52 that the health services provided to women shall be acceptable only if women give their prior consent with full awareness of the facts; in other words, if the consent is prior to the medical intervention. 177. That said, the Court understands that exceptions exist where health personnel may act without requiring consent in cases in which the patient is unable to give their consent and an immediate, urgent or emergency surgical or medical procedure is necessary given the serious risk to the patient’s health or life. This exception has been established in the laws of several States Parties to the American Convention, as will be described below (infra para. 200), and has been recognized in the European sphere,214 as well as by the Special Rapporteur on the right of everyone to enjoy the highest attainable standard of physical and mental health.215 The Court considers that urgency or emergency refers to the imminence of a risk and, consequently, of a situation in which the intervention cannot be postponed, excluding those cases in which it is possible to wait to obtain consent. Regarding tubal ligation, the Court stresses that this surgical procedure, the purpose of which is to prevent a future pregnancy, cannot be characterized as an urgent or emergency procedure due to imminent risk, so that this exception is not applicable. 178. Indeed, it must be emphasized that the 2011 FIGO ethical recommendations on sterilization and the United Nations Inter-Agency statement corroborate this understanding, when they consider that, even if a future pregnancy would endanger the life and health of the woman, she would not become pregnant immediately, so that the measure can be taken subsequently.216 Thus, sterilization is not an emergency medical procedure. This reasoning was also adopted by the European Court of Human Rights in the case of V.C. v. Slovakia, in which the facts took place on August 23, 2000. In its judgment, the European Court concluded that the tubal ligation procedure performed during a caesarean section did not constitute an imminent necessity from a medical point of view because the threat to the patient’s life would materialize only in the event of a future pregnancy, so that such an intervention was not generally considered as life-saving surgery.217 179. Additionally, the Court cannot admit the argument submitted by the State during the hearing in this case, that the medical personnel acted in accordance with the parameters established in the 1993 WHO manual entitled: “Female sterilization: a guide to provision of services.” The State indicated that, based on this document, there was a difference between voluntary surgical sterilizations and sterilizations for health reasons or medically indicated, 218 establishing that the latter Cf. A Declaration on the Promotion of Patients’ Rights in Europe, adopted by the WHO Regional Office for Europe in 1994, Article 3; Oviedo Convention, Article 8, and Explanatory Report on Article 8 of the Oviedo Convention, paras. 56 to 59. 214 Cf. UN, Report of the Special Rapporteur on the right of everyone to the highest attainable standard of physical and mental health, Anand Grover, A/64/272, August 10, 2009, para. 12. 215 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 of October 2012 and October 2015, which include the 2011 Ethical recommendations on female sterilization, and United Nations Interagency Statement “Eliminating forced, coercive and otherwise involuntary sterilization,” adopted by OHCHR, UN Women, UNAIDS, UNDP, UNFPA, UNICEF and WHO, 2014 (evidence file, volume VIII, annex 25 to the brief with motions, pleadings and evidence, folios 2452 and 2457). See also, Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Juan E. Méndez, A/HRC/22/53, February 1, 2013, paras. 31 to 35, and Report of the Special Rapporteur on torture and other cruel, inhuman or degrading treatment or punishment, Juan E. Méndez, A/HRC/31/57, January 5, 2016, para. 45. 216 Cf. ECHR, Case reasoning was adopted I.G., M.K. and R.H. v. annexes 26, 27 and 28 217 of V.C. v. Slovakia, No. 18968/07. Judgment of November 8, 2011, paras. 110 to 117. The same in the case of N.B. v. Slovakia, No. 29518/10. Judgment of June 12, 2012, para. 74, and the Case of Slovakia, No. 15966/04. Judgment of November 13, 2012, para. 122 (evidence file, volume VIII, to the brief with motions, pleadings and evidence, folios 2474 to 2577). In this regard, the Court understands from this document that voluntary surgical sterilizations would refer to the choice of sterilization as a permanent contraception method, without other reasons related to the patient’s health. Moreover, the Court understands that sterilization for reasons of health or by medical indication would result from situations in which, owing to the woman’s health (a high-risk pregnancy), the physician recommends that contraception method as the most appropriate. However, in that case, sterilization is also voluntary and requires informed consent. The manual establishes that: “[i]n almost all countries sterilization is provided for certain health indications, such as ruptured uterus, a multiple caesarean sections 218