victim “remains missing, and no specific hypothesis has been offered with respect to her identity.” The note goes on to state: [The] case [of Ms. Grisonas Andrijauskaite], like that of thousands of people reported missing in the same context, depends on a massive process in which genetic sequences extracted from skeletal remains recovered in circumstances suggesting the presence of forced disappearance […] are compared with genetic reference profiles provided by close relatives of the victims. [...] The sequence from the same reference (daughter of [the Julien Grisonas couple]) has not produced a significant match with human remains indicative of identity to date. 238 213. Based on the foregoing, without ignoring the complexity involved in searching for a disappeared person in contexts such as this, the Court finds that the State’s obligation to investigate the whereabouts and, if applicable, locate the remains of Ms. Grisonas Andrijauskaite cannot be exhausted by mass comparison of genetic sequences. On the contrary, in order to be effective and compatible with due diligence, the State’s obligation in this regard must include all possible efforts, carried out systematically, rigorously, and with all appropriate and suitable means, 239 including requesting the cooperation of other States, 240 none of which is understood to have taken place based on what has been reported. 214. Although it has not found any breach of due diligence in criminal investigations, the Court highlights the autonomous nature of the obligation to search for and locate missing persons, 241 which must be carried out efficiently, comprehensively, adequately, and diligently, independent of those investigations. 242 This autonomous obligation is closely related to the right of family members to know the truth about the fate of their loved ones. Based on the foregoing, the Court concludes that the State did not comply with its obligation to carry out a systematic and rigorous search with all due diligence to establish the whereabouts of Ms. Grisonas Andrijauskaite. 215. In the case of Julien Cáceres, by contrast, the information provided on the process reveals that a series of procedures ordered by the court in charge of the preliminary investigation aimed at locating his remains were carried out. Of particular interest is the information provided by the authorities of the Municipal Cemetery of the Partido de General San Martín, along with the documentary evidence collected. According to the content of the note provided, the EAAF completed its analysis of all this material and was able to conclude the following: There are serious indications that the person whose death was documented by means of a death certificate […] in the Civil Registry of San Martin […], whose body was originally buried in an individual grave in the Cf. Note from the Argentine Forensic Anthropology Team of July 27, 2020, addressed to the National Director of International Legal Affairs in Human Rights of the Ministry of Justice and Human Rights (evidence file, volume IV, annex 25 to the answering brief, folios 15924 and 15925). 239 Cf. Case of Contreras et al. v. El Salvador, supra, par. 191, and Case of Garzón Guzmán et al. v. Ecuador, supra, par. 74. 240 Cf. Case of Gelman v. Uruguay, supra, par. 234, and Case of Contreras et al. v. El Salvador, supra, par. 152. 241 Cf. Case of Garzón Guzmán et al. Ecuador, supra, par. 75. In this sense, the International Convention for the Protection of All Persons from Enforced Disappearance, adopted by the General Assembly of the United Nations on December 20, 2006, in its Articles 15, 19(1), 24(2), 24(3), 25(2), and 25(3) refers to the obligation to search for and locate the disappeared persons, specifically and distinct from the criminal investigation. The Committee on Enforced Disappearances has reaffirmed the specific obligations that exist for States in this matter. Cf. Committee on Enforced Disappearances, Concluding observations on the report submitted by Spain under Article 29, paragraph 1, of the Convention, UN Doc. CED/C/ESP/CO/1, December 12, 2013, par. 32, Concluding observations on the report submitted by Burkina Faso under Article 29, paragraph 1, of the Convention, UN Doc. CED/C/BFA/CO/1, May 24, 2016, par. 40; Concluding observations on the report submitted by Honduras under Article 29, paragraph 1, of the Convention, UN Doc. CED/C/HND/CO/1, July 4, 2018, par. 25(1); Concluding observations on the report submitted by Chile under Article 29, paragraph 1, of the Convention, UN Doc. CED/C/CHL/CO/1, May 8, 2019, par. 27(a). Also see Committee on Enforced Disappearances, Guiding principles for the search for disappeared persons, UN Doc. CED/C/7, May 8, 2019, Principles 6 and 13. 242 See Committee on Enforced Disappearances, Guiding principles for the search for disappeared persons, UN Doc. CED/C/7, May 8, 2019, Principles 1, 4 to 8, 10, 12, 13, 15, and 16. 238 56

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