(restitutio in integrum), that is, restoring the situation as it was prior to the harm caused by the
breach of an international obligation and redressing the consequences that the breach caused, as
well payment of damages.12
8.
Thus, the concept of “comprehensive redress” has shaped the development of reparation
measures. This stems from the recognition that human rights violations have a multitiered impact
on victims13, and redress must therefore be oriented not only toward redressing the rights that were
infringed, but also providing comprehensive compensation and repair for the damage caused 14 and
thus restoring the individuals’ dignity, the quality of their lives, and the well-being and peace of mind
they had before the violations. For serious human rights violations, this holds paramount
importance.15
9.
Using this perspective, the Court has found it necessary to order a range of measures, and
the specific forms of redress vary according to the injury caused. 16 Thus, in addition to awarding
measures of restitution and pecuniary compensation dating back to its first judgment on
reparations,17 a shift began in 2001, and measures of satisfaction and guarantees of non-recurrence
took on particular significance as a means to ensure that the acts that constituted human rights
violations, so adjudged by the Inter-American Court, not be repeated and to reverse their
consequences. Over the years the Court has ordered: (a) investigation of the facts that produced the
violations, and when relevant, to identify, prosecute and sanction those responsible; 18 (b) restoration
of rights, goods and freedoms; 19 (c) rehabilitation, by means of medical, psychological and/or
reparaciones y efectos de las Sentencias" in García Roca, Javier, Fernández, Pablo Antonio, Santolaya, Pablo y Canosa, Raúl
(Editors), El Diálogo entre los Sistemas Europeo y Americano de Derechos Humanos, Thomson Reuters-Civitas, Pamplona,
2012, pp. 447 and 448.
12
I/A Court HR. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs. Judgment of July 21, 1989. Series
C No. 7, para. 26.
Cf. I/A Court HR. Case of the Pueblo Bello Massacre v. Colombia. Merits, Reparations and Costs. Judgment of January
31, 2006. Series C No. 140.
13
I/A Court HR. Case of the Río Negro Massacres v. Guatemala. Preliminary Objection, Merits, Reparations and Costs.
Judgment of September 4, 2012. Series C No. 250, para. 248; Case of the Santo Domingo Massacre v. Colombia. Preliminary
Objections, Merits and Reparations. Judgment of November 30, 2012. Series C No. 259, para. 292, and Case of the Massacres
of El Mozote and surrounding areas v. El Salvador. Merits, Reparations and Costs. Judgment of October 25, 2012. Series C
No. 252, para. 305.
14
Cf., inter alia, I/A Court HR. Case of the Mapiripán Massacre v. Colombia. Merits, Reparations and Costs. Judgment
of September 15, 2005. Series C No. 134, para. 294; Case of the Massacres of El Mozote and surrounding areas v. El Salvador.
Merits, Reparations and Costs, supra, para. 305; Case of the Las Dos Erres Massacre v. Guatemala. Preliminary Objection,
Merits, Reparations and Costs. Judgment of November 24, 2009. Series C No. 211, para. 226, and Case of Rochac Hernández
et al. v El Salvador. Merits, Reparations and Costs. Judgment of October 14, 2014. Series C No. 285, para. 177.
15
I/A Court HR. Case of Garrido and Baigorria v. Argentina. Reparations and Costs. Judgment of August 27, 1998.
Series C No. 39, para. 41, and Case of Blake v. Guatemala. Reparations and Costs. Judgment of January 22, 1999. Series C
No. 48, para. 31.
16
17
I/A Court HR. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, para. 25.
Cf., inter alia, I/A Court HR. Case of Velásquez Rodríguez v. Honduras. Reparations and Costs, supra, paras. 32 to
35; Case of El Amparo v. Venezuela. Reparations and Costs. Judgment of September 14, 1996. Series C No. 28, para. 61 and
operative paragraph 4, and Case of Espinoza Gonzáles v. Peru. Preliminary Objections, Merits, Reparations and Costs.
Judgment of November 20, 2014. Series C No. 289, para. 309 and operative paragraph 10.
18
Cf., inter alia, I/A Court HR. Case of Loayza Tamayo v. Peru. Merits. Judgment of September 17, 1997. Series C No.
33, operative paragraph 5; Case of Loayza Tamayo v. Peru. Reparations and Costs. Judgment of November 27, 1998. Series
C No. 42, operative paragraphs 1 to 3, and Case of expelled Dominicans and Haitians v. Dominican Republic. Preliminary
Objections, Merits, Reparations and Costs. Judgment of August 28, 2014. Series C No. 282, paras. 452 to 457.
19
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