A/HRC/28/73 civil and political rights, such as the right to a fair trial and the right to public participation. This overview illustrates the above-mentioned thesis that nearly every human right can be affected by corruption; this point is highlighted in the submission by OHCHR. 19. Judicial corruption is a very concrete example that illustrates the negative impact of corruption on the enjoyment of human rights. While corruption in all areas threatens the rule of law, democracy, and human rights, in the case of judicial corruption the right of access to the court and the right to a fair trial by an independent, impartial and competent tribunal is directly affected. 11 20. As States have different kinds of obligations resulting from their human rights commitments, it is useful to classify the possible violations of human rights caused by corruption according to the different obligations imposed on States: (a) Firstly, corruption can affect individuals (individual negative impact). As has been shown before, there is often a direct violation of the human rights of the individual who is affected by corruption. Depending on the context in which corruption occurs, a wide range of different human rights can be violated. Corruption frequently results in discriminatory access to public services. 12 The impact on an individual can also be the result of an indirect effect from corruption. For example, if public authorities illegally allow the deforestation of land in return for a bribe, the right to food, the right to housing and the right to health of the people living in the area concerned may be violated; (b) Secondly, corruption can affect specific, identifiable groups of individuals (collective negative impact). This category includes the effects of corruption that not only affect individuals but also impact upon groups of individuals. For example, corruption can exclude the poor from access to goods and services offered by the administration, or from access to justice. Or, coming back to the example given above, illegal deforestation may affect specific ethnic minorities or indigenous peoples living in the areas concerned. It can be concluded that vulnerable groups such as women, children, persons with disabilities, the elderly, the poor, indigenous people or people belonging to minorities are particularly affected by corruption. This is especially true in relation to access to public services and welfare, which is often of tremendous importance for people belonging to the abovementioned groups. In her opening statement made on 13 March 2013 at the Human Rights Council’s panel discussion on the negative impact of corruption on the enjoyment of human rights, the former High Commissioner for Human Rights referred, as an example of the negative impact of corruption on the enjoyment of human rights, to vulnerable groups’ access to justice being undermined.13 Sometimes, corruption is only one element of a human rights violation or one factor aggravating an already existing human rights violation concerning specific groups. For example, if the right to education of certain vulnerable groups is already violated as a result of discriminatory access requirements, the demand by an official for payment of a bribe compounds the human rights violation. Another example is persons deprived of their liberty, who can be victims of corruption, and at the same time, of inhuman or degrading treatment;14 11 12 13 14 Parliamentary Assembly of the Council of Europe, Committee on Legal Affairs and Human Rights (background document prepared by the European Human Rights Association), AS/Jur (2014) 19, p. 10. See, for example, The Human Rights Case Against Corruption, p. 4. See also International Council on Human Rights Policy and Transparency International, eds., Corruption and Human Rights: Making the Connection (2009), p. 32 et seq. The Human Rights Case Against Corruption, p. 4. For more detail, see the seventh annual report of the Subcommittee on Prevention of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, CAT/C/52/2, para. 83 et seq. 7