111. Express and implied obligations.

Although the European Convention on Human Rights¹ imposes primarily negative obligations on states, requiring the authorities to refrain from interfering with the Convention rights, some of those rights expressly envisage the imposition of positive obligations on states: for example, the right to free legal assistance in criminal cases², the right to education³ and the right to free elections⁴ all require the active provision of state resources. The European Court of Human Rights also increasingly interprets the Convention rights, including those rights that do not expressly impose obligations, so as to impose positive obligations on states to take active steps