A/HRC/31/54 51. Other treaty monitoring bodies and human rights mechanisms have articulated legal standards with respect to remedies in the context of homelessness. In A.T. v. Hungary, the Committee on the Elimination of Discrimination against Women addressed the link between violence against women and homelessness, recommending as part of an effective remedy to “ensure that A. T. is given a safe home in which to live with her children”.46 52. In its 2014 concluding observations on the United States, the Human Rights Committee noted that criminalization of homeless people raises concerns of discrimination and cruel, inhuman or degrading treatment. 47 It recommended that the federal Government engage with State and local authorities to abolish discriminatory laws and policies criminalizing homelessness; intensify efforts to find solutions for people who are homeless; and offer incentives for decriminalization to local authorities.. The federal Government recently announced that it is implementing the recommendations, including by linking access to federal housing grants to the repeal of local laws that criminalize homelessness. 53. The Human Rights Committee has also acknowledged that widespread homelessness leads to serious health consequences and death and has stated that positive measures are required under article 6 of the International Covenant on Civil and Political Rights on the right to life to address homelessness.48 The Committee has considered homelessness in the context of forced evictions, finding that failure to consider that an eviction might result in homelessness constitutes an arbitrary interference with the home. 49 54. Regional human rights systems have also, to various extents, offered avenues for effective remedies for those who are homeless. The revised European Social Charter, in its article 31, includes the obligation “to prevent and reduce homelessness with a view to its gradual elimination”. In European Federation of National Organisations working with the Homeless (FEANTSA) v. France,50 the European Social Rights Committee held that “the measures currently in place to reduce the number of homeless are insufficient, both in quantitative and qualitative terms”, and constituted a violation of article 31.2 of the Charter. 55. The Inter-American Commission on Human Rights and the Inter-American Court of Human Rights have developed important jurisprudence recognizing the obligation of the State to protect the special relationship between indigenous peoples and land in addressing violations in which, for example, members of indigenous communities have been “violently forced from their homes and traditional lands into a situation of ongoing displacement”.51 In addition, in considering the plight of street-connected children, the Court has explained that the right to life requires States to take positive measures to ensure access to the conditions needed to lead a dignified life, recognizing that the right to life belongs “at the same time to the domain of civil and political rights as well as economic, social and cultural rights”.52 56. The African Commission on Human and Peoples’ Rights has affirmed that the right to adequate housing is implied in the African Charter by its articles 14 on the right to property, 16 on the right to highest attainable standard of mental and physical health and 46 47 48 49 50 51 52 14 See communication No. 2/2003, A.T. v. Hungary, Views adopted by the Committee on the Elimination of Discrimination against Women on 26 January 2005, para. 9. See CCPR/C/USA/CO/4. See, for example, CCPR/C/79/Add.105, para. 12. See communication No. 2073/2011, Liliana Assenova Naidenova et al. v. Bulgaria, Views adopted on 30 October 2012, para. 14.7. Complaint 39/2006 (2007). See Inter-American Court of Human Rights, Moiwana Community v. Suriname, judgement of 15 June 2015, para. 186. Available from www.corteidh.or.cr/docs/casos/articulos/seriec_124_ing.pdf See Inter-American Court of Human Rights, Villagran-Morales et al. v. Guatemala, judgement of 19 November 1999. Available from www.corteidh.or.cr/docs/casos/articulos/seriec_63_ing.pdf.