A/HRC/37/53 is central to housing strategies, since they map out the means through which the right to housing will be fulfilled.6 22. Rights-based housing strategies should draw on the right to housing not only as a set of legal standards, but also as a transformative vision and a call to action. This vision motivates local and national governments, social movements and communities around the world to act. Strategies must be “living documents” that evolve and respond as new challenges arise, and new voices are heard. In practice 23. Different legal traditions and policy contexts allow for a range of articulations of the right to housing. Many national constitutions now recognize it explicitly; others affirm governments’ responsibility to adopt policies to promote or ensure access to housing. Elsewhere, courts have adopted inclusive interpretations of other constitutional rights, such as the right to life, to guarantee the right to housing. Some States rely primarily on legislation to protect the right to housing. 24. Strategies may rely on courts to play an important role in clarifying obligations emanating from the right to housing. In India, after reviewing evidence of the effect of cold weather on the health of homeless persons, the Supreme Court found a violation of the right to life and ordered the construction of shelters. 7 25. In Nigeria, affected communities have successfully argued that forced evictions constitute a violation of the constitutional right to dignity. 8 The High Court in Abuja has stated that the right to housing should not be construed narrowly to mean having a roof over one’s head but should be viewed broadly as a right to live somewhere in relative peace, security and dignity. It also indicated that governments have a responsibility to create housing policies to enhance those values. 9 26. The Constitution of Uruguay guarantees the right to a decent home, which is given effect in a five-year housing plan for the period 2015–2019.10 The plan draws on the right to the city and the comprehensive definition of adequate housing as contained in general comment No. 4 which addresses, for example, issues of discrimination and socio-spatial segregation. 27. The Housing (Scotland) Act 1987 embraces the immediate obligation to address homelessness by requiring local governments to provide housing to anyone who is unintentionally homeless, including those facing domestic violence and overcrowded accommodation.11 28. In each of these country contexts, civil society has identified violations of the right to housing and continues to advocate for its more effective implementation. This suggests 6 7 8 9 10 11 6 For more on respect, protect and fulfil see: International Commission of Jurists, Maastricht Guidelines on Violations of Economic, Social and Cultural Rights (Maastricht, 26 January 1997). Available from www.refworld.org/docid/48abd5730.html. See People’s Union for Civil Liberties v. Union of India & Others, Supreme Court of India, Civil Petition No. 196 (2001). See Akakpo Agemo & Ors. v. Attorney General of Lagos State & Others, High Court of Lagos State (26 January 2017). Available from https://static1.squarespace.com/static/535d0435e4b0586b1fc64b54/t/58947fc686e6c0558d87e37e/14 86127074123/170126+Ruling+-+Akakpo+Agemo+%26+Ors+v+LASG+%26+Ors.pdf. See Chief Jacob Obor & Others v. Federal Capital Development Authority & Others, High Court in Abuja (2 February 2017). www.fcthighcourt.gov.ng/download/main%20judgement/2017_judgements/1st_quarter/court_23_hon ._justice_a._i._kutigi/CHIEF-JACOB-OBOR-13-ORS-V.-F.C.D.A-3-ORS-TITLE-TO-LANDDEMOLITION.pdf. Available from www.anv.gub.uy/archivos/2016/02/PLAN_QUINQUENAL_DE_VIVIENDA_2015_2019.pdf. See Fiona King, “Scotland: Delivering a Right to Housing”, in Journal of Law and Social Policy, vol. 24 (2015), p. 158.