100 Arguments of the Commission 227. In relation to Article 63(1) of the Convention, the Commission argued that: a) Lori Berenson should be the beneficiary of the reparations ordered by the Court as a result of the violations that are declared; b) The State should adopt the necessary measures under the provisions of its domestic law to ensure that the violations of Lori Berenson’s human rights cease; c) The State should guarantee Lori Berenson the enjoyment of her human rights that have been violated, and adopt pecuniary and nonpecuniary reparations; d) As a guarantee of non-repetition, the State should modify Decree Laws Nos. 25,475 and 25,659, “given their [...] incompatibility with the Convention”; e) The State should be ordered “to pay the relevant costs incurred at the national level, and also those incurred at the international level by processing the case before the Commission and […] the Court”; and f) The argument on admissibility presented by the State, namely, that it had not submitted “to the Court the matter of the compensatory rights that the Commission ha[d] calculated in favor of Lori Berenson […], because it considered that the procedural mechanisms which domestic legislation provides to all individuals to request reparation for any damages they allege they have suffered had been available to her and she had not used them,” was totally time-barred and refers to matters that had already been decided, in both the report on admissibility and the report on merits.” Arguments of the representatives of the alleged victim 228. In relation to Article 63(1) of the Convention, the representatives of the alleged victim requested that: a) The State should carry out an “immediate modification” of the Peruvian anti-terrorist legislation to adapt it to the norms of international law, in accordance with the American Convention; b) The State should conduct an investigation into the facts of the case, to identify and sanction those responsible for the unlawful acts committed against Lori Berenson, and adopt all measures of domestic law necessary to comply with this obligation; c) The State should establish a precise legal definition of the term “terrorism.” “Terrorist acts” should be prosecuted when they are committed by the State or any person or organization; d) Peruvian legislation should establish a classification of “political prisoners”, which complies with the requirements of international law;

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