80
on her own in order to protect her life and safety.380 She testified as part of the criminal investigation of
Ms. Ana Teresa Yarce, and of the investigation of the forced displacement of Luz Dary Ospina Bastidas,
how her security situation was exacerbated by Mrs. Yarce’s murder, and the subsequent surge in threats
by the paramilitary members based in the area, which led to her displacement.381 The gravity of the
security situation of Ms. Naranjo is borne out by the precautionary measures granted to her by the
IACHR on October 22, 2004 in order to safeguard hers and her next of kins’ life and physical integrity
and, subsequently, by the provisional measures granted to her by the Inter-American Court on July 5,
2006; both measures are still in effect as of this date. The IACHR also highlights the murder of several
family members of Ms. Naranjo while the provisional measures were in effect, including her son-in-law
and 16-year-old grandson.382
279. The IACHR moreover notes that the forced displacement of Ms. Rúa, Ospina, Mosquera
and Naranjo took place in a context of heightened risk for women human rights defenders, generated by
an escalation of the armed conflict in Comuna 13 in 2002, and its aftereffects. Their forced
displacement coincides with military operations implemented by the State in Comuna 13 over 2002, and
the subsequent paramilitary occupation of the zone.
280. The Colombian State���s failure to prevent in the case under consideration is particularly
serious in light of the quantity of rulings issued by international and national bodies on the urgency to
deal with forced displacement in Colombia, as a byproduct of the armed conflict that the country is
experiencing, and its disproportionate impact on women.383 The IACHR, the Office of the High
Commissioner for Human Rights in Colombia, the Special Rapporteur on Violence against Women, and
the Mesa de Trabajo Mujer y Conflicto Armado en Colombia, have all alerted the Colombian State in
2002 as to the high number of displaced women as a result of the violence stemming from the
Colombian armed conflict; and this problem is closely linked to the absence of an effective prevention
policy of the State.384
380
Observations of the Petitioners in reference to the matter of Miryam Eugenia Rúa Figueroa et al – Case 12.595
dated May 3, 2012, pg. 6.
381
Annexes 72 and 71. Statement of Mery Naranjo, Office of the Attorney General of the Nation, December 13, de
2004 and addendum to her statement on August 24, 2005. Criminal proceeding on the murder of Mrs. Ana Yarce; Annex 59.
Statement given by Mrs. Mery Naranjo, May 14, 2009. Criminal proceeding for the forced displacement of Luz Dary Ospina
Bastidas.
382
Decision of the Inter-American Court of Human Rights in the Matter of Mery Naranjo et al – Comuna 13, Colombia,
November 25, 2010, par. 53.
383
IACHR, United Nations, Report of the United Nations High Commissioner for Human Rights on the Human Rights
Situation in Colombia, 2002 Annual Report, February 24, 2003, pars. 88-91; United Nations, Report submitted by Mrs. Radhika
Coomaraswamy, Special Rapporteur on Violence against Women, its causes and consequences; Mission to Colombia (November
1-7, 2001), Visit to Colombia, March 11, 2002, Executive Summary, pars. 59-86; IACHR, Third Report on the Human Rights
Situation in Colombia, OEA/Ser.L/V/II.102, Doc. 9, rev. 1, February 26, 1999, Chapter VI, Internal Forced Displacement, par. 1,
section C, par. 26; Mesa de Trabajo Mujer y Conflicto Armado, First Report 2001, Report on Violence against Women and Girls
in the Colombian Armed Conflict, Mesa de Trabajo Mujer y Conflicto Armado, First Report 2001, Mesa de Trabajo Mujer y
Conflicto Armado, April 2001, pgs. 7-9.
384
IACHR, United Nations, Report of the United Nations High Commissioner for Human Rights on the Human Rights
Situation in Colombia, 2002 Annual Report, February 24, 2003, pars. 88-91; United Nations, Report submitted by Mrs. Radhika
Coomaraswamy, Special Rapporteur on Violence Against Women, its causes and consequences: Mission to Colombia (November
1-7, 2001), Visit to Colombia, March 11, 2002, Executive Summary, pars. 59-86; IACHR, Third Report on the Human Rights
Situation in Colombia, OEA/Ser.L/V/II.102, Doc. 9, rev. 1, February 26, 1999, Chapter VI, Internal Forced Displacement, par. 1,
section C, par. 26; Mesa de Trabajo Mujer y Conflicto Armado, First Report 2001, Report on Violence against Women and Girls