A/HRC/28/62 VI. Accountability under domestic law 40. While enhanced international accountability of local and other subnational governments is important, international mechanisms can only be supplementary to effective domestic procedures and remedies.36 The Committee on Economic, Social and Cultural Rights has emphasized the importance of ensuring effective domestic remedies for Covenant rights. It has recognized that, while the method by which rights are given effect in national law is a matter for each State party to decide, “the means used should be appropriate in the sense of producing results which are consistent with the full discharge of its obligations by the State party”.37 41. Within the flexible framework established by the Committee, local and subnational governments have been made accountable to the right to adequate housing under domestic law in a variety of ways, ranging from constitutional rights through legislative and administrative requirements to rights-based housing strategies. 42. Statutory and administrative remedies often engage important components of the right to adequate housing and they are of particular importance at the local and subnational levels – the levels at which housing programmes are administered and where rights holders usually first seek effective resolutions. It is particularly important that administrative remedies be timely and effective in relation to housing, since the most fundamental interests are often at stake. 43. Many States now include recognition of the right to adequate housing in their constitutions and virtually all constitutions include rights such as non-discrimination or the right to life, which should provide protection of key components of the right to housing. Whereas interaction between international human rights bodies and States has focused on national rather than local level governments, the opposite has generally been the case in the context of domestic courts. Various constitutional housing rights claims have focused on the role of local or subnational governments. The effective application of constitutional rights at the local and subnational levels is thus critical for enhanced accountability of subnational governments to the right to adequate housing. 44. The Special Rapporteur is encouraged by the growing number of cases being brought to courts domestically which address alleged violations of housing rights by local and subnational governments. Those cases have generated new understandings of the critical role that courts and administrative bodies can play in adjudicating claims and enforcing the obligations of local and subnational governments to realize the right to adequate housing. Developments at the domestic level in the adjudication of housing rights claims have informed emerging international human rights norms. In parallel, domestic court cases have made explicit references to international standards, such as those related to the scope and content of the right to adequate housing in general comment No. 4 (1991) on the right to adequate housing and general comment No. 7 (1997) on the right to adequate housing: Forced evictions of the Committee on Economic, Social and Cultural Rights. 45. The jurisprudence of the South African Constitutional Court has been particularly influential. The South African Constitution guarantees the right to access adequate housing and obliges all levels of government to take reasonable legislative and other measures, within available resources, to achieve the progressive realization of that right. The famous Grootbroom case on the right to adequate housing considered the obligations of Cape 36 37 Committee on Economic, Social and Cultural Rights, general comment No. 9 (1998) on the domestic application of the Covenant, para. 4. Ibid., para. 5. 13