Chapter 2 | Page 67 elements necessary for a dignified life, such as protection from starvation, primary education, emergency health care and basic housing.100 At the very least, ‘the minimum essential level of each right is incumbent upon every State party.’101 Furthermore, the Committee observed that: a State party in which any significant number of individuals is deprived of essential foodstuffs, of essential primary health care, of basic shelter and housing, or of the most basic forms of education is, prima facie, failing to discharge its obligations under the Covenant. If the Covenant were to be read in such a way as not to establish such a minimum core obligation, it would be largely deprived of its raison d'être.102 The concept of ‘minimum core content’, which provides a more practical and attainable standard of compliance for States, at the same time also takes attention away from focusing on richer and broader goals of ESC rights. Some of the criticisms of the concept highlight the difficulty of applying the standard to States with various socio-economic conditions, and its tendency to rank and order some rights.103 As Katharine Young points out, ‘it is a concept trimmed, honed, and shorn of deontological excess. It reflects a “minimalist” rights strategy, which implies that maximum gains are made by minimizing goals’.104 On the other hand, the ESCR Committee has emphasised that the concept of ‘minimum core’ provides an understanding of the direction and that States should follow in their compliance and gives an indication as to when such policy action or direction can be considered retrogressive.105 According to the Limburg Principles and Maastricht Guidelines, minimum core obligations reflect the ‘minimum subsistence rights for all’ which apply 100 CESCR General Comment No 3, E/1991/23, above n 49. 101 Ibid., [10]. 102 Ibid. 103 Karin Lehmann, 'In Defense of the Constitutional Court: Litigating Socio-Economic Rights and the Myth of the Minimum Core' (2006) 22(1) American University International Law Review 163. 104 Katharine G Young, 'The Minimum Core of Economic and Social Rights: A Concept in Search of Content' (2008) 33 The Yale Journal of International Law 113-175. 105 See for example, CESCR General Comment No 3, E/1991/23, above n 49; Committee on Economic, Social and Cultural Rights, General Comment No 18: The Right to Work (Article 6 of the International Covenant on Economic, Social and Cultural Rights), 35th sess, UN Doc E/C.12/GC/18 (6 February 2006).