Chapter 2 | Page 68 ‘irrespective of the availability of resources of the country concerned or any other factors and difficulties.’106 Thus, it can be argued that the minimum core reflects a ‘minimalist’ rights strategy, which trades rights-inflation for rights ambition,107 and the minimum core obligations set standards which cannot be sacrificed even for measures aimed at medium or long-term improvements of rights.108 The minimum core obligations thus should be given first priority by the State and sufficient resources should be allocated for their realisation.109 Meeting these minimum core obligations ‘should trump all other policy considerations.’110 2.3.1.4 Non-retrogression, limitations and derogations Although the Covenant does not explicitly prohibit retrogression111 of rights, it is recognised as part of the State obligations under the Covenant. The idea is that States should not allow the existing protection of ESC rights to deteriorate unless there is strong justification for any regressive measure.112 Recognising that the enjoyment of ESC rights is necessary for the enjoyment of all other rights,113 the Committee emphasised that regressive measures should be allowed only after careful consideration of the merits and reasons advanced 106 UN Commission on Human Rights, Note verbale dated 86/12/05 from the Permanent Mission of the Netherlands to the United Nations Office at Geneva addressed to the Centre for Human Rights ("Limburg Principles"), UN Doc E/CN.4/1987/17 (8 January 1987); International Commission of Jurists (ICJ), 'Maastricht Guidelines on Violations of Economic, Social and Cultural Rights' (1997). 107 Young, above n 104, 114. 108 Sabine Michalowski, 'Sovereign Debt and Social Rights - Legal Reflections on a Difficult Relationship' (2008) 8 Human Rights Law Review 35-68, 45. 109 Report of the United Nations High Commissioner for Human Rights, E/2007/82, above n 25, [12(d)]. 110 Ignacio Saiz, 'Rights in Recession? Challenges for Economic and Social Rights Enforcement in Times of Crisis' (2009) 1(2) Journal of Human Rights Practice 277-293, 283. 111 Note that a number of authors use the terms ‘regression’ as well as ‘retrogression’ in this context. This thesis uses ‘retrogression’ to reflect the ESCR Committee’s usage. 112 CESCR General Comment No 3, E/1991/23, above n 49. 113 Hertel and Minkler, above n 2, 2-8.