4. Reproductive rights and ­human rights standards and principles In one of its decisions on an individual complaint,44 the Committee on the Elimination of All Forms of Discrimination against Women found that a state had violated Article 10 (h) (access to information) by failing to provide appropriate information and advice on family planning to a Roma woman who had been sterilized in connection with the removal of a dead foetus. The only form of consent had been a handwritten note to the extent that she requested a sterilization, a term she did not know and only understood after the procedure had been done. In their Concluding Observations as part of the state reporting procedure, the United Nations Committees have focused much on the duty to ensure education and awareness on sexual and reproductive health, including on HIV, and have in that respect highlighted the special needs of indigenous groups, ethnic and linguistic minorities and other vulnerable groups and of adolescents.45 44 CEDAW/C/36/D/4/2004, Ms. A. S. vs. Hungary Annex 1. 45 For an overview of the Concluding Observations, see RIGHT TO THE HIGHEST ATTAINABLE STANDARD OF HEALTH THE RIGHT TO THE HIGHEST ATTAINABLE STANDARD OF HEALTH IN LAW Article 12 of the International Covenant on Economic, Social and Cultural Rights ­recognizes the right of all persons to the highest attainable standard of health. The same right for children is set out in Article 24 of the Convention on the Rights of the Child, and for p ­ ersons with disabilities in Article 25 of the Convention on the Rights of Persons with Disabilities. Article 12 of the Convention on the Elimination of All Forms of D ­ iscrimination against Women prohibits discrimination against women in the field of healthcare and ­furthermore guarantees women “appropriate services in connection with pregnancy, ­confi nement and the post-natal period, granting free services where necessary, as well as ­adequate nutrition during pregnancy and lactation”. In Article 14 on rural women, securing “access to adequate health care facilities, including information, counselling and services in ­family planning” is set out as an obligation. The ACHPR recognizes the right to health in Article 16, and Article 14 of the Protocol to the African Charter on Human and Peoples’ Rights on the Rights of Women in Africa seeks to ensure the right to health, especially to sexual and reproductive health. Article 8 of the ECHR has been understood to include the right to health. 109

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