International Human Rights Law: Substantive Rights · International Human Rights Law: Substantive...

Richard Hustad, Norwegian Centre for Human Rights, [email protected] © 2008, All Rights Reserved

International Human Rights Law: Substantive Rights (HUMR 5120/4120/1120)

Lecture 4The Right to Education29 October 2008

Richard Hustad, Norwegian Centre for Human Rights, HUMR 5120/4120/1120, Lecture 4: Right to Education © 2008, All Rights Reserved

Substantive Right of the Day:

The Right to Education


Outline of Class• Focus: Freedom of Expression

– Specific definitions of selected notable issues within the right– General procedure with the right– International standards (avoiding Eurocentricity)

• Format: Case Approach and Discussion– Use of cases to articulate details of the right– Participatory discussion to understand and apply right to reality– Instructor’s role of posing questions, not providing ’answers’– Students should question everything and at any time

• Expected Outcome: Value added– More thorough understanding of the right than the reading enables– Ability to consider an issue within the right and effectively analyze it

• Reminder:


International Education LawInternational Covenant on Economic, Social and Cultural Rights, Article 13

1. The States Parties to the present Covenant recognize the right of everyone to education. They agree that educationshall be directed to the full development of the human personality and the sense of its dignity, and shall strengthenthe respect for human rights and fundamental freedoms. They further agree that education shall enable all persons to participate effectively in a free society, promote understanding, tolerance and friendship among all nations and all racial, ethnic or religious groups, and further the activities of the United Nations for the maintenance of peace.

2. The States Parties to the present Covenant recognize that, with a view to achieving the full realization of this right: (a) Primary education shall be compulsory and available free to all; (b) Secondary education in its different forms, including technical and vocational secondary education, shall be

made generally available and accessible to all by every appropriate means, and in particular by theprogressive introduction of free education;

(c) Higher education shall be made equally accessible to all, on the basis of capacity, by every appropriate means, and in particular by the progressive introduction of free education;

(d) Fundamental education shall be encouraged or intensified as far as possible for those persons who have not received or completed the whole period of their primary education;

(e) The development of a system of schools at all levels shall be actively pursued, an adequate fellowship system shall be established, and the material conditions of teaching staff shall be continuously improved.

3. The States Parties to the present Covenant undertake to have respect for the liberty of parents and, when applicable, legal guardians to choose for their children schools, other than those established by the public authorities, whichconform to such minimum educational standards as may be laid down or approved by the State and to ensure thereligious and moral education of their children in conformity with their own convictions.

4. No part of this article shall be construed so as to interfere with the liberty of individuals and bodies to establish and direct educational institutions, subject always to the observance of the principles set forth in paragraph I of thisarticle and to the requirement that the education given in such institutions shall conform to such minimum standards as may be laid down by the State.

European Convention on Human Rights, Protocol 1, Article 2

No person shall be denied the right to education. In the exercise of any functions which it assumes in relation to educationand to teaching, the State shall respect the right of parents to ensure such education and teaching in conformity withtheir own religions and philosophical convictions.


Object, Purpose and Context(See the Vienna Convention on the Law of Treaties, Article 31)

CESCR/COM GC 13 (1)• Innate value of education

– ”a well-educated, enlightened and active mind, able to range freelyand widely, is one of th joys and rewards of human existence.”

• Instrumental value of education– Indispensable means of realizing other human rights (empowering

women, safeguarding children from exploitative and hzardouslabour and sexual exploitation, promoting human rights and democracy, protecting the environment, and controlling populationgrowth”)

– [A]n empowerment right [to] lift […] out of poverty.


University of Oslo during Occupation


Didrik Arup Seip, UiO President

The Aula


University of Oslo30 Nov. 1943


Art. 13 (2) (a), (b) & (c): ”free to all”• Primary education?

– GC 11 (7): ”The nature of this requirement is unequiocal. The right is expresslyformulated so as to ensure the availability of primary education withoutcharge….”

But:– GC 11 (1): States have two years to make a plan, plus reasonable time to

implement that plan– GC 11 (8): State must adopt a plan of action within two years of becoming a

party that sets out how this requirement will be achieved.– GC 11 (9): The obligation to adopt a plan of action is immediate without regard

to resources.– GC 11 (10): ”The plan of action must be aimed at securing the progressive

implementation of the right to compulsory education, free of charge […].”• Secondary education?• Higher education?

– GC 13 (14): ” ’Progressive introduction of free education’ means that whileStates must prioritize the provision of free primary education, they also have an obligation to take concrete steps” for free secondary and higher education.

– Leyla Sahin v. Turkey (ECHR, 2005): ”[T]here is no watertight divisionseparating higher education from other forms of education.” (para. 136)


Right to Private Schooling

• CESCR, Art. 13 (4)– ”No part of this article shall be construed so as to interfere with the

liberty of individuals and bodies to establish and direct educationalinstitutions […].”

• CESCR/COM, GC 13 (30)– ”[E]veryone, including non-nationals, has the liberty to establish

and direct educational institutions. The liberty also extends to ’bodies,’ i.e. legal persons or entities.”


Right to Private SchoolingIngrid Jordebo v. Sweden (ECHR, 1987)• Facts:

– A private foundation opened a primary school which it successfullyoperated for several years. It then applied for accreditation to teach middle and upper stages of education.

– The local government denied this request on the articulatedground that the teachers were not sufficiently qualified for thisfunction.

• Holding:– Kjeldsen v. Denmark stood for the proposition that their is a right to

start and run a private school.– In this case, that right was not violated.


Art. 13 (2): ”available free to all”Lindgren and Lundquist v. Sweden, 1998 HRC 298 & 299• Facts:

– Authors’ children attended private schools that did not offer the same levelof subsidies as public schools (tuition, transport, textbooks, school meals).

• Holding (under CCPR, Art. 26):– ”The State party cannot be deemed to be under an obligation to provide

the same benefits to private schools; indeed, the preferential treatmentgiven to public sector schooling is reasonable and based on objectivecriteria.”

– ”The decision of the authors of these communications to choose private education was not imposed on them by the State party or by themunicipalities concerned, but reflected a free choice recognized and respected by the State party and the municipalities. Such free decision, however, entails certain consequences, notably payment of tuition, transport, textbooks and school meals. The Committee notes that a Stateparty cannot be deemed to discriminate against parents who freely choosenot to avail themselves of benefits which are generally open to all.”


Art. 13 (2): ”available free to all”Blom v. Sweden, 1985 HRC 191• Facts:

– Author alleged discrimination between public and private schoolsbecause the public school system had a system of cash stipends for expenses while if one opted for a private school this stipend was not available.

• Holding (under CCPR, Art. 26):– Funding and benefits distinctions between public and private

school systems are not discriminatory, per se. (para. 10.3)


Art. 13 (2): ”available free to all”Waldman v. Canada, 1996 HRC 694• Facts:

– Author is a member of the Jewish faith in Ontario, Canada whosends his children to a Jewish private school that receives nofunding from the state, despite the school’s desire for funding.

– In Ontario, the state funds an ordinary public school system and a system of Catholic schools. The reason for this system dates to the 1860s when there was severe discrimination against theCatholic religion.

– Ontario refuses to fund the religious school.

• Holding (under CCPR, Art. 26):– The question is a comparison of public funding of one

denomination versus other denominations, but not ordinary publicschool versus Jewish schools.

– When the state acts with regard to one conviction, it must provideequal treatment to other convictions.


ECHR, Prot. 1, Art. 2, 1st: AccessBelgium Linguistics Case (ECHR, 1968)• Facts:

– French speaking minorities in Flemish areas did not have minoritylanguage education

– Flemish-speaking minorities in French areas did have minoritylanguage instruction

• Holding:– There is a right of access and a right of ’effective’ access– No right to instruction in language of choice– No requirement to establish particular types of educational

systems—simply access to those that exist. (para. 7)• In particular, not even a requirement to establish or subsidize

schools in other languages.– Nevertheless, a violation in cooperation with Article 14’s prohibition

of discrimination.


ECHR, Prot. 1, Art. 2, 1st: AccessCyprus v. Turkey (2001)• Facts:

– In Northern Cyprus, Greek-Cypriots received primary education in Greek-speaking schools, but at the secondary level education wasavailable only in Turkish or English.

• Holding:– ”In the strict sense […] there is no denial of the right to education”

(para. 277)– The language restriction was an effective barrier to secondary

education because there was no ’realistic’ option

• Rule of Law:– Effective barriers to access are a violation, even if not so on their

face.


Effective Access to Private SchoolsConsider X v. UK (ECHR, 1978)• In Northern Ireland, schools were denominational.

– Public schools are Protestant– Private schools are Catholic

• If there were no other school alternatives, does a parent have an effective choice in educationalenvironment? Is free choice really free?

Lough View IntegratedPrimary School,

Belfast, N. Ireland


Art. 13 (2): Special MeasuresWaldman v. Canada, 1996 HRC 694• Facts:

– Ontario case with non-funded Jewish schools in comparison to publicly-funded Catholic schools.

– State alleged that distinction was not discrimination becauseCatholics had historically endured discrimination and the publicfunding was to remedy that situation (in fact, the Catholic fundingwas secured in the 1867 constitution).

• Holding:– ”The material before the Committee does not show that members

of the Roman Catholic community or any identifiable section of thatcommunity are now in a disadvantaged position compared to thosemembers of the Jewish community that wish to secure theeducation of their children in religious schools. Accordingly, theCommittee rejects the State party's argument that the preferentialtreatment of Roman Catholic schools is nondiscriminatory […].”(para. 10.4)


Access to ”higher education”• CESCR, Art. 13 (2) (c): ”Higher education shall be made

equally accessible to all, on the basis of capacity, by everyappropriate means […].”– GC 13 (19): ”higher education is not to be ’generally available,’ but only

available ’on the basis of capacity.’ The ’capacity’ of individuals should be assessed by reference to all their relevant expertise and experience.”

– GC 13 (32): ”The adoption of temporary special measures intended to bring about de facto equality for men and women and for disadvantagedgroups is not a violation of the right to non-discrimination with regard to education, so long as such measures do not lead to the maintenance ofunequal or separate standards for different groups, and provided they arenot continued after the objectives for which they were tkaen have beenachieved.”

– GC 13 (59): States must take measures to address de facto educationaldiscrimination.

• Leyla Sahin v. Turkey (ECHR, 2005) – ”[A]ny State [that sets up institutions of higher education] will be under an

obligation to afford an effective right of access to [them].” (para. 137)– Due to the importance of education, ”it would be hard to imagine that

institutions of higher education existing at a given time do not come withinthe scope of the first sentence of Article 2 of Protocol 1.” (para. 137)


University of Michigan Law SchoolConsider Grutter v. Bollinger, 539 U.S. 306 (2003)

• Simplified facts: Admission to the university used the followingweighted evaluation to arrive at an assessment value that wasnot determinative of admission, but to which there was greatdeference.– 110 = previous academic achievements– 10 = socio-economic status– 10 = under-represented minority identification– 5 = personal achievement– 5 = alumni connections– 5 = scholarship athlete– 2.5 = scholarship athlete– 2.5 = quality of admission essay

• Holding: Student diversity was important because it bothcounters racial stereotypes and ensures the presence of racialminorities in the nation's elite.


ECHR, Prot. 1, Art. 2, 1st: AccessTimishev v. Russia (2005)• Facts:

– Family originally from Chechnya moved to neighboring Russianregion and children sought to attend local schools in that region.

– The local Russion region refused to permit the children to attendschools there on two grounds: (1) they should attend the schoolsin their home region in Chechnya, and (2) since the schools in theregion were already over-filled, admitting the children would denythe rights of children originally from that region.

• Holding:– This is a blatant denial of access to education guaranteed by the

first sentence.– Right of all children in region must be considered, not one against

another.– State action prevented Timishev’s children from attending school.


ECHR, Prot. 1, Art. 2, 1st: AccessCampbell and Cosans v. UK (1982)• Facts:

– Cosans was suspended from school for refusing to submit to corporal punishment (being hit for breaking rules).

– He would not be readmitted to school until he (and his mother) consented to this form of punishment at the school.

– He remained out of school for nearly one year.

• Holding:– Violation of the 1st sentence of Art. 2.– State action prevented Cosans from accessing education

(suspension).


Access for Ilegal Immigrants?• Should education be available only to legal residents of a

particular state?

• CoE, Council of Ministers, Recommendation 1353 (1998), Article 21: ”Education is a fundamental human right and therefore access to all levels, including higher education, should be equally available to all permanent residents of theState signatories to the European Cultural Convention.”

• CESCR/COM 13 (34): ”The Committee takes note of article 2 ofthe Convention on the Rights of the Child and article 3(e) ofUNESCO Convention Against Discrimination in Education and confirms that the principle of non-discrimi-nation extends to all persons of school age residing in the territory of a State party, including non-nationals and irrespective of their legal status.”


ECHR, Prot. 1, Art. 2, 2nd: CurriculumKjeldsen, et. al. v. Denmark (1976)• Facts:

– Denmark was concerned about the number of unwanted pregnancies so established a committee of experts to examine the issue.

– The committee proposed that sex education be integrated into the schoolcurriculum and the Danish parliament unanimously agreed.

– The curriculum started in 1st grade with concept of family and in 5th to 7th grades included puberty and sexual activities.

– Children were not allowed to be exempt.– Applicants parents claimed violation of their Christian beliefs.

• Holding:– The existence of private schools does not relieve the state of its duty to

respect the rights of parents. The Protocol places restrictions on ”anyfunctions” by the state. (para. 50)

– The second sentence safeguards pluralism within public education, whichis essential for the preservation of a ’democratic society.’

– Parents’ convictions must be respected throughout the entire Stateeducation program, whether religious or philosophical. (para. 51)

– ”The state is forbidden to pursue an aim of indoctrination that might be considered as not respecting parents’ religious and philosophicalconvictions.” (para. 53)


ECHR, Prot. 1, Art. 2, 2nd: CurriculumAngelini v. Sweden (1986)• Facts:

– Applicants were parents of atheist children at a school where therewas a class instructing in the state religion.

• Holding:– Instruction in religion is not a rights violation when exemptions or

alternatives are available.


ECHR, Prot. 1, Art. 2, 2nd: Curriculum Kjeldsen, et. al. v. Denmark (ECHR, 1976)• Facts:

– Denmark had a system of sex education in public schools.– The state also provided substantial subsidies to private schools of

various religious faiths and alternative teaching methodologies.

• Holding:– Private schools may be an alternative educational choice of the

parents, but cannot be the only alternative to indoctrination in public schools. (para. 50)


ECHR, Prot. 1, Art. 2, 2nd: CurriculumW & D.M. and M & H.I. v. UK (1984)• Facts:

– Applicants wanted to send children to single-sex primary schools, but there were no available places at these schools. As a result, the children attended public co-educational schools.

– Applicants claimed that the public schools to which they wereforced by circumstance to accept were indoctrinating the children.

• Holding:– The test for evaluating education curriculum is whether teachings

are ”conveyed in an objective, critical or pluralistic manner.”– The objective of this test is to prevent the school from competing

with the parents in the transmission of values and convictions. (para. 100)

– No violation in this case


ECHR, Prot. 1, Art. 2, 2nd: CurriculumHartikainen v. Finland, 1978 HRC 40• Facts:

– The authors did not believe in any religion, yet claimed a violationof Article 18 (freedom of religion or belief)

– The curriculum included a course about various religions and religious beliefs.

• Holding (under CCPR, Art. 18 (4)):– A no-belief system is protected under Article 18.– There is no infringement on freedom of belief when instruction is

given in ”a neutral and objective way and respects the convictionsof parents.”


Convictions in SchoolsHRC GC 22 to CCPR Art. 18 (religion)• “[A]rticle 18.4 permits public school instruction in

subjects such as the general history of religions and ethics if it is given in a neutral and objective way”,

• “public education that includes instruction in a particular religion or belief is inconsistent with article18, paragraph 4 unless provision is made for non-discriminatory exemptions or alternatives that wouldaccommodate the wishes of parents or guardians.”


Convictions in SchoolsLeirvåg v. Norway, 2003 HRC 1155• Facts:

– Norwegian ’KRL’ Case

• Holding (under CCPR, Art. 18):– The curriculum of the course (para. 14.3)

• ”[T]he subject gives priority to tenets of Christianity over otherreligions and philosophies of life.”

• The curriculum was not presented in a neutral and objectiveway: it is in relgion, not about religion

– The exemption from the course (paras. 14.6 – 14.7)• The ”system of partial exemption imposes a considerable

burden on [parents].”• The ”scheme does not ensure that education of religious

knowledge and religious practice are separated in a way thatmakes the exemption scheme practicable.”

• Students experience ”loyalty conflicts.”


Convictions in SchoolsFolgerø v. Norway, (ECHR, 2007)• Facts:

– Norwegian ’KRL’ Case

• Holding (under ECHR, Prot. 1, Art. 2, 2nd):– The curriculum was unbalanced (para. 90-95):

• The object of the course was explicitly Christian• Composition of course was a ”clear preponderance of Christianity”• Required ”fundamentals” (”thorough knowledge”) of Christianity versus

”main features” of other convictions.– The exemption system was insufficient (paras. 96-102)

• It was impractical to determine what was objectionable• It resulted in self-censorship in objecting because it required parents to

explain own convictions (privacy issues)• The ”reasonableness” standard of review led to self-censorship in

objecting to avoid conflict over nature of convictions• Even a granted exemption was no guarantee that student would not

be subject to objectionable material (teachers try to work around)


ECHR, Prot. 1, Art. 2, 2nd: ’Convictions’Belgium Linguistics Case (ECHR, 1968)• Facts:

– French speaking minorities in Flemish areas did not have minoritylanguage education

– Flemish-speaking minorities in French areas did have minoritylanguage instruction

• Holding:– No right to instruction in language of choice– States must heed parental preferences only with regard to

religious or philosophical convictions.– Violation of ECHR Art. 2 in cooperation with Art. 14—

discrimination– There is a right of access and a right of ’effective’ access.


ECHR, Prot. 1, Art. 2, 2nd: ’Convictions’Valsamis v. Greece (1996)• Facts:

– Parents of a child objected to the required school attendance at a national day parade, alleging that it infringed upon their pacifistbeliefs as Jehovah’s Witnesses because military processions wereincluded in some parades.

• Holding:– Religious convictions within the definition of the ECHR flow from

beliefs that ”enjoy both the status of a ’known religion’ and theadvantages flowing from that as regards observance.” (para. 25)

– Methodology of Court:• Majority Opinion: the court independently evaluated the nature

of the parade in question and held that it did not violatepacifistic views.

• Dissent: ”We are of the opinion that the court has to accept”the applicants claim of incompatibility with a belief system. (para. 32)


ECHR, Prot. 1, Art. 2, 2nd: ’Convictions’Campbell and Cosans v. UK (1982)• Facts:

– Scottish corporal punishment case– Parents claimed such punishment on their child was contrary to

their philosophical convictions (outside of any particular religiousscheme)

• Holding:– ’Convictions’ is not the same as ’opinions’ or ’ideas’– ’Convictions’ is more like ’beliefs’: it ”denotes views that attain a

certain level of cogency, seriousness, cohesion and importance. (para. 36)

– ’Philosophical convictions:’ (para. 36)• ”such convictions as are worthy of respect in a democratic

society and are not incompatible with human dignity…”• Those that relate to ”a weighty and substantial aspect of

human life and behaviour.”


Education in Human RightsIs this convictions in schools?• UDHR, Art. 26, ”Education shall be directed […] to

the strengthening of respect for human rights and fundamental freedoms […].”

• CESCR, Art. 13 (1): ”Education […] shall further theactivities of the United Nations for the maintenanceof peace.”

• Vienna Programme of Action (1993), para. 79: ”TheWorld Conference on Human Rights calls on all States and institutions to include human rights, humanitarian law, democracy and rule of law as subjects in the curricula of all learning institutions.”


Balancing RightsEducation vs. Subsistence• CESCR/COM GC 13 (55): ”States parties have an

obligation to ensure that communities and families are not dependent on child labour.”


Children’s Rights vs. Parents’ RightsIACt.HR, Advisory Opinion OC-17 (2002)• ”[T]he right to education, which contributes to the possibility of

enjoying a dignified life and to prevent unfavorable situations for the minor and for society itself, stands out among the specialmeasures of protection for children and among the rightsrecognized for them in Article 19 of the American Convention.”(para. 84)

• ”[C]hildren’s rights require that the State not only abstain from unduly interfering in the child’s private or family relations, butalso that, according to the circumstances, it take positive stepsto ensure exercise and full enjoyment of those rights. Thisrequires, among others, economic, social and culturalmeasures.” (para. 88)

• ”The State, given its responsibility for the common weal, must likewise safeguard the prevailing role of the family in protectionof the child; and it must also provide … assistance to the familyby public authorities, by adopting measures that promote familyunity.” (para. 88)


Balancing Rights: HeadscarfsHudoyberganova v. Uzbekistan2003 HRC 1155

• Facts:– Author was a member of Islamic faith. She wore a headscarf

(’hijab’) to her university classes.– Three years after her enrollment, the university passed a

regulation forbidding the wearing of headscarfs in classes.– The author refused to remove her headscarf and was expelled

from the university for a ”negative attitude towards the professors”and a violation of the no-headscarf rule.

• Holding:– Absent a justification by the state party, there was a violation of

Article 18, para. 2 (freedom of expression).

• Rule of Law:– There is a right of expression (manifest one’s religion) within the

classroom, subject to valid justifications.


Balancing Rights: HeadscarfsLeyla Sahin v. Turkey• Facts:

– “By virtue of the Constitution, the law and regulations, and in accordancewith the case-law of the Supreme Administrative Court and the EuropeanCommission of Human Rights and the resolutions adopted by theuniversity administrative boards, students whose ‘heads are covered’ (whowear the Islamic headscarf) and students (including overseas students) with beards must not be admitted to lectures, courses or tutorials. Consequently, the name and number of any student with a beard or wearing the Islamic headscarf must not be added to the lists of registeredstudents. However, students who insist on attending tutorials and enteringlecture theatres although their names and numbers are not on the lists must be advised of the position and, should they refuse to leave, theirnames and numbers must be taken and they must be informed that theyare not entitled to attend lectures. If they refuse to leave the lecturetheatre, the teacher shall record the incident in a report explaining why it was not possible to give the lecture and shall bring the incident to theattention of the university authorities as a matter of urgency so thatdisciplinary measures can be taken.”


Balancing Rights: HeadscarfsKaraduman v. Turkey (ECHR, 1993)• Holding:

– State ban on head scarfs was lawful in this instance because it was protecting other students from pressure exerted upon them by conservative Islamic elements at the school to wear headscarfs.


Balancing Rights: HeadscarfsDahlab v. Switzerland (ECHR, 2001)• Facts:

– A teacher wore a headscarf

• Holding:– This was a ”powerful external symbol” that could be seen as

having a proselytising effect. It could be seen as counter to genderequality, tolerance, and non-discrimination that teachers shouldconvey.


’Education’Campbell and Cosans v. UK (ECHR, 1982)• Facts:

– Corporal punishment case from Scotland– State claimed that ECHR distinguished between substantive

curiculum and ”ancillary” matters of administration which wereoutside the scope of ’education’ or ’teaching.’ (para. 32)

• Holding:– ”Education is the whole process whereby, in any society, adults

endeavour to transmit their beliefs, culture and other values to theyoung.”

– ”Teaching or instruction refers in particular to the transmission ofknowledge and to intellectual development.” (para. 33)

– Discipline falls within the educational system in general. (para. 35)

• Rule of Law:– HR protections extend beyond just ’teachings’ to include the entire

educational system.


Balancing Rights: HeadscarfsLeyla Sahin v. Turkey, 1998 ECHR 44774

• Holding:– ”The restriction pursued the legitimate aims of protecting the rights

and freedoms of others and maintaining public order. The obviouspurpose of the restriction was to preserve the secular character ofeducational institutions.” (para. 158)

• Dissent:– The applicant was de facto deprived of the right of access to the

university and, consequently, of her right to education. (para. 15)– The applicant was left with no educational alternative rendering her

right to education ineffective (she ended up at a university in Austria where it would be difficult to have her medical degreerecognized in Turkey).


© 2008• This presentation is the copyright of Richard Hustad.• All rights are reserved. There is no claim to any of the photographs,

illustrations, or quotations—all of which are part of the public domain.• Except for the quotation of short passages for the purposes of criticsm and

review, no part of this publication may be represented, reproduced, stored in a retrieval system, or transmitted, in any form or by any means, electronic, mechanical, photocopying, recording or otherwise, without the prior writtenpermission of the author.

• Permission is expressly granted for educational or any other not-for-profitpurpose as long as credit is attributed according to contemporary methods andthe author is notified in writing.

Contact Info:

Richard HustadPhone: 22 84 20 58

E-mail: [email protected]: NCHR Room 444

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