The only 53 Commissioner for Human Rights of the Council of Europe, Report following her visit to the United Kingdom from 27 June to 1 July 2022, CommDH(2022)27, https://rm.coe.int/report-on-the-visit-to-united-kingdom-from-27-june- to-1-july-2022-by-d/1680a952a5; par. 54. 54 Commissioner for Human Rights of the Council of Europe, Report following her visit to the United Kingdom from https://rm.coe.int/report-on-the-visit-to-united-kingdom-from-27-june- 27 June to 1 July 2022, CommDH(2022)27, to-1-july-2022-by-d/1680a952a5; par. 54. 11 connection between undue obstacles to legal recognition for trans women and freedom of all women from gender and sexual-based violence is based on an erroneous perception of trans women as being males and, specifically, predatory males.