CEDAW/C/69/D/85/2015 and that the communication should therefore be declared inadmissible as manifestly ill-founded. Should the Committee find the communication admissible, the State party further maintains that it has not been established that there are substantial grounds for believing that it would constitute a violation of the Convention to return the author and her son to Somalia. Issues and proceedings before the Committee concerning admissibility 9.1 In accordance with rule 64 of its rules of procedure, the Committee must decide whether the communication is admissible under the Optional Protocol. Pursuant to rule 66, it may decide to consider the admissibility of the communication separately from its merits. 9.2 In accordance with article 4 (2) (a) of the Optional Protocol, the Committee is satisfied that the same matter has not been and is not being examined under another procedure of international investigation or settlement. 9.3 The Committee notes that the author claims to have exhausted domestic remedies and that the State party has not challenged the admissibility of the communication on that ground. The Committee observes that, according to the information available to it, appeals against decisions of the Refugee Appeals Board cannot be lodged before national courts. Accordingly, the Committee considers that it is not precluded by the requirements of article 4 (1) of the Optional Protocol from considering the matter. 9.4 The Committee takes note of the State party’s claim that the communication is manifestly ill-founded, pursuant to article 4 (2) (c) of the Optional Protocol, owing to the lack of substantiation. The Committee regrets the insufficient quality of the submissions, notwithstanding that the author is represented by an attorney-at-law. In that regard, the Committee recalls the author’s claim that she fears being killed by her family or surrendered to Al-Shabaab in the event of her return to Somalia, because she had a relationship with H., her now deceased spouse, despite her family’s disapproval. The author has claimed that, if the State party returned her and her son to Somalia, she would be personally exposed to serious forms of gender-based violence, as defined under articles 2, 12, 15 and 16 of the Convention. 9.5 The Committee refers to its general recommendation No. 32 (2014), in which it states that, “under international human rights law, the non-refoulement principle imposes a duty on States to refrain from returning a person to a jurisdiction in which he or she may face serious violations of human rights, notably arbitrary deprivation of life or torture or other cruel, inhuman or degrading treatment or punishment” (para. 21). The Committee further refers to its general recommendation No. 19 (1992), in which it recalls that “gender-based violence, which impairs or nullifies the enjoyment by women of human rights and fundamental freedoms under general international law or under human rights conventions, is discrimination within the meaning of article 1 of the Convention”, and that such rights include the right to life and the right not to be subject to torture (para. 7). The Committee has further elaborated its interpretation of violence against women as a form of gender discrimination in its general recommendation No. 35 (2017) on gender-based violence against women, updating general recommendation No. 19, in which it reaffirms the obligation of States parties to eliminate discrimination against women, including gender-based violence, resulting from the acts or omissions of the State party or its actors, on the one hand, and non-State actors, on the other (para. 21). 9.6 In the case at hand, the Committee observes that there is no claim that the State party has directly violated the provisions of the Convention invoked, but rather that the violation would occur if the State party returned the author and her son to Somalia, 12/14 18-06600