Several organizations, such as World Health Organization (WHO) and Human Rights Watch prioritize women's reproductive rights over fetal rights. Under European law, fetus is generally regarded as an in utero part of the mother and thus its rights are held by the mother. The European Court of Human Rights opined that the right to life does not extend to fetuses under Article 2 of the European Convention on Human Rights (ECHR). In "H. v. Norway", the European Commission did not exclude that "in certain circumstances" the fetus may enjoy "a certain protection under Article 2, first sentence". Three European Union member states (Ireland, Hungary and Slovakia) grant the fetus the constitutional right to life. The Constitution of Norway grants the unborn royal children the right of succession to the throne. In English common law, fetus is granted inheritance rights under the born alive rule. Islamic law grants the fetus the right to life particularly after ensoulment, which according to various Islamic jurists happens after 40–42 days or four months after conception (some Shiite jurists believe the ensoulment occurs after 11 to 14 days, during the implantation of the fertilized egg in the uterine wall). Both the Sunni and Shiite jurists accord the fetus inheritance rights under two conditions: if a man dies and a pregnant wife survives him, the fetal right to inherit is secure and the inheritance cannot be disposed of before the fetus' share is set aside. Under the second condition, if a woman aborts the fetus at any stage and ignores any vital signs, the fetus is entitled to the inheritance of any legitimate legator who dies after its conception. The legal debate on fetal rights sometimes invokes the notion of fetal viability. Its primary determinant is fetal lung capacity which typically develops at twenty-three to twenty-four weeks. The twenty-three weeks is usually regarded as the lower bound of fetal viability because technology has been unable to surpass the limit set by lung development. It was nonetheless stated that technology has made it possible to regard the fetus as a patient independent of the mother. In "Winnipeg Child and Family Services v. G.", the judges argued that "technologies like real-time ultrasound, foetal heart monitors and foetoscopy can clearly show us that the foetus is alive" and thus the born alive rule is "outdated and indefensible". The creation of human embryos for all research purposes is prohibited by the Convention for the Protection of Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine.