A/HRC/45/13/Add.3 cause heightened economic hardship reinforcing structural dependencies and impact the mental and physical health of women and girls.262 134. The European Court in Varnava v. Turkey also held that an enforced disappearance generates a specific effect on relatives, which may amount to cruel or inhuman treatment as breach of article 3 ECHR to the detriment of these relatives. Although factors identified in relation to the impact of enforced disappearances of persons on their relatives were not considered to be gender specific, in Çakıcı v. Turkey the Court referred to considerations of “particular circumstances of the case,” including the family ties and relationships, the involvement of a family member in investigative steps in order to obtain information, and the States reaction to these efforts by a particular family member.263 Considering that jurisprudence showed that State agents had diverging reactions towards female family members and female victims of enforced disappearances, gender-specific circumstances consideration may be interfered as part of particular circumstances of the case.264 135. For instance, in Sri Lanka, the Office of Missing Persons referred to a gendersensitive approach, including psychosocial responsive strategies, which support family members of those disappeared at all stages of the search including in circumstances where the death of the missing or disappeared person has been confirmed.265 F. Differential approach in cases of disappearances of migrants 136. Migrants266 are frequently subject to deprivation of liberty, which may place them at risk of facing enforced disappearances due to the failure in safeguarding communication channels between migrants and family members while being in administrative detention,267 or detention and summary return without due process for migrants intercepted at sea and in violation of the principle of non-refoulement.268 The position of structural vulnerability of migrants in the absence of adequate transnational investigative mechanisms leads to difficulties in clarifying the fate and whereabouts of disappeared migrants and locating and returning human remains to their families. The Working Group recalled the direct link between migration and enforced disappearances in relation to particular risks arising from migratory journeys.269 137. The Working Group documented enforced disappearances of individuals during their migratory journeys in transit or in their country of destination and persons migrating due to the threat of being disappeared.270 Individuals also migrated in order to take part in the search for truth seeking further information that contributes to the establishment of the whereabouts or fate of disappeared persons.271 Preventing relatives from contributing to the identification of disappeared persons by State authorities results in the loss of traceable documental evidence. In other cases migrants have disappeared in detention facilities because they are not duly registered followed by the refusal of State authorities to disclose their whereabouts.272 138. In these contexts, States shall investigate any allegation of involvement, collusion or acquiescence of State authorities in criminal acts, which may result in the disappearance of 262 263 264 265 266 267 268 269 270 271 272 See Human Rights Committee, Sassene v. Algeria, communication No. 2026/2011, 29 October 2014, paras. 3.4, 7.6, 7.11; See Human Rights Committee, Rosa María Serna et als. v. Colombia, communication No. 2134/2012, 9 July 2015. European Court of Human Rights, Çakıcı v. Turkey, application No. 23657/94, para. 98. Available at http://opiniojuris.org/2016/09/05/emerging-voices-the-european-court-of-human-rightsand-women-affected-by-enforced-disappearances-of-their-relatives/. A/HRC/42/40/Add.1, p. 65. See the definition used by the WGEID, A/HRC/36/39/Add.2 para. 5; See Section III, J of the Thematic Report. A/HRC/7/12 para. 44. A/HRC/33/67 para. 34; A/HRC/WGEID/112/1, para. 96; A/HRC/33/51/Add.1, para. 55. A/HRC/36/39/Add.2, para. 51; See A/72/335. A/HRC/WGEID/118/1 paras. 121–122; A/HRC/WGEID/119/1, paras. 20–21; E/CN.4/1984/21, para. 102. See also E/CN.4/1492, annex VIII, paras. 1 and 2.1 and annex IX, p. 5. E/CN.4/1985/15, para. 135. See also A/HRC/30/38/Add.5, paras. 33–41. UNHCR, Monitoring Immigration Detention: Practical Manual (UNHCR, 2014) p. 20. 45