A/HRC/7/32 page 11 52. The United Nations Food and Agriculture Organization (FAO) stated that the formulation of the right to food in paragraph 20 should be in line with general comment No. 12 (1999) of the Committee on Economic, Social and Cultural Rights and the FAO Voluntary Guidelines to Support the Progressive Realization of the Right to Adequate Food in the Context of National Food Security. The formulation suggested was as follows: “Every human being has the right to culturally and nutritionally adequate food, free from adverse substances. States and the international community are duty bound to ensure, as a minimum, the fundamental rights to be free from hunger, and to progressively realize the physical and economic access to adequate food for all.” 53. FAO stressed that the narrow focus on “ownership” of land in paragraph 21 could be usefully complemented by the concepts of secure tenure and usufruct rights over land and other natural resources (“security of land tenure”). 54. FAO requested clarification of the phrases “organized arrangements” and “distribution of food or similar measures” in paragraph 22, and suggested that the paragraph be reformulated as follows: “In situations where food assistance is deemed the most appropriate way of providing emergency relief or a safety net, the food should be safe and nutritionally and culturally adequate. Food distribution should be organized in ways that respect human dignity and ensure the fullest possible participation by the population groups concerned.” 55. FAO recommended that the word “international” be removed from the first sentence of paragraph 23, as theft of humanitarian assistance should be an offence, whether it is national or international. It also questioned the appropriateness of requiring “exemplary punishment” in light of the principle of proportionality. It was pointed out that the concept of “food smuggling” would require further clarification and might not, in fact, constitute a violation of the right to food. Since the concept of “perished foodstuffs” is not defined, FAO suggested substituting the word “perished” by “expired”. 56. The South African Human Rights Commission and Volontari nel Mondo drew attention to the special situation of women and girls and proposed adding a text recognizing this situation. The South African Human Rights Commission pointed out that women and girls who work or live on farms are acutely vulnerable to violence, including sexual violence, and discrimination. Therefore it proposed that the draft guiding principles address the issue of gender-based mistreatment in paragraph 21. It also indicated that protection of grazing rights should not be limited to nomadic herders. 57. The NGO Committee for Social Development pointed out the absence of any reference in the draft guiding principles to international responsibility in times of natural disasters such as drought or tsunami. 58. Volontari nel Mondo recommended that participation in food assistance arrangements by population groups concerned, as set out in paragraph 22, be organized in such a way as to avoid dependence and respect biodiversity.