27 84. In the said decision T-590/98, the Colombian Constitutional Court decided: To call upon all State authorities to halt this state of affairs; to ask the Attorney General and the Ombudsman to give particular importance to the protection of human rights defenders in the execution of their constitutional duty to safeguard and promote human rights, [and] to call upon all the inhabitants of Colombia to comply with Article 95 of the Constitution, which obliges them to defend and disseminate human rights as the basis of peaceful coexistence.43 85. Indeed, this Court recognizes, as noted by the Colombian Constitutional Court in the said ruling, that the State has adopted a series of measures designed to assist and protect human rights defenders including, in particular, the following: (i) legal recognition of human rights organizations; (ii) public recognition of organizations composed of human rights defenders by State authorities; (iii) the formulation and implementation of the National Action Plan on Human Rights and International Humanitarian Law; and (iv) provision of police protection to human rights organizations, among others. 86. Nevertheless, the Constitutional Court indicated that, when the facts of the present case occurred: Despite the presidential directives [designed to protect human rights defenders and to promote their activities44], the attacks on human rights defenders [continued] and State authorities failed to take action to protect them, even when they had been informed of the threats they faced. This situation is plainly unconstitutional […].45 87. The Court finds that in order to prevent such situations, States must create the necessary conditions for the effective enjoyment and exercise of the rights established in the Convention.46 Compliance with this obligation is tied intrinsically to the protection and recognition of the importance of the role of human rights defenders,47 whose work is essential to strengthen democracy and the rule of law. 88. It is worth noting that the monitoring, denunciation, and educational activities undertaken by human rights defenders make an essential contribution to respect for human rights, because they act as guarantors against impunity. Thus, human rights defenders Mr. Valle Jaramillo was expressly mentioned in this Report when it indicated that “[v]arious human rights leaders have been murdered since 1996. [In particular], Jesús Valle Jaramillo, a well-known human rights advocate, was shot dead in his office in Medellín in February 1998 […], after he denounced the existence of links between the Colombian military and the paramilitary groups.” Cf. UN. Statement by the Chairperson of the Commission on Human Rights on the situation in Colombia, fifty-third session (1997). Statement of the Chairperson, 16 April 1997. 43 Judgment T-590 of the Constitutional Court of Colombia, supra nota 39 (folio 1409). 44 It is important to note that the presidential directives referred to by the Colombian Constitutional Court were the specific measures taken by the Colombian State to counteract the dangers to which human rights defenders were exposed. Cf. testimony given by the expert witness, Rainer Huhle, supra note 40, who referred to the existence of “several presidential directives addressed to all public officials [ordering them to] abstain from criticizing the work of the human rights defenders; [however,] the problem was that there was no mechanism to monitor […] whether a public official disobeyed this directive […]”. 45 Judgment T-590 of the Constitutional Court of Colombia, supra nota 39 (folio 1399). 46 Cf. Case of the “Mapiripán Massacre”, supra note 21, para. 111; Nogueira de Carvalho et al. v. Brazil. Preliminary objections and merits. Judgment of November 28, 2006. Series C No. 161, para. 74, and Servellón García et al. v. Honduras. Merits, reparations and costs. Judgment of September 21, 2006. Series C No. 152, para. 108. 47 Cf. Case of the Monagas Detention Center (“La Pica”). Provisional measures. Order of the Inter-American Court of Human Rights of February 9, 2006, fourteenth considering paragraph; Case of Nogueira de Carvalho et al., supra note 46, para. 74, and Case of the Persons Deprived of Liberty in the “Dr. Sebastião Martins Silveira” Prison, in Araraquara, São Paulo. Provisional measures. Order of the Inter-American Court of Human Rights of September 30, 2006, twenty-fourth considering paragraph.