Right to Housing (Articles 14, 16 and 18(1)) 77. In SERAC & CESR v Nigeria, the Commission held that, although the right to housing or shelter is not explicitly provided for under the African Charter, housing rights are protected through the combination of provisions protecting the right to property (art 14), the right to enjoy the best attainable standard of mental and physical health (art 16), and the protection accorded to the family (art 18(1)). 78. The human right to adequate housing is the right of every person to gain and sustain a safe and secure home and community in which to live in peace and dignity. xxvii It includes access to natural and common resources, safe drinking water, xxviii energy for cooking, heating, cooling and lighting, sanitation and washing facilities, means of food storage, refuse disposal, site drainage and emergency services. 79. The right to housing imposes, amongst others, the following obligations on States parties to: Minimum Core Obligations a. Refrain from and protect against forced evictions from home(s) and land, including through legislation.xxix All evictions must be carried out lawfully and in full accordance with relevant provisions of national and international human rights and humanitarian law.xxx States should apply appropriate civil or criminal penalties against any public or private person or entity within its jurisdiction that carries out evictions in a manner inconsistent with applicable national and international law, including due process. b. Guarantee to all persons a degree of security of tenure which confers legal protection upon those persons, households and communities currently lacking such protection, including all those who do not have formal titles to home and land, against forced evictions,xxxi harassment and other threats. c. Ensure at the very least basic shelter for everybody National Plans, Policies and Systems d. Carry out comprehensive reviews of relevant national legislations and policies with a view to ensuring their conformity with international human rights provisions. Such reviews should also ensure that existing legislation, regulation and policy address the privatization of public services, inheritance and cultural practices, so as not to lead to, or facilitate forced evictions. e. Implement housing programmes, including subsidies and tax incentives, to expand housing construction to meet the needs of all categories of the population, particularly low-income families; f. Prioritise in national plans and policies the provision of shelter for all persons in desperate need of emergency housing; 40