NHRI of India.28 However, the requirement to support pluralism through a gender diverse leadership body is an essential requirement of the Paris Principles and thus more important to address than conferring the NHRI with ‘quasi-judicial’ functions, which are covered by the General Observations but are not considered a mandatory requirement of the Paris Principles.29 The SCA frequently considers the representation of women on an NHRI’s decision-making body, examining both representation in practice and mechanisms in law and policy to promote equitable representation. As a minimum, the SCA will expect some form of general provision applicable to appointing authorities to encourage the representation of women on the NHRI decision-making body. While there is nothing in the General Observations to indicate that such a provision should be in the principal enabling legislation of the NHRI, the SCA’s reporting suggests that in practice there is an expectation that any requirement be established in law.30 An alternative approach to supporting gender representation is for the institution’s legal framework to establish a minimum number or proportion of women members on the NHRI’s decision-making body. This ostensibly provides a stronger guarantee of equitable gender representation, although minimum quotas have caused accreditation problems for some NHRIs where the number of appointed female commissioners in practice is below the quota prescribed by law.31 There are various examples of NHRI legislation from the Asia Pacific region that establish prescribed gender representation on the NHRI’s decision-making body. For instance, article 12.9 of the Law on the National Human Rights Commission of Mongolia provides that the ‘[a]ppointment of the Commissioners shall consider gender equality and forty percent of the Commissioners provided in Article 12.1 of this Law shall be representation from one of sexes’.32 Article 5(7) of the National Human Rights Commission of Korea Act also provides that ‘[t]he number of commissioners of any gender shall not exceed 6/10 of the total number of commissioners’.33 The SCA’s jurisprudence on gender representation in the composition of the NHRI’s decisionmaking body confirms that there is no clear proportion or threshold that is universally applicable in any context. On multiple occasions the SCA has remarked that only having a single female commissioner on a large commission with five or more members will not be sufficient gender representation.34 In its most recent reviews of the NHRIs of Qatar and Oman, the SCA highlighted 28 See, eg, Protection of Human Rights Act 1993 (India), section 13, according to which the NHRI shall ‘while inquiring into complaints under this Act, have all the powers of a Civil Court trying a suit under the Code of Civil Procedure. See also Ombudsman (Komesina 0 Sulufaiga) Act 2013 (Samoa) sch 3 s 6, which requires that candidates for appointment as Ombudsman be ‘qualified for appointment as a judge of the District Court’. 29 General Observation 2.9 on The quasi-judicial competency of NHRIs (complaints-handling) acknowledges that ‘[t]he Paris Principles do not require that an NHRI have the ability to receive complaints or petitions from individuals or groups regarding the alleged violation of their human rights’: General Observations (n 16) 50. 30 The SCA has made recommendations for NHRIs to advocate for such a provision in their ‘enabling law’ on many occasions: Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Session of the Sub-Committee on Accreditation, Geneva, 13-17 November 2017 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/SCA_Report_November_2017__ENG.pdf> (‘November 2017 SCA Report’) 28 (Poland) and 47 (Nicaragua); Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Session of the Sub-Committee on Accreditation, Geneva, 14-18 May 2018 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/SCA_Report_May_2018-Eng.pdf> (‘May 2018 SCA Report’) 32 (Nicaragua) May 2018. See also David Langtry and Kirsten Roberts Lyer (n 18) 100-101. 31 See, eg, May 2024 SCA Report (n 15) 21 (Cameroon). 32 Law on the National Human Rights Commission of Mongolia 2020 (Mongolia) [translation Legal Institute of Mongolia <https://legalinfo.mn/en/edtl/16532053985811>] art 12.9. 33 National Human Rights Commission of Korea Act (Korea) [translation National Human Rights Commission of Korea <https://www.humanrights.go.kr/template/resources_eng/file/National%20Human%20Rights%20Commission%20Act.pdf >] art 5(7). 34 See, eg, Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Session of the Sub-Committee on Accreditation, Geneva, 13-17 March 2017 < https://www.ohchr.org/sites/default/files/Documents/Countries/NHRI/GANHRI/SCA_Final_Report_-_March_2017_English.pdf> (‘March 2017 SCA Report’) 12 (Niger); Global Alliance of National Human Rights Institutions, Subcommittee on Accreditation, Report and Recommendations of the Session of the Sub-Committee on Accreditation, Geneva, 3-7 October 2022 <https://www.ohchr.org/sites/default/files/documents/countries/nhri/ganhri/2022-11-08/SCA- Gender Equality and the Paris Principles 7