only embraces ‘any distinction, exclusion, restriction or preference based on race, colour, descent, or national or ethnic origin’.410 As a result, the inter-linkages between different grounds of discrimination as they affect women belonging to indigenous or minority groups do not always appear to be systematically addressed by these bodies. As far as the CEDAW is concerned, in most cases the emphasis is placed upon rural or vulnerable women rather than minority and indigenous women, thus not really capturing directly intersectionalities between gender and other grounds of discrimination, including race, colour and ethnic origin. Nevertheless, the categories of vulnerable and rural women are sometimes used also to encompass women belonging to minority groups and indigenous communities. In a few cases, minority women are made explicitly the subject of detailed consideration.411 In its 2004 special session on indigenous women, the UN Permanent Forum on Indigenous Issues recommended that the CEDAW pay special attention to issues related to the gender dimension of racial discrimination against indigenous peoples.412 Regarding the CERD, following the adoption of the General Recommendation No. 25 on ‘Gender related dimensions of racial discrimination’,413 it has been drawing increasing attention to the specific situation of minority women, including in respect of participation in public life,414 literacy and education,415 access to health care416 and exposure to violence.417 In the General Recommendation No. 25 the CERD acknowledged that racial discrimination does not always affect women and men in the same way. The CERD observed that: ‘[c]ertain forms of racial discrimination may be directed towards women specifically because of their gender, such as sexual violence committed against women members of particular racial or ethnic groups in detention or during armed conflict; the coerced sterilization of indigenous women; abuse of women workers in the informal sector or domestic workers employed abroad by their employers. Racial discrimination may have consequences that affect primarily or only women, such as pregnancy resulting from racial bias-motivated rape; in some societies women victims of such rape may also be ostracized. Women may also be further hindered by a lack of access to remedies and complaint mechanisms for racial discrimination because of gender-related impediments, such as gender bias in the legal system and discrimination against women in private spheres of life.’ In its Concluding Observations on Namibia of 2008, for example, the CERD declared itself ‘concerned about the high incidence of rape of San women by members of other 42 communities, which seems to be caused by negative stereotypes’.418 The case of San women is not isolated. In the Great Lakes region, Batwa women’s vulnerability to rape is exacerbated by widespread superstitions.419 The CERD consequently developed a methodology for fully taking into account the gender-related dimensions of racial discrimination, by giving particular consideration to: (a) the form and manifestation of racial discrimination; (b) the circumstances in which racial discrimination occurs; (c) the consequences of racial discrimination; and (d) the availability and accessibility of remedies and complaint mechanisms for racial discrimination.420 In its General Recommendation No. 32 of 2009 concerning ‘the meaning and scope of special measures’,421 the CERD confirmed that: ‘[t]he “grounds” of discrimination are extended in practice by the notion of “intersectionality” whereby the Committee addresses situations of double or multiple discrimination - such as discrimination on grounds of gender or religion – when discrimination on such a ground appears to exist in combination with a ground or grounds listed in Article 1 of the Convention.’ A recent study by UNICEF/MRG entitled State of the World’s Minorities and Indigenous Peoples 2009 examined, in particular, the gender dimension of minority and indigenous education, shedding some light on the situation of indigenous and minority girls, and on the number of factors, both internal and external to the community, that can hinder their educational opportunities and future job prospects. It highlighted that although the prioritization of boys’ education over girls’ is common also in majority communities, the higher poverty rate of many minority and indigenous communities means that they are more likely to be forced to make this choice. It also identified hunger, the remoteness of the areas where minority and indigenous communities live, and the connected risk of physical violence against minority and indigenous girls, as elements that have a great impact on girls’ education.422 Some apparently neutral regulations adopted by states at the national level can further disproportionately affect women and girls belonging to minority and indigenous groups. This has been the case with restrictions on the wearing of headscarves or other visible religious symbols in schools and universities. While the position taken by the ECtHR in the cases brought up before it has been that, although such restrictions constituted an interference with the applicant’s right to manifest her religion, they were necessary in a democratic society to protect the rights and freedoms of MINORITY GROUPS AND LITIGATION: A REVIEW OF DEVELOPMENTS IN INTERNATIONAL AND REGIONAL JURISPRUDENCE