111 the impunity prevailing in the case, a situation that did not allow them to return. This set of facts denied the members of the community who had been displaced within the territory of the State, as well as those who were in exile in French Guiana, their rights to freedom of movement and of residence, for which reason the Court found the State responsible for abridgment of Article 22 of the Convention to the detriment of the members of that community.231 171. The Court deems that to define the content and scope of Article 22 of the Convention in a context of domestic displacement, the content of the Guiding Principles on Internal Displacement issued in 1998 by the Representative of the Secretary General of the United Nations is especially significant.232 172. Furthermore, the regulations on displacement included in Protocol II to the 1949 Geneva Conventions are also especially useful to apply the American Convention to the situation of domestic armed conflict in Colombia. Specifically, Article 17 of Protocol II prohibits ordering the displacement of civilian population for reasons related to the conflict, unless this is required by the safety of civilians or for imperative military reasons, and in the latter case “all possible measures shall be taken in order that the civilian population may be received under satisfactory conditions of shelter, hygiene, health, safety and nutrition.” In this regard, in a 1995 judgment, the Constitutional Court of Colombia deemed that “in the Colombian case, application of these rules by the parties in conflict is also especially imperative and important, because the country’s armed conflict has severely affected the civilian population, as shown by the alarming data on forced displacement of persons.”233 173. The facts of the instant case are set within a widespread situation of forced internal displacement in Colombia, caused by the domestic armed conflict. As pointed out above, this problem, which current dynamics began in the 1980s, has been worsening and currently affects a population of 1.5 to 3 million displaced persons (supra para. 96.57). 174. The Court notes that the phenomenon of internal displacement and its consequences have been widely analyzed from various standpoints. Recently, the Constitutional Court of Colombia issued a comprehensive ruling in which it addressed the actions for protection of constitutional rights filed by 1150 displaced families, primarily female heads of households, elderly people, and minors, as well as some indigenous families. In this judgment, it referred to said situation of vulnerability of the displaced population as follows: […] due to the circumstances of internal displacement, those persons […] who are forced to “abruptly leave their place of residence and their customary economic activities, having to migrate elsewhere within the national territory” to flee the violence stemming from the domestic armed conflict and due to systematic disregard for human rights or for international humanitarian law, they are subject to a much higher level of vulnerability, which entails a grave, massive and systematic violation of their basic rights and, therefore, the authorities should pay special attention to it: “Persons displaced by violence are in a situation of weakness that merits special treatment by the State.” Along these same lines, the Court has asserted “the need to direct the State’s political agenda toward solving the problem of internal displacement and the duty of 231 See Case of the Moiwana Community, supra note 4, paras. 107 to 121; likewise see Case of Ricardo Canese, supra note 185, paras. 113 to 120. 232 See United Nations Guiding Principles on Internal Displacement, E/CN.4/1998/53/Add.2 of February 11, 1998. Also see Case of the Moiwana Community, supra note 4, paras. 113 to 120. 233 See judgment C-225/95 of May 18, 1995, issued by Constitutional Court, para. 33.