VOLUME 11 economic risk." 61 Such reasoning reminisces on the minimum core concept of the CESCR Committee, however without including reasonableness test. The Committee further elaborated on economic and social rights in five complaints against Greece, 62 where it adopted the combination of the minimum core approach and reasonableness test of state compliance with their obligations under economic and social rights. The Committee held in Federation of Employed Pensioners of Greece (IKA-ETAM) v. Greece that "even when reasons pertaining to the economic situation of a state party make it impossible for a state to maintain their social security system at the level that it had previously attained, it is necessary . . . for that state party to maintain the social security system on a satisfactory level that takes into account the legitimate expectations of beneficiaries of the system and the right of all persons to effective enjoyment of the right to social security. ' ' 63 The Committee does not require a state party to maintain the equal level of rights in times of crime; as it takes a more cautious, reasonable, and humane approach to the difficulties faced by governments in times of crises. Nonetheless, the Committee held that "the Government has not conducted the minimum level of research and analysis into the effects of such far-reaching measures that is necessary to assess in64 a meaningful manner their full impact on vulnerable groups in society." However, states also seek to justify the adoption of the austerity measures, which affect economic and social rights. In a private law setting, a debtor would be obliged to repay her debt to the creditor, unless it declares insolvency. In a sovereign financing context, a state is also liable to repay its debt to creditor, being another state, international organisation or corporation. However, states are often faced with multiple obligations they need do address. Further, the ranking of repayment of such obligations is not clear. 65 Dowell-Jones and Kinley aptly noted that "human rights are intimately tied up with the economic health of the state, as well as, of course, much else besides." 66 In answering these questions, a dilemma arises: should a state give priority to repayment of its public debt or should it first ensure that it observes, at very least, reasonable minimum essential level of every economic and social right? Respect for economic and social rights and sovereign 61 European Comm. of Soc. Rights, complaint No. 66/2011, General Federation of Employees of the National Electric Power Corporation (GENOP-DEI) / Confederation of Greek Civil Servants' Trade Unions (ADEDY) v. Greece; Decision on the merits, 23 May 2012, para. 47. 62 European Comm. of Soc. Rights, No. 80/2012, Pensioner's Union of the Agricultural Bank of Greece (ATE) v. Greece No. 79/2012 Panhellenic Federation of Pensioners of the Public Electricity Corporation (POS-DEl) v. Greece; No. 78/2012 Pensioners' Union of the Athens-Piraeus Electric Railways (I.S.A.P.) v. Greece; No. 77/2012 Panhellenic Federation of Public Service Pensioners v. Greece No. 76/2012 Federation of Employed Pensioners of Greece ((IKA -ETAM) v. Greece. 63 European Comm. of Soc. Rights, Complaint No. 65/2011, Federation of Employed Pensioners of Greece (IKA-ETAM) v. Greece, Para. 69. 64Id. at. Para. 79. 65 Anna Gelpern, Building a Better Seating Chartfor Sovereign Restructurings,53 Emory L.J., 1119, 1142-1147 (2004). 66Dowell-Jones, supra note 7, at 184.

Select target paragraph3