Chapter 2 | Page 52 discussed in Chapter 1, and makes the human rights endeavour relevant and sustainable. From this perspective, State intervention is invoked only when individuals do not have the means that enable them to enjoy the rights. For example, enjoyment of the right to an adequate standard of living is, first and foremost, achieved through individual effort. However, the State has an obligation to create the necessary socio-economic conditions and legal environment that will facilitate full enjoyment of this right. The State’s responsibility to provide becomes indispensable only if individuals are unable to achieve the standard of living expected for a dignified life from the perspective of ESC rights fulfilment. While the tripartite terminology of respect, protect and fulfil captures the spectrum of responsibilities on the State to ensure the enjoyment of human rights by the rights-holders, expectations of direct policy action can also be discerned in the obligations of conduct and result. 2.2.3 Obligations of conduct and result The language of the obligation of conduct and result is useful to recognise the actions and outcomes in relation to the State’s behaviour in advancing human rights. In the context of international law, the obligation of result involves a guarantee of outcome, whereas the obligation of conduct is in the nature of best efforts obligations―that is, ‘obligations to do all in one’s power to achieve a result, but without ultimate commitment’.28 The primary distinction here is that the State is responsible for the outcomes, whether or not these outcomes are the direct result of State policy or actions.29 Hence, it can be argued that a stronger 28 Ineke Boerefijn, 'Establishing State Responsibility for Breaching Human Rights Treaty Obligations: Avenues Under UN Human Rights Treaties' (2009) LVI Netherlands International Law Review 167-205, 171. 29 Sital Kalantry, Joycelyn Getgen and Steven Arrigg Koh, 'Enhancing Enforcement of Economic, Social and Cultural Rights Using Indicators: A Focus on the Right to Education in the ICESCR' (2010) 32 Human Rights Quarterly 253-310, 298.