154 THE YALE JOURNAL OF INTERNATIONAL LAW [Vol. 33: 113 respect—and retains a focus on the result-bas ed duties to fulfill. 231 With this abstraction, commentators have been ab le to formulate the varied types of positive and negative obligations flowing from the recognition of an economic and social right. In more concret e terms, for example, a governmentsponsored forced evi ction is incompatible with the duty to respect a right to housing, a gover nment failure to regul ate the security of tenure for rental accommodations or informal settlements implicates th e duty to protect the right, and the inadequate provision of emergency housing facilities exemplifies a failure of th e duty to fulfill a right. 232 The Committee has designated all three types of obligations as “core, ” provided they impact on the prioritized content of economic and social righ ts. Although the so-called “tertiary” duties (the duties to fulfi ll) are supposedly less precise than the other forms of obligation, 233 the Committee has included them under the core obligations umbrella. Yet, despite this heavy analytical arsenal, the enumer ation of cor e obligations has been far from coherent. Instead, the Committee has followed a meandering course of logic as to what amounts to su ch obligations, delivered by recourse to the work of the UN speci alized agencies, the declarations of international gatherings of particul ar expertise, and a consensus of the Committee members themselves.234 The Committee’s first attempt to enumerate core obligations leaned heavily on the “organizing principles” that would be necessary to substantiate the content of each right in more concrete terms, and focused on the availability, accessibility, an d quality of the material good relating to each right.235 These principles formed the basis of the core content of the right to food, set out in General Comment Number 12 in 1999,236 which commenced a 231. Id. at 110-14 (pointing out this overlap and out lining the different obligations to respect, protect, and fulfill); see also Maastricht Guidelines on Vi olations of Economic, Social and Cultural Rights, supra note 41, ¶ 6 (endorsing the typology, with examples). 232. See also General Comment No. 12 , supra note 33; General Comment No. 13 , supra note 33; General Comment No. 14 , supra note 10; UNDP 2000 Housing Rights, supra note 33 (all invoking the respect, protect, an d fulfill typology). For an example of the South African Constitu tional Court finding a negative violation of the ri ght to housing in section 26(1), see Jaftha v Schoeman 2005 (1) BCLR 78 (CC) at 91-92 (S. Afr.) (holding South Africa’s Magistrates’s Court Act (permitting “a person to be deprived of existing access to adequate housing”) unconstitutional where it perm itted the sale in execution of people’s hom es in order to sa tisfy even petty debts). F or commentary on Jaftha, see Liebenberg, Needs, Rights and Transformations, supra note 106, at 27-29. 233. See Scott & Macklem, supra note 173, at 77 (“[O]ne must not attach too great a degree of imprecision to the obligation to fulfill social rights.”). 234. For a discussion of the expertise of the Comm ittee, see SEPÚLVEDA, supra note 174, at 2944 (describing the Committee’s present working methods). 235. The Special Rapporteur on Prim ary Education, Katarina Tom aševski relied on the principles of availability, accessib ility, acceptability, and adaptability. See Econ. & Soc. Council [ECOSOC], Comm’n on Human Rights, Preliminary Report of the Special Rapporteur on the Right to Education, ¶¶ 51-74, U .N. Doc. E/CN.4/1999/49 (Jan. 13, 1999) ( prepared by Katarina Tomaševski); see also BRIGIT C.A. TOEBES, THE RIGHT TO HEALTH AS A HUMAN RIGHT IN INTERNATIONAL LAW 36465 (1999) (adopting similar principles of availa bility, accessibility, equality, and quality for substantiating the protection offered by the right to health). 236. General Comment No. 12 , supra note 33, ¶ 8 (identifying the core content as encompassing “[t]he availability of food in a quantity and quality suffi cient to satisfy the dietary needs of individuals, free from adverse substances, and acceptable with in a given culture; [and t]he accessibility of such food in ways that are sustaina ble and that do not interfere with the enjoy ment of other human rights”); see also id. ¶¶ 12-13 (providing a f urther definition of “availability” and “accessibility”).