reported victims of domestic violence, the number of victims with disabilities
increased by 11%. The COVID-19 and the Rights of Persons with Disabilities:
Guidance emphasizes that persons with disabilities have experienced a higher risk
of violence, particularly when isolated during the pandemic. Women with
disabilities face higher rates of violence and also experience worse violence than
men with disabilities. However, when persons with disabilities try to reach out to
domestic violence help hotlines or protective services, they face ongoing prejudice
and difficulties. Because women and children with disabilities are already at risk
of violence (please refer to Table 16.1 of the CRPD Second Report, and Points 26
and 79 of the independent opinion of the NHRC), the NHRC is concerned that due
to stresses caused by the pandemic worsening domestically in 2021, these groups
are at an even higher risk of violence and face even more perilous situations. Thus,
the NHRC has appealed to the government to refer to the guidance mentioned
above and actively adopt policies to minimize the harm done to vulnerable groups
such as women and children with disabilities to ensure adequate services and
protection.
Articles 1 to 4: Purpose, definitions, general principles and general
obligations
12. The ROC’s People with Disabilities Rights Protection Act (hereinafter referred to
as the PDRPA) amended its definition of persons with disabilities in 2007 and took
into account activities and participation factors to adhere to the International
Classification of Functioning, Disability, and Health (hereinafter referred to as the
ICF) endorsed by the WHO. However, the NHRC raises the following existing
issues and concerns:
(1) Nine years have passed since the amendment of the PDRPA in 2012. The
central competent authority utilizes the “Body Functions and Structures”
(code bs) and “Activity, Participation and Environmental Factors” (code
de) assessment categories in assessing disabilities. However, it still only
adopts the results of medical diagnoses to identify the eligibility of persons
with disabilities and determining their level of disability. This means that
only impairments of body functions and structures (code bs) are
considered, whereas obstacles to activity, participation and environmental
11