waters, with all the accompanying filth, dirt and garbage into the major rivers and eventually the Manila Bay. If there is one factor responsible for the pollution of the major river systems and the Manila Bay, these structures would be on top of the list. The attribution of primary responsibility for the condition of Manila’s waterways to informal setter communities is common in public opinion. However, it is worrying that such a pronouncement is made by the chief judicial institution of the Philippines, without any further elaboration or evidentiary basis on which to ascribe such responsibility. The exercise of judicial power in this fashion promotes discrimination against the urban poor and should not be accepted from a government which purports to defend and support a broad understanding of human rights. (b) National Technical W orking Group The NTWG for the implementation of the PHP50 Billion informal settler resettlement fund has made some significant headway for the promotion of human rights within its policy framework, notably through the leadership of the DILG. An important element of the policy-making dynamic is the incorporation of civil society participation mechanisms into the NTWG’s structure. NGOs and other community representatives were invited to participate in sessions of the NTWG where policy guidelines were discussed and developed, which has encouraged a policy framework that is at least in part adapted to account for the rights and interests of the urban poor. Although not yet publicly available, these policy guidelines exhibit a number of strengths in terms of human rights protection, generally promoting community driven resettlement plans and explicitly incorporating CHR human rights-based resettlement guidelines into the operating framework. The policy of the NTWG also adopted in-city resettlement as a priority in terms of resettlement options made available to affected communities. The AusAID technical assistance programme to support NGOs in the delivery of resettlement services also operates to encourage civil society participation in the resettlement process. Unfortunately, some features of this framework restrict its capacity to effectively enforce human rights standards. The current guidelines promulgated by the NTWG must be understood as a policy document only. They are contained in a joint memorandum circular between government agencies, which is subsidiary to other laws and regulations and generally not enforceable against agencies who do not comply with its terms. Importantly, the policy guidelines are programme-specific and therefore cannot operate outside the jurisdictional and temporal scope of the programme, leaving all other communities subject to eviction and resettlement under existing laws. While the innovations of the NTWG should be recognised for their promotion of human rights standards, notably through various community participation mechanisms, they do not affect the generally applicable legal framework which continues to operate during all other cases of eviction and resettlement. As at December 2013, only 1,604 households have been resettled under the programme, which has been operating for almost four years. This represents only 1.5% of the target 104,000 to be resettled, a figure which raises concerns about the efficiency and effectiveness of the programme. Also worrying is that no household has yet been resettled through a community-driven proposal, with all currently approved 65