5. INTERNATIONAL HUMAN RIGHTS TREATIES International human rights law addresses itself to States and regulates their conduct with respect to individuals within their territorial control. Accordingly, an individual may bring claims under international human rights law for violations by State actors or for violations resulting out of State failure to protect the treaty rights of the individual. Human rights law does not yet recognise the right of individuals to bring actions directly against the perpetrator, whether public or private actors, before any of the regional or international human rights bodies; claims can only be filed against States. Given that women are often victims of violence by non-State actors, making claims under international human rights law has limited use for women. This presents a real barrier for justice for women, particularly in internal armed conflict situations where women are victims of sexual violence by all parties including the rebel groups.143 Despite the limitations of international human rights law, the individual complaints mechanisms of certain human rights treaties are among the few options available to women to pursue justice. The use of such mechanisms therefore needs to be strengthened. The treaty bodies with the most potential to address specific gender related violations and the ones often used by women applicants are the follows: 5.1 UN Convention on Elimination of All Forms of Discrimination against Women (CEDAW) 5.1.1 Substantive protections The UN Convention on the Elimination of All Forms of Discrimination against Women (CEDAW)144 sets out the obligations of State Parties to combat discrimination and promote substantive equality for women. Despite being singularly the most significant human rights treaty focused on women’s human rights, the word ‘violence’ does not appear in it at all. This omission was corrected in 1992 when the CEDAW Committee issued General Recommendation 19.145 It explains that ‘gender-based violence’ such as family violence, forced marriage, dowry deaths, acid attacks, female circumcision, sexual harassment, compulsory sterilisation or abortion or conversely denial of reproductive health services, battering, rape and other forms of sexual assault are forms of discrimination that gravely affect women’s enjoyment of their human rights and therefore fall clearly within the prohibition of discriminatory conduct in CEDAW. General Recommendation 19 also specifically addresses the situation of women in armed conflict. References to armed conflict in General Recommendation 19 include: 143  a clarification that gender-based violence which impairs or nullifies “the right to equal protection according to humanitarian norms in time of international or internal armed conflict” is prohibited by CEDAW.  The CEDAW Committee, explaining Article 6 of CEDAW that deals with prohibition of all forms of traffic in women, states that “Wars, armed conflicts and the occupation of territories often lead to increased prostitution, trafficking in women and sexual assault of women, which require specific protective and punitive measures.” See below, for discussion on the applicability of international humanitarian law. 144 The text of CEDAW is available at: http://www.ohchr.org/english/law/cedaw.htm. Entered into force 2 September 1981. 145 Committee on the Elimination of Discrimination against Women, General Recommendation No. 19, Violence against women, (11th Session, 1992) UN Doc. HRI\GEN\1\Rev.1. Available at http://www.un.org/womenwatch/daw/cedaw/recommendations/recomm.htm#recom19. 42 INTERNATIONAL HUMAN RIGHTS TREATIES | REDRESS