49 168. That said, the Court notes that the inter-American system for the protection of human rights does not include a treaty-based norm on regional bioethics and human rights that develops the scope and content of the rule of informed consent.196 Therefore, to interpret the scope of the State obligations in relation to the facts of this case, the Court will have recourse, based on the general rules of interpretation established in Article 29 of the American Convention, and in the Vienna Convention on the Law of Treaties,197 to the international corpus juris on the matter, as it has on previous occasions.198 Regarding consent, the corpus juris is based on international declarations, guidelines, opinions of expert medical committees, directives, criteria and other authorized statements by specialized bodies, such as the World Health Organization (hereinafter “WHO”), the International Federation of Gynecology and Obstetrics (hereinafter “FIGO”), the World Medical Association (hereinafter also “WMA”), the United Nations Educational, Scientific and Cultural Organization (hereinafter “UNESCO”), the United Nations Treaty Bodies, the Council of Europe, and the European Court of Human Rights. These agencies have established common legal standards that constitute general protection for the prior, free, full and informed nature of consent. 169. Regarding the State's argument that the Commission had made numerous references to its thematic reports,199 seeking to use them to analyze the facts of the case, the Court notes that, among other sources, these were cited in the Merits Report to interpret the scope and content of the obligations established in the American Convention. Even though the Court considers that the criteria established in these reports do not generate binding obligations for the State, this does not prevent the Commission from taking them into account because, when appropriate, they may guide or reinforce the Court’s interpretation and application of the international corpus juris in this case insofar as they identify, systematize and analyze the relevant regional and international legal criteria. B.2.a The elements of consent in international law and jurisprudence 170. The Court will now examine how informed consent and its elements have been treated and developed at the international level, with regard to both medical interventions in general 200 and to the consent that should be obtained in cases of female sterilization. 171. Informed consent was codified in the aftermath of the Second World War and in reaction to the atrocities committed with the publication of the 1947 Nuremberg Code of medical ethics. Even The Court notes that, within the framework of the Council of Europe and the European system, diverse documents exist that expressly regulate the patient’s prior, free, full and informed consent for the performance of any medical intervention. Cf. Articles 1 to 3 of A Declaration on the Promotion of Patients’ Rights in Europe, adopted by the WHO Regional Office for Europe in 1994; articles 5 and 6 of the Convention for the Protection of the Human Rights and Dignity of the Human Being with regard to the Application of Biology and Medicine: Convention on Human Rights and Biomedicine (hereinafter “Oviedo Convention”), adopted by the Council of Europe on April 4, 1997, which entered into force on December 1, 1999, and its Explanatory report, and article 3 of the Charter of Fundamental Rights of the European Union, adopted in 2000, and amended in 2007. 196 Cf. The Right to Information on Consular Assistance within the Framework of Due Process of Law. Advisory Opinion OC-16/99 of October 1, 1999. Series A No. 16, para. 114, and Case of Gonzales Lluy et al. v. Ecuador, supra, para. 21. 197 Cf. The Right to Information on Consular Assistance within the framework of Due Process of Law. Advisory Opinion OC16/99, supra, para. 120; Juridical Status and Rights of Undocumented Migrants. Advisory Opinion OC-18/03 of September 17, 2003. Series A No. 18, para. 117; Case of the “Street Children” (Villagrán Morales et al.) v. Guatemala. Merits. Judgment of November 19, 1999. Series C No. 63, paras. 192 to 194, and Case of the Pacheco Tineo Family v. Bolivia. Preliminary objections, merits, reparations and costs. Judgment of November 25, 2013. Series C No. 272, paras. 129, 135, 216 and 217. 198 Access to Maternal Health Services from a Human Rights Perspective of June 7, 2010, and Access to Information on Reproductive Health from a Human Rights Perspective of November 22, 2011. 199 In general, the term medical interventions will be understood in its broad sense; that is, it encompasses all the medical interventions performed for prevention, diagnosis, treatment, rehabilitation and surgical procedures; scientific research, and the participation of subject patients during medical practice to teach students. 200

Select target paragraph3