Chapter 2 | Page 49 obligations’,13 while Judge Kate O'Reagan and Rolf Künnemann refer to a ‘continuum of a variety of duties’14 and a ‘spectrum of obligations’,15 respectively. At one end of this spectrum, the State has an obligation of no interference and, at the other end, positive duties are imposed on the State.16 The nature of State obligations arising out of the ICESCR may be represented at any point in the continuum and must be fully complied with in order to make ESC rights realisation meaningful. The drafting history of the ICESCR shows that the language of general and substantive obligations in the text of the Covenant did not go through a full ‘rationalisation’ process before adoption, which left a number of ‘inconsistencies’.17 This has resulted in some incongruities in terminology and the level of descriptive detail included in the articles.18 Significantly, the language of obligations used in different articles on substantive rights adopts a broad array of terminology. For example, the terms ‘recognise’, ‘ensure’ ‘respect’ and ‘guarantee’ are used in reference to the substantive rights without any discernible pattern or logic.19 Despite this lack of clarity in some areas of State obligation, the Covenant provides a firm legal basis, in plain and unequivocal language, for the States parties to take appropriate steps towards the realisation of all substantive rights recognised therein. 13 Cited from María Magdalena Sepúlveda, The Nature Of The Obligations Under The International Convenant On Economic, Social And Cultural Rights (Intersentia, Utrecht, 2003), 137. 14 Cited from ibid. 15 Rolf Künnemann, 'A Coherent Approach to Human Rights' (1995) 17(2) Human Rights Quarterly 323-342. 16 Sepúlveda, above n 13, 14. 17 Mathew Craven, The International Covenant on Economic, Social, and Cultural Rights: A Perspective on its Development (Clarendon Press, Oxford, 1995), 51. 18 For example, the amount of details in Article 11 and 13 is not maintained in Article 9, which provides very little insight into the nature of the right. 19 See, Todd Landman, Protecting Human Rights (Georgetown University Press, Washington, D.C., 2005), 49.