Right to life and HRD: General Comment No 36 is an ally to HRD protection

General Comment no. 36 focused on areas such as the importance of strong methods of accountability, and sent a strong message against the narrow legal interpretation of the right to life, as was appropriate in a globalized world, and it underscored the right to life with dignity.

States parties must take the necessary measures to respond to death threats and to provide adequate protection to human rights defenders (Declaration on the Right and Responsibility of Individuals, Groups and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms, 9 Dec. 1998, art. 12(2)) and such measures should reflect the importance of their work (Declaration on the Right and Responsibility of Individuals, Groups and Organs of Society to Promote and Protect Universally Recognized Human Rights and Fundamental Freedoms, 9 Dec. 1998, art. 18(2)).
(par.27). The duty to protect the right to life requires States parties to take special measures of protection towards persons in situation of vulnerability whose lives have been placed at particular risk because of specific threats (Cf. Barrios Family v. Venezuela, Judgment of the I/A CHR of 24 Nov. 2011, para. 124. 74) or pre-existing patterns of violence. These include human rights defenders (Concluding Observations: Paraguay (2013), para. 15)

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