A/HRC/22/72 10. The right to food requires that women have physical and economic access at all times to adequate food or means for its procurement. 5 All resources to ensure food, including water, firewood, or livestock, need to be physically accessible for rural women. They also need to dispose of economic accessibility, individually and at household level. This means that rural women need to have the means for the acquisition of food through purchase, inheritance, production or work. Thus, they should be able to have access to income-generating sources, such as employment that ensure decent wages for decent living, credit or loans, property and inheritance rights; access to production services, such as land, tools, technology, seeds, or production certificates; and access to produced goods and their markets. 11. Specific State obligations in relation to the right to food exist at three levels. First, the obligation to respect requires States not to take actions that would impair the access to food of women, either by “arbitrarily taking away people’s right to food or by making it difficult for them to gain access to food”. 6 All exclusions or restrictions based on gender suffered by rural women in their access to resources for ensuring their right to food constitute violations of this obligation. Second, the obligation to protect requires State actions that prevent private actors from depriving women of their access to food. 7 By allowing practices within families that prevent rural women from accessing resources, States are failing to protect their right to food. Third, the obligation to fulfil has two dimensions. The obligation to facilitate means that States have to take positive actions to strengthen women’s access to and utilization of resources and to other means of ensuring their livelihood.8 The absence of legislation ensuring property and inheritance rights for women and the lack of services such as employment or credit underlines the failure of States to comply with their obligation to facilitate. In situations where women are unable to realize their right to food for reasons beyond their control, States are under the obligation to provide food directly.9 12. A second key instrument for the legal protection of the right to food of rural women is the Convention on the Elimination of All Forms of Discrimination against Women (CEDAW). Article 14 emphasizes the prohibition of discrimination against women in rural areas and the equal enjoyment by women and men alike of the right to participate and benefit from rural development. It contains a list of specific rights upon which the livelihood of rural women is strongly dependent and that shall be ensured by States: (a) To participate in the elaboration and implementation of development planning at all levels; (b) To have access to adequate health care facilities, including information, counselling and services in family planning; (c) To benefit directly from social security programmes; (d) To obtain all types of training and education, formal and non-formal, including that relating to functional literacy, as well as, inter alia, the benefit of all community and extension services, in order to increase their technical proficiency; (e) To organize self-help groups and co-operatives in order to obtain equal access to economic opportunities through employment or self employment; 5 6 7 8 9 Ibid., para 7. J. Ziegler, C. Golay, C. Mahon, S.A. Way, The Fight for the Right to Food. Lessons Learned, Palgrave Macmillan, 2011, p. 19. CESCR, general comment No. 12, para 15. Ibid. Ibid. 5