A/HRC/27/55 calls on the United Nations to establish appropriate accountability mechanisms for ongoing and future missions as well as to review and reinforce measures for adequate sanitation and preventive measures. C. Violations of the obligation to fulfil 35. Violations of the obligation to fulfil may be the most critical category. Such violations are often complex and affect a large number of victims, yet they have generally received the least attention. Potential claimants face considerable challenges in relation to gaining access to justice for alleged structural or systemic violations. Jurisprudence, including the standards of review developed by courts in recent years, has demonstrated, however, that violations of the obligation to fulfil can indeed be adjudicated. 36. Violations of the obligation to fulfil can be grouped in the following categories: (a) Failure to develop, implement and monitor strategies, plans and programmes; (b) Failure to properly raise, allocate and utilize the maximum available resources; (c) Corrupt practices; (d) Unjustified retrogressive measures; (e) Failure to prioritize the necessary steps to ensure minimum essential levels of access to water and sanitation; (f) Failure to provide adequate services in public facilities and institutions and in emergency situations. 1. Failure to develop, implement and monitor strategies, plans and programmes 37. Article 2(1) of the Covenant stipulates that States must take steps to achieve progressively the full realization of economic, social and cultural rights by all appropriate means. Steps must be deliberate, concrete and targeted as clearly as possible towards the full realization of human rights. 35 Where resource constraints prevent a State from fully realizing the rights to water and sanitation immediately there is an immediate obligation to adopt a strategy for the realization of those rights. To assess progress towards the full realization of human rights, States must monitor progress. The Committee on Economic, Social and Cultural Rights regularly calls on countries to put into place mechanisms for that purpose.36 38. Violations may result from failure: (a) to design and implement a strategy based on human rights standards and principles; (b) to identify and meet targets in line with human rights standards; (c) to ensure effective monitoring and accountability; and (d) to target vulnerable or marginalized communities. 39. A seminal decision on the obligation to progressively realize socioeconomic rights is that taken in the Grootboom case, in which the Constitutional Court of South Africa considered the plight of a community lacking basic shelter, sanitation facilities and access to clean water. 37 To determine whether the State had complied with the obligation of 35 36 37 Committee on Economic, Social and Cultural Rights, general comment No. 3 (1990), on the nature of States parties’ obligations, para. 2. See, for example, E/C.12/YEM/CO/2, para. 4; E/C.12/BIH/CO/2, para. 21. Constitutional Court, South Africa, Government of the Republic of South Africa and Others v Grootboom and Others, 2000 (11) BCLR 1169 (CC). 11