11 52. For its part, the Archdiocese of Guatemala’s Recovery of Historical Memory Project (hereinafter “REMHI”)32 documented the following: Although these massacres will never be fully explained […], the Army offensive, the progression of massacres, and their internal structure obey a certain logic […]. They were not merely spontaneous reactions by soldiers or officers. In order to isolate the guerrillas, the Army launched a series of large-scale indiscriminate massacres against their civilian support base. The Army routed these civilians out of their hiding places in the hills and forests; it terrorized them; it laid siege to them to starve them out, after having burned their homes and stored crops, destroyed their household utensils, and stole their belongings. In this way, people were forced to surrender and subsequently clustered into “special camps”. This practice of massacres, 33 pursuit, burning and siege is known as the scorched-earth policy. 53. 1982 was a year of transition from selective to indiscriminate repression.34 As documented by the CEH, the perpetrators committed slaughters targeting all members of a community, without making any distinction between those who participated directly in the hostilities and those who had no link or contact with the guerrilla movement at all.35 54. Furthermore, the survivors of the massacres were subjected to harsh conditions in the process of forced displacement, which included being pursued by the perpetrators.36 In its second special report from 1983, titled “The Situation of Human Rights in Guatemala”, the IACHR documented the massive displacement triggered in Guatemala as a result of the large-scale repression in 1981 and 1982.37 The CEH, for its part, wrote that: The magnitude of the institutional violence to which Guatemala’s civilian population was subjected during the armed conflict is amply demonstrated by the phenomenon of forced displacement. Estimates are that between 500 thousand and one and a half million Guatemalans 38 were forced to flee as a direct consequence of the repression, particularly during the 1980s. 1.2.4. Forced disappearance of persons 55. The practice of forcibly disappearing persons during Guatemala’s armed conflict was part of the counterinsurgent strategy, targeted at apprehending and exterminating masses of people, without leaving any evidence of their fate or whereabouts. The case law of the Inter-American Court found that forced disappearance was a Guatemalan State practice perpetrated mainly by agents of the 32 Annex 4. Project headed by the Human Rights Office of the Archdiocese of Guatemala (ODHAG). The Report of the REMHI Project was published in 1998, under the title “Guatemala: Never Again!” Available [in Spanish] at: http://www.derechoshumanos.net/lesahumanidad/informes/guatemala/informeREMHI.htm. 33 Annex 4. REMHI. Guatemala: Never Again! The Report of the Recovery of Historical Memory Project. Volume II, The Methodology of Horror. 34 Annex 4. REMHI. REMHI. Guatemala: Never Again! The Report of the Recovery of Historical Memory Project. Volume II, The Methodology of Horror. 35 Annex 1. CEH, Memory of Silence, Volume V, Conclusions and Recommendations, par. 131. 36 Annex 1. CEH, Memory of Silence, Volume V, Conclusions and Recommendations, paragraphs 65-67 37 IACHR, Third Report on the Situation of Human Rights in the Republic of Guatemala, OEA/Ser.L/V/II.66, approved on October 3, 1985 [available only in Spanish]. 38 Annex 3. CEH, Memory of Silence, Volume III, Human Rights Violations and Acts of Violence, par. 2951.