A/HRC/15/20* (ii) The husband of a woman, his family, or his clan, has the right to transfer her to another person for value received or otherwise; or (iii) A woman on the death of her husband is liable to be inherited by another person.” 44. There are no reliable statistics on numbers of victims, not least because it is very difficult to distinguish forced marriages, contracted on the basis of force, threat of harm or deception, from arranged marriages that may involve considerable social pressure to consent. The problem is not restricted to specific countries and cases often have a transnational dimension. The United Kingdom Forced Marriage Unit, for example, handles about 250–300 cases a year of nationals facing forced marriages.18 45. Child marriages, unions that involve at least one partner below the minimum legal age of marriage, constitute a form of forced marriage since the child is not in a position to consent. Article 16 of the Convention on the Elimination of All Forms of Discrimination against Women specifies that “the betrothal and the marriage of a child shall have no legal effect, and all necessary action, including legislation, shall be taken to specify a minimum age for marriage”. The Committee on the Elimination of Discrimination against Women considers that the minimum age for marriage should be 18 years for both man and woman.19 This age limit, which is in line with the definition of the child provided by the Convention on the Rights of the Child, is also reflected in the African Charter on the Rights and Welfare of the Child (art. 21). 46. A comprehensive United Nations Children’s Fund (UNICEF) study has found that women and girls who were married below 18 years of age are less educated and more likely to experience domestic violence.20 The domestic servitude inherent to child marriages disempowers girls by denying them educational opportunities and the option to form protective networks of friends and peers. 5. Servitude resulting from the economic exploitation of severe dependency 47. Servitude and other slavery-like practices prohibited by article 8 of the Covenant on Civil and Political Rights extend beyond the specific instances recognized by the 1956 Supplementary Convention on Slavery and includes other cases of economic exploitation in which the victim is so dependent on the perpetrator that s/he cannot leave the situation of exploitation.21 Dependency in this context can derive from a multiplicity of physical, economic, social, cultural, psychological and legal factors. While each factor may by itself not be strong enough to create the severe dependency characterizing servitude, the factors may reinforce each other creating a net of dependency factors from which the victim cannot extract herself. 48. Relevant economic factors include advance or deferred payment designed to increase dependency, payment that keeps workers below the poverty level, payment in kind only or prohibitions to freely change employers. 18 19 20 21 10 Ibid., para. 30. Committee on the Elimination of Discrimination against Women, general recommendation 21 on equality in marriage and family relations (1994), para. 36. See UNICEF, Early Marriage: A Harmful Traditional Practice (New York, 2005). See Manfred Nowak, U.N. Covenant on Civil and Political Rights: CCPR Commentary, second edition (N.P. Engel Publications, 2005), art. 8 of the Covenant on Civil and Political Rights, para. 12. Nowak highlights that the travaux préparatoires of the Covenant indicate that the term “servitude” was to be applicable to all conceivable forms of dominance and degradation. GE.10-15169