;

(b) The improvement of all aspects of environmental and industrial hygiene;

(c) The prevention, treatment and control of epidemic, endemic, occupational and other diseases;

(d) The creation of conditions which would assure to all medical service and medical attention in the event of sickness.

While the fundamental right to health is subject to progressive development, States should nevertheless ensure that it is moving towards its full realization, as stated in Article 2 of the Covenant.

Non- Discrimination

Article 2 paragraph 2 of the ICESCR provides for non-discrimination in the implementation of the Covenant – “The States Parties to the present Covenant undertake to guarantee that the rights enunciated in the present Covenant will be exercised without discrimination of any kind as to race, colour, sex, language, religion, political or other opinion, national or social origin, property, birth or other status”.

Non-discrimination is not subject to progressive development – it must be respected immediately upon accession to the Covenant. However, according to the World Economic Forum “we still face wide gaps in research and treatment ability for areas that are unique to women”^[iii], which is in contravention of Art. 2, para. 2 ICESCR. Maternal health, and abortion are just two of many areas of treatment that pertain exclusively to the health of persons of female sex (females). Even if a law doesn’t single out females in fact, if there is no equivalent adverse effect on males, then the law may be found to be discriminatory.^[iv] Health inequality is a result of systemic discrimination against women and gender diverse persons, and it must be compliant with international law.

In 2000, the Committee on Economic, Social and Cultural Rights issued General Comment No. 14: The Right to the Highest Attainable Standard of Health (Art. 12), according to which:

“To eliminate discrimination against women, there is a need to develop and implement a comprehensive national strategy for promoting women’s right to health throughout their life span. Such a strategy should include interventions aimed at the prevention and treatment of diseases affecting women, as well as policies to provide access to a full range of high quality and affordable health care, including sexual and reproductive services. A major goal should be reducing women’s health risks, particularly lowering rates of maternal mortality and protecting women from domestic violence. The realization of women’s right to health requires the removal of all barriers interfering with access to health services, education and information, including in the area of sexual and reproductive health. It is also important to undertake preventive, promotive and remedial action to shield women from the impact of harmful traditional cultural practices and norms that deny them their full reproductive rights.” (author’s emphasis)

Pregnancy can be both a direct and indirect cause of harm to women. Maternal morbidity and mortality are direct consequences of pregnancy, especially for adolescents. Indirectly, lack of access to safe abortion services can result in the administration of unregulated and unsafe abortions that can cost a woman or girl her life. Furthermore, sex or gender-based violence and femicide can be tragic indirect consequences of an unintended or unwanted pregnancy by an intimate partner or family members.

As a State party to the Convention of Elimination of Discrimination against Women (CEDAW), Canada submitted its tenth periodic report as proscribed by Article 18 of the Convention. The Committee on the Elimination of All Forms of Discrimination Against Women, in their 2024 Concluding Observations on the tenth periodic report of Canada^[v]recommended that Canada “ensure access to legal abortion services in all provinces and territories, including for women from disadvantaged groups”. Furthermore, the Committee cited “the persistent barriers in the public health system hindering access to abortion care, disproportionately affecting women from disadvantaged groups, women in remote and rural areas and undocumented migrants”^[vi].

Canada’s counterargument

Canada argues that it has one of the world’s lowest populations densities with just 4.6 people per km^{2 [vii]} per km², second only to Russia. Extending all aspects of healthcare across a territory of almost 10,000,000 km^{2 [viii]} is challenging and expensive. Consequently, the Canada Health Act (1985), section 3, provides that “it is hereby declared that the primary objective of Canadian health care policy is to protect, promote and restore the physical and mental well-being of residents of Canada and to facilitate reasonable access to health services without financial or other barriers.”^[ix] (author’s emphasis) But constitutional law must be in alignment with international law.

Positive obligations of the State

The right to health requires positive obligations from the State including the duty to fulfil and the duty to promote.

The duty to fulfil the right to health requires due attention to the four A’s: availability, accessibility, adequacy and acceptability. The acceptability of healthcare, which is also known as quality, is explained by the World Health Organization (WHO). The WHO “considers several aspects of quality, including whether Universal Health Care (UHC) is timely – reducing wait times and harmful delays – and equitable – providing care that does not vary in quality on account of age, gender, ethnicity, disability, geographic location, and socio-economic status”^[x]. Reducing harmful delays for abortion is essential.

The duty to promote, in the case of reproductive healthcare, means ensuring availability of education and information on access to necessary services including contraception, family planning, adoption, emergency contraception and medical abortion options.

Territorial scope

Although Canada is a federal State which is divided into provinces and territories with a decentralized administration of healthcare under each, any obligations on the State apply to its entire territory. This rule of law is affirmed in several sources of international law, including the Vienna Convention on the Law of Treaties (VCLT), Art. 29 on the territorial scope of treaties[xi].

In its General Comment No. 28 on the core obligations of States parties, the Committee on the Elimination of Discrimination against Women (CEDAW) addresses the devolution of powers.

“…The decentralization of power, through devolution and delegation of Government powers in both unitary and federal States, does not in any way negate of reduce the direct responsibility of the State party’s national or federal Government to fulfil its obligations to all women within its jurisdiction. (…) States parties have to make sure that the devolved authorities have the necessary financial, human and other resources to effectively and fully implement the obligations of the State party under the Convention. (…) Furthermore, there must be safeguards to ensure that decentralization or devolution does not lead to discrimination with regard to the enjoyment of rights by women in different regions.”

Essentially, the State (Canada) may be found responsible for acts or omissions by provincial authorities that violate human rights.

Key Human Rights Inquiries and case law

Inaccessibility of healthcare provisions can be a cause of indirect discrimination and of de facto or substantive inequality. This has been affirmed through UN Human Rights Treaty Bodies and case law alike.

According to the CEDAW Committee’s General recommendation No. 35 on gender-based violence against women, updating general recommendation No. 19, paragraph 18“Violations of women’s sexual and reproductive health and rights, such as forced sterilization, forced abortion, forced pregnancy, criminalization of abortion, denial or delay of safe abortion and/or post-abortion care, forced continuation of pregnancy, and abuse and mistreatment of women and girls seeking sexual and reproductive health information, goods and services, are forms of gender-based violence that, depending on the circumstances, may amount to torture or cruel, inhuman or degrading treatment.”^[xii]

The UN Human Rights Committee (HRC) considered a communication^[xiii] submitted Amanda Jane Mellet against Ireland in 2013. She was a married women who found out in the twenty-first week of pregnancy that her foetus had congenital heart defects that would be fatal, either in utero or shortly after birth. Mellet was deeply concerned over the potential suffering of her baby and considered abortion to be the best option. However, abortion was illegal in Ireland even if the impairment would be fatal.

“2.4 On 28 November 2011, she flew with her husband to Liverpool and the following day she received medication at the Women’s Hospital to begin the process of terminating her pregnancy. On 1 December, she received further medication to induce labour. She was in labour for 36 hours and on 2 December she delivered a stillborn baby girl. Still feeling weak and bleeding, she had to travel back to Dublin, only 12 hours after the delivery, as they could not afford to stay any longer in the United Kingdom.⁽¹⁾There is no financial assistance from the State or from private health insurers for women who terminate pregnancies abroad.”^[xiv]

(…)

“3.3 (…) The travel abroad was also a significant source of added anxiety and exposed her to obstacles which impinged on her physical and mental integrity and dignity. She had to make preparations for the travel; was deprived of the support of her family; had to stay in a foreign and uncomfortable environment while in Liverpool; and had to spend a sum of money which was difficult for her to raise. While waiting at the airport to fly home, only 12 hours after the termination, she was bleeding, weak and light-headed.”^[xv]

The HRC found Ireland in violation of article 7 of the International Covenant on Civil and Political Rights (ICCPR), which provides a non-derogable right which states that “No one shall be subjected to torture or to cruel, inhuman or degrading treatment or punishment. In particular, no one shall be subjected without his free consent to medical or scientific experimentation.”^[xvi].

The Committee also found that Ireland violated article 17 of the ICCPR, which prohibits interference with private life, and article 26 which guarantees equality before the law.

In the context of Mellet v Ireland, the State of Ireland prohibited and criminalized abortion expect in cases where the mother’s life was at risk and furthermore declined to provide information on resources where an abortion could legally be performed given the extenuating circumstances. The Irish law provided no access to remedy and denied Mellet post-abortion care, including grievance counselling, which they only provided to mothers who had delivered a stillborn foetus.

The circumstance of travelling 218 km to access a legal abortion, as did Mrs. Mellet, is entirely conceivable given Canada’s vast territorial expanse. Additionally, how far along in pregnancy a woman is can limit the number of healthcare facilities available to perform the medical abortion. According to Abortion Access Tracker “because of limitations to residents of certain regions, as well as overwhelming demand while being severely under-resourced, there is low availability of abortion care after 20 weeks in Canada.” Therefore hypothetically, in cases that are sufficiently analogous, Canada may too be found in violation of the Convention Against Torture, of which it ratified in 1987. (The U.S. is even more likely given the current circumstances; even though the U.S. hasn’t ratifed the treaty, the prohibition of torture has a jus cogens status, a status of non-derogability, and has become a part of customary international law. )

This obstacle to the right to health in Canada adversely affects women and girls from rural and remote regions. And without any funding for travel expenses, including meals, accommodation, potential airfare or ferry costs, lost time from work, and childcare costs, lack of financial support will significantly and adversely affect women and girls from lower socio-economic statuses.

Canadian non-profit organizations like Abortion Care Canada and Action Canada for Sexual Health and Rights have been providing support to help women facing barriers to bodily autonomy and reproductive freedom. But the Liberals have released a draft budget for the next few years in Canada, with a notable 80% decrease in funding to the Department of Women and Gender Equality (WAGE) due to the expiration of time-limited spending, without renewal. If abortion access is already an issue in 2025, what will it be like in 2026 or 2027? Abortion Care Canada states that the change in funding not only impacts the ability to provide services but may result in full organizational closure.^[xvii]

Consequences to abortion inaccessibility

The United Nations Committee on Elimination of Discrimination Against Women (CEDAW) has expressed concern over the potentially life-threatening consequences of unplanned and/or unwanted pregnancies, unsafe abortions and preventable maternal deaths^[xviii]. And, according to a study by Doctors without Borders/Medicins sans Frontieres on unsafe abortions “the life-threatening consequences include severe hemorrhage, sepsis (severe general infection), poisoning, uterine perforation, or damage to other internal organs. A woman may require urgent hospital care for a blood transfusion, major reparative surgery, or a hysterectomy—the complete, and irreversible, removal of the uterus.”^[xix]

In October of 2025 the United Nations Human Rights Council adopted a resolution that addresses Preventable maternal mortality and human rights^[^xx]. The Council noted with concern that “the risk of maternal mortality is higher for adolescents and highest for girls under 15 years of age and that complications in pregnancy and childbirth are a leading cause of death and severe morbidity among adolescent girls in low- and middle-income countries, acknowledging that the issue also persists in high-income countries.”^[xxi]

The obstacles to obtaining a legal abortion can result in the some of the same adverse outcomes as it does in States where abortion is illegal, including attempts at unsafe abortion, maternal death, susceptibility to remaining in an abusive relationship, increased vulnerability to lack of education and/or lack of employment, loss of financial independence and stability, suicide and infanticide. If they survive, the cost of an unwanted pregnancy may be a lifetime of hardship for mother and child alike.

In addition to the cost of an unwanted pregnancy on an individual and child, the community and ultimately the State pay a price too. Support may start with a pre-natal shelter^[xxii], natal supplement^[xxiii], infant formula^[xxiv], and other supplemental support. Then there is the standard Canada child benefit (CCB) at up to $7,997 per year for each child under 6 and $6748 per year for each child aged 6-17, as well as provincial income assistance (in B.C. $1405 per month for a single parent with one child^[xxv]), totalling approximately $25,000 annually for a single parent with a young child. This cost to Canadian taxpayers is significantly higher than the cost of accommodating access to abortion services or preventative measures including education and contraception.

Recommendations by International Human Rights Treaty Bodies

The United Nations Human Rights Committee (HRC) conducted a Universal Periodic Review (UPR) on Canada’s human rights performance in 2023. The issue of inaccessibility of abortion services was cited in both the Summary of stakeholders’ submissions on Canada^[xxvi] and in the Report of the Working Group^[xxvii], with concerns expressed by Iceland and Norway. Canada responded to the recommendations of the Working Group as “noted”^[xxviii] – a vague acknowledgement that makes no promises.

Additionally, the treaty monitoring body for the International Covenant on Economic, Social and Cultural Rights (ICESCR), a core human rights legal instrument which Canada ratified and acceded to in 1976, expressed the same concerns. In the Concluding Observations on the sixth periodic report of Canada^[xxix] the Committee on Economic, Social and Cultural Rights provided these recommendations to Canada:

51. The Committee welcomes the information provided by the delegation on measures taken to facilitate access to legal abortion services. It remains concerned, however, at disparities in access to such services and to affordable contraceptives (art. 12)

52. The Committee recommends that the State party ensure access to legal abortion services in all provinces and territories. The Committee also recommends that the State party ensure that physicians’ conscientious objection does not impede women’s access to legal abortion services. The Committee also recommends that affordable contraceptives be made accessible and available to all, and in particular those living in remote areas and those living in poverty. The Committee refers to its General Comment No. 22 (2016) on the right to sexual and reproductive health.

Furthermore, Canada has been urged to ratify the Optional Protocol to the International Covenant on Economic, Social and Cultural Rights (ICESCR) in the interest of enabling the political participation of citizens and NGOs alike. Women’s rights advocacy groups should also continue to encourage ratification of the Optional Protocol to the ICESCR as it would enable individuals and groups to file complaints to the Committee in cases of State non-compliance with the Covenant, following exhaustion of local remedies.

Conclusion:

Could Canada be found in violation of Article 12 (the right to health) of the International Convention on Economic Social and Cultural Rights? Or worse?

When the UN treaty monitoring bodies, such as the CEDAW Committee or the Committee on Economic, Social and Cultural Rights find that a States’ actions or omission are not in conformity with their treaty obligations, they will consider the circumstances of each specific case. Whether or not a States’ actions or omissions were the result of extraordinary circumstances that are considered permissible or not, would be up to the Committee to decide. Hence, it is only if the State’s treaty performance is challenged that the ruling would emerge.

[i] Table 7: Planned three-year spending on core responsibilities and internal services; Planned Spending and human resources; Women and Gender Equality Canada’s 2025-26 Departmental Plan; Government of Canada website: https://www.canada.ca/en/women-gender-equality/transparency/departmental-plans/2025-2026.html#toc4 Accessed Sept. 14, 2025

[ii] International Covenant on Economic, Social and Cultural Rights; 1966; adopted by the General Assembly resolution 2200A (XXI)

[iii] Women’s health: Why is the health of at least half the global population so often overlooked? Deeptha Khanna; January 2, 2023; https://www.weforum.org/stories/2023/01/women-health-gap-davos-2023/ (Accessed August 27, 2025)

[iv] See for example Fraser v. Canada (Attorney General), 2020 SCC 28, [2020] 3 S.C.R. https://decisions.scc-csc.ca/scc-csc/scc-csc/en/item/18510/index.do

[v] Pg. 15; paragraph 38 (e); CEDAW Concluding observations on the tenth periodic report of Canada; UN Doc. CEDAW/C/CAN/CO/10; October 30, 2024.

[vi] Pg. 14; paragraph 37 (e); CEDAW Concluding observations on the tenth periodic report of Canada; UN Doc. CEDAW/C/CAN/CO/10; October 30, 2024.

[vii] Hannah Ritchie and Edouard Mathieu (2019) – “Which countries are most densely populated?” Published online at OurWorldinData.org. Retrieved from: ‘https://ourworldindata.org/most-densely-populated-countries’ [Online Resource] Accessed October 24, 2025.

[viii] https://www.canada.ca/en/immigration-refugees-citizenship/corporate/publications-manuals/discover-canada/read-online/canadas-regions.html Accessed October 24, 2025.

[ix] Section 3; https://laws-lois.justice.gc.ca/eng/acts/C-6/page-1.html#h-151484 Accessed October 30, 2025.

[x] Core components of the right to health; Key facts; Human Rights; WHO; December 1, 2023; https://www.who.int/news-room/fact-sheets/detail/human-rights-and-health#:~:text=The%20right%20to%20health%20includes,goods%20and%20services%20for%20all (Accessed Aug 21, 2025)

[xi] Article 29, Vienna Convention on the Law of Treaties (1969); Entered into force on 27 January 1980.

United Nations, Treaty Series, vol. 1155, p. 331 https://legal.un.org/ilc/texts/instruments/english/conventions/1_1_1969.pdf

[xii] Para. 18, page 7; General recommendation No. 35 on gender-based violence against women, updating general recommendation No. 19; UN CEDAW Committee; CEDAW/C/GC/35; 26 July 2017.

[xiii] Human Rights Committee; Views adopted by the Committee under article 5 (4) of the Optional Protocol, concerning communication No. 2324/2013;CCPR/C/116/D/2324/2013; distributed 17 Nov. 2016; https://docs.un.org/en/CCPR/C/116/D/2324/2013

[xiv] Ibid, para. 2.2 and 2.4; page. 2.

[xv] Ibid, para. 3.3, page 3.

¹The author states that they spent €3,000 in total, including the €2,000 fee they paid for the procedure.

[xvi] Art. 7,Part II, International Convention on Civil and Political Rights; adopted by UN General Assembly res. 2200A (XXI) 1966; https://www.ohchr.org/en/instruments-mechanisms/instruments/international-covenant-civil-and-political-rights

[xvii] https://abortioncarecanada.ca/the-autonomy-fund/ Accessed October 25, 2025.

[xviii] Para. 2; CEDAW/C/OP.8/PHL/1; https://www.ohchr.org/en/stories/2015/06/un-womens-committee-makes-inquiry-sexual-and-reproductive-health-rights-philippines (accessed August 29, 2025)

[xix] Unsafe abortion: A preventable danger; Unsafe abortion is one of the five leading causes of maternal mortality, and the only one that is preventable. Medicins sans Frontieres; March 7, 2019; https://www.doctorswithoutborders.org/latest/unsafe-abortion-preventable-danger#:~:text=For%20women%20who%20use%20these%20unsafe%20methods%2C,complete%2C%20and%20irreversible%2C%20removal%20of%20the%20uterus. Accessed Sept. 28, 2025

[xx] Resolution A/HRC/60/L.20/Rev.1 https://docs.un.org/en/a/hrc/60/l.20/rev.1 Adopted by the Human Rights Council; 60th Session, October 2025.

[xxi] Ibid. Preamble, page 4, paragraph 7.

[xxii] “If you are pregnant, you may be able to get money to secure or maintain stable housing before your child is born. You must have no spouse and have no other dependent children.” https://www2.gov.bc.ca/gov/content/family-social-supports/income-assistance/on-assistance/supplements Accessed Sept. 15, 2025.

[xxiii] “If you are pregnant or have an infant less than thirteen months old, you may be able to get an extra $80 per month.” Ibid.

[xxiv] For your child’s first 12 months, you could get money for: Regular infant formula. This is when the child has a medical need for regular infant formula; Specialized infant formula. This is only if your child has a medical condition that requires special formula. You may be able to get this longer than 12 months if it’s medically required; Ibid.

[xxv] https://www2.gov.bc.ca/gov/content/family-social-supports/income-assistance/on-assistance Accessed Sept. 15, 2025.

[xxvi] Pg. 7; point 66 sub-heading “Right to health”; Summary of stakeholders’ submissions on Canada – Report of the Office of the United Nations High Commissioner for Human Rights; UN document A/HRC/WG.6/44/CAN/3; September 4, 2023.

[66. JS3 stated that, although abortion was a decriminalized health-care service, many people lacked access to the public health system entirely and others faced prohibitive barriers to abortion care, including travel costs, long wait times, immigration status and intimate partner violence.119 (Joint submission 3 submitted by: The Sexual Rights Initiative, Ottawa (Canada); Action Canada for Sexual Health and Rights; Barbra Schlifer Commemorative Clinic; Justice for Migrant Workers; J4MW-YWCA Hamilton – The Community Research Platform at McMaster University, Sexual Rights Initiative)]

[xxvii] Pg. 16, points 37.186 (by Iceland) and 37.187 (by Norway); Report of the Working Group on the Universal Periodic Review – Canada; UN document A/HRC/55/12; December 19, 2023.

[xxviii] Pg. 2 (Recommendations and Canadian Position); Report of the Working Group on the Universal Periodic Review – Canada – Addendum – Views on conclusions and/or recommendations, voluntary commitments and replies presented by the State under review; UN Doc. A/HRC/55/12/Add.1; March 15, 2024.

[xxix] Pg. 9; paragraphs 51 and 52; Concluding Observations on the sixth periodic report of Canada; E/C.12/CAN/CO/6; March 23, 2016.

2025-11-05