UPR Sexual Rights Database

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UN Member State that is reviewed on its human rights record as part of the UPR process.

Categories of the types of information used during reviews

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Source of Reference

Recommending State

UN Member State or Permanent Observer making sexual rights related recommendations, comments or asking questions to the State under Review.

Review Documentation

Sources of information used as the basis for a State’s review.  Includes the State’s National Report, UN Compilation Report and a Stakeholder Summary.

UN Regional Group to which State under Review belongs.

UN Regional Group to which Recommending State belongs.

This will only match recommendations where the Source of Review is a State.

Implementation notes

State responses to recommendations and issues raised in the UN Compilation and Stakeholder summary.

Displaying 52626 - 52650 of 58186 recommendations found
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    UN Compilation

    Issue:
    • International human rights instruments
    Type:
    Review Documentation
    Session:
    29th Session, January 2018
    Status:
    Reference Addressed
    Contents:
    The United Nations country ... recommended that Tonga ratify the core international human rights treaties, including the ICCPR, ICESCR, CEDAW,..., and the CRPD. [Para 2]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Stakeholder Summary

    Issue:
    • Early marriage
    Type:
    Review Documentation
    Session:
    29th Session, January 2018
    Status:
    Reference Addressed
    Contents:
    JS1 noted that under the Births, Deaths and Marriage Registration Act 1962, children from the ages of 15 – 17 years old were allowed to marry with parental consent. It recommended that the relevant section of this Act be repealed with a view to raising the age to 18 years. [Para 37]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    UN Compilation

    Issue:
    • Gender equality
    Type:
    Review Documentation
    Session:
    29th Session, January 2018
    Status:
    Not Followed up with a Recommendation
    Contents:
    … In doing so, Tonga was encouraged to give due consideration to the participation of communities, practitioners, cultural actors and nongovernmental organizations from civil society, as well as vulnerable groups (minorities, indigenous peoples, migrants, refugees, youth and people with disabilities), and to ensure that equal opportunities were given to women and girls to address gender disparities. [Para 28]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    National Report

    Issue:
    • Violence against women / gender-based violence
    • Domestic violence
    Type:
    Review Documentation
    Session:
    2nd session, May 2008
    Status:
    N/A
    Contents:
    The PPDVP is an initiative of NZAID, New Zealand Police (NZPOL) and the Pacific Islands Chiefs of Police (PICP). The long-term goal of the programme is a safer Pacific free from domestic violence. The focus is primarily on building the capacity of Pacific Police services to prevent/respond effectively to domestic violence. This will include the development and maintenance of effective partnerships between Police and other agencies/NGOs with a role in preventing/responding effectively to domestic violence. In 2006/07 NZAID commenced implementation of the Programme, this included successful recruitment and training of PPDVP implementing staff and in-country mentors. [Para 100]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Czechia

    Czechia
    Regional group
    EEG
    Political group
    EU
    Issue:
    • Women's and / or girls' rights
    Type:
    Recommendation
    Session:
    2nd session, May 2008
    Status:
    Rejected
    Contents:
    Amend legislation discriminating against women in the fields of inheritance, ownership to land and child support.
    Implementation
    Stakeholder Summary:
    Para 16) CSO HRTF reported that his Majesty King George Tupou V had appointed a Royal Land Commission on 10 October 2008, pursuant to the Royal Commissions Act (Cap 41) Laws of Tonga, which empowered such appointment to inquire into matters of importance to the public welfare. It added that the final report had been released in June 2012 with recommendations to increase women's rights to land, more specifically for women to be allowed to register a town allotment. However this recommendation did not allow women to register bush allotments with the reasoning being that only men attended to the bush for agricultural purposes. CSO HRTF called on the Government to consider full rights of women to land registration.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Costa Rica

    Costa Rica
    Regional group
    GRULAC
    Political group
    OAS
    OEI
    ACS
    Issue:
    • Discrimination based on sexual orientation
    • Sexual violence
    • Discrimination based on gender identity
    • Criminal laws on same-sex sexual practices
    • Violence on the basis of sexual orientation
    • Violence on the basis of gender identity
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Unclear Response
    Contents:
    Decriminalize consensual same-sex relations, criminalize discrimination based on sexual orientation and gender identity, as well as sexual violence, including corrective rape, and take action to end impunity.
    Explanation
    Noted. Tonga received 16 recommendations in relation to this area encouraging Tonga to decriminalize same sex relationships. However, Tonga currently retains its position in the first UPR Report which stated that “whilst current laws might criminalize certain consensual sexual conduct, Tonga is a Christian society that believes in tolerance and respect across difference. A respect for difference allows the widest margins of appreciation to lawmakers as well as other stakeholders and encourages robust debate about equality within society."
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Chile

    Chile
    Regional group
    GRULAC
    Political group
    OAS
    OEI
    Issue:
    • Early marriage
    • Sexual violence
    • Domestic violence
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Unclear Response
    Contents:
    Develop a legal framework for the protection of children, with special emphasis on raising the age of criminal responsibility, the prohibition of child marriages, and the protection of children from extrajudicial corporal punishment in the context of the criminal justice system, as well as corporal punishment in the home and sexual crimes within the domestic sphere.
    Explanation
    Noted.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Chile

    Chile
    Regional group
    GRULAC
    Political group
    OAS
    OEI
    Issue:
    • International human rights instruments
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Accepted
    Contents:
    Intensify efforts to advance the ratification of ... the CEDAW.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Italy

    Italy
    Regional group
    WEOG
    Political group
    EU
    Issue:
    • International human rights instruments
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Accepted
    Contents:
    Strengthen efforts to ratify the CRPD.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Slovenia

    Slovenia
    Regional group
    EEG
    Political group
    EU
    Issue:
    • Women's and / or girls' rights
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Accepted
    Contents:
    Increase women’s access to justice and ensure affordability of legal services.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    United States

    United States
    Regional group
    WEOG
    Political group
    OAS
    Issue:
    • Sexual violence
    Type:
    Recommendation
    Session:
    43rd Session, May 2023
    Status:
    Accepted
    Contents:
    Given high rates of sexual assault, does the Government of Tonga intend to expand laws criminalizing sexual assault?
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Switzerland

    Switzerland
    Regional group
    WEOG
    Political group
    OIF
    Issue:
    • International human rights instruments
    • Gender equality
    Type:
    Recommendation
    Session:
    15th session, February 2013
    Status:
    Accepted
    Contents:
    Ratify in particular the two international Covenants, concerning ... OP-ICESCR, OP-ICCPR; CEDAW ...
    Implementation
    National Report:
    Para 19) In May 2017, Tonga was represented at a Training on the Benefits to Pacific Island Nations of National Mechanisms for Human Rights Implementation/ Reporting and the Two Covenants, ICCPR and ICESCR hosted by the Office of the Human Rights Commissioner in Nadi, Fiji.
    Para 21) Although Tonga has not ratified ICCPR, the Tongan laws continue to comply with the ICCPR principles as seen in the case of R v Vola [2005] Tonga LR 404, where the Tongan courts applied the principles of ICCPR despite Tonga’s non-ratification.
    Para 22) Although Tonga has not ratified ICESCR, the principles of ICESCR are incorporated in the Tongan laws, which includes laws to the right to adequate health care, right to education, and the right to a decent home, food, shelter, the right to fair wages and equal remuneration for equal value and right to take part in cultural life…
    Para 52) Tonga announced that it is ready to ratify CEDAW at the 59th session of the Commission on the Status of Women at the UN General Assembly in New York on 12 March 2015.
    Para 112) On 6 March 2015, His Majesty’s Cabinet approved for the Tonga to ratify the Convention on the Elimination of All Forms of Discrimination Against Women (CEDAW).
    Para 113) On 9 March 2015, Tonga made an international commitment during the 59th Session of the Commission on the Status of Women (CSW).
    Para 114) Tonga is currently working on revising the reservations to CEDAW to be consistent with issues raised by the public before it can proceed to the ratification process.

    UN Compilation:
    Para 2) The United Nations country team noted that, despite the recommendations accepted by Tonga during the second cycle of the universal periodic review to ratify core international human rights treaties, no concrete progress had been made thus far.
    Para 3) The United Nations country team stated that, in March 2015, the Cabinet had approved the process of ratification of the CEDAW, with a number of reservations pertaining to the accession to the throne, nobility, abortion and same-sex marriage. Progress had stalled due to public protest, particularly by women religious leaders associated with the church. In February 2017, the then Prime Minister called for public consultations on ratification with the participation of local women’s groups, given that the country was divided over the subject.

    Stakeholder Summary:
    Para 3) JS1 highlighted that Tonga had not ratified the following instruments: the CEDAW and its OP, … ICESCR; and the ICCPR and its OP …
    Para 7) JS1 reported that in 2015, the Government of Tonga had stated at the 59th session of the Commission on the Status of Women in New York that it was ready to commence the process of ratifying CEDAW. However, a decision by the King in Privy Council put on hold the process, claiming that the decision of the Government to ratify CEDAW contradicted Clause 39 of the Constitution, which stipulated that only the King could make treaties.

  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Thailand

    Thailand
    Regional group
    Asia-Pacific Group
    Political group
    ASEAN
    Issue:
    • Gender equality
    Type:
    Recommendation
    Session:
    15th session, February 2013
    Status:
    Accepted
    Contents:
    Further develop concrete measures or steps to expand the representation of women in Government and Parliament as well as to other decision-making positions, as appropriate.
    Implementation
    National Report:
    Para 46) Tonga has continued to make commitments on the international, regional and national level to improve women’s political participation.
    Para 47) Tonga is committed to Sustainable Development Goal 5 to achieve gender equality and empower all women and girls.
    Para 48) 16 of 106 candidates for the 2014 General Elections were women, despite the high number of women, none were successful in the elections.
    Para 49) However, after a Supreme Court ruling in January 2016 one of the members of Parliament was forced to vacate his seat. This led to a by-election in July 2016 that resulted in a female candidate being elected into Parliament.
    Para 50) The November 2017 Elections has a total of 86 candidates, where 15 of those candidates are women.
    Para 54) The Tongan Government introduced the Tonga Strategic Development Framework 2015-2025 in 2015 and one of the seven national outcomes is for a more inclusive sustainable and empowering human development with gender equality. This is supported by the following Organisational Outcomes under the Social Pillar: (a) improve gender equality by implementing the government’s gender development policy and ensuring a more balanced and effective engagement by both men and women in decision making and social, economic and political institutions (OO2.1e); …
    Para 62) In 2014, the Legislative Assembly held the first ever Practice Parliament for Women in Tonga. This event was to increase the potential of women to become effective political leaders. It was to encourage and empower women to achieve their potential as leaders. This was supported by the United Nations Development Programme (UNDP).
    Para 65) The Tonga Revised National Policy on Gender and Development identified six Gender Equity Issues in Tonga namely: • … Unequal Political Representation and Participation in Decision-Making; …

    UN Compilation:
    Para 11) The United Nations country team reported that … in 2014, the Government introduced the revised national policy on gender and development, which focused on promoting equal access, participation and distribution of the benefits of the development process for all women, men and children. However, such measures had yet to be fully implemented.
    Para 43) The United Nations country team emphasized that the representation of women in the Legislative Assembly remained extremely low, with currently only one woman representative.

    Stakeholder Summary:
    Para 35) The low participation of women across the decision-making spectrum was of concern to JS1. Whilst there had been an increase in female appointed chief executive officers to government ministries, the appointment of women to the highest decision- making positions remained, in most places, stagnant. JS1 stated that, for example, there had been no women appointed judges since the last review, no female cabinet members and only one female in the Parliament following a bye-election in June 2016. In recognition of the Sustainable Development Goal 5.5, Parliament had approved a motion for two reserved seats for women. However, JS1 expressed concern that such a number (representing seven percent of the total number of parliamentarians) was low compared to UN standards and best practices. …JS1 noted that in June 2017, the King had invested a female as a Law Lord, which was deemed to have been a big step forward for women.
    Para 36) According to JS1, the Electoral Boundaries Commission Act 2010 under which the Kingdom had been divided into 17 electoral constituencies – with one seat allocated per constituency – did not favour women candidates as it made it more difficult for women to compete with male candidates. It was even more difficult when there was a lack of support from political parties for women candidates.

  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    United States

    United States
    Regional group
    WEOG
    Political group
    OAS
    Issue:
    • Criminal laws on same-sex sexual practices
    Type:
    Recommendation
    Session:
    15th session, February 2013
    Status:
    Rejected
    Contents:
    Repeal the provisions of the Tongan Criminal Offences Act criminalizing consensual sex between adults of the same gender.
    Explanation
    The de-criminalisation of consensual sex between same sex adults is an issue that Tonga still wishes to consider further, through robust and comprehensive dialogue with a vast group of stakeholders. Whilst there is no doubt that such consensual adults are recognised and accepted as established members of the community, their lifestyle remains an issue to be further considered. Such dialogue will have to be conducted against the context of Tonga's embedded conservative Christian values, and also well established criminal policy that prohibits against the act of sodomy when it is committed between different sexes in a malicious and violent manner. Tonga however wishes to record that it has not yet prosecuted any same sex adults for committing the act of sodomy, and so far, the criminal prosecutions for sodomy have only been restricted in the context of criminal offending, rather than against consensual same sex partners.
    Implementation
    National Report Annex:
    Not implemented.

    UN Compilation:
    Para 12) The United Nations country team noted that the Criminal Offences Act (1988) still criminalized same-sex sexual relations between consenting adults and carried a maximum penalty of 10 years’ imprisonment and, at the court’s discretion, the use of corporal punishment. The 1988 Constitution of Tonga, while containing a declaration of rights that provided for equality before the law (clause 4), did not refer to freedom from discrimination, nor did other laws exist ensuring protection from discrimination on grounds of sexual orientation and gender identity.

  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    UN Compilation

    Issue:
    • Gender equality
    Type:
    Review Documentation
    Session:
    15th session, February 2013
    Status:
    Neglected
    Contents:
    RO Pacific underlined that economic empowerment of women faced persistent challenges, with gender wage gaps, low women employment rates in the formal economy, and few women in senior management positions in the public and private sectors. [Para 21]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Stakeholder Summary

    Issue:
    • International human rights instruments
    Type:
    Review Documentation
    Session:
    43rd Session, May 2023
    Status:
    Reference Addressed
    Contents:
    Joint Submission 1 (JS1) recommended that Tonga consider ratifying the OPs-CRC and the OP-CEDAW. [Para 2]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Stakeholder Summary

    Issue:
    • International human rights instruments
    Type:
    Review Documentation
    Session:
    43rd Session, May 2023
    Status:
    Not Followed up with a Recommendation
    Contents:
    JS1 also recommended that Tonga ratify the 2000 Protocol to Prevent, Suppress and Punish Trafficking in Persons Especially Women and Children, supplementing the United Nations Convention against Transnational Organized Crime and consider revising the Transnational Crimes Act to ensure protecting the rights of victims of trafficking. [Para 5]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Turkey

    Turkey
    Regional group
    WEOG
    Political group
    OIC
    Issue:
    • International human rights instruments
    Type:
    Recommendation
    Session:
    29th Session, January 2018
    Status:
    Unclear Response
    Contents:
    Ratify the ICESCR.
    Explanation
    Noted. Tonga is committed to ensuring that it ratifies all core international human rights conventions to promote and protect the rights of its citizens. Tonga will consider acceding to the conventions, in accordance with its domestic processes. Notwithstanding the fact that Tonga is not yet a member of these conventions, many of the underlying human rights principles enshrined in core human rights conventions, already form the basis for many Tongan laws.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Mozambique

    Mozambique
    Regional group
    Africa Group
    Political group
    AU
    OIC
    Commonwealth
    Issue:
    • International human rights instruments
    Type:
    Recommendation
    Session:
    29th Session, January 2018
    Status:
    Unclear Response
    Contents:
    Consider withdrawing reservations to the CEDAW as well as setting up the National Human Rights Commission, in light of Paris Principles.
    Explanation
    Noted. Tonga is committed to ensuring that it ratifies all core international human rights conventions to promote and protect the rights of its citizens. Tonga will consider acceding to the conventions, in accordance with its domestic processes. Notwithstanding the fact that Tonga is not yet a member of these conventions, many of the underlying human rights principles enshrined in core human rights conventions, already form the basis for many Tongan laws. On the issue of ratification of the CEDAW, Tonga had announced that it was ready to ratify the Convention at the fifty-ninth session of the Commission on the Status of Women, held at United Nations Headquarters on 12 March 2015. However, due to public protests, Tonga had had to defer the ratification process for further consultation. Through targeted and strategic consultations, Tonga continued to move towards ratification. In addition, the underlying principles of the Convention were being addressed through projects linked to the commitments of Tonga to the 2030 Agenda for Sustainable Development. For Tonga, the ratification of the CEDAW was an ongoing process and represented a generational change.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Montenegro

    Montenegro
    Regional group
    EEG
    Issue:
    • Criminal laws on same-sex sexual practices
    Type:
    Recommendation
    Session:
    29th Session, January 2018
    Status:
    Unclear Response
    Contents:
    Enact a new legislation or amend existing laws with a view to decriminalize same-sex relations between consenting adults.
    Explanation
    Noted. The main recommendations under this theme were to: eliminate all discriminatory treatment related to sexual orientation or gender identity, and the decriminalising of same-sex consensual sex. Tonga has no national policies or regulation which condone discrimination against sexual orientation and gender identity. The Government continues to support the work of the ‘Tonga Leiti Association’ (TLA) which advocates for the rights of people with different sexual orientation or gender identity and celebrates their contribution to Tongan society in entertainment, sport and business. Through government grants, the TLA has received assistance for the refurbishment of their office quarters and the provision of a vehicle to help improve their public awareness and advocacy outreach. The decriminalisation of consensual sex between same sex adults is an issue that Tonga still wishes to consider further. It requires thorough, robust and comprehensive dialogue against the backdrop of cultural sensitivities and conservative Christian values of the Tongan society.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Italy

    Italy
    Regional group
    WEOG
    Political group
    EU
    Issue:
    • Early marriage
    Type:
    Recommendation
    Session:
    29th Session, January 2018
    Status:
    Accepted
    Contents:
    Take steps to end child marriages by raising to 18 the minimum age of marriage for both boys and girls.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Argentina

    Argentina
    Regional group
    GRULAC
    Political group
    OAS
    OEI
    Issue:
    • Early marriage
    • Sexual violence
    • Women's and / or girls' rights
    Type:
    Recommendation
    Session:
    29th Session, January 2018
    Status:
    Accepted
    Contents:
    Take the necessary measures to modify the national legislation to increase the legal minimum age for marriage, as well as to raise awareness of deeply rooted attitudes and stereotypes, in particular by investigating and sanctioning cases in which girls are forced to marry children with whom they have been seen or even with their rapists.
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    Stakeholder Summary

    Issue:
    • International human rights instruments
    Type:
    Review Documentation
    Session:
    29th Session, January 2018
    Status:
    Reference Addressed
    Contents:
    … In this regard, JS1 underscored that a judicial review was needed to clarify such
    claim [the decision of the Government to ratify CEDAW contradicted Clause 39 of the Constitution, which stipulated that only the King could make treaties] in order for the Government to move forward with the ratification of CEDAW. [Para 7]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    UN Compilation

    Issue:
    • Early marriage
    • Maternal health / morbidity / mortality
    • Marital rape
    • Violence against women / gender-based violence
    • Domestic violence
    • Adolescent pregnancy
    Type:
    Review Documentation
    Session:
    29th Session, January 2018
    Status:
    Not Followed up with a Recommendation
    Contents:
    The UN country team stressed that ... Girls were often forced by their parents to marry and in certain cases teenage pregnancy was involved. ... That situation had left many children, particularly girls, exposed to early pregnancy, thereby putting their and their babies’ health at risk, even resulting in death at times. [Para 46] The UN country team added that this situation had also resulted in an increased risk of domestic violence, including marital rape and emotional abuse, as well as children leaving school early, which deprived them of their right to education. [Para 47]
  • State Under Review:

    Tonga

    Tonga
    Regional group
    Asia-Pacific Group
    Political group
    PIF
    Commonwealth
    Source Of Reference:

    National Report

    Issue:
    • Gender equality
    • Women's participation
    Type:
    Review Documentation
    Session:
    2nd session, May 2008
    Status:
    N/A
    Contents:
    Women outnumber men in educational achievement at primary, secondary and tertiary level. Leadership positions in business and government, including those of Governor of the Reserve Bank, Permanent Representative to the United Nations, Ambassador to the People's Republic of China, Attorney General and Solicitor General are all held by women. Despite women's powerful position in Tongan social structure and despite the opportunities for education and advancement there are issues to be addressed. [Para 66]