A/HRC/12/22 page 10 III. THE IMPACT OF COUNTER-TERRORISM MEASURES AND POLICIES ON THE ENJOYMENT OF ECONOMIC, SOCIAL AND CULTURAL RIGHTS A. The inadequate fulfilment of economic, social and cultural rights 24. Because of the nature of the counter-terrorism measures adopted by States, policy priorities may appear to be distorted. Economic, social and cultural rights have not been among the priorities of the human rights discourse in the context of counter-terrorism, which has largely focused on civil and political rights, leaving little or no space for discussion of the impact of counter-terrorism measures on economic, social and cultural rights, or the positive measures that States need to adopt to implement them as part of any strategy to address terrorism. This has been reflected in public spending on counter-terrorism, which in most countries has focused on the military, on policing and on intelligence gathering and analysis. Allocations to areas such as basic social services (for example, health and education) and international development have largely not increased or, worse, have declined. This trend, however, appears to be changing as States broaden their counter-terrorism responses. 25. Classic examples of counter-terrorism measures that have an impact on economic, social and cultural rights are measures that affect the right to housing. This right is often subject to abuse through forced evictions and house demolitions, especially in high-security zones. These actions often lead to displacement and deepen poverty, resulting in additional human rights violations. 26. The European Court of Human Rights stated, in a case where it found that the destruction of a home and possessions by security forces amounted to inhuman treatment, that “even assuming that the acts in question were carried out without any intention of punishing the applicant, but instead as a discouragement to others or to prevent his home from being used by terrorists, this would not provide a justification for the ill-treatment”.20 In relation to the right to housing, several resolutions of the Commission on Human Rights and the Human Rights Council, as well as a general comment of the Committee on Economic, Social and Cultural Rights, have reaffirmed that forced evictions represent a violation of human rights, and provided clarification on the due process requirements for evictions that can be justified under international human rights law.21 20 21 Bilgin v. Turkey (Application No. 23819/94), 16 November 2000. See Committee on Economic, Social and Cultural Rights, general comment No. 7 and Commission on Human Rights resolution 1993/77. See also Basic principles and guidelines on development-based evictions and displacement, A/HRC/18, annex I.