A/HRC/27/55 circumstances among homeless people who had devised a makeshift “toilet” from which one individual carried bags of human waste to dispose of in public toilets. The Special Rapporteur noted that this may amount to cruel, inhuman or degrading treatment.16 The Human Rights Committee in its review of the United States also expressed concern with respect to the criminalization of behaviours related to homelessness.17 23. Violations also result from decisions to deprive stigmatized groups, such as homeless people, undocumented migrants, occupiers of informal settlements or prisoners, of water and sanitation as a form of punishment for unlawful or undesired activity. The Special Rapporteur on torture has documented that detainees have been forced to rely on water to drink delivered by their families, or on water from toilets. 18 The Special Rapporteur on water and sanitation has also voiced concerns that limiting access to water and sanitation may be used as a, sometimes excessive, form of punishment for prisoners.19 In cases of secret detention, Special Rapporteurs 20 and the Council of Europe have expressed concern about detainees being forced to wear diapers, which is “offensive to the notions of dignity”.21 24. The Special Rapporteur is pleased to see that violations of the obligation to respect, such as unjustifiable disconnections or pollution of water resources are regularly brought to court. She encourages greater attention to violations that are linked to discrimination and stigmatization and threaten the inherent and equal dignity of all human beings. B. Violations of the obligation to protect and abuses by non-State actors 25. The obligation to protect requires States to enact and enforce necessary protections of the rights to water and sanitation to protect individuals from human rights abuses by third parties. Such obligation is generally considered to be of immediate effect, although in some cases it will take time and resources to develop the necessary institutional capacity and frameworks. Non-State actors, including private actors and international organizations, also contribute to the realization of human rights and, conversely, their action or inaction may also lead to human rights abuses. Where private actors are involved in the provision of water and sanitation services, their role comes with human rights responsibilities.22 Where States fail to provide services, private actors may be the only ones who step in as providers. Other private actors may have an impact on the rights to water and sanitation through their industrial or agricultural activities. 26. Violations of the obligation to protect can be grouped under several categories: (a) Failure to protect in the context of service provision; (b) Failure to protect necessary resources or infrastructure from pollution or interference; (c) At the same time, non-State actors may fail to comply with their human rights responsibilities. 16 17 18 19 20 21 22 8 A/HRC/18/33/Add.4, para. 58. CCPR/C/USA/CO/4, para. 19. A/64/215 and Corr.1, paras. 43–44. A/HRC/18/33/Add.3, para. 52. A/HRC/13/42, pp. 157, 163 and 166. Parliamentary Assembly of the Council of Europe, Committee on Legal Affairs and Human Rights, Alleged secret detentions and unlawful inter-state transfers involving Council of Europe member states, AS/Jur (2006) 16 Part II, provisional version, 7 June 2006, para. 87. A/HRC/15/31, para. 23.