down. In addition, her relatives said they had to pay a quota so that she could remain in the maternal area, where her movement was also restricted.61 51. In addition to the foregoing, the reasonable accommodation that should have been made to ensure the victim’s rights, not only affected the limited physical space that constrained Mrs. Chinchilla’s movement; it also had an impact on her enjoyment of the right to health, both within and outside the prison facilities.62 Therefore it is important to draw a distinction between general accessibility from the perspective of disability, and reasonable accommodation to which a person with disability has the right to make effective their civil, political, economic, social and cultural rights, on an equal basis with others. 52. Accessibility has taken root so firmly in international human rights law that it may even be considered as a right per se.63 In General Comment No. 2, of 2014, the RPD Committee considers that accessibility is a vital precondition for persons with disabilities to live independently and participate fully and equally in society.64 Accessibility should be viewed as a disability-specific reaffirmation of the social aspect of the right of access,65 given that persons with disabilities face technical and environmental—in most cases, human-built environmental - barriers related to social and cultural development as well as customs. 66 Cf. Case of Chinchilla Sandoval v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of February 29, 2016, Series C No. 312, para. 217. 61 The relationship between persons with disabilities and access to the right to health is established in General Comment No. 5, concerning Persons with Disabilities, and in General Comment No. 14, on the Right to the Highest Attainable Standard of Health, both of the Committee on Economic, Social and Cultural Rights, which in combination state that the right to physical and mental health of persons with disabilities also implies the right to have access to medical and social services. However, at international level there are few precedents concerning reasonable accommodation, because it is a relatively new concept in relation to the right to health, or medical treatment, which must be adopted in prisons for people with disabilities. In general, the discussion on the right to health of persons with disabilities has focused on the health conditions of persons with mental disabilities. Cf. Committee on Economic, Social and Cultural Rights, General Comment 14, The Right to the Highest Attainable Standard of Health (Article 12 of the International Covenant on Economic, Social and Cultural Rights), (Twentysecond Session, 2000), U.N. Doc. E/C.12/2000/4 (2000), para. 26. Also Committee on Economic, Social and Cultural Rights, General Comment 5, Persons with Disabilities (Eleventh Session, 1994), U.N. Doc. E/C.12/1994/13 (1994), para. 34. 62 Accessibility is one of the principles that underpins the Convention on the Rights of Persons with Disabilities (Art. 3 (f)). Historically, the movement in support of persons with disabilities has argued that access to the physical environment and public transport is a precondition for freedom of movement, as guaranteed under Article 13 of the Universal Declaration of Human Rights and Article 12 of the International Covenant on Civil and Political Rights. Similarly, access to information and communication is seen as a precondition for freedom of opinion and expression, as guaranteed under Article 19 of the Universal Declaration of Human Rights and Article 19, paragraph 2, of the International Covenant on Civil and Political Rights. Article 25 (c) of the International Covenant on Civil and Political Rights enshrines the right of every citizen to have access, on general terms of equality, to public service in his or her country. The International Convention on the Elimination of All Forms of Racial Discrimination, guarantees to everyone the right of access to any place or service intended for public use, such as transportation, hotels, restaurants, cafes, theaters and parks (Art. 5 f)). Thus, a precedent has been set in the international human rights legal framework. Cf. Committee on the Rights of Persons with Disabilities, General Comment No. 2, Article 9: Accessibility, CRPD/C/GC/2, May 22, 2014, paras. 1, 2 and 3. 63 Cf. Committee on the Rights of Persons with Disabilities, General Comment No. 2, Article 9: Accessibility, CRPD/C/GC/2, May 22, 2014, para. 1. 64 Cf. Committee on the Rights of Persons with Disabilities, General Comment No. 2, Article 9: Accessibility, CRPD/C/GC/2, May 22, 2014, para. 4. 65 19