The obligation to fulfil States have principal responsibility for the direct provision of education in most circumstances.56 Thus, the obligation to fulfil requires States to take appropriate legislative, administrative, budgetary, judicial and other measures towards the full realisation of the right to education.57 In turn, the obligation to fulfil incorporates three elements: an obligation to facilitate, an obligation to provide and an obligation to promote. Fulfil (facilitate) As part of the obligation to fulfil, States are required to facilitate the right to education by taking positive measures which enable and assist individuals and communities to enjoy the right to education within a context that is appropriate and acceptable to the particular circumstances of the respective State.58 Consequently, measures adopted will vary between States. By way of illustration, the CESCR has said that a State must facilitate the acceptability of education by taking positive measures to ensure that education is culturally appropriate for minorities and indigenous peoples, and of good quality for all.59 Fulfil (provide) States also have a duty to provide access to all types and levels of education which enables all individuals to exercise their right to education. According to the CESCR,60 States are obliged to provide a specific right in the ICESCR when an individual or group is unable, for reasons beyond their control, to realise the right themselves by the means at their disposal. The extent of this obligation is subject to the text of the Covenant. In this respect, the CESCR emphasised, first, that States have principal responsibility for the direct provision of education in most circumstances and, secondly, that, given the differential wording in relation to primary, secondary, higher and fundamental education, the parameters of a State’s obligation to provide are not the same for all levels of education. Accordingly, in light of the text of the 56 CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at para 48. 57 Maastricht Guidelines at para 6. 58 CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at para 47. 59 The example of fulfil (facilitate) in CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at para 50, is “taking positive measures to ensure that education is culturally appropriate for minorities and indigenous peoples, and of good quality to all.” 60 See CESCR General Comment No. 13: The right to education E/C.12/1999/10 8 December 1999 at paras 47 – 48. 47