55 183. In the Court’s opinion consent cannot be considered free if a woman is asked to provide it when she is not in a condition to take a fully informed decision because she is in a situation of stress and vulnerability, inter alia, such as, during or immediately after giving birth or undergoing a caesarean section. The 1993 WHO manual established that it was not appropriate for a women to opt for sterilization if there were physical or emotional factors that could limit her capacity to take an informed and well-considered decision, such as, while she was in labor, receiving sedatives or going through a difficult situation before, during or after an incident or treatment related to her pregnancy.226 This was ratified in the 2011 FIGO ethics considerations on sterilization, 227 in the World Medical Association Statement on Forced and Coerced Sterilisation 228 and in the United Nations Interagency Statement.229 The Court notes that this standard was even included in Bolivia’s domestic law in 1997 (infra para. 212). Also, the Special Rapporteur on the right of everyone to the highest attainable standard of physical and mental health has emphasized that: “[c]oercion includes conditions of duress such as fatigue or stress.”230 Similarly, the European Court of Human Rights has concluded that asking for consent while a woman is in labor or shortly before she undergoes a caesarean section clearly does not permit her to take a decision of her own free will.231 184. In the understanding that consent arises from the concept of autonomy and liberty, it is also understood that it can be withdrawn for any reason, without disadvantage or prejudice, even if it is only withdrawn verbally, because it is not definitive.232 As previously described, obtaining consent is the product of a two-way process between doctor and patient,233 so that health personnel must Female sterilization: a guide to provision of services, 1993 (evidence file, volume XIII, annex 3 to the State’s final arguments, folio 5518); 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 November 2003, October 2012 and October 2015, which includes the Ethical considerations on sterilization of 1989, 1990, 2000 and 2011, pp. 59 and 217 (2003), pp. 436 and 437 (2012) and p. 538 (2015), 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 to 2453). Cf. WHO, Female sterilization: a guide to provision of services, 1993 (evidence file, volume XIII, annex 3 to the State’s final arguments, folio 5517). 226 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 of October 2012 and October 2015, which include the 2011 Ethical recommendations on female sterilization, p. 437 (2012) and p. 539 (2015). 227 Cf. WMA, WHO, Female sterilization: a guide to provision of services, 1993 (evidence file, volume VIII, annex 31 to the brief with motions, pleadings and evidence, folios 2613 and 2614). 228 Cf. 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, folio 2457). 229 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. 14. 230 Cf. ECHR, Case of V.C. v. Slovakia, No. 18968/07. Judgment of November 8, 2011, paras. 111 and 112. The same reasoning was adopted in the Case of N.B. v. Slovakia, No. 29518/10. Judgment of June 12, 2012, para. 77, and Case of I.G., M.K. and R.H. v. Slovakia, No. 15966/04. Judgment of November 13, 2012, para. 122 (evidence file, volume VIII, annexes 26, 27 and 28 to the brief with motions, pleadings and evidence, folios 2474 to 2577). 231 Cf. Declaration of Helsinki, Principle 26; Universal Declaration on Bioethics and Human Rights, Article 6; WHO, Female sterilization: a guide to provision of services, 1993 (evidence file, volume XIII, annex 3 to the State’s final arguments, folios 5518 and 5523), and FIGO, Guidelines regarding informed consent, adopted in 2007, which reaffirm the indications in the 1995 document and add, above all, that “consent can be withdrawn at any time.” In this regard, see 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, p. 317 (2012) and p. 400 (2015). 232 Cf. WHO, Female sterilization: a guide to provision of services, 1993 (evidence file, volume XIII, annex 3 to the State’s final arguments, folio 5512), and 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 November 2003, October 2012 and October 2015, which include the Guidelines regarding informed consent, adopted in 1995 and reaffirmed and supplement 233