Gender-specific forms of ill-treatment can also occur on the basis of an individual’s real or perceived sexual orientation or gender identity. Examples of how states fail to meet their obligation to prohibit torture and other ill-treatment of sexual minorities are:135 • in a number of countries laws punish consensual same-sex relationships and transgender behaviour by corporal punishment; • rape of a man or of a male-to-female transsexual woman being classified as a lesser charge of ‘sexual assault’; and • the status of sexual minorities may affect the consequences of their ill-treatment in terms of their access to complaint procedures or medical treatment. Sexual abuse is a broad term encompassing all acts involving one person causing another person to engage in an unwanted sexual act by force or threat. Although sexual abuse is a violation of human rights, international human rights law referring to sexual abuse is very limited. No international human rights instruments or jurisprudence specifically identify sexual abuse as a form of torture or other ill-treatment (with rape as an exception). However, the Committee on the Rights of the Child continually makes reference to illtreatment in connection with sexual abuse.136 Further, Article 19 of the CRC provides that: 1. States Parties shall take all appropriate legislative, administrative, social and educational measures to protect the child from all forms of physical or mental violence, injury or abuse, neglect or negligent treatment, maltreatment or exploitation, including sexual abuse, while in the care of parent(s), legal guardian(s) or any other person who has the care of the child [emphasis added]. E v United Kingdom137 appears to be the only case in an international tribunal dealing with sexual abuse as a violation of the prohibition on torture and other ill-treatment. The ECHR 134 Report of the Special Rapporteur on violence against women, Commission on Human Rights, fifty-fourth session, E/CN.4/1998/54, 26 January 1998 at [130]. 135 Interim report of the Special Rapporteur on the question of torture and other cruel, inhuman or degrading treatment or punishment, fifty-sixth session, A/56/156, 3 July 2001 at [18]-[20]. 136 See for example Concluding Observations of the Committee on the Rights of the Child: Fiji. 24/06/98. CRC/C/15/Add.98, Committee on the Rights of the Child at [37]. 93