Chapter 2 | Page 48 the same ground as the ICESCR8 and, in the Inter-American human rights mechanism, the Protocol of San Salvador includes recognition of ESC rights, although their enforceability is often questioned.9 The African Charter on Human and Peoples’ Rights included from the outset the full range of human rights including ESC rights.10 Despite a slow start, ESC rights also enjoy constitutional status in countries in Africa, Asia, Europe, and Latin America, in sub-national units in North America and elsewhere,11 and in regional and international human rights instruments.12 These instruments of the international human rights regime lay down general and specific obligations on the States parties to respect, protect and fulfil the rights recognised in them. The nature of these obligations and the manner in which they are interpreted and understood in international law as well as their domestic application are fundamental aspects of human rights scholarship. The specific terminology of human rights obligations provides guidance on how these commitments are understood, implemented and monitored. 2.2.1 Terminology of ESC rights obligations The general nature of human rights obligations has generated a vast array of terminological classifications. Henry Shue uses the term a ‘continuum of 8 Council of Europe, European Social Charter, opened for signature 18 October 1961, CETS No. 035 (entered into force 26 February 1965). 9 See for example, Oswaldo R Ruiz-Chiriboga, 'The American Convention and the Protocol Of San Salvador: Two Intertwined Treaties Non-Enforceability of Economic, Social and Cultural Rights in the Inter-American System' (2013) 31(2) Netherlands Quarterly of Human Rights 159-186. 10 Manisuli Ssenyonjo, 'Reflections on state obligations with respect to economic, social and cultural rights in international human rights law' (2011) 15(6) The International Journal of Human Rights 969-1012, 972- 973. 11 For example, International Commission of Jurists, Courts and the Legal Enforcement of Economic, Social and Cultural Rights: Comparative experiences of justiciability (International Commission of Jurists, Geneva, 2008). 12 Katharine G Young, Constituting Economic and Social Rights (Oxford Scholarship Online, Oxford, 2012), 1 (Online) <10.1093/acprof:oso/9780199641932.001.0001>.