providing the conditions needed to leave a dignified life. 279 Along the same lines, the European Court has held that the states, on being responsible for public mental health centers, should adopt the measures necessary for the conditions of those centers to be adequate. 280 Accordingly, the staff at mental health centers should adopt all measures necessary for protecting the life and integrity of persons with disabilities who have been institutionalized 281; and the enhanced nature of the state’s obligations as a result of its special position as guarantor of the rights of the persons under its custody is equally applicable. 142. In the case of Ximenes Lopes v. Brazil, the Court indicated as follows regarding the particular risks faced by persons with mental disabilities who have been institutionalized: Regarding the safeguard of life and personal integrity, it is necessary to consider that the persons with disabilities, who live in psychiatric institutions or are undergoing treatment therein, are particularly vulnerable to torture and other types of cruel, inhuman or degrading treatment. The vulnerability inherent to people with mental disabilities is compounded by the high degree of intimacy which is typical of the treatment of psychiatric illnesses, which makes these persons more susceptible to mistreatment when they are hospitalized. In the context of health care institutions, whether they are public or private centers, the staff in charge of the care of patients exercise a strong control or dominance over the persons who are under their custody. This intrinsic imbalance in power between hospitalized patients and the persons having authority over them is usually greater in psychiatric institutions. Torture and other forms of cruel, inhuman, or degrading treatment, when inflicted on these people, affect their psychic, physical, and moral integrity, entail an insult to their dignity, and seriously restrict their autonomy, which could aggravate their condition All the foregoing circumstances require the strict supervision of such institutions. The States have the duty to supervise and guarantee that in all psychiatric institutions, either public or private, the patients´ right to receive a worthy, human, and professional treatment be preserved and that said patients be protected against exploitation, abuse, and degradation. 282 2.4 General considerations on the right to health and to informed consent in health matters 143. Both the IACHR and the Court have issued pronouncements on the relationship between the right to humane treatment and the right to health. 283 The Inter-American Court has interpreted on repeated occasions that the right to humane treatment is directly and immediately tied to care for human health 284 and that “the lack of adequate medical care” may entail its violation. 285 The Commission considers that this intrinsic relationship constitutes an expression of the interdependence and indivisibility existing between civil and political rights, on the one hand, and economic, social and cultural rights, on the other. In the words of the Court, both groups of rights should be “fully understood as human rights, without any rank and enforceable in all the cases before competent authorities.” 286 I/A Court HR. Case of Ximenes Lopes v. Brazil. Judgment of July 4, 2006. Series C No. 149, para. 138. ECHR, Stanev v. Bulgaria. Judgment of January 17, 2012, para. 209. 281 ECHR, Valentin Campeanu v. Rumania. Judgment of July 17, 2014, para. 130. 282 I/A Court HR. Case of Ximenes Lopes v. Brazil. Judgment of July 4, 2006. Series C No. 149, paras. 106-108. 283 IACHR, Report No. 102/13, Case 12,723, Merits, TGGL, Ecuador, November 5, 2013. IACHR. Report: Access to Maternal Health Services from a Human Rights Perspective. June 7, 2010. Section II. 284 I/A Court HR. Case of Suárez Peralta v. Ecuador. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 21, 2013. Series C No. 261, para. 130; and Case of Vera Vera et al. v. Ecuador. Preliminary Objection, Merits, Reparations and Costs. Judgment of May 19, 2011. Series C No. 226, para. 43. 285 I/A Court HR. Case of Suárez Peralta v. Ecuador. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 21, 2013. Series C No. 261, para. 130; Case of Tibi v. Ecuador. Preliminary Objections, Merits, Reparations and Costs.. Judgment of September 7, 2004. Series C No. 114, para. 157, and Case of Vera Vera et al. v. Ecuador. Preliminary Objection, Merits, Reparations and Costs. Judgment of May 19, 2011. Series C No. 226, para. 44. 286 I/A Court HR. Case of Acevedo Buendía et al. (“Discharged and Retired Employees of the Comptroller”) v. Peru. Preliminary Objection, Merits, Reparations and Costs. Judgment of July 1, 2009. Series C No. 198, para. 101. Along the same lines, see: United Nations. Committee on Economic, Social and Cultural Rights. General Comment No. 9, para. 10. 279 280 25

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