A/HRC/4/20 page 32 changed but because the jurisprudence on human rights and constitutional adjudication was unfamiliar and, by some courts, resisted.” Bowe v. The Queen, Privy Council Appeal No. 44 of 2005 (8 March 2006) (appeal from the Court of Appeal of the Bahamas), para. 42. 137 The Special Rapporteur has, for example, engaged in dialogue with several Governments on the universal significance of the jurisprudence of the Judicial Committee of the Privy Council. E/CN.4/2006/53/Add.1, pp. 34-36, 199-206, 247-249. 138 ICCPR, art. 6(4). 139 ICCPR, art. 6(1). 140 ICCPR, art. 7. Note that insofar as a violation of Article 7 results in the deprivation of life it also constitutes a violation of Article 6. See ICCPR, art. 6(2): “sentence of death may be imposed only … not contrary to the provisions of the present Covenant”. 141 See also E/CN.4/2006/53/Add.1, 232-242. 142 ICCPR, art. 14(5): “Everyone convicted of a crime shall have the right to his conviction and sentence being reviewed by a higher tribunal according to law.” 143 The relevance of a range of factors has been noted by judicial and quasi-judicial bodies. See, e.g., Thompson v. Saint Vincent and the Grenadines, Communication No. 806/1998 (2000), para. 8 (“defendant’s personal circumstances” and the “circumstances of the particular offence”); Hilaire, Constantine and Benjamin et al. v. Trinidad and Tobago, Series C, No. 94 (21 June 2002), para. 87 (“prior criminal record of the offender”, “the subjective factors that could have motivated his conduct”, “the degree of his participation in the criminal act”, “the probability that the offender could be reformed and socially readapted”, “whether the death penalty is the appropriate punishment or not for the specific case in light of the circumstances of the offender’s conduct”). 144 While this explanation of the reasoning behind these cases is somewhat stylized, it clarifies far more than it obscures. 145 ICCPR, art. 6(2). 146 Lubuto v. Zambia, Communication No. 390/1990 (1995), para. 7.2. 147 The distinction between evaluating general legislation and individual sentences under human rights law can also be understood as an example of the difference between “macro-policy at the central level” and the “micro-policy of specific law enforcement bodies”. See Liu Renwen, “Strict Restriction on Death Penalty and its Paths in China” in The Road to the Abolition of the Death Penalty in China: Regarding the Abolition of the Non-Violent Crime at the Present Stage (Press of Chinese People’s Public Security University of China, 2004). 148 Thompson v. Saint Vincent and the Grenadines, Communication No. 806/1998 (2000), para. 8.2.