appropriate steps to prevent, investigate, punish and redress such abuse through effective policies, legislation, regulations and adjudication.”15 The commentary to this Principle further clarifies that “States may breach their international human rights law obligations where such abuse can be attributed to them, or where they fail to take appropriate steps to prevent, investigate, punish and redress private actors’ abuse.”16 Principle 1 recognizes an obligation on the part of the State to protect against abuses committed by businesses that negatively affect people within its territory and/or jurisdiction. The duty to protect against human rights violations and abuses is also highlighted in jurisprudence of regional human rights courts. The Inter-American Court of Human Rights discussed the duty of due diligence in its seminal case, VelásquezRodríguez v. Honduras. The decision held that “[t]he State has a legal duty to take reasonable steps to prevent human rights violations and to use the means at its disposal to carry out a serious investigation of violations committed within its jurisdiction, to identify those responsible, to impose the appropriate punishment and to ensure the victim adequate compensation.”17 The decision further articulated that the State has a duty to use “all those means of a legal, political, administrative and cultural nature that promote the protection of human rights and ensure that any violations are considered and treated as illegal acts, which, as such, may lead to the punishment of those responsible and the obligation to indemnify the victims for damages.”18 The Inter-American Court also emphasized that “[a]n illegal act which violates human rights and which is initially not directly imputable to a state … can lead to international responsibility of the state, not because of the act itself, but because of the lack of due diligence to prevent the violation or to respond to it as required by the convention.”19 Additionally the duty to protect has been found in case law from the African Commission on Human and Peoples’ Rights, the Economic Community of West African States (ECOWAS) Community Court of Justice, and the European Court of Human Rights (ECtHR). A 2001 decision by the African Commission on Human and Peoples’ Rights, SERAC and CESR v. Nigeria, held that States have a duty to protect right holders by the use of legislation and other measures against potential abuses committed by others.20 This case held that there is a duty to create 15 Id. 16 Id. 17 Velásquez Rodríguez v. Honduras, Inter-American Court of Human Rights, Judgment of 29 July 1988, Inter-Am Ct. H.R, (Ser C) No.4 (1988), para 174. 18 Id. at para 175. 19 Id. at para 172. 20 The Social and Economic Rights Action Center and the Center for Economic and Social Rights v. Nigeria, African Commission on Human and Peoples’ Rights, App No.155/96, 27 October 2001, para 46. 5