standard than that offered to other students, is one of the most extreme examples of the precarious position of Roma parents and pupils’.208 Indeed, although the UNESCO Convention against Discrimination in Education permits establishment and maintenance of separate educational systems for linguistic reasons, such permission is conditional on optional attendance and high-quality education, which conforms to state standards.209 Otherwise, segregation of minorities would constitute discrimination. In the Inter-American context,210 the IACtHR considered a discriminatory denial of access to education in The Yean and Bosico Children v Dominican Republic.211 In the Dominican Republic, children who did not possess a birth certificate could not access day schools; this limitation adversely affected children of Haitian origin, who often struggled in acquiring an identity document. Violeta Bosico, a child of Haitian origin, was denied her birth certificate and hence her access to education in day schools was barred. She was initially admitted to day school without a birth certificate and studied up until third grade.212 However, when she tried to enrol for the fourth grade in day school, she was denied access because she did not have a birth certificate.213 Therefore, she enrolled in evening school for adults over 18 years of age where she attended fourth and fifth grades. The purpose of evening school was to teach adults to read and write only, with pupils doing two grades in one year. The compressed type of education adopted in this school made fewer demands than day school.214 The IACHR strongly condemned this denial of access to education in the Dominican Republic. In 2001, as a part of a friendly settlement, the Dominican Republic granted Violeta Bosico her birth certificate and she returned to day school. Moreover, the IACHR awarded non-pecuniary damages to the applicant and her parents for a violation of her right to education by the Dominican Republic. Accordingly, access to education should be nondiscriminatory; in addition, requirements such as residence and birth certificates may unduly limit minorities’ access to education. Furthermore, access to education should be physically accessible as exemplified in the ECtHR’s judgment in Cyprus v Turkey.215 Significantly, the ECtHR’s interpretation of access to education also has a linguistic component in this case. The case concerned the compatibility of a total ban on the availability of Greeklanguage secondary schools with the terms of P1-2 in Northern Cyprus, occupied by Turkey. While secondary education in Greek was formerly available to children of Greek Cypriots, it had been subsequently abolished by the Turkish-Cypriot authorities. Primary education in Greek was still available to children in Northern Cyprus; 22 however, if parents of these children wished them to continue their education in Greek they had to send them to schools in Southern Cyprus. Alternatively, children could attend English or Turkish schools available in the north. The vast majority of families chose the first option and many schoolchildren received their secondary education in the south.216 However, significant restrictions existed on their return to the north upon completion of their studies: until 1998 male students who attained the age of 16 and female students who attained the age of 18 were not allowed to return to the north permanently.217 This restriction resulted in the separation of many families upon children’s completion of their studies. In its assessment, the ECtHR first applied the principles established in Belgian Linguistics: P1-2 does not guarantee the choice of the language of instruction.218 The ECtHR ruled that in the strict sense there was no denial of the right to education because children had access to a Turkish- or English-language school in the north. However, taking into consideration that the authorities assumed responsibility for providing primary education in Greek, their failure to ‘make continuing provision for it at the secondary-level must be considered in effect to be a denial of the substance of the right at issue’.219 Children’s attendance of Greek schools in the south could not be considered as a viable alternative having regard to its impact on family life in the light of limitations imposed on their return to Northern Cyprus. In addition, the Court emphasized that ‘[t]he authorities must no doubt be aware that it is the wish of Greek-Cypriot parents that the schooling of their children be completed through the medium of the Greek Language’.220 Therefore, by 16 votes to 1 the ECtHR found that there was a breach of P1-2. Overall, Cyprus v Turkey is a significant development in the ECtHR’s jurisprudence regarding minority education. It affirms that access to education should not negatively impact family life of minorities. Moreover, the ECtHR established that where the state offers primary education in a minority language, it may also be responsible for the provisions of secondary education in a minority language. Can the ECtHR depart from the principles in Belgian Linguistic and move from the exceptions to be found on a case-by-case basis, such as in Cyprus v Turkey, to a general principle of education in a minority language? Such a development is possible, and probably desirable. However, this does raise difficulties. First, the wording of P1-2 does not prima facie allow the ECtHR to find a general obligation to secure education in a minority language. Second, the ECHR does not contain an equivalent of Article 27 ICCPR. Third, general human rights provisions can and should be read in a minority-friendly fashion,221 but they do not necessarily generate generally applicable MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE