A/HRC/28/62 was entitled under the Housing Act, she challenged the local authority’s actions as a violation of her right to the protection of home and family life under article 8 of the European Convention.53 The court held that accessible accommodation was important because it would facilitate family life and would secure her “physical and psychological integrity”. The court ruled that “it would have restored her dignity as a human being”. 53. Despite those significant advances in a number of jurisdictions, domestic courts in other cases have failed to apply constitutional provisions and other domestic law to subnational governments in a manner that is consistent with international human rights norms. Moreover, local and other subnational governments have not consistently implemented remedies where courts have ordered compliance with the right to adequate housing. 54. In some States, constitutional guarantees of the right to adequate housing have provided little protection against forced evictions carried out by local governments. For instance, the Special Rapporteur has drawn the attention of the Government of Sri Lanka to the fact that the city of Colombo Urban Regeneration Project reportedly authorized the removal of thousands of shanty dwellers. Residents were not provided with adequate information regarding their relocation and resettlement sites or adequate and timely compensation for loss of land, housing structures, assets or small businesses. Reportedly, affected residents who have sought remedies through the courts, based on the constitutional right to adequate housing, have not had consistent success. Where the courts have ordered remedies, they have not always been implemented.54 55. In the Philippines, courts have not always interpreted the constitutional right to adequate housing consistently with international human rights norms. For example, courts ruled in one case that there was no constitutional obligation to provide resettlement opportunities for displaced communities.55 In another case, the court found that anyone designated a “professional squatter” may be deprived of any due process rights with respect to evictions.56 56. The Special Rapporteur is concerned that victims of violations of rights to adequate housing by local and other subnational governments are often denied access to justice or effective remedies, even where constitutional provisions exist. VII. Emerging initiatives for human rights accountability of subnational level governments in relation to housing 57. Just as the implementation of housing rights is increasingly in the hands of local government, it is at the local level that new approaches and initiatives for government accountability to the right to adequate housing are emerging. Local governments are 53 54 55 56 16 R. v. Enfield London Borough Council, ex parte Bernard, Queen’s Bench Division Administrative Court (Sullivan J), 25 October 2002. See case No. LKA 11/2104 (A/HRC/28/85). Galay v. Court of Appeal G.R. No. 120132, 4 December 1995. Available from www.lawphil.net/judjuris/juri1995/dec1995/gr_120132_1995.html. Republic of the Philippines v. Mijares, G.R. Nos. 170615-16, 9 July 2009. Available from http://sc.judiciary.gov.ph/jurisprudence/2009/july2009/170615-16.htm.