2008] The Minimum Core of Economic and Social Rights 153 giving legal priority to the range of alternative re sponses that the state may take, whether they lie in actively providing for par ticular entitlements or in protecting the existing social institutions which have helped to secure them. Proponents of this approach suggest that in focusing on obligations rather than content, one need not take a position on the hierarch y of the elements of each right, but concentrate on the more practical issue of timing.225 For example, “core obligations” en compass both obligations of conduct, which require a specific co urse of conduct (whether an act or omission), and obligations of result, which are fulfille d by a course of conduct left to the state’s discretion. Some commentators have suggested that the minimum core concept relates only to obligations of result because it is able to signal only the extent to which individuals are enjoying (or will enjoy) their rights rather than assess the policies and procedures that bring about that result. Thus, for example, Tara Melish pres ents a helpful four-dimen sional quadrant of the duties flowing from economic and soci al rights—utilizing both the resultconduct and individual-collective dis tinction—and places the minimum core obligation in the r esult-based, individual-based category of duties. 226 Nonetheless, this view does not accord with the “cor e obligations” orientation of the Committee. In contrast to an earlier view that the Covenant imposed only “obligations of result,”227 the Committee’s position is now to recognize a mixture of t he two types of obligation228 and include both types within its assessment of “core obligations.” This attitude gives implicit credence to the inevitable collapsibility of the two notio ns when the rights themselves come under closer analysis. Like the proce ss-substance dichotomy in the field of constitutional law, 229 the conduct-result distinction endures as much for its ability to further conceal some already hard-to-see relationships as for its ability to point out the ob vious. Obligations of conduct will frequently rely on an objective towards which the conduct aims. And obligations of result will themselves imply a parti cular course of action.230 Thus, the shift from core content to core obligation may entail a greater emphasis on conduct depending on how it is cast, but does not dispense with the substantive goals of certain minimum criteria. Similarly, the influen tial typology of duties suggested by Henry Shue and applied, in an adapt ed form, by the Committee, highlights the act and omission dimensions of the obligations of conduct—both duties to protect and 225. Audrey R. Chapm an & Sage Russell, Introduction to CORE OBLIGATIONS: BUILDING A FRAMEWORK FOR ECONOMIC, SOCIAL AND CULTURAL RIGHTS 1, 9 (Audrey R. Chapman & Sage Russell eds., 2002) [hereinafter CORE OBLIGATIONS]. 226. Melish, supra note 14, at 248. 227. Report of the International Law Commission, 2 Y.B. INT’L L. COMM’N 1, 20 (1977). 228. E.g., General Comment No. 3 , supra note 1; see also U.N. Econ. & Soc. C ouncil [ECOSOC]. Comm. on Econ., So c. & Cultural Rights, Summary Record of the 21st Meeting , ¶ 7, U.N. Doc. E/C.12/1990/SR.21; Maastricht Guidelines on Violations of Economic, Social and Cultural Rights, supra note 41, at 694; Alston & Quinn, supra note 27, at 165 (describing th e obligation under Article 2(1) to “undertake to take steps” as one of conduct). 229. Laurence H. Tribe, The Puzzling Persistence o f Process-Based Constitutional Theories, 89 YALE L.J. 1063, 1064 (1980) (questioning the departure from substance in John Hart Ely’s sem inal work on a process -based constitutional theory, DEMOCRACY AND DISTRUST: A THEORY OF JUDICIAL REVIEW (1980)). 230. CRAVEN, THE INTERNATIONAL COVENANT, supra note 5, at 107.