particular, the intervenors emphasise the impact of violence on children and its longlasting negative impacts, including injury or psychological impact or other disruption to the child’s quality of life. Protective measures should include the establishment of social programmes to provide necessary support for the child and for those who have the care of the child, prevention and identification, reporting, referral, investigation, treatment and follow-up of instances of violence against children (Article 19(2)). The protection of children from violence and exploitation thus requires states to take “tailored measures” to reduce children’s vulnerability to violence and exploitation.52 24. If a child has been a victim of violence, the state has a duty to promote their “physical and psychological recovery and social reintegration”, in an environment which fosters their “health, self-respect and dignity” (Article 39 CRC). The CRC Committee considers that states parties should ensure the “recovery and gender-sensitive reintegration of adolescents who are recruited into armed forces and groups”.53 25. In relation to marriage, the CRC Committee reaffirms in its General Comment No. 20 that States should take all appropriate measures to protect all children under the age of 18 who fall within their jurisdiction from child marriage, a form of forced marriage.54 26. States obligations to take positive measures under Article 4 CRC is “particularly strong” in relation to the protection of children from ill-treatment and potential violations of their right to life.55 Article 6 CRC enshrines children’s right to life, survival and development, and Article 37(a) protects them from inhuman, cruel and degrading treatment. In both F.B. et al & D.A. et al v. France and P.N. et al v. Finland, the CRC Committee found that the children’s state of nationality violated Article 37(a) by failing to protect the child victims, and Article 6(1) by failing to protect the child victims from an imminent and foreseeable threat to their lives. As France and Finland knew about these conditions and were capable of taking action, they had a positive obligation to protect the children from the imminent risk to their right to life and actual violation of their freedom from cruel, inhuman and degrading treatment.56 27. According to Article 18(2) CRC, states have the duty to render “appropriate assistance” to support parents and legal guardians. As such, states have an obligation to notify a child’s parents that the child may be vulnerable to violence or exploitation, unless doing so would be against the child’s best interests. 28. Article 28 CRC recognises children’s right to education which requires states to take measures to encourage regular attendance at schools and the reduction of drop-out rates (Article 28(e) CRC).57 States parties must therefore take measures to ensure children’s attendance, especially for children of the age of compulsory education.58 Failure to identify child trafficking and protect children from this form of harm violates their right to freedom from violence and exploitation, and violates their right to education. 29. The CRC Committee recommended that the United Kingdom ensure that child victims of trafficking are “always treated as victims and have access to the necessary 52 CRC General Comment No.13 (2011), The right of the child to freedom from all forms of violence, §72(f). 53 CRC General Comment No. 20, op. cit., § 82. 54 ibid., § 40; see also Joint general recommendation No. 31 of the Committee on the Elimination of Discrimination against Women/general comment No. 18 of the Committee on the Rights of the Child (2019) on harmful practices, 2019, §20-24. 55 CRC Committee F.B. et al & D.A. et al v. France, op. cit., § 6.6. 56 ibid., § 6.9; CRC Committee, P.N. et al v. Finland, op. cit. 57 CRC General Comment No. 20, op. cit., §§69, 71. 58 ibid., § 69. 6

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