18 doctrine, is inadmissible. This reasoning is unsound since it would suffice for the perpetrators of a forced disappearance to hide or destroy a victim's body, which is frequent in such cases, for there to be total impunity for the criminals, who in these situations attempt to erase all traces of the disappearance. 74. With regard to disappearances, the foregoing is reinforced by the statements of the expert Dr. Enrique Bernales-Ballesteros, during the public hearing, which the State did not refute, to the effect that when the events in this case occurred the forces of law and order had the practice of forced disappearances of persons considered to be members of subversive groups; he presented statistics on the increase of such disappearance during that period (supra, para. 42). XII 75. In its petition, the Commission alleged that the State had violated Article 8 of the Convention with "regard to the right of Castillo-Páez and his family to defend their rights through a lawyer." 76. In that regard, the Commission pointed out that an attempt had been made on the life of the attorney of the victim's family, Dr. Augusto Zúñiga-Paz, obliging him to withdraw from the defense and be replaced by the legal team of the Institute of Legal Defense of the Human Rights Commission of Peru. 77. The above-mentioned attorney, Augusto Zúñiga-Paz, in his statement before this Court, affirmed that on June 15, 1991 (March 15, 1991, according to the file) he was attacked by means of an envelope containing explosives which caused him serious injury and that this attack was made because of his defense in a number of cases, including the case concerning the detention of Mr. Castillo-Páez, which led him to cease his legal representation of the relatives; he was forced to leave the country and is currently living in Sweden (supra, para. 30.e.). 78. What is not clear, nor is there any evidence to prove it, is that the attack was intended specifically to deprive the victim's family of legal defense, inasmuch as the witness himself said that he was assisting various persons, and that he was involved in an accusation against the former President of Peru, Mr. Allan García-Pérez. 79. At the same time, it is recorded that the victim's relatives received legal assistance in order to file the remedy of habeas corpus and the corresponding criminal case, so that the relatives were not deprived of legal defense, although in exercising it they did encounter difficulties [not directly linked to this Case] which, in the Court's view, do not constitute a violation of Article 8 of the Convention, inasmuch as other lawyers took over the defense. XIII 80. As regards the violation of Article 25 of the Convention concerning judicial protection, the parties adduced the following arguments: a. In its application, the Commission considered that the right enshrined in that article obliges the State to provide effective recourse and that this duty "was violated by Peru through several actions taken by the State that prevented [Mr. Castillo-Páez from being set free] and ultimately caused the crimes to go unpunished." In support of this argument, the Commission invoked the judgment of August 19, 1991, in which the Fourteenth Criminal Court of the Lima Judicial District referred to the