Tuesday, 10 October 2017

A Critical Analysis of the HIV Prevention and Control Act, 2014 from a Health and Human Rights Perspective

By Bakampa Brian Baryaguma

1.                  Introduction

The importance of the right to health need not (and cannot) be overemphasized, for the simple reason that everything else about the person hinges on that right, so much so that in the past, courts, in exercise of their inherent jurisdiction, have even intervened to circumvent individual interests, where such interests were considered to be adverse to the health and wellbeing of the person concerned, or of another dependent person.[1] For example, an unhealthy person may not fully enjoy his or her right to education, as he or she would not comfortably attend school; the same person would thereby live in a state of compromised dignity, which is an affront to the inherent human right to live a dignified life; last but not least, that person would not fully enjoy his or her civic, cultural or economic rights.

It is for these and more reasons that national objective and directive principle of state policy XX, of the 1995 Uganda Constitution, states that, ‘The State shall take all practical measures to ensure the provision of medical services to the population.’ The state has gone a step further to enact specialized and enabling legislation to achieve this objective. A case in point is The HIV Prevention and Control Act, 2014, assented to by H.E. the President on 31 July, 2014. According to its long title, the Act is meant, ‘… to provide for the prevention and control of HIV and AIDS, including protection, counseling, testing, care of persons living with and affected by HIV and AIDS, rights and obligations of persons living with and affected by HIV and AIDS; to establish the HIV and AIDS Trust Fund; and for other related matters.’

This Act is undoubtedly well intentioned, but its provisions pose serious challenges especially, when viewed from the interrelated, interdependent and indivisible perspectives of health and human rights, as shown in the following discussion.

2.                  Critical Analysis of the Act from a Health and Human Rights Perspective

A.                The Title of the Act

The title of the Act is problematic. The Use of the words prevention and control makes the Act somewhat coercive and rather stigmatizing, due to the effect of portraying HIV and AIDS victims as undesirable members of the society.

I think the word Management would have been a more nuanced alternative for the words prevention and control, such that the final text would have read as, The HIV and AIDS Management Act. The element of coerciveness and stigmatization, currently inherent in the Act, undermines the human rights approach to fighting HIV and AIDS, thereby impairing the health of the very people it is meant to serve.

B.                 Reasonable Care to be Taken to Avoid Transmission of HIV

Section 2 of the Act requires a person to take reasonable steps and precaution, and also use protective measures to protect him or herself and others, against HIV infection, during sexual intercourse.

From a health point of view, it is difficult to see how possible it is to protect others, since, logically, the duty to protect oneself against diseases and infections primarily lies with the individual especially, for a disease or infection like HIV and AIDS that involves willful and personal sexual associations between people. The scope of others is too wide and places an onerous burden on the person to protect a potentially limitless number of people. Such an overly extensive duty is in itself potentially an abuse of the human rights of the person bearing the duty to protect.

C.                 Persons Incapable of Giving Informed Consent to HIV Testing

Section 10 permits parents, guardians, persons next of kin, caretakers or agents, of persons who are incapable of giving informed consent to voluntary HIV testing, to give such informed consent on their behalf. Under sub-section (2)(d), those envisaged include anybody suffering from any impairment rendering him or her incapable of giving his or her informed consent.

The wide scope of this section and the overreaching power it gives those specified to give informed consent on behalf of those incapable of giving it, render the section highly susceptible to abuse, to the detriment of the concerned person’s right to privacy, and indeed, personal integrity, as enshrined under Articles 27 and 24 respectively, of the 1995 Uganda Constitution.

D.                Dispensing with Consent to Test for HIV

Under Section 11, consent to test for HIV may be dispensed with, where it is unreasonably withheld, or in situations of an emergency due to grave medical or psychiatric condition; and in both instances, if the medical practitioner reasonably believes that such test is clinically necessary or desirable, in the interest of the person to be tested.

Unfortunately, however, the phrases, unreasonably withheld, an emergency due to grave medical or psychiatric condition, clinically necessary or desirable and the interest of the person to be tested are not defined, which leaves a lot of room for potential abuse, thereby clearly posing serious threats to the concerned person’s right to privacy and personal integrity, as enshrined under Articles 27 and 24 respectively, of the 1995 Uganda Constitution.

E.                 HIV Testing of Persons Charged with Sexual Offences

Section 12 provides that a person apprehended for a sexual offence should be tested for HIV, for purposes of criminal proceedings and investigations.

This section is highly problematic, from a health perspective, because it may not serve any meaningful purpose. Imagine a situation where a wrong person is apprehended for commission of a sexual offence, is mandatorily tested for HIV, against his or her will, and it emerges for instance, that he or she is HIV positive and this is inevitably revealed to him before or during trial. That person can easily commit suicide because he or she was not psychologically ready to receive the bad news; no matter the amount of counseling given, since the mind may not be “forced” to adapt to a given situation. The traditional emphasis on voluntary HIV testing proves more useful.

This involuntary testing would also be tantamount to violation of the person’s right to privacy and personal integrity. It also undermines the person’s dignity, and borders on cruel and degrading treatment, contrary to Article 24 of the Constitution.

F.                  Routine HIV Testing

Section 13 provides for routine HIV testing of victims of sexual offences, pregnant women and their partners, for purposes of preventing HIV transmission.

Such mandatory testing is counterproductive both from public health and human rights perspectives especially regarding partners of married women, many of whom may find little incentive to test, since they are neither victims, nor carriers of the pregnancy.

From a public health perspective, it may lead people to shun public health centers, in favour of informal and usually unqualified establishments, and thus seriously impede the public health response to HIV that has been very successful in the past, based on voluntary counseling and testing.

From a human rights perspective, it violates the rights to privacy and dignity of the persons identified, and may also amount to degrading treatment, contrary to Articles 27 and 24 of the 1995 Uganda Constitution.

G.                Disclosure or Release of HIV Test Results

Section 18(2) of the Act allows medical practitioners to disclose or release results of an HIV test to a number of people, including sexual partners of the tested person, and medical practitioners or qualified officers directly involved in the treatment or counseling of that person.

Whereas the section pertinently captures instances where HIV results may be justifiably disclosed to third parties, it nevertheless, poses subtle dangers especially, from a public health perspective. There is a risk of it serving to drive a number of people away from getting tested for fear of their results being disclosed to third parties without their knowledge, which will be a significant impediment to the ability of the state to have accurate data upon which to rely in crafting effective public health responses. Public health interest demands sensitivity to the concerns of those tested, offering them all opportunities in the first case, to make such disclosure themselves.

H.                State Obligations in HIV Control

Section 24(1) calls upon the state to ‘devise measures’ to control the spread of HIV. While this is an important provision especially, in terms of ensuring a human rights based approach to the response to HIV in Uganda, the language used – devise measures – is however, extremely non-committal and may weaken the obligations thereby imposed. A more mandatory phraseology such as ‘ensure’ would have been more appropriate to uphold and safeguard the human rights of those living with and affected by HIV and AIDS.

I.                   Attempted and Actual Transmission of HIV

Section 41 deals with attempted transmission of HIV. It states that a person who attempts to transmit HIV to another person commits a felony, punishable with utmost five years imprisonment, a fine, or both.

Section 43(1) addresses actual transmission of HIV. It stipulates that willful and intentional transmission of HIV to another person is an offence, punishable with imprisonment of not more than 10 years, a fine, or both.

From a public health perspective, these sections are very problematic, because any punitive provisions in a public health law, moreover one with the expressed intention of promoting human rights, are counterproductive. Besides, the offences also carry with them the dangers of misuse for blackmail and extortion. Consequently, from a legal perspective, they will also present formidable difficulties of proof and related matters that would be involved in prosecuting such crimes, culminating in increased stigmatization of people living with HIV and AIDS.

3.                  Conclusion

The HIV Prevention and Control Act, 2014, it must be noted, is by and large, a good law, although it faces its own peculiar challenges, both from a health and human rights perspective, as discussed above. Apparently, the rights to privacy and personal integrity, as enshrined under Articles 27 and 24 respectively, of the 1995 Uganda Constitution, are the most assaulted by this law.

It is therefore, hoped that in performance of their respective duties, even with this law in place, the public health and legal authorities will endeavour to perform their duties with utmost diligence, giving full efficacy to the Act and the Constitution, by holding dearly, the best interests of people living with and affected by HIV and AIDS, whom this law is principally designed to benefit, in full compliance with medical law and standards to act in accordance with practices that are accepted as proper, by a responsible body of skilled medical personnel.[2]


Notes and References



[1] See, for instance, Re S (Adult: Refusal of Medical Treatment) [1992] 4 All ER 671, where a health authority applied for a declaration to authorise the surgeons and staff of a hospital, under the authority’s control, to carry out an emergency caesarean section operation upon a 30-year-old woman patient, who had been admitted to hospital with ruptured membranes and in spontaneous labour with her third pregnancy, and who had continued in labour since then. She was six days overdue beyond the expected date of birth and had refused, on religious grounds, to submit herself to such an operation, supported in this by her husband. The surgeon in charge of the patient was emphatic in his evidence that the operation was the only means of saving the patient’s life and that her baby could not be born alive if the operation was not carried out. It was held that the court would exercise its inherent jurisdiction to authorise the surgeons and staff of a hospital to carry out an emergency caesarean section operation upon a patient, contrary to her beliefs, if the operation was vital to protect the life of the unborn child. Accordingly, a declaration was granted that such an operation and any necessary consequential treatment which the hospital and its staff proposed to perform on the patient was in the vital interests of the patient and her unborn child, and could be lawfully performed despite the patient’s refusal to give her consent to the operation.

[2] This is the professional standard required of medical practitioners. In the case of Bolitho (Administratrix of the Estate of Bolitho (Deceased)) vs City and Hackney Health Authority [1997] 4 All ER 771, 776, Lord Browne-Wilkinson stated that, ‘The locus classicus of the test for the standard of care required of a doctor or any other person professing some skill or competence is the direction to the jury given by McNair J in Bolam v Friern Hospital Management Committee [1957] 2 All ER 118 at 122, [1957] 1 WLR 583 at 587: ‘I myself would prefer to put it this way: a doctor is not guilty of negligence if he has acted in accordance with a practice accepted as proper, by a responsible body of medical men skilled in that particular art …. Putting it the other way round, a doctor is not negligent, if he is acting in accordance with such a practice, merely because there is a body of opinion that takes a contrary view.’

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