42 ARTICLE 16(1) (FREEDOM OF ASSOCIATION)182 OF THE AMERICAN CONVENTION, IN RELATION TO ARTICLE 1(1) (OBLIGATION TO RESPECT RIGHTS) THEREOF 140. The representatives pointed out that “[t]he murder of Jeannette Kawas, as a result of her tireless efforts to protect the environment through the foundation [PROLANSATE], of which she was the President, constituted a deprivation of her right [to] use any means she deem[ed] appropriate to exercise her freedom of association, [...] from the individual perspective of such right.” They added that her murder “must be seen as a violation of the freedom of association from a collective standpoint [insofar as] its impunity had an intimidating effect on the environmental movement in Honduras, especially because her death marks the start of a context of violence against environmental advocates. […] The right of individuals to associate with others for an environmental cause in Honduras may not be freely exercised, and the murder and ensuing impunity in the Kawas case has been a true reflection of that situation.” Furthermore, they alleged that the State, through the Attorney General’s Office, “has accepted that all the theories regarding the incident are related to the Jeannette’s fight as an environmentalist.” 141. The Commission made no reference to the alleged violation of the right of freedom of association. 142. In its answer to the application, the State argued that “both the application and the brief containing pleadings, motions and evidence list the different activities carried out by Blanca Jeannette Kawas-Fernández as well as the organizations to which she belonged; therefore, it is evident that the State [...] never prevented her from freely associating with others, nor did it place any restrictions on such right.” 143. Article 16(1) of the American Convention provides that individuals under the jurisdiction of the States Parties have the right and freedom to associate freely with others, without any interference by the public authorities that could limit or impair the exercise of such right. It relates, therefore, to the right to join with others in lawful common pursuits, without pressure or interference that may alter or impair the nature of such purpose.183 144. In addition to the aforesaid negative obligations, the Inter-American Court has pointed out that freedom of association also “gives rise to positive obligations to prevent attacks on it, to protect those who exercise it, and to investigate violations restricting such freedom.”184 These positive obligations must be enforced, even in the sphere of relations between individuals, if necessary.185 182 In this regard, Article 16(1) of the Convention provides that: “everyone has the right to associate freely for ideological, religious, political, economic, labor, social, cultural, sports, or other purposes.” 183 Cf. Case of Baena-Ricardo et al. Merits, Reparations and Costs, supra note 96, para. 156. Cf. also Case of Huilca-Tecse v. Perú. Merits, Reparations and Costs. Judgment of March 3, 2005. Series C No. 121, para. 69; and Case of Cantoral-Huamaní and García-Santa Cruz v. Perú. Preliminary Objection, Merits, Reparations, and Costs. Judgment of July 10, 2007. Series C No. 167, para. 144. 184 Cf. Case of Huilca-Tecse. Merits, Reparations and Costs, supra note 183, para. 76, and Case of CantoralHuamaní and García-Santa Cruz. Preliminary Objection, Merits, Reparations, and Costs, supra note 183, para. 141. 185 Cf. Case of Huilca-Tecse. Merits, Reparations and Costs, supra note 183, para. 76; and Case of CantoralHuamaní and García-Santa Cruz. Preliminary Objection, Merits, Reparations, and Costs, supra note 183, para. 141.