92 of those who are legally within a State to move freely within this State and choose their place of residence.195 207. Accordingly, using an evolutive interpretation of Article 22 of the Convention that takes into account the applicable interpretation norms, and in keeping with Article 29(b) thereof — which prohibits a restrictive interpretation of rights — the Court has considered that Article 22(1) of the Convention protects the right not to be forcibly displaced within a State Party to the Convention.196 208. As has been proved (supra para. 125(104) to 125(110)), the facts of this case took place in a widespread situation of internal forced displacement that affected Colombia as a result of the internal armed conflict. Consequently, before deciding whether these facts constituted a violation by the State of Article 22 of the Convention to the detriment of the persons allegedly displaced owing to the events in La Granja and El Aro, the Court finds it necessary to examine, as it has in other cases,197 the problem of forced displacement in light of international human rights law and international humanitarian law, as well as the manifestation of this phenomenon in the context of the internal armed conflict in Colombia. 209. In this regard, the Court considers that the Guiding Principles on Internal Displacement issued by the Representative of the United Nations Secretary-General in 1998 are especially relevant to define the content and scope of Article 22 of the Convention in a context of internal displacement.198 In addition, given the situation of internal armed conflict in Colombia, the displacement regulations contained in Protocol II to the 1949 Geneva Conventions are also particularly useful. Specifically, Article 17 of Protocol II, which prohibits ordering the displacement of the civilian population for reasons connected with the conflict, unless the security of the civilians involved or imperative military reasons so demand. And, in that case, “all possible measures shall be taken in order that the civilian population may be received under satisfactory conditions of shelter, hygiene, health, safety and nutrition.” In this regard, the Colombian Constitutional Court has considered that “in the case of Colombia, the application of these rules by the parties in conflict is particularly urgent and important, because the armed conflict in the country has gravely affected the civilian population, as shown, for example, by the alarming data on forced displacement of persons.”199 210. Owing to the complexity of the phenomenon of internal displacement and the wide range of human rights affected and jeopardized, and taking into account the 195 Cf. Case of the “Mapiripán Massacre”, supra note 8, para. 168; Case of the Moiwana Community, supra note 12, para. 110; and Case of Ricardo Canese, supra note 194, para. 115. Likewise, cf. The United Nations Human Rights Committee, General comment No. 27 of 2 November 1999, paras. 1, 4, 5 and 19. 196 Cf. Case of the “Mapiripán Massacre”, supra note 8, para. 188. 197 Cf. Case of the “Mapiripán Massacre”, supra note 8, para. 169. 198 Cf. the United Nations Guiding Principles on Internal Displacement, E/CN.4/1998/53/Add.2 of February 11, 1998; see also, Case of the “Mapiripán Massacre”, supra note 8, para. 171; Case of the Moiwana Community, supra note 12, paras. 113 to 120. 199 Cf. judgment C-225/95 of May 18, 1995, delivered by the Constitutional Court, para. 33.

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