43 members, who have also been the target of unwarranted and baseless legal inquiries, in violation of their rights to freedom of association and expression.160 165. The Office of the Colombian Ombudsperson has confirmed that in the aftermath of Operation Orión in Comuna 13, the new armed actors in the area took a series of measures intended to “clamp down on the community, eliminate or drive out social representatives and leaders who refuse[d] to participate in the new established order and who continue[d] to press economic, social and political demands.”161 It also made reference to the coercive tactics that the self-defense groups employed to those ends.162 The Office of the United Nations High Commissioner for Human Rights in Colombia also reported how the violations of rights committed during the military offensives conducted in 2002 had a direct effect on social, human rights and peace organizations in Comuna 13.163 166. The Office of the Ombudsperson continues to identify leaders working in community organizations, on community action boards and in nongovernmental organizations as persons exposed to particular peril in Comuna 13 because of the illegal armed groups that constantly emerge in the area and which continue to threaten these community and social organizations and intimidate, stigmatize and threaten their leadership as a means of exercising control and instilling terror.164 H. The Context of Risk for Women Human Rights Defenders in Colombia 167. In the context of its historical analysis of the Colombian armed conflict the Commission has noted in particular its concern for the situation of insecurity of women who work in the defense of human rights in Colombia165. This situation has also been highlighted by a number of international organs for the protection of human rights, civil society organizations, and the Constitutional Court of Colombia.166 160 Panorama de Derechos Humanos, Noche y Niebla y Violencia Política en Colombia, Caso Tipo No. 2: Comuna 13, [Human Rights Picture, Night, Fog and Political Violence in Colombia], CINEP & Justicia y Paz, Bogotá, May 2003, p. 30. 161 Annex 48. Risk Assessment No. 009-07, Office of the Colombian Ombudsperson, p. 2. 162 Annex 48. Risk Assessment No. 009-07, Office of the Colombian Ombudsperson, p. 8. 163 United Nations, Report of the United Nations High Commissioner for Human Rights on the human rights situation in Colombia, Annual Report 2002, February 24, 2003, paragraph 46; Annex 49. Risk Assessment No. 009-07, Office of the Colombian Ombudsperson, p. 1; and Annex 35. Risk Assessment No. 016-10, Office of the Colombian Ombudsperson, pp. 6-7. 164 Annex 47. Risk Assessment No. 016-10, Office of the Colombian Ombudsperson, p. 17. 165 IACHR, Violence and Discrimination Against Women in the Armed Conflict in Colombia, OEA/Ser.L/V/II. Doc. 67, October 18, 2006, para. 225; IACHR, Annual Report 2009, Follow up Report on the Report Violence and Discrimination Against Women in the Armed Conflict in Colombia, OEA/Ser.L./V/II. Doc. 67, October 18, 2006, paras. 105-106. 166 See, for example, United Nations, Report by the Special Rapporteur on Violence against Women, its causes and consequences, Ms. Rhadika Coomaraswamy, Mission to Colombia, March 11, 2002, paras. 90-91; United Nations, Report of the Special Representative of the United Nations Secretary General on Human Rights Defenders, Hina Jilani, Visit to Colombia, April 24, 2002, paras. 138-147; Committee for the Elimination of Discrimination against Women, Observations on the Report of the State of Colombia, February 3, 1999, para. 271; United Nations, Reports by the United Nations High Commissioner for Human Rights on the situation of human rights in Colombia, Annual Report 2002, February 24, 2003, paras. 102-108; Annual Report 2003, February 17, 2004, paras. 85-89; and Annual Report 2004, February 28, 2005, pages 4 and 120; Mesa de Trabajo Mujer y Conflicto Armado, Informe sobre Violencia Socio-Política contra las Mujeres, Jóvenes y Niñas en Colombia, Mujer y Conflicto Armado, October 2004, pp. 91-102; Mesa de Trabajo Mujer y Conflicto Armado, Informe sobre Violencia Socio-Política contra las Mujeres, Jóvenes y Niñas en Colombia, Mujer y Conflicto Armado, October 2004, pp. 91-102; Mesa de Trabajo Mujeres y Conflicto Armado, Informe sobre Violencia Socio-Política Contra Mujeres, Jóvenes, y Niñas en Colombia, Third Report 2002,

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