A/HRC/33/54 establishment of viability and growth without creating incentives that would inadvertently increase the risk of non-compliance. Such a framework should act as a deterrent to disruptive litigation that creditors could engage in during negotiations to restructure sovereign debts. In explicit reference to vulture funds, the Assembly highlighted that their activities forced indebted countries to divert many of their resources to handle such litigation, thereby undermining the purpose of the debt restructuring processes. 54. In September 2015, the General Assembly adopted resolution 69/319,63 in which it declared that sovereign debt restructuring processes should be guided by the Basic Principles on Sovereign Debt Restructuring Processes, as included in the report of the Ad Hoc Committee (A/AC.284/2015/2).64 According to the principle of sustainability, debt restructuring workouts should lead to stable debt situations while promoting sustained and inclusive economic growth and sustainable development. This relevant principle also requires minimizing economic and social costs, warranting the stability of the international financial system and respecting human rights. 65 55. By its general character, sustainability has become a key principle in the promotion and protection of economic development, growth and human rights. 66 In times of debt crisis, different interests are at play and a balance must be struck between them. The private interest of the outset creditor’s rights cannot be protected at the expense of the public interest of protecting and promoting the sustained and inclusive economic growth and sustainable development of a country. 56. Against this background, the Human Rights Council, on 26 September 2014, adopted, by a large majority, another landmark resolution, entitled the “Effects of foreign debt and other related international financial obligations of States on the full enjoyment of all human rights, particularly economic, social and cultural rights: the activities of vulture funds”, supported by a large majority. In resolution 27/30, the Council explicitly condemned the direct negative effect that the debt repayment to those funds, under predatory conditions, had on the capacity of Governments to fulfil their human rights obligations.67 The Council called upon States to consider implementing legal frameworks to curtail predatory vulture fund activities within their jurisdictions. VIII. Impact of the activities of vulture funds on human rights 57. Human rights monitoring bodies have contributed to articulating the linkage between the activities of vulture funds and human rights, in particular by focusing on the negative impact such activities have on the capacity of the State to fulfil its human rights obligations (see in particular A/HRC/14/21).68 Empirical research has also analysed the negative economic and financial consequences derived from commercial litigation against 63 64 65 66 67 68 Adopted by a vote of 136 in favour and 6 against, with 41 abstentions. The nine principles are sovereignty, good faith, transparency, impartiality, equitable treatment, sovereign immunity, legitimacy, sustainability and majority restructuring. For a comment, see J.P. Bohoslavsky and M. Goldmann, “An incremental approach to sovereign debt restructuring: sovereign debt sustainability as a principle of public international law”, Yale Journal of International Law, 2016 (forthcoming). OHCHR, “Restructuring of sovereign debt: United Nations expert stresses General Assembly principles are binding”, 10 September 2015. Adopted by a vote of 33 in favour and 5 against (Czech Republic, Germany, Japan, United Kingdom and United States), with 9 abstentions. It was co-sponsored by 79 additional States. The duty to fulfil imposes on the State an obligation to take appropriate legislative, administrative, budgetary, judicial and other measures towards the full realization of economic, social and cultural rights. 15