4 10. By a favourable confluence of factors, the Inter-American Court at last succeeded, in the present Judgment of reparations in the Trujillo Oroza case, to establish an important precedent for the consideration of the delict of forced disappearance of persons and the corresponding reparations. To attempt to "individualize" or to "separate" the facts of a case such as that of Trujillo Oroza would lead to an undue fragmentation and decharacterization of that delict9, with negative consequences not only for the victims and their relatives, but also, ultimately, for the legal regime itself of the international protection of the rights of the human being. 11. The same attention paid by the Court to the integrality of the continuing situation of the forced disappearance of the victim, in its Judgment as to the merits in the Trujillo Oroza case, applies likewise to its present Judgment on reparations. The American Convention stipulated that when the Court decides that there was a violation of a right protected by such Convention, the Court shall rule that "the consequences of the measure or situation which constituted the breach of that right be remedied" (Article 63(1)). There is, thus, a clear and ineluctable link of causality between the establishment of the violations of human rights under the American Convention and the reparations due as a consequence of such violations, which may occur by a continuing situation. 12. The concept of continuing situation finds support in the international case-law in the matter of human rights, as I indicated, with details, in my Separate Opinion in the aforementioned Blake case (merits, 1998, par. 11), to which I allow myself here to refer10. In fact, both the European Court of Human Rights and the Human Rights Committee (under the United Nations Covenant on Civil and Political Rights), e.g., have assumed jurisdiction in cases in which, although the facts have started before the entry 9 . In this respect, in one of my Separate Opinions in the case Blake versus Guatemala (Reparations, 1999), I criticized the artificiality of having the application - in the circumstances of that case - of a classic postulate of the law of treaties (pertaining to the competence ratione temporis of the Court) unduly fragmented and decharacterized the delict of forced disappearance of persons (pars. 3 and 36). This decomposition, - I added, - was "endowed with an anti-historical character, in the sense that it points to the direction opposite to the contemporary doctrinal and jurisprudential development tending towards the consolidation of a true international legal regime against grave violations of human rights" (párr. 45). 10 . Besides the case-law quoted therein, one can add other examples, more recent ones. In its judgment of 10.05.2001, in the case Cyprus versus Turkey, e.g., the European Court of Human Rights established a "continuing violation" of Articles 2 (right to life) and 5 (right to personal freedom) of the European Convention, given the absence of an effective investigation, on the part of the public power, in order to clarify the whereabouts of the disappeared Greek-Cypriot persons (par. 136), who were allegedly under custody when they disappeared (par. 150); it also established "continuing violations" of Articles 3 and 8 of the Convention (pars. 158 and 175), as well as of Article 1 of Protocol n. 1 to the Convention (pars. 189 and 269-270). - The Human Rights Committee (under the Covenant on Civil and Political Rights of the United Nations), on its turn, in the case Ivan Somers versus Hungary (1996), e.g., in declaring the petition or communication admissible (as to the issues under Article 26 of the Covenant), confirmed its constant position in the sense that if cannot consider alleged violations of the Covenant that occurred before the entry into force of it (and its first Protocol) for the State Party at issue, except if the alleged violations continue to occur after such entry into force; the Committee added that "a continuing violation must be interpreted as an affirmation, by act or clear implication, of the previous violations of the State Party" (par. 6.3). In the case E. and A.K. versus Hungary (1994), despite having declared the communication inadmissible, the Committee applied the same criterion for the determination of the existence of a "continuing violation" of the Covenant (cf. par. 6.4).