According to Article 23(2) of the International Covenant on Civil and Political Rights, the right of men and women of marriageable age to marry and found a family should be recognised. Traditionally, the right to marry and found a family is reserved for heterosexual couples only. This view is embodied in the 2002 United Nations Communication of Joslin v New Zealand. In 2013, same-sex marriage in New Zealand became legal. Nevertheless, Joslin is still being cited elsewhere by anti-same-sex marriage campaigners and lawyers globally.