A/HRC/17/25 (d) Programming informed by the recommendations of international human rights bodies and mechanisms.24 23. In practical terms, this approach does not simply require that the goals and outcomes of development are loosely aligned with those of human rights. More is necessary; in particular, it is vital that the processes around development and implementation of programming adopt a human rights-based approach, as will be discussed further. Similarly, use of human rights in development requires the use of good programming practices, but adoption of such practices in and of itself does not constitute adoption of a right to health, or human rights-based approach. For instance, use of monitoring and evaluation is not uncommon in development practice, and yet its inclusion does not constitute use of a human rights-based approach without an attendant careful analysis of both the rights and duties of the parties involved in the programme, and an examination of their capacity to claim their rights and fulfill their obligations, respectively. 24. The actual content of a right to health approach as applied to development programming may vary in individual circumstances, and the Special Rapporteur believes that adaptation and flexibility are necessary depending on the nature of the development initiatives undertaken, the context, and so forth. However, in the Special Rapporteur’s opinion, adoption of a right to health approach should at least require: (1) the clear and explicit placement of human rights at the centre of health-related programming strategies, and (2) inclusion of some or all of the core elements of a right to health approach in a methodical manner. The framework should be considered in its entirety, and if elements of the framework are not adopted, it should be clear that their inclusion has at least been considered, rather than individual elements being cherry-picked in an ad-hoc manner. Operationalization of a rights-based approach to health should also reflect the Common Understanding. B. Complementarities of the right to health and the right to development 25. In considering the relationship between the right to health and development, the Special Rapporteur considers it necessary to reflect on the complementarities of the right to health and the right to development. The present section does not exhaustively examine the relationship between the right to health and the right to development, but seeks to contribute to a discussion of how these rights feed into, and realize the core goals of, development. 26. The concept of a “right to development” was articulated in a series of international conferences, culminating in 1986, when the right was recognized in a declaration adopted by the General Assembly,25 and in 1993 the right to development was reaffirmed, as part of the Vienna Declaration and Programme of Action.26 Before that, in 1981, the right to development was also enshrined in Article 22 of the African Charter on Human and Peoples' Rights. 27. Within the United Nations system, a Working Group on the Right to Development was established in 1989 with a mandate to monitor and review progress made in the promotion and implementation of the right to development. The Working Group has been supported in its work by an independent expert on the right to development (1998-2003) 24 25 26 Ibid., p. 2. A/RES/41/128 A/CONF.157/23 9