The coalition of NGOs, which was earlier involved in galvanising civil society during the Interlaken process, also issued joint preliminary comments on the leaked Brighton draft. The core of the comments reflect the criticism that I have voiced on this blog earlier and which is also shared by the group of other NGOs on which I posted yesterday:
"Against this background we are deeply concerned that some measures at the heart of this Draft have the potential to marginalise and undermine the functioning of the Court without the evidence having been produced to establish that such radical change is needed and with little recognition of the damage they could do to the Convention system in the long-term. ... We are particularly concerned at two aspects of the draft Declaration:To be continued!
· The proposal to incorporate the principle of subsidiarity and the doctrine of the margin of appreciation – broadly defined – into the text of the Convention.
· The proposals to amend the admissibility criteria."