on the subject. 57 The Commission supported the representatives' claim, specifying that the criminal offense of "forced disappearance" (i) provided for requirements for the formation of the crime that prevented the judicial interpreter from interpreting conduct in terms of the offense; (ii) placed the burden of proving the events on the victim's relatives; and (iii) considered only the "public officer" as the active subject of acquiescence in the crime, excluding the possibility of the perpetration of the crime by individuals acting with the support or acquiescence of the State. 58 Thus, both the IACHR and the representatives demanded the reform of the criminal classification as reparation. 59 25. A In light of the principle of effet utile, the Court reaffirmed the existence of an obligation arising from the exegesis of Article 2 of the Convention for States to effectively adapt their legislation to the parameters of the Convention 60 and, in view of the argument made, it highlighted that States have the duty to classify the crime of "forced disappearance", and they must do so in accordance with international parameters on the subject. 61 This is because the adequate classification of forced disappearance is of "primary character for the effective eradication of this practice", its inclusion under other types such as kidnapping, torture or homicide not being sufficient. 62 The Court concluded, therefore, that Article 320 of the Peruvian Criminal Code violated international parameters 63 and ruled, as a reparatory measure 64, that: The State must adopt all measures necessary to amend, within a reasonable period of time, its criminal law in order to render it consistent with the international standards on forced disappearance of persons, paying special attention to the provisions of the American Convention and the Inter-American Convention on Forced Disappearance, pursuant to the criteria established in paragraphs 90 to 110 of the instant Judgment. 65 26. Similar reasoning has been adopted in subsequent cases in which the Court has ordered the modification of the States’ criminal legislation - all regarding the classification of "forced disappearance" in their domestic legal systems. 66 It was in the case of Albán Cornejo et al. v. Ecuador (2007), however, that the Court had, for the first time, the opportunity to rule on the adequacy of criminal norms other than Cf. Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 135, para. 88. 58 Ibid., para. 87. 59 Ibid., para. 69-70. 60 Ibid., para. 91. 61 Ibid., para. 96. 62 Ibid., para. 92. 63 Ibid., para. 100-10. 64 It should be noted that, in a previous case, the victim's representatives had already demanded recognition of a violation of Article 2 of the ACHR due to an inadequate classification of forced disappearance in the Honduran Penal Code, but the Court did not discuss this argument. Cf. Case of Juan Humberto Sánchez v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of June 7, 2003. Series C No. 99. 65 Cf. Case of Gómez Palomino v. Peru. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 135, para. 149. 66 Cf. Case of Blanco Romero et al. v. Venezuela. Merits, Reparations and Costs. Judgment of November 28, 2005. Series C No. 138, para. 105; Case of Heliodoro Portugal v. Panama. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 12, 2008. Series C No. 186, para. 183; Case of Tiu Tojín v. Guatemala. Merits, Reparations and Costs. Judgment of November 16, 2008. Series C No. 190, para. 58; Case of Anzualdo Castro v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 22, 2009. Series C No. 202, para. 167; Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 23, 2009. Series C No. 209, para. 318; Case of Contreras et al. v. El Salvador. Merits, Reparations and Costs. Judgment of August 31, 2011. Series C No. 232, para. 219; Case of Gomes Lund et al. (“Guerrilha do Araguaia”) v. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 24, 2010. Series C No. 219, para. 287. 57 9