59. The Complainants also submit that the right to life is also enshrined in Section 33 (1) of the Nigerian Constitution and in international human rights instruments that Nigeria has ratified. They conclude that the right to life requires States to take measures to protect individuals from arbitrary and avoidable loss of life and that this right should not be interpreted in a restrictive manner. Violation of the right to health and sexual and reproductive health 60. The Complainants avow that Nigeria's per capita spending on health is USD 72, one of the lowest in the world. They add that despite Nigeria's commitment in the 2001 Abuja Declaration to allocate at least 15% of its annual budget to improving the health sector, the Nigerian government has failed miserably to meet this commitment. They claim that, on the contrary, the budget allocation to the health sector has continued to be around 5-6%. According to the Complainants, for a country endowed with so many natural resources, low spending on health, including maternal health, is not only unacceptable, but the failure of the Nigerian Government to reduce preventable maternal injuries and deaths is a violation of the right to health. . 61. The Complainants consider that the riglit to health, fully guaranteed by Article 16 of the African Charter, requires States to ensure the right to health of every individual by taking the necessary measures to protect the health of their populations and ensuring that this includes access.to medical care in the event of illness. Relying on previous decisions of the Commission, the Complainants insist that African.governments should ensure the provision of adequate health care services to all women, particularly poor women and those living in rural areas. 62. In their' submissions, the Complainants also refer to the Commission's Concluding ()p;;er;ation~ ()p. Nigeria's 5th Periodic Report where it expressed concern aboiif t1;1e"']ackof "a legal framework for health in Nigeria that clearly defines the roles and responsibilities of health professionals, as well as the oversight responsibilities of Government in the health sector as a whole. The Commission therefore recommended the establishment of a comprehensive legal framework to address these issues. )" 63. 11