A/HRC/43/47/Add.1 other developments have generally led to increasing obstacles to the use of minority languages in a range of public services. 54. Some of the issues raised include the weak use of the Basque language in areas of Navarre having large concentrations of Basque speakers. While existing legislation recognizes the co-official status of Basque with Castilian in the Basque-speaking regions of Navarre and the mixed-language zones, the use of the Basque language appears not to be sufficiently guaranteed or implemented, according to members of this linguistic minority. In Navarre, as in other parts of the country, judicial pronouncements have in recent years limited the permissible use of minority languages. This includes an October 2019 pronouncement of the High Court of Justice of Navarre that overturned provisions requiring bilingual public signage and notices in mixed-language and non-Basque-speaking areas, and setting aside any consideration of Basque as a merit in job positions unless absolutely necessary. Article 231 of the organic law on the judiciary has been identified as one of the obstacles to the full implementation by Spain of its human rights obligations in relation to the use of co-official minority languages, since it stipulates that in judicial procedures, judges, magistrates, prosecutors, clerks and other officers are to use Castilian, and that coofficial minority languages will be allowed only if no party objects. In most cases, this has led to criminal, civil and administrative judicial authorities proceeding officially in Castilian. Furthermore, members of the public who may wish to use a minority language in such proceedings cannot be guaranteed that the magistrate or other officials would be directly able to understand the minority language if it were to be used. While in theory individuals may still use a minority co-official language even when Castilian is the language used for the proceedings, consistent reports in different parts of the country indicate that individuals are simply told to comply with the chosen use of the national language. In the view of the Special Rapporteur, this blanket obstacle to the use of a minority co-official language gives rise to concerns regarding compliance by Spain with its human rights obligations, particularly the prohibition of discrimination, as outlined in the handbook on language rights of linguistic minorities and the Declaration on the Rights of Persons Belonging to National or Ethnic, Religious and Linguistic Minorities. 55. In light of what appear to be consistent impediments to the use of co-official languages that could be deemed to be discriminatory in some autonomous communities, the Special Rapporteur invites the Government to consider modifying article 231 of the organic law on the judiciary so as to guarantee a more directly exercisable right to use minority coofficial languages jointly with Castilian, so that the proceedings before criminal, civil and administrative judicial authorities can effectively be held in both co-official languages. 56. The Special Rapporteur was made aware of numerous other issues regarding the use of minority languages in autonomous communities. In Galicia, legislation and a number of initiatives promoting the visibility and position of Galician seem impressive initially, and the authorities of Galicia must be commended in that regard. However, many appear not to be implemented effectively, and the Special Rapporteur received consistent reports of members of the Galician-speaking minority being unable to use their own language, despite the apparent right to do so with public authorities in the region. Similar allegations were heard in other autonomous communities, such as Navarre. In addition, persons belonging to linguistic minorities who live outside of autonomous communities where their languages are co-official find it particularly difficult to use their language in most areas of public life. 57. The issue of the language of education, and striking the appropriate balance, is particularly sensitive and challenging in Spain. This is partly due to recent judicial pronouncements that have emphasized the prominent constitutional position of the sole national official language, which, in accordance with article 3 of the Constitution, all Spaniards have the duty to know and the right to use, and what they may imply in relation to the right to be taught in Castilian as opposed to in co-official languages. It is also partly because educational policies, including those regarding the medium of instruction, fall within the competence of the country’s constituent communities, with 6 of the 17 autonomous communities having co-official languages in addition to Castilian. This multiplicity of languages in different regions has led to various educational approaches, leading to some claims that co-official minority languages are not being used to the extent they ought to be in education, and related counterclaims, and even claims from some parties that the use of minority languages in education may, in certain contexts, contravene the Constitution. In 2015, for example, the Supreme Court of Spain ruled against the Catalan 12