be read holistically in light of the interdependence and indivisibility of its provisions.41 Under Article 4 CRC, States must undertake all ‘appropriate measures’ to realise children’s rights with no discretion,42 and take positive measures to give full effects to all the rights of children under their jurisdiction.43 21. The CRC Committee has issued two relevant Views on complaints brought under the Optional Protocol to the CRC on Communications Procedure (OPIC) 44 which concerned the repatriation of children who were being held in detention camps in the Syrian Arab Republic.45 The present case raises a slightly different CRC issue the duty that was still owed to child citizens during their minority - prior to them reaching adulthood or, if applicable, to being deprived of their citizenship. In both cases, the CRC Committee noted that a state’s jurisdiction is not limited to its “territory”, and can include domestic acts that are performed, or that produce direct and foreseeable effects, outside its national borders.46 The CRC Committee held that the nationality of the children, France and Finland, had the capability and power to protect the rights of the children detained in Syrian camps through repatriation or other consular responses, and as such exercised jurisdiction over them.47 States have the duty to realise the rights of children who fall under their jurisdiction, including the rights of children who are their nationals and who are in vulnerable situations in another countries’ territory. The CRC committee notes that “persons up to the age of 18 years are entitled to continuing protection from all forms of exploitation and abuse” (emphasis added).48 22. Article 3(1) CRC provides that children’s best interests should be a primary consideration in all matters affecting them. This obligation also concerns “[i]naction or failure to take action and omissions”, such as when states fail to take measures to protect children from abuse.49 Any decision affecting children must include (i) an evaluation of possible impacts on the children; (ii) procedural guarantees for the best interests assessment and determination; (iii) an explanation as to how children’s best interests have been weighed under Article 3.50 Exceptionally, if the decision taken was not in the child’s best interests, it must explain how the child’s best interests were still a primary consideration and why it did not override competing interests.51 23. Articles 19, 34-36 CRC recognise children’s right to protection from all forms of physical and mental violence, sexual abuse and exploitation, and sale and trafficking. Article 36 imposes on states an obligation to protect children from all other forms of exploitation prejudicial to any aspects of their welfare, irrespective of whether they meet the technical definition of trafficking. CRC General Comment No. 13 sets out measures which states must take to protect children from violence. In 41 See CRC General Comment No. 5: General measures of implementation of the CRC, 2003, § 18. CRC Committee, General Comment 19 (2016) on Public Budgeting for the Realization of Children’s Rights, 2019, CRC/C/GC/19, § 18. 43 CRC Committee, F.B. et al & D.A. et al v. France, 2022, CRC/C/89/D/77-79-109-2019, § 6.6. 44 Optional Protocol to the Convention on the Rights of the Child on a communications procedure, General Assembly resolution A/RES/66/138, 19 December 2011. 45 CRC Committee, F.B. et al & D.A. et al v. France, op. cit.; CRC Committee, P.N. et al v. Finland, 2022, CRC/C/91/D/100/2019. 46 ibid., §§ 6 - 6.9; P.N. et al v. Finland, § 10.8. 47 ibid. 48 CRC General comment No. 20, (2016) on the implementation of the rights of the child during adolescence, § 40. 49 CRC General Comment No. 14, (2013) on the right of the child to have his or her best interests taken as a primary consideration, 29 May 2013, CRC/C/GC/14, § 18. 50 ibid., § 6(c). 51 ibid., § 97. See also § 14. 42 5