This article addresses the recent shift
towards finding States responsible for
gender-based violence perpetrated by non-
State actors. Using recent cases in the
areas of domestic violence, sexual assault
and reproductive violations, the article
demonstrates that international judicial
bodies are beginning to view gender-based
violence in the private sphere as a human
rights violation. The article analyzes
recent articulations of States' positive
obligations, namely the State's obligation
to exercise due diligence to prevent,
investigate and remedy VAW. The article