A/HRC/4/37 page 24 July 2006, the Special Representative wrote to the Government of the Philippines concerning the killing of Annaliza Abanador-Gandia, a pro-democracy activist and leader of a womens’ rights organization who had been followed by two unidentified men and shot dead. In October 2006, the Special Representative wrote to the Government of Iraq concerning the alleged shooting by 10 men of Faliha Ahmed Jabori, head of the women’s rights organization, Maternity and Childhood, and to the Government of Russia concerning the murder of Anna Politkovskaia, a prominent human rights defender and journalist. 103. In numerous cases from all regions, police, military or government officials are the alleged perpetrators of violence, including sexual violence and death threats against women human rights defenders. In February 2006, a joint communication was sent to the Government of China concerning a housing rights activist and cyber dissident who was arrested by police. In March and April 2006, joint communications were sent to the Government of the Sudan concerning two cases where a humanitarian organization assisting women who have suffered gender-based sexual violence as a result of the conflict in Darfur and an organization offering legal aid to women were obstructed by the Humanitarian Aid Commission, a government agency. In the first instance the organization was ordered to hand over all its assets and close its health and nutrition centres and its food distribution unit. In the second case, the organization’s assets were declared frozen because they had applied for funding from the European Union. In April 2006, a joint communication was sent to the Government of Zimbabwe concerning a 65-year-old human rights defender and former Chairwoman of the Porta Farm Residents’ Committee, who spoke out against forced evictions that took place in 2004 and 2005. She received death threats and was allegedly threatened with expulsion from the community if she continued to interact with human rights groups. 104. In her report on her visit to Brazil (A/HRC.4/37/Add. 2), the Special Representative has reported on the plight of widows of rural workers who are now leading a movement. She was deeply distressed at the allegation that elements opposing their work had resorted to labelling them as prostitutes in an attempt to undermine their social credibility in communities where they live and work. IV. CONCLUSIONS AND RECOMMENDATIONS 105. The progressive achievement of economic, social and cultural rights (ESCR) or the obligation of the State being dependent on the availability of resources should not be misunderstood as allowing States to adopt policies that violate these rights or negate the probability of their realization. The Special Representative recommends appropriate guarantees in national constitutions that give full legitimacy and recognition to activities for the promotion and protection of these rights. 106. Where ESCR are expressed as principles of State policy in the national constitution and not as fundamental rights, States must ensure that these principles are not deviated from and that civil society actors have the full opportunity to participate in discussions of social or economic policies or projects. In particular they must have the opportunity to monitor the effects of such policies and projects, to register their objections and to receive responses from the State with regard to any action that undermines the right to strive for attaining these rights.