return and permanence of those affected, were implemented without any type of negative discrimination based on race or any other condition of the affected population.” B. Considerations of the Court 315. This Court has indicated in other cases that, owing to the complexity of the phenomenon of internal displacement and the broad range of human rights it affects or jeopardizes, and based on the circumstances of special vulnerability and defenselessness in which those displaced usually find themselves, their situation can be understood as a de facto situation of lack of protection.561 According to the American Convention, this situation obliges the States to adopt measures of a positive nature to reverse the effects of their said situation of weakness, vulnerability and defenselessness, even in relation to the actions and practices of private third parties.562 316. The Colombian Constitutional Court has referred to the situation of vulnerability of the displaced as follows: “owing to the circumstances that surround internal displacement, the persons […] who are obliged ‘to abandon their place of residence and their usual economic activities hastily, and migrate to another place within the borders of national territory’ in order to flee from the violence generated by the internal armed conflict and by the systematic disregard for human rights or international humanitarian law, are exposed to a much greater degree of vulnerability, which entails a gross, massive and systematic violation of their fundamental rights and, for the same reason, warrants granting special attention from the authorities. Those displaced by the violence are in a situation of weakness that makes them deserving of special treatment by the State.”563 317. Similarly, the Constitutional Court has indicated that the vulnerability of the displaced is accentuated by their rural origins and, in general, has a particularly intense effect on women who are heads of household and represent more than half the displaced population. Internal displacement also creates a security crisis, because the groups of internally displaced become a new source or resource for recruitment by paramilitary, drug-trafficking and guerrilla groups. 564 Among the many adverse effects of the resettlements resulting from the internal forced displacement, in many cases, the return home of the displaced is carried out without the necessary conditions of security and dignity for them.565 In addition to the severe psychological effects, the following have been stressed: (a) loss of land and dwelling; (b) marginalization; (c) loss of home; (d) unemployment; (e) deterioration in living conditions; (f) increase in diseases and in mortality; (g) loss of access to property; (h) food insecurity, and (i) social dislocation, impoverishment, and an accelerated deterioration of living conditions.566 318. As verified in other cases, the Court takes note that, in order to deal with the problem of internal displacement, Colombia has taken a series of measures567 at the legislative level 561 Cf. Case of Chitay Nech et al. v. Guatemala, para. 141. 562 Cf. Case of the Mapiripán Massacre v. Colombia, para. 179, and Case of the Río Negro Massacres v. Guatemala, para. 174. 563 Cf. Colombian Constitutional Court, Judgment T-025 of January 22, 2004 (evidence file, folios 4363 and ff.). See also: Case of the Ituango Massacres v. Colombia. Preliminary objection, merits, reparations and costs, para. 211. 564 Cf. United Nations, Economic and Social Council, Report of the Special Rapporteur on adequate housing as a component of the right to an adequate standard of living, and on the right to non-discrimination in this context, E/CN.4/2005/48, 3 March 2005, para. 38. Also, Case of the Mapiripán Massacre v. Colombia, para. 175, and Case of the Ituango Massacres v. Colombia. Preliminary objection, merits, reparations and costs, para. 212. 565 Cf. United Nations, Report of the United Nations High Commissioner for Human Rights on the situation of human rights in Colombia, E/CN.4/2003/13, 24 February 2003, para. 94 (evidence file, folio 3717). 566 Cf. Case of the Mapiripán Massacre v. Colombia, para. 175, and Case of the Ituango Massacres v. Colombia. Preliminary objection, merits, reparations and costs, para. 213. 567 Cf. Colombian Constitutional Court, Judgment T-025 of January 22, 2004 (evidence file, folios 897 and ff.), and its follow-up rulings, including Ruling 005 of January 26, 2009, on protection of the fundamental rights of the Afro- 106