the failure of a duty holder (primarily the State) to fulfill its obligations to respect, protect and fulfill a human right. Violations may be by commission (a wrongful act, such as forced eviction, or discrimination), or by omission (the State’s failure to act in protecting or fulfilling the right) “to take steps, individually and through international assistance and cooperation…to the maximum of its available resources, with a view to achieving progressively the full realization of the right[ to adequate housing] by all appropriate means, including particularly the adoption of legislative measures”^[1] in such a way as to ensure the continuous improvement of living conditions.”^[2]