Epilogue:

Migrant Rights in International Law: Exploring the Gendered Experiences of Migrant Women and Girls

“…43 The applicant alleges that she was forced to take part in pornographic films and photographs by her husband in Bulgaria and was subjected to psychological and physical violence, including sexual abuse. 44 The applicant claimed that Bulgaria, as a State party to CEDAW, violated Articles 1, 2, 3, 5 and 16 of CEDAW as a result of the discriminatory treatment that she and her daughter, as women, received from its authorities, and Bulgaria's failure to protect them from domestic gender-based violence and to sanction the perpetrator. 45 Despite the fact that Bulgaria was found to be in violation of Articles 2, 5, and 16 of CEDAW, and the applicant and her daughter have suffered serious moral and pecuniary damage and prejudice, the remedy applied by the CEDAW Committee was compensation to the victims of the human rights violation 'commensurate with the gravity of the violations of their rights'.…”

“…44 The applicant claimed that Bulgaria, as a State party to CEDAW, violated Articles 1, 2, 3, 5 and 16 of CEDAW as a result of the discriminatory treatment that she and her daughter, as women, received from its authorities, and Bulgaria's failure to protect them from domestic gender-based violence and to sanction the perpetrator. 45 Despite the fact that Bulgaria was found to be in violation of Articles 2, 5, and 16 of CEDAW, and the applicant and her daughter have suffered serious moral and pecuniary damage and prejudice, the remedy applied by the CEDAW Committee was compensation to the victims of the human rights violation 'commensurate with the gravity of the violations of their rights'. 46 This case demonstrates that, while violations of CEDAW provisions take place and such violations are denounced by the CEDAW Committee (known in human rights as 'naming and shaming'), little is in fact done to punish the human rights violator or bring justice to the victims of violation other than requiring the violator to compensate the victim.…”