of fundamental rights in Chapter III. Since health education and nutrition are not covered by that Chapter, this procedure provides an important method of enforcement of rights relating to health, education and food security. The enforcement provision also allows the High Court to refer these matters to the Human Rights Commission for inquiry and report (S. 7 (3)). The relief to be granted by the High Court is also very wide and extends to giving the relief or remedy requested in the petition or “grant such other relief or make directive as it may consider just and equitable.” (S. 7 (1) and S. 7 (4)). Appeals against decisions of the High Court may be filed in the Supreme Court (S. 8). These important enforcement procedures to claim education and health rights do not appear to have surfaced in petitions in the High Court, and remain ignored. We have noted that Art. 11 on freedom from torture and cruel inhuman treatment has been interpreted by the Supreme Court as a right to life and protection of dignity. This jurisprudence too can be creatively interpreted to recognize a right of access to basic health services and education. Limitations in Access to Constitutional Remedies The Sri Lankan Supreme Court has developed a jurisprudence on Equality and Torture that is relevant for remedies regarding violation of human rights regarding reproductive health and GBV. However the general limitations that apply in regard to enforcement of fundamental rights protected by the Constitution apply in this area [See Annex]. 1) The power of judicial review is limited. New legislation can be challenged at the Bill stage, in its passage through Parliament, but cannot be reviewed after enactment for violation of the Constitution (Art. 80 (3)). Similarly Art 16 says that “written and unwritten laws” of the past cannot be challenged. This means that enacted laws cannot be reviewed. In the controversial Anuradhapura Rape Case referred to earlier however the Supreme Court did review and strike down the minimum sentence for sexual violence enacted by the Penal Code Amendment in 1995. This was clearly an extra Constitutional exercise of judicial review and is controversial, but was not reviewed by the Supreme Court in the recent KurunegalaRape case (2015) of statutory rape of a girl child, where a sentence of imprisonment imposed by the Court of Appeal was suspended. 2) Art 126 (1) indicates that only “executive and administrative action” may be challenged. This means that infringements by private non-State actors may be excluded. However there is jurisprudence in the Supreme Court making private Non-State Actors accountable when the State has failed in its obligation to protect from violation of guaranteed fundamental rights, by their inaction. The concept of an individual public official “command responsibility” for violation has also been recognized. [See Annex]. Therefore Non-State and private actors such as individuals or private institutions like Hospitals, Schools and private Employers may become liable for infringements of fundamental rights together with the State, where it has a regulatory role and responsibility, and failed to fulfill that obligation. 3) General Restrictions incorporated in Constitutional provisions on fundamental rights. The Constitution incorporates limitations on fundamental rights on grounds such as national security, racial and religious harmony, public health (Art. 15 (1) (2) (7). Yet the right to freedom of thought, conscience and religion, (Art 10) and freedom from torture (Art 11) are absolute, COMPENDIUM ON LAW, GENDER BASED VIOLENCE AND REPRODUCTIVE RIGHTS 39