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