11 40. The peremptory nature of Article 3 common to the four 1949 Geneva Conventions on international humanitarian law has been judicially recognized. 21 In my opinion, this provision, together with the references to the fundamental guarantees of the 1977 Protocols I (Article 75) and II (Articles 4 to 6) additional to the four 1949 Geneva Conventions on international humanitarian law, and the provisions regarding non-derogable rights in human rights treaties such as the American Convention, belong to the domain of international jus cogens. This is, per se, sufficient to reject the said objection of “lack of jurisdiction ratione materiae” as being manifestly inadmissible. 41. Furthermore, every time that an attempt has been made to disassociate the provisions of these two aspects of the protection of human rights (international human rights law and international humanitarian law), the results have been disastrous – as illustrated, today, by the attempt being made by the State (which is not a party to the American Convention) responsible for those detained in Guantánamo Bay. 22 The convergence between international human rights law, international humanitarian law and international refugee law – which, as I have been maintaining for many years, is expressed at both the normative, and the hermeneutic and operational levels - ensures the maximum protection of the individual in any and every circumstance, 23 and even more since the norms belong to the domain of jus cogens. VII. Epilogue: The expansion of the international jurisdiction 42. Above and beyond the solution of international disputes, the compulsory jurisdiction testifies to the rule of law in the international sphere, leading to a more cohesive and inspired international legal system, guided by the imperative of the realization of justice. Also, the multiplicity of international tribunals nowadays (for example, in addition to the ICJ, the International Tribunal for the Law of the Sea, the International Criminal Court, the international (inter-American and European) human rights courts, the ad hoc international criminal tribunals – for Rwanda and for the Former Yugoslavia, and the Court of Justice of the European Communities) constitute an encouraging development of the growing recourse to judicial channels to resolve disputes, and the formation of the embryo of a future international judiciary. 43. This development reveals that the ancient ideal of international justice has been revitalized and is gaining ground nowadays. It has also affirmed and developed the ability of international law to adequately resolve international disputes in different domains of human activity (cf. supra). Today, such disputes no longer reveal a strictly inter-State dimension as in the past. International human rights 21 . Cf. ICJ, Nicaragua v. The United States of America, ICJ Reports (1986) pp. 114-115, para. 220. 22 . For this ominous, fragmenting and erroneous attempt, and also an equally erroneous and reductionist vision of the scope of the third and fourth 1949 Geneva Conventions on International Humanitarian Law, cf. U.S., Additional Response of the United States to Request for Precautionary Measures of the Inter-American Commission on Human Rights - Detainees in Guantanamo Bay, Cuba, of July 15, 2002, pp. 1-35. Contrary to that State’s allegations, there is no juridical vacuum or limbo, and every individual is protected by law, in any circumstances whatsoever (even those detained and sentenced), applying the provisions of international humanitarian law and international human rights law concomitantly. 23 . A.A. Cançado Trindade, "Derecho Internacional de los Derechos Humanos, Derecho Internacional de los Refugiados y Derecho Humanitario Internacional: Aproximaciones y Convergencias", in 10 Años de la Declaración de Cartagena sobre Refugiados - Memoria del Coloquio Internacional (San José, Costa Rica, December 1994), San José, IIDH/ACNUR/Gob. Costa Rica, 1995, pp. 77-168.