The aim of the MCW and the RPRHA is to provide legal grounding for women's rights, including their rights to health and to access contraceptive information and services.49 However, the laws’ full implementation has been undermined by a number of developments since the Committee's inquiry visit. As admitted in the state party report, “the issuance of landmark policies like the RPRH law…have yet to be translated into improved delivery of services and ultimately, better health outcomes, especially for the poor.”50 i. Judicial orders and other factors preventing full implementation of the RPRHA In its Inquiry Report, the Committee expressed concern that judicial actions questioning the legality of the RPRHA could lead to “partial, or even total, repeal, in contravention of the state party's obligations … under article 12 [of the Convention].”51 After the Committee’s visit, the Supreme Court of the Philippines (the Court) suspended the law’s implementation by issuing an order in the case of Imbong v Ochoa, which challenged the constitutionality of the law.52 In its decision, the Court upheld the constitutionality of the state party’s mandate to provide universal access to contraceptive information and services particularly to marginalized women,53 age and development appropriate reproductive health education for adolescents in all schools,54 and a nationwide multimedia-campaign to raise public awareness on reproductive health,55 as well as the mandate for LGUs to assist in the implementation of the law.56 In the same decision, the Court declared unconstitutional several key provisions of the RPRHA protecting women's access to contraception. Under the decision, providers may, without penalty, refuse to provide elective reproductive health procedures; all minors, including those who have already experienced pregnancy, must secure parental consent to access modern contraceptives; a married individual must secure spousal consent to undergo ligation or vasectomy; institutions may exercise conscientious objection; and private health facilities, nonmaternity specialty hospitals and hospitals run by religious groups do not have the obligation to refer women seeking modern contraceptives to alternative health care providers.57 The Committee has stated that these types of restrictions are inappropriate, stating that “[d]ecisions to have children or not … must not … be limited by spouse, parent, partner or Government.”58 Further, according the Committee, giving priority to any religious ideology over women’s health rights is expressly contrary to the state obligation to ensure women’s right to non-discrimination as discussed in the Inquiry Report. 59 Moreover, the Committee has established that women’s access to “non-biased, scientifically sound and rights-based counseling and information” must be guaranteed by states parties and that in instances of conscientious objection by practitioners, women must be referred to alternative medical personnel.60 The protections in the RPRHA also have been undermined by the recent temporary restraining order (TRO) issued by the Court indefinitely prohibiting the Department of Health (DOH) from “procuring, selling, distributing, dispensing or administering, advertising and promoting the hormonal contraceptives ‘Implanon’ and ‘Implanon NXT.’” 61 The TRO, issued in June 2015 which is effective indefinitely, also prohibits the Philippine Food and Drug Administration (FDA) from “granting any and all pending applications for registration and/or recertification for reproductive products and supplies, including contraceptive drugs and devices”.62 These orders demonstrate the Court’s failure to uphold women’s right to the full range of contraceptive methods under the RPRHA and to understand the immediate nature of the risk and harm women suffer when they have limited access to contraceptives and to recognize and protect women’s rights by permitting ongoing legal challenges to undermine their right to access the full range of contraceptive information and services. 4