A/HRC/28/62 32. Treaty bodies have also dealt with responsibilities of subnational governments in complaints procedures. For example, in Liliana Assenova Naidenova et al. v. Bulgaria (CCPR/C/106/D/2073/2011), a Roma community challenged a forced eviction initiated by the Sofia Metropolitan Municipality, Vuzrajdane subdistrict, acting independently of the national Government. The community was unsuccessful in challenging the eviction domestically, with the Sofia City Court determining that the eviction was lawful and the Supreme Administrative Court upholding that decision. The Human Rights Committee requested interim measures to stop the city from proceeding with the eviction and, after considering the communication on the merits, found that the State party would violate the petitioners’ rights under article 17 of the Covenant if the eviction proceeded without the provision of adequate alternative accommodation for the community. The national Government used the Committee’s decision to exert pressure on the Municipality to refrain from carrying out the eviction. Two years later, the permanent injunction remains in place and the community is in discussion with the municipal authorities on alternative housing. 33. The Committee on the Elimination of Discrimination against Women has also dealt with housing cases that engage subnational level governments. In Kell v. Canada (CEDAW/C/51/D/19/2008), an indigenous woman alleged that in the context of domestic violence, she had been dispossessed of her housing as a result of decisions taken by the local housing authorities. The Committee deemed the Northwest Territories Housing Corporation and the local housing authority to be agents of the State party, referring to them as such, and concluded that, as a result of the actions of the local housing authority, the State party had violated articles 2, paragraphs (d) and (e), and article 16, paragraph 1 (h), read in conjunction with article 1 of the Convention, which protect against discrimination by public authorities and the equal rights of spouses with respect to property.33 B. Universal periodic review 34. The universal periodic review process has also engaged the responsibilities of subnational governments, particularly municipalities, in the implementation of human rights. Many States engage with subnational level governments in the development of their State report for the review. A number of States’ reports for the universal periodic review include information on the role of subnational governments with respect to housing, and some have acknowledged the challenges of multi-jurisdictional responsibilities in relation to housing. The recommendations emanating from the universal periodic review process rarely engage the human rights obligations of municipalities and local governments and seldom engage local or other subnational governments on issues of housing. C. Special procedures 35. Special procedures regularly engage with subnational levels of government in the context of mandated activities because they have a number of opportunities to do so. During official country missions and working visits, for example, special rapporteurs regularly meet with local and other subnational authorities to assess the implementation of human rights. In the case of the mandate on adequate housing, official visits have systematically included an exchange of views with city councils or other subnational officials. At times, country missions have served as a bridge, with the Special Rapporteur 33 See also CEDAW/C/32/D/2/2003 for a link between domestic violence and inadequate housing alternatives. 11