46
increase in the number and scope of military actions and the coercion by the armed actors especially
impacted women and their organizations, including threats and assaults directed against women and
their families, leading to their displacement.179 The report indicates, in particular, that:
Although displacement is simultaneously a violation of all rights (civil, political, social, economic,
and cultural) and an infraction of international humanitarian law, in the case of the women who
participate in social organizations it is often preceded by violent acts and is geared to disrupting
180
organizational processes.
173. It is also important to note pronouncements by the Constitutional Court of Colombia
referring to the risks women human rights defenders face in the Colombian armed conflict. For example,
Judgment T-496 of 2008 issued by the Constitutional Court of Colombia protected the rights to life,
security, liberty, physical integrity, and access to justice for several women human rights defenders.181
In that judgment the Constitutional Court found that given their gender, women defenders of women’s
human rights “are exposed to particular risks and to a specific situation of vulnerability in many aspects
of their lives in the context of the armed conflict. In their legal action they reveal their status as victims
who have survived violent acts, a situation that imposes extreme and abrupt material and psychological
burdens on them.”182
174. In its Order 092-08 – adopted to protect the fundamental rights of women displaced by
the armed conflict – the Constitutional Court of Colombia also identified belonging to social
organizations and the performance of leadership work and the promotion of human rights by women in
areas affected by the armed conflict as a gender risk that furthers the forced displacement of women
human rights defenders.183 The Constitutional Court documented, in its judgment, having received
information from several entities indicating that women who take on public visibility as representatives
of women’s, social, and community organizations have become targets of homicides, persecution,
arrests, arbitrary detentions, torture, disappearance, acts of sexual violence, and threats by members of
illegal armed groups, including in places such as Medellín.184 These acts have also been directed against
members of their families.185 Notwithstanding the efforts made by the Colombian State to overcome
the problems identified by the Constitutional Court, the IACHR continues receiving information about
the specific risks to their security that women human rights defenders continue to face in the context of
the armed conflict due to their sex, their status as social leaders, and the incompatibility of their work
with the interests of the armed actors in the conflict.186
179
Mesa de Trabajo Mujeres y Conflicto Armado, Informe sobre Violencia Socio-Política Contra Mujeres, Jóvenes, y
Niñas en Colombia, Third Report 2002, February 2003, p. 14.
180
Mesa de Trabajo Mujeres y Conflicto Armado, Informe sobre Violencia Socio-Política Contra Mujeres, Jóvenes, y
Niñas en Colombia, Third Report 2002, February 2003, p. 14.
181
Constitutional Court of Colombia, Judgment
http://www.nrc.org.co/biblioteca/sentencia-T-496-08.pdf.
182
T-496
2008
(Case
T-1783291),
available
at:
Constitutional Court of Colombia, Judgment T-496 of 2008 (Case T-1783291), para. 10.4.
183
Constitutional
Court
of
Colombia,
http://www.corteconstitucional.gov.co/relatoria/autos/2008/a092-08.htm
184
Constitutional Court of Colombia, Order 092-08, Section III.1.5.
185
Constitutional Court of Colombia, Order 092-08, Section III.1.5.
186
of
Order
092-08,
available
at:
Video, IACHR, Thematic Hearing, Situation of the Human Rights of Women in Colombia, March 14, 2013, available
at: http://www.oas.org/es/cidh/audiencias/advanced.aspx?lang=es; IACHR, Press Release, IACHR’s Preliminary Observations on