132 THE YALE JOURNAL OF INTERNATIONAL LAW [Vol. 33: 113 needs” was to make exp licit the instrumental b enefits of basic needs satisfaction for a nati onal economy, r ather than regardi ng such a f ocus as anathema to economic growth. 101 Another more directly pertinent effect was to sponsor research into the “inner limit” of human needs in areas of nutrition, housing, health, literacy, and employ ment. For example, the United Nations Environment Programme encouraged research on an “inner limit” of minimum human needs, which, along wi th an “outer limit” of ecological requirements, would act as constraints on development policy. The World Bank dispensed with the ba sic needs strategy in the 1980s in favor of the more interventionist approach of “structural adjustment,” which it believed would better respond to th e globally depend ent development 102 Yet the failure of the basic needs challenges for less-developed states. strategy can be attributed to its own theoretical shortcomings as well as to global trends. Even advoca tes of the approach warned that it could collapse into a technical exercise of finding the conditions in which the abstract human animal could survive.103 Its detractors warned of the irrelevance of prescribing “inner limits” for actual populations. As critic G ilbert Rist remarked, its usefulness was restricted to “anti-societies” or “non-societies.” 104 And finally, as Philip Alston noted in his extens ive survey, the deve lopment hierarchy promoted by basi c needs (with its opposition to nonmaterial indicators of development and its limite d approximation of what civil and political rights might entail) did not match the normative goals of human rights.105 It is a stretch, but not a great stretch, to suggest that the criticisms of the basic needs strategy also apply to the survival-based interpretation of the minimum core. Although the former was developed in the development field, and the latter in the legal, there is an important analogy between them. Both the basic needs strategy and the s urvival-based minimum core attempt t o bracket other dimensions of human values by prescribing the “inner limits” of survival. Yet such values are bracketed at great cost. Not only does bracketing the values limit its usefulness for its target population s by inaccurately understanding their actual needs, th e approach could ac tively harm their interests by reducing t hem to “pass ive . . . r ecipients of pr edefined services rather than as agents involved in interpreting their needs and shaping their life conditions.”106 There are empirical li nks between material deprivation and a lack of democratic voice, because of the lack of accountability when things go wrong. Famines, as t he argument famously goes, do not occur in 101. E.g., INT’L LABOUR ORG., EMPLOYMENT, GROWTH AND BASIC NEEDS: A ONE-WORLD PROBLEM (1976). 102. See, e.g., CYPHER & DIETZ, supra note 48, at 516. 103. JOHAN GALTUNG, GOALS, PROCESSES, AND INDICATORS OF DEVELOPMENT: A PROJECT DESCRIPTION 13 (1978) (pointing to potential problem s in th eoretical abstraction, as well as “cultural biases and historical specificities . . . in the concept of needs”). 104. GILBERT RIST, THE HISTORY OF DEVELOPMENT: FROM WESTERN ORIGINS TO GLOBAL FAITH 163, 167-68 (new rev. ed. 2002). 105. Philip Alston, Human Rights and Basic Need s: A Critical Assessment , 12 H UM. RTS. J./REVUE DES DROITS DE L’HOMME 19, 55-56 (1979). 106. FRASER, UNRULY PRACTICES, supra note 75, at 174. Liebenberg applies F raser’s terminology to South Africa’s ec onomic and social rights. See Sandra Liebenberg, Needs, Rights and Transformations: Adjudicating Social Rights , 17 S TELLENBOSCH L. REV. 5 (2006) [hereinafter Liebenberg, Needs, Rights and Transformations].