V. Specific Issues 1. As well as being able to understand the basic principles of how rights work, those implementing human rights strategies must also address certain specific issues which may be directly relevant to ensuring that human rights are used to their best. These are:    Equality and non-discrimination Extra-territorial application of human rights Accountability of non-State actors A. The Importance of Equality and Protection from Discrimination in International Human Rights Law 2. A guarantee of equal treatment is essential to democracy and that democracy is founded on the principle that each individual has equal value. 3. The protection against discrimination is the cornerstone of international human rights law’s commitment to equality. Equality lies at the heart of post war human rights protection and access to equality and the rooting out of unjustified discrimination has been the motivation behind the emergence of modern human rights standards. Principles of equality should be seen as the thread that draws together human rights, and the values of a democratic society, which flow from them. 4. All human rights treaties include an equality guarantee,115 as do most domestic constitutional frameworks.116 Similarly at the national level, there are often comprehensive laws forbidding discrimination. However, there are various ways of seeking to ensure equality and non – discrimination. For example, all human rights treaties provide for formal equality or consistency in treatment by prohibiting unjustified differential treatment. This is known as ��direct discrimination’.117 Others also impose an obligation on States to secure substantive equality by, in particular, prohibiting unjustified conditions, which, whilst neutral in appearance, disadvantage certain protected groups. This is known as ‘indirect discrimination’.118 115 Articles 1, 2 and 7 UDHR; Articles 1, 2, 3 and 26 ICCPR; Articles 1, 2 and 3 ICESCR; articles 1 and 2 ICERD; Articles 1-4 CEDAW; Articles 2, 50 and 30 CRC; Articles 2, 3, 4, 5 and 12, CRPD; Article 3 Arab Charter; Article 14 ECHR; Article 2 ACHPR; Article 1 ACHR. 116 Palestinian Basic Law, Article 9. 117 Human Rights Committee, General Comment No.18, HRI/GEN/1/Rev.9 (Vol. I) p.195 (1989). CERD General Recommendation No.14, 42nd Session (1993). Communication 24/1977, Lovelace v Canada, 30 July 1981; Communication 35/1978, Aumeeruddy –Cziffra v Mauritius, 9 April 1981; before the European Court, Belgian Linguistics Case, 23 July 1968; African Commission, Communications 27/89 et al, Organisation Mondiale contre Torture and others v Rwanda, 31 October 1996; Inter-American Commission, Case 11.671, Carlos Garcia Saccone v Argentina, Report No.8/98, 2 March 1998. 118 CERD General Recommendation No.14, 42nd Session (1993). See also CERD, Communication 31/2003, LR et al v Slovak Republic, 10 March 2005. Human Rights Committee, Communication 208/1986, Bhinder v Singh v Canada, 9 November 1989. DH and others v Czech Republic, 13th November 2007, European Court. Belgian Linguistics Case, 23 July 1968. 40