Chapter 2 | Page 55 Robertson,34 Balakrishnan et al,35 Skogly,36 Elson, Balakrishnan and Heintz,37 Apodaca,38 Felner,39 Fukuda-Parr, Lawson-Remer and Randolph,40 and Saul, Kinley and Mowbray,41 among others. In addition, the ESCR Committee and Special Rapporteurs have addressed various aspects of the application of these concepts in practice. While this article sets out the foundational premise of obligations, its exact formulation and interpretation has been seen as problematic. The article has been described as a ‘somewhat confused and unsatisfactory provision’42 and it has been asserted that ‘the combination of convoluted phraseology and numerous qualifying sub-clauses seems to defy any real sense of obligation’.43 Moreover, the wording of the article is also seen as giving States an almost 34 Robert E Robertson, 'Measuring State Compliance with the Obligation to Devote the "Maximum Available Resources" to Realizing Economic, Social, and Cultural Rights' (1994) 16 Human Rights Quarterly 693-714. 35 Radhika Balakrishnan et al, Maximum Available Resources & Human Rights: Analytical Report (Center for Women’s Global Leadership, New Jersey, 2011). 36 Sigrun Skogly, 'The Requirement of Using the ‘Maximum of Available Resources’ for Human Rights Realisation: A Question of Quality as Well as Quantity?' (2012) 12 Human Rights Law Review 393-420. 37 Diane Elson, Radhika Balakrishnan and James Heintz, 'Public Finance, Maximum Available Resources and Human Rights' in Aoife Nolan, Rory O'Connell and Colin Harvey (eds), Human Rights and Public Finance: Budgets and the Promotion of Economic and Social Rights (Hart Publishing, Oxford, 2013) 13. 38 Clair Apodaca, 'Measuring the Progressive Realization of Economic and Social Rights' in Shareen Hertel and Lanse Minkler (eds), Economic Rights: Conceptual, Measurement, and Policy Issues (Cambridge University Press, Cambridge, 2007) 165. 39 Eitan Felner, 'Closing the ‘Escape Hatch’: A Toolkit to Monitor the Progressive Realization of Economic, Social, and Cultural Rights' (2009) 1 Journal of Human Rights Practice 402435. 40 Sakiko Fukuda-Parr, Terra Lawson-Remer and Susan Randolph, 'Measuring the Progressive Realization of Human Rights Obligations: An Index of Economic and Social Rights Fulfillment' (Economics Working Papers - Paper No 200822, University of Connecticut, Department of Economics). 41 Saul, Kinley and Mowbray, above n 7. 42 Matthew Craven, 'The Justiciability of Economic, Social and Cultural Rights' in Richard Burchill, David John Harris and Anne Owers (eds), Economic, Social and Cultural Rights: Their Implementation in United Kingdom Law (University of Nottingham Human Rights Law Centre, Nottingham, 1999) 1-12, 5. 43 Ibid.