Article 23 has unusual status within the Covenant, prompting Nowak to describe it as ‘the most prominent provision in the Covenant containing an institutional guarantee i.e. protection of a status under private law as a human right’. Although Article 23 protects the family unit, it is no less a human right in the hands of the individual. It bears some similarity to Article 17, which protects against unlawful or arbitrary interference with a person’s family, but serves a distinct purpose. Commenting on the distinction between the two provisions, Fernando Volio noted that ‘Article 17 took account of the family and provided for the privacy of its members. It underscored the importance of this particular human grouping and reinforced its unique solidarity.