52 Chekera-Radu/Women’s land and property rights CESCR) has also used its General Comments to elaborate that equality as provided for in its treaty also includes substantive equality.51 Further, the Committee has stated that in ensuring equality it is permissible for states to give different treatment where it is a measure designed to suppress factors that perpetuate discrimination.52 The three committees have addressed the need to take into account various factors in all spheres of life that infringe on women’s rights in several concluding observations to states. In particular, the CEDAW Committee has in a number of concluding observations criticised states on placing emphasis only on formal equality.53 In relation to redressing disadvantage it has consistently directed states to factors within the family that impede on equality.54 The Committees have focused on the differences in power within the marriage and inheritance practices. They have in addition directed states to target measures on achieving equality to groups of vulnerable women such as women with disabilities,55 rural women and indigenous women,56 to deal with institutional barriers that stand in the way of equality. The CEDAW Committee has in its decisions been to a large extent applying an interpretation of substantive equality that is in keeping with its expression of substantive equality in the various General Recommendations. Cusack argues however that the consistency of the generous substantive interpretation has varied between different categories of rights.57 In keeping with the substantive equality interpretation requiring an acknowledgment of women’s context, the CEDAW Committee has stressed the importance of taking into account women’s specific needs, intersecting factors that make women vulnerable to inequality.58 It has emphasised the importance of eliminating gender stereotypes as a means of realising de facto equality.59 In Kell v Canada, the state was obliged to have taken into account the fact that the author was aboriginal and vulnerable. Similarly, in Alyne da Silva Pimentel Teixeira v Brazil, the Committee 51 General Comment 16. General Comment 20. 53 C Buckley, A Donald et al (eds) Towards convergence in international human rights law: approaches of regional and international systems (2016) 202. 54 Concluding Observations on the initial, second and third Report of Djibouti, CEDAW Committee 28 July 2011 UNDoc CEDAW/C/DJI/CO1-3/2011, Concluding Observations on the Seventh Periodic Report of New Zealand, CEDAW Committee 27 July 2012 UNDoc CEDAW/C/NZI/CO/7(2012). 55 As above. 56 UN Committee on the Elimination of Discrimination Against Women, Concluding Comments of the Committee on the Elimination of Discrimination against Women: Honduras, 10 August 2007, CEDAW/C/HON/CO/6, http://www.refworld.org/docid/ 46d28100d.html (accessed 14 July 2017). 57 S Cusack & L Pusey ‘CEDAW and the rights to non discrimination and equality’ (2013) 14 Melbourne Journal of International Law 16. 58 Kell v Canada (26 April 2012), Communication 18/2008, UNDoc CEDAW/C/51/D/ 19/2008 (2012). 59 RB v Turkey, Communication 28/201, CEDAW Committee (12 April 2012) UNDoc CEDAW/C/51/D/28/2010 (2012). 52