50 though this instrument referred to medical interventions arising from scientific research,201 as of that time it was established that the voluntary consent of the human subject was absolutely necessary, and this meant that the person involved should have legal capacity to give consent, should be able to exercise free power of choice, and should have sufficient knowledge and comprehension of the elements of the subject matter involved to take a decision. This latter element required that the information provided should include the nature, duration and purpose of the experiment, and the method, inconveniences and effects upon the subject’s health. 202 In other words, as of that time, it was understood that consent must be prior, free and obtained after having received comprehensible information. 172. After the Nuremberg Code on medical ethics, various documents have referred more specifically to patients’ rights and to medical interventions in general and have repeated the need to obtain prior consent to any medical intervention following a process of free, full and informed choice. The World Medical Association, UNESCO and the WHO, among other bodies, have also referred to this. 173. Furthermore, in relation to sexual and reproductive rights, both the Programme of Action of the International Conference on Population and Development, held in Cairo in 1994, 203 and the Declaration and Platform for Action of the Fourth World Conference on Women held in Beijing in 1995,204 refer to the need to obtain responsible, voluntary and informed consent for the exercise of these rights. Additionally the FIGO Committee for the Ethical Aspects of Human Reproduction and Women’s Health has referred to the elements of consent in recommendations on standards for informed consent since 1995, and on female sterilization since 1989. These standards were repeated and systematized in 2014 by several agencies of the universal system when issuing a statement on “Eliminating forced, coercive and otherwise involuntary sterilization.” 174. Likewise, the Court underlines that the European Court of Human Rights has interpreted the rule of informed consent on several occasions, both in cases relating to medical interventions in general,205 and in specific cases of female sterilization, establishing that such consent is essential for the performance of any medical intervention. In particular, the European Court decided that prior, free, full and informed consent was a requisite for a surgical sterilization procedure in relation to facts that occurred in Slovakia in 1999.206 The Committee for the Elimination of Discrimination against Other international treaties have also expressly recognized informed consent in relation to medical experiments. Articles 7 of the International Covenant on Civil and Political Rights, 15 of the Convention on the Rights of Persons with Disabilities, and 9 of the Arab Charter on Human Rights establish similar provisions in the sense that “no one shall be subjected without his free consent to medical or scientific experimentation.” Additionally, there are other international documents that clearly establish the need to obtain free, full and informed consent; they include the Istanbul Protocol with regard to medical examinations to determine the existence of torture or other cruel, inhuman or degrading treatment, and the Ethical Guidelines for Biomedical Research on Human Subjects. Cf. United Nations, Istanbul Protocol. Manual on Effective Investigation and Documentation of Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment, August 9, 1999, adopted in 2000, paras. 63 and 64, and Council for International Organizations of Medical Sciences (CIOMS), in collaboration with the World Health Organization (WHO), International Ethical Guidelines for Biomedical Research involving Human Subjects, Geneva, 2002, standards 4, 5 and 6. 201 202 Cf. Nuremberg Code of medical ethics, 1947. Cf. Programme of Action of the International Conference on Population and Development, Cairo, UN doc A/CONF.171/13/Rev.1, 1994, para. 7.17. 203 Cf. Declaration and Platform for Action of the Fourth World Conference on Women, Beijing, A/CONF.177/20, 1995, paras. 96 and 106.g). 204 See, inter alia, ECHR, Case of Glass v. The United Kingdom, No. 61827/00. Judgment of March 9, 2004; Case of Juhnke v. Turkey, No. 52515/99. Judgment of May 13, 2008; Case of M.A.K. and R.K. v. The United Kingdom, Nos. 45901/05 and 40146/06. Judgment of March 23, 2010; Case of R.R. v. Poland, No. 27617/04. Judgment of May 26, 2011; Case of Elberte v. Latvia, No. 61243/08. Judgment of January 13, 2015. 205 Cf. ECHR, Case of V.C. v. Slovakia, No. 18968/07. Judgment of November 8, 2011; Case of N.B. v. Slovakia, No. 29518/10. Judgment of June 12, 2012, and Case of I.G., M.K. and R.H. v. Slovakia, No. 15966/04. Judgment of November 206