obligations apply irrespective of the availability of resources or any other factors and difficulties".46 The intention behind the proposal is clear: it is to strengthen the credibility of the monitoring of the Covenant, by adopting a position of restraint that would allow the Committee to tackle only the most obvious cases, where the conduct of the government is clearly below the standards of acceptability. The idea that the monitoring of the Covenant would be facilitated by the identification, within each of the rights, of an "essential content", corresponding to a set of "core obligations" imposed on all States, has a strong pedigree. It already took centre stage during the discussions that led to the Limburg Principles on the Implementation of the International Covenant on Economic, Social and Cultural Rights adopted in 1986. 47 The experts who developed the Principles agreed that, though resources available to each State matter to assess the scope of that State's obligations to realize economic, social and cultural rights, each State should "ensure respect for minimum subsistence rights for all", "regardless of the level of economic development".48 The expression of "minimum subsistence rights" found support in particular with Philip Alston, a member of the Committee who, writing in his academic capacity, also urged that the Committee should “find a way of conveying to states the fact that priority must be accorded to the satisfaction of minimum subsistence levels of enjoyment of the relevant rights by all individuals.”49 Unsurprisingly, the views expressed by the Limburg Principles soon found their way into the doctrine elaborated by the Committee on Economic, Social and Cultural Rights, after Alston convinced his colleagues about the need to clarify the content of the obligations the Covenant imposed on States.50 It is this effort which resulted in the adoption by the Committee of General Comment No. 3, which as we have seen details the nature of States' obligations under Article 2(1) of the Covenant:51 the Committee expresses the view in this general comment that "a minimum core obligation to ensure the satisfaction of, at the very least, minimum essential levels of each of the rights is incumbent upon every State party".52 The doctrine presents two major infirmities, however, which significantly limit its usefulness as a guide in the jurisprudence of the Committee. First, as already noted,53 the identification of the "minimum essential content" does not imply that the question of resources simply becomes irrelevant : even a State that fails to guarantee that minimum level of enjoyment may argue that such failure is attributable to a lack of available resources, provided it demonstrates that "every effort has been made to use all resources that are at its disposition in an effort to satisfy, as a matter of priority, those minimum obligations".54 Identifying certain core components does serve to shift the burden of proof: it 46 Chapman, "The Status of Efforts to Monitor Economic, Social and Cultural Rights", in Shareen Hertel and Lanse Minkler (eds), Economic Rights. Conceptual, Measurement, and Policy Issues (Cambridge: Cambridge Univ. Press, 2007), 143-164, at 154. 47 Limburg Principles on the Implementation of the International Covenant on Economic, Social and Cultural Rights, cited above note 16. 48 Id., para. 25. 49 Philip Alston, "Out of the Abyss: The Challenges Confronting the New U.N. Committee on Economic, Social and Cultural Rights", cited above note 17, at 359-360. 50 Summary Record of the 3rd Meeting, Committee on Economic, Social and Cultural Rights, 3rd Sess., at p. 3, UN Doc. E/C.12/1989/SR.3. 51 General Comment No. 3 (1990), cited above note 41. 52 General Comment No. 3 (1990), cited above note 41, para. 10. 53 See above, text corresponding to note 41. 54 General Comment No. 3 (1990), cited above note 41, para. 3. In 1997, the Maastricht Guidelines on Violations of Economic, Social and Cultural Rights stated that the minimum core obligations referred to in General Comment No. 3 "apply irrespective of the availability of resources of the country concerned or any other factors and difficulties" (para. 9; emphasis added). This is not an accurate reading of the Committee's own position. Although it is true that (as correctly stated by the Maastricht Guidelines) "resource scarcity does not relieve States of certain minimum obligations in respect of the implementation of economic, social and cultural rights" (para. 10; emphasis added), this does not imply that resource availability is irrelevant in assessing whether the duty to guarantee at least the minimum essential content of rights is complied with : the position of the Committee, rather, is that the burden shall be on the State to prove that it has done everything in its capacity to ensure at least that level of guarantee. Audrey Chapman took part in the expert meeting held in Maastricht in January 1997, but she overstates her case where she suggests that the meeting took up the approach she advocated (see Chapman, "The Status of Efforts to Monitor Economic, Social and Cultural Rights", cited above, at 155). 11