2008] The Minimum Core of Economic and Social Rights 129 right to life on the one hand, and the rights to food, health, and housing on the other. For example, the Human Rights Committee extended the application of the right to life to the preventive heal th and food contexts, by requiring the adoption of positive measures to protect life through the elimination of disease epidemics and malnutrition.82 More recently, human rights advocates involved in the inter-American context have suggested that the right to life should form the orienting framework for econo mic and social rights litigation. 83 Courts in domestic systems have referenced the right to life in the context of emergency healthcare and shelter in India 84 and the right to minimum welfare in Canada.85 Even early participants in the American we lfare rights movement pointed to the r ight to life—and the right to live—as founding the constitutional protection of citizens’ welfare entitlements.86 Of course, these examples are attribut able to the legal persuasiveness of the right to life, which is protected in the foundational texts of both covenants and constitutions in a form someti mes substituting for, and sometimes surpassing, the protections of other material interests. In this sense, it is strategically sound (as well as jurisd ictionally contingent), to invoke the connections between the right to life and other economic and social rights.87 Yet there are other reasons to emphasize life. A connec tion between the minimum core and the basic needs requir ed for life and su rvival is useful because it focuses attentio n on the most urgent steps necessary for the satisfaction of those rights, which pr econdition the exercise of all rights— 82. See, for exam ple, ICCPR, supra note 38, art. 6, which was cited in Secretariat, Compilation of General Comments and General Reco mmendations Adopted by Human Rights Treaty Bodies, at 127, U.N. Doc. HRI/GEN/1/Rev.6 (2003). The Comment stated, at ¶ 5: The Committee has noted that th e right to li fe has been too often narrowly interpreted. The expression “inherent right to life” cannot properly be understood in a restrictive manner, and the protection of this right requi res that States adopt positive measures. In this connection, the Committee con siders that it would be desi rable for States parties to take all possible measures to r educe infant mortality and to incr ease life expectancy, especially in adopting measures to eliminate malnutrition and epidemics. Id. 83. James L. Cavallaro & Emily Schaffer, Less As More: Rethinking Supranational Litigation of Economic and Social Rights in the Americas , 56 H ASTINGS L.J. 217, 272 (2004) (favoring an expansive construction of the right to life (as well as the right to pr operty) which m ay be indirectly protective of economic and social rights). But cf. Melish, supra note 14, 312-33 (foreseeing problems of norm-dilution and underbreadth and, instead, advocating a direct approach to litigation fram ed by the economic and social rights themselves). 84. Samity v. State of W .B., (1996) 4 S.C.C. 37 (In dia) (the right to em ergency healthcare); see Sheetal B. Shah, Note, Illuminating the Possible in the Developing World: Guaranteeing the Human Right to Health in India, 32 V AND. J. TRANSNAT'L L. 435, 450 (1999); see also Ahmedabad Mun. Corp. v. Nawab Khan Gulab Khan, (1996) Supp. 7 S.C.R. 548 (India) (right to life incorporated right to shelter and requirement of alternative housing for ev ictees); Olga Tellis v. Bom bay Mun. Corp., (1985) 3 S.C.C. 545 (India) (finding that the right to dwell on pavements accepted as part of t he right to life and the right to livelihood). 85. Gosselin v. Quebec, [2002] S.C.R. 84, 429, 641 (Can.) (Arbour, J., dissenting) (arguing that the right to life is infringed by a large decrease of social security to recipients under thirty). 86. MARTHA F. DAVIS, BRUTAL NEED: LAWYERS AND THE WELFARE RIGHTS MOVEMENT, 1960-1973, at 37 (1993); see also Edward V. Sparer, The Right to Welfare, in THE RIGHTS OF AMERICANS 82 (Norman Dorsen ed., 1971). 87. Cavallaro & Schaffer, supra note 83 (arguing for the centrali ty of the right to life on strategic, rather than p hilosophic, grounds). One n eed only think of the associations built up in the United States over time, between the right to life and the state’s restrictions on abortion, which dampens the enthusiasm for many of building an extensive life protection from the due process clause.