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especially when they’re made in public and by a gaggle, it’s incumbent upon the State to research with due diligence and expedition.’ 307 The explicit references to non-State actors and due diligence within the context of a State’s obligation to protect human rights suggest an application of indirect horizontal effect by the CteeERD based on procedural obligations of the Dutch State (i.e. to investigate and punish non-State actors accused of racial discrimination). Had the Committee disregarded the case primarily based on the non-State id of the potential

 

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