Assessing the CEDAW Committee’s determination of continuing gender-based discrimination against wartime sexual slavery survivors in the Philippines

This case note examines the Views of the Committee on the Elimination of Discrimination against Women in Alonzo et al. v . The Philippines , the first international recognition of the rights of Filipino women survivors of Japan’s wartime sexual slavery. Departing from previous litigation and other efforts emphasising Japan’s state responsibility, the Committee framed the Philippines’ decades-long refusal to support the survivors’ claims as a form of continuing gender-based discrimination violative of the CEDAW. By focusing on present forms of gender-based discrimination, the decision helps highlight international human rights law’s distinctive role in addressing gendered harms for past atrocities. The note grounds the significance of the Committee’s decision in the ways in which it addresses and characterises wartime sexual slavery’s lasting and persistent effects on survivors. Non-discrimination in the rubric of international human rights law may help ameliorate the absence of adequate and effective remedies sought by women survivors in previous legal efforts.