A Guide to Litigating Identity Systems INCREASED ENGAGEMENT WITH INTERNATIONAL HUMAN RIGHTS LAW 78. While Mauritius, India, and Jamaica are State Parties to the International Covenant on Civil and Political Rights, and therefore have an obligation to fulfil the rights guaranteed under the Convention, including the right to privacy, the Convention does not find a mention in the judgments analysed on the rights implications of identity systems. The Kenyan High Court briefly mentions the Convention, but little consideration is given to its impact beyond the existence of a right to privacy.326 The Kenyan High Court’s most complete engagement with international human rights law is limited to privacy and data protection principles issued by the OECD and the African Union, which the court cites in evaluating the data protection framework in which the Kenyan national identity system operates.327 79. Although the obligations imposed on State Parties to a treaty have important implications for all national authorities, including the executive and the legislature, the judiciary is a key actor in reviewing the compatibility of domestic legislation with international human rights treaties 328 and assessing whether the state is complying with its international obligations. International human rights law also fills gaps at the domestic level through a reliance on international norms and standards. International human rights law can be understood as “part of a broader set of interrelated, mutually reinforcing processes and institutions-interwoven strands in a rope-that together pull human rights forward, and to which international law makes distinctive 326 See Huduma Namba Judgment, ¶ 747. 327 See Huduma Namba Judgment, ¶¶ 843–846 (comparing the Kenyan data protection framework to established international principles contained in the OECD Privacy Principles and the African Union Convention on Cyber Security and Personal Data Protection). 328 European Commission for Democracy Through Law (Venice Commission), Draft report on the implementation of international human rights treaties in domestic law and the role of courts, https://www.venice.coe.int/webforms/documents/default.aspx?pdffile=CDL(2014)046-e 77