A/HRC/43/47 regional or international treaties incorporating language or minority rights standards, such as the ILO Indigenous and Tribal Peoples Convention, 1989 (No. 169), the European Charter for Regional or Minority Languages, and the Framework Convention for the Protection of National Minorities. It is also at the end of the twentieth century that nonbinding documents dealing with minority language rights or minority rights generally proliferated, including in education, with the Declaration on the Rights of Persons Belonging to National or Ethnic, Religious and Linguistic Minorities, the United Nations Declaration on the Rights of Indigenous Peoples, the Vienna Declaration and Programme of Action and the Document of the Copenhagen Meeting of the Conference on the Human Dimension of the Conference on Security and Cooperation in Europe, among others, as well as guidance documents such as the Oslo Recommendations Regarding the Linguistic Rights of National Minorities, the Hague Recommendations Regarding the Education Rights of National Minorities, the Lund Recommendations on the Effective Participation of National Minorities in Public Life and Language Rights of Linguistic Minorities: A Practical Guide for Implementation, a handbook developed by the Special Rapporteur on minority issues. C. Interpretation by United Nations treaty bodies 41. Contemporary jurisprudence has also neither been consistent nor comprehensive: different treaties are still relatively “young” and there have been different approaches and views in the interpretation of the extent to which there is a “right” to use the language of minorities in education, and what this use implies. For example, in one of the most important cases in this area, the European Court of Human Rights clearly stated that there was no “automatic” right to be educated in one’s language under article 2, Protocol 1 of the Convention for the Protection of Human Rights and Fundamental Freedoms (Belgian Linguistics Case 6 ), even in combination with the prohibition of discrimination on the ground of language. However, contrary to what has often been written by some experts, it did not exclude the possibility that, in appropriate circumstances, it could be discrimination on the ground of language not to use one’s mother tongue as a medium of instruction. 42. Nevertheless, United Nations treaty bodies have at times left little doubt that minorities and indigenous peoples do have a right to be educated in their own language in some circumstances. In addition, such a right where it is practical would also seem to be enshrined in treaties such as the Framework Convention for the Protection of National Minorities and the European Charter for Regional or Minority Languages, as interpreted by the advisory committee of experts of each of these treaties. 7 43. There are undoubtedly contradictions and inconsistencies. Over a period of decades, there may be an evolution as to how international law standards are interpreted in their meaning and application, especially in relation to indigenous peoples or minorities. Additionally, certain concepts, such as an individual’s right to identity – even though not actually recognized in most treaties – have had an influence on how various bodies interpret and apply legal obligations in areas such as education, of which language is an important component. 44. Most reports tend to confirm an acceptance of the right to education in a minority’s or indigenous people’s mother tongue. At times this acceptance includes higher education in public institutions without restrictions, while at others it means that there should be “multilingual” schools that include children from the majority linguistic community. It is not always clear whether, in practical terms, this means that single-medium education in a 6 7 8 See European Court of Human Rights, Case “Relating to Certain Aspects of the Laws on the Use of Languages in Education in Belgium” v. Belgium (Merits), (application Nos. 1474/62, 1677/62, 1691/62, 1994/63 and 2126/64), judgment of 23 July 1968. See Advisory Committee of the Framework Convention for the Protection of National Minorities, “Thematic commentary No. 3: the language rights of persons belonging to national minorities under the Framework Convention”, ACFC/44DOC(2012)001 rev, Strasbourg, 5 July 2012, part VI.