A/HRC/27/55 other countries, for instance in Kenya.85 In the Beja case, a South African court found that a denial of meaningful engagement and effective community participation in decisionmaking regarding the design and installation of toilets violated constitutional rights.86 The Special Rapporteur recommends that increased attention be paid to the obligation to ensure participation. F. Violations of extraterritorial obligations 70. Violations of extraterritorial obligations are a growing concern in relation to the rights to water and sanitation, for instance in the context of transboundary water resources, the activities of transnational corporations, or donor activities. The Maastricht Principles on Extraterritorial Obligations, adopted by 40 experts to clarify the extraterritorial obligations of States on the basis of existing international law, affirm that the obligations to respect, protect and fulfil extend extraterritorially and that States must ensure the right to a remedy. 87 Human rights obligations also apply to actions of States as members of international organizations.88 The International Law Commission stated that a State member of an international organization would be breaking international law if it caused that organization to commit an act that would be illegal under international law for a State to carry out itself.89 71. Extraterritorial violations may occur, for example, when (a) States fail to regulate activities of companies under their jurisdiction that cause violations abroad; (b) States contribute to human rights violations in the context of development cooperation activities, including by imposing conditions that undermine rights; (c) States adopt sanctions that negatively affect the realization of human rights in other countries; (d) States fail to respect human rights or restrict the ability of others to comply with their human rights obligations in the process of elaborating, applying and interpreting international trade and investment agreements; (e) States fail to prevent harm resulting from greenhouse gas emissions which contribute to climate change that have negative impacts on the realization of human rights;90 and (f) water contamination or use causes human rights violations in a neighbouring country. 72. Treaty bodies have increasingly addressed violations of extraterritorial obligations. The Human Rights Committee has called for the regulation and monitoring of corporate activities abroad that may violate human rights and for measures to ensure access to remedies in the event of such violations. 91 Both the Human Rights Committee and the Committee on Economic, Social and Cultural Rights have expressed concern about the denial by Israel of access to water and sanitation and about the destruction of infrastructure 85 86 87 88 89 90 91 20 High Court of Embu, Kenya, Ibrahim Sangor Osman and Others v. the Hon. Minister Of State for Provincial Administration & Internal Security and Others, Constitutional Petition No. 2 of 2011 (3 November 2011). The High Court of South Africa (Western Cape High Court, Cape Town), Beja and Others v. Premier of the Western Cape and Others, (21332/10), 29 April 2011, para. 146 and note 38. Maastricht Principles on Extraterritorial Obligations of States in the area of Economic, Social and Cultural Rights (2012), Principle 37. Ibid., Principle 15. International Law Commission, “Draft Articles on Responsibility of International Organizations with Commentaries” in Report of the International Law Commission on the work of its 63rd session (2011) (A/66/10), art. 61, para. 1. See A/HRC/10/61, para. 29. CCPR/C/DEU/CO/6, para. 16.