14. Within the universal system for the protection of human rights, added to what has been mentioned in the judgment, the United Nations High Commissioner for Human Rights, in his 2017 report to the Human Rights Council, referred to the effects of multiple and intersecting forms of discrimination and violence in the context of racism, racial discrimination, xenophobia and related intolerance on the full enjoyment of all human rights by women and girls.8 He also indicated the need to offer special protection, adapted to the needs of women and girls, emphasizing the violation of rights owing to socioeconomic exclusion and poverty. 15. The Committee for the Elimination of Discrimination against Women (hereinafter “CEDAW”) has indicated that “discrimination against women is compounded by intersecting factors that affect some women to degrees or in ways that differ from those affecting men or other women.”9 Thus, “intersecting factors make it more difficult for women from those groups to gain access to justice.”10 16. Meanwhile, the European Court of Human Rights related characteristics that are assumed to define a vulnerable group to the violation of rights they have suffered; for example, determination of the essential content of a right differs in the case of gypsies,11 prisoners,12 or unaccompanied minors.13 In this regard, the European Court has use the concept of “particular vulnerability” considering that “the domestic courts failed to take account of the applicant’s particular vulnerability inherent in her position as an African woman working as a prostitute.”14 Based on the concept of the “particular vulnerability” of the applicant, an African woman offering sexual services on the street, it is possible to appreciate the intersection of factors such as her race, sex, and social and work situation. 17. Intersectionality has been considered a useful tool for interpreting human rights as interdependent, interrelated and indivisible, because they allow the different factors of oppression and violation to be examined.15 In the instant case, it is possible to analyze the different factors of vulnerability that have their own profile, but at the same time interact in an intersectional manner with the others. Similarly, this Court has recognized that “certain groups of women suffer discrimination throughout their life based on more than one factor combined with their sex, which increases their risk of suffering acts of violence and other human rights violations.”16 Cf. Human Rights Council, Impact of multiple and intersecting forms of discrimination and violence in the context of racism, racial discrimination, xenophobia and related intolerance on the full enjoyment of all human rights by women and girls, Report of the United Nations High Commissioner for Human Rights, April 21, 2017, UN Doc. A/HRC/35/10. 8 CEDAW. General recommendation No. 33 on women’s access to justice, CEDAW/C/GC/33, August 3, 2015, para. 8. 9 CEDAW. General recommendation No. 33 on women’s access to justice, CEDAW/C/GC/33, August 3, 2015, para. 8. 10 11 Cf. ECHR, Case of Buckley v. The United Kingdom, No. 20348/92, Judgment of September 29, 1996. Cf. ECHR, Case of Salman v. Turkey, No. 21986/93, Judgment of June 27, 2000, and Case of Algür v. Turkey, No. 32574/96, Judgment of October 22, 2002. 12 Cf. ECHR, Case of Mubilanzila Mayeka and Kaniki Mitunga v. Belgium, No. 13178/03, Judgment of October 12, 2006. 13 14 ECHR, Case of B.S. v. Spain, No. 47159/08, Judgment of July 24, 2012, para. 71. Cf. Andrea Catalina Zota-Bernal, «Incorporación del análisis interseccional en las sentencias de la Corte IDH sobre grupos vulnerables, su articulación con la interdependencia e indivisibilidad de los derechos humanos», Eunomía. Revista en Cultura de la Legalidad, 2015. Available at: https://e-revistas.uc3m.es/index.php/ EUNOM/article/view/2803/1534. 15 Case of I.V. v. Bolivia. Preliminary objections, merits, reparations and costs. Judgment of November 30, 2016. Series C No. 329, para. 247, and Case of Gonzales Lluy et al. v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of September 1, 2015. Serie C No. 298, para. 288. 16 4