51 Women ruled similarly in the case of A.S. v. Hungary with regard to facts that took place in January 2001.207 175. As indicated, the Court notes that the key aspect of the legal standards aimed at protecting individuals faced with medical procedures has been prior, free, full and informed consent. These elements, which are characteristic of valid consent, have been present in the fields of medicine and human rights since the adoption of the 1947 Nuremberg Code of medical ethics and continue to be central to the development of bioethics and law. Furthermore, the Court considers that the standards for informed consent for medical interventions in general are applicable to female sterilization because this is a surgical procedure. However, owing to the nature and gravity of the procedure, which involves a woman losing her reproductive capacity permanently, there are special factors that must be taken into account by the health personnel during the process of informed choice that may result in obtaining informed consent to submit to sterilization. The Court will now define the content of the essential elements of consent derived from the international corpus juris. i) The prior nature of the consent 176. The first element of consent to be considered is its prior nature, which means that consent must always be given before any medical intervention. The Court notes that it is not possible to validate consent after the medical intervention had concluded. The prior nature of the consent has been referred to, or is understood implicitly, in all the international instruments that regulate this matter. Indeed, the 1964 Declaration of Helsinki on ethical principles for medical research involving human subjects208 and the 1981 Declaration of Lisbon on the rights of the patient,209 both adopted by the World Medical Association, as well as the 2005 Universal Declaration on Bioethics and Human Rights of UNESCO,210 emphasize that “[a]ny preventive, diagnostic and therapeutic medical intervention is only to be carried out with the prior, free and informed consent of the person concerned.” This has been ratified also by the FIGO,211 the WHO212 and the Committee for the Elimination of Discrimination against Women in its General Recommendation No. 24,213 in the sense 13, 2012 (evidence file, volume VIII, annexes 26, 27 and 28 to the brief with motions, pleadings and evidence, folios 2474 to 2577). UN, Committee for the Elimination of Discrimination against Women, A.S. v. Hungary (Communication No. 4/2004), CEDAW/C/36/D/4/2004, August 29, 2006; the facts of this case took place in January 2001. In the inter-American system, the Court has no case law on informed consent in cases of forced, involuntary or coercive sterilization. However, it should be pointed out that the Inter-American Commission intervened in and approved a friendly settlement agreement in the matter of María Mamérita Mestanza v. Peru. 207 Cf. Declaration of Helsinki. Ethical principles for medical research involving human subjects, adopted by the World Medical Association in 1964, revised in 2013, Principles 25 to 32. 208 Cf. Declaration of Lisbon on the rights of the patient, adopted by the World Medical Association in 1981, revised in 2005 and reaffirmed in 2015, Principles 3, 7 and 10. 209 Cf. Universal Declaration on Bioethics and Human Rights, adopted by the General Conference of UNESCO on October 19, 2005, article 6. UNESCO has also regulated the principle of prior, free and informed consent in other declarations, such as the Universal Declaration on the Human Genome and Human Rights, adopted on November 11, 1997, that mentions the requirements of “prior, free and informed consent” in its articles 5 and 9. 210 Cf. FIGO, Recommendations on ethics issues in obstetrics and gynecology by the FIGO Committee for the Study of Ethical Aspects of Human Reproduction and Women’s Health, November 2003, October 2012 and October 2015, which include the Guidelines regarding informed consent, adopted in 1995 and reaffirmed and supplemented in 2007, as well as the Ethical recommendations on female sterilization of 1989, 1990, 2000 and 2011. 211 Cf. WHO, Female sterilization: a guide to provision of services, 1993 (evidence file, volume XIII, annex 3 to the State’s final arguments, folios 5517 to 5518). This document indicates that women must have sufficient time to make up their minds about sterilization before the surgical procedure. This period may vary according to the circumstances of each woman. 212 Cf. UN, Committee for the Elimination of Discrimination against Women, General Recommendation No. 24, Women and health, 1999, paras. 20 to 22 (evidence file, volume VIII, annex 39 to the brief with motions, pleadings and evidence, folio 2711). 213