Chapter 1 | Page 5 actions are manifest in policy actions and directions, this obligation requires the incorporation of ESC rights obligations into policymaking and implementation processes. This element of the obligation also implies that, while the State is the primary duty-bearer in taking necessary steps for the realisation of these rights, there is recognition that the State must actively seek and make use of international assistance and co-operation in order to ensure the realisation of these rights. Secondly, ‘to the maximum of its available resources’ implies a duty to make the maximum use of resources (hence the capacity) of the State to ensure realisation of these rights. The phrase also indicates recognition of the essential role of ‘resources’ in ensuring realisation of these rights, with accompanying obligations to give priority in resource allocation to the rights recognised in the Covenant. Thirdly, these rights must be realised fully through a ‘progressive’ policy approach, indicating that while actions targeting the enjoyment of rights may not achieve immediate success, there is nonetheless a clear obligation on the State to approach the realisation of these rights in a consistent and progressive manner with a clear aim of eventually achieving full realisation. Fourthly, the phrase ‘by all appropriate means’ indicates that States must employ all policy tools and means available in order to achieve the realisation of these rights. The specific mention of ‘legislative measures’ indicates the seriousness of the intention in the application of these means, and the need to entrench policy actions within the overall governance of the State. These individual conceptual elements derived from Article 2(1) have attracted significant interest and discussion among scholars.13 The key issues arising include: the challenges associated with determining what ‘taking steps’ implies in terms of State action; the meaning of ‘maximum available resources’ in relation to resources and capacity; whether ‘progressive realisation’ 13 For example, Philip Alston and Gerard Quinn, 'The Nature and Scope of States Parties' Obligations under the International Covenant on Economic , Social and Cultural Rights' (1987) 9(2) Human Rights Quarterly 156-229; Manisuli Ssenyonjo, Economic, Social and Cultural Rights in International Law (Hart Publishing, Oxford, 2009).