considering paragraph). Consequently, the State must provide a detailed and complete account of the measures adopted and the need for them to ensure that, in Venezuela, the remedy of habeas corpus can be exercised effectively in situations of forced disappearance. e) Regarding the obligation to adopt, within a reasonable time, the necessary measures to amend its criminal laws to make them compatible with international standards for the protection of the individual in relation to the forced disappearance of persons (tenth operative paragraph of the judgment) 22. The State indicated that, Article 45 of the Constitution of the Bolivarian Republic of Venezuela “expressly establishes the prohibition of forced disappearance of persons […], even in a state of emergency.” 23. The representatives indicated that “[to] date, no official information exists on the existence of a reform initiative on this matter”; hence, they considered that the State’s obligation had not been fulfilled. 24. The Commission observed “that even though, in its 2007 report, Venezuela indicated that ‘the National Assembly was required to revise and amend the content of article 180-A of the Criminal Code in force in relation to the crime of forced disappearance,” in its most recent briefs, it had not referred to the said initiative. Therefore, the Commission asked the Court to require the State to submit detailed information on the measures adopted or planned in order to comply with this obligation. 25. After the order of July 7, 2009 (supra having seen paragraph 2), the State did not report on progress with regard to the July 11, 2006, decision of the Criminal Cassation Chamber of the Supreme Court of Justice in which it “urged the National Assembly to revise and to amend the content of article 181-A of the Criminal Code in force.”14 The State merely referred to the content of article 45 of the Constitution of the Bolivarian Republic of Venezuela. In this regard, the Court recalls that the obligation contained in this measure of reparation requires the real reform of domestic criminal laws as indicated in the judgment.15 Given that the State has not submitted information on the specific actions taken to reform its criminal law in the terms indicated, the Court finds that this aspect remains pending. Consequently, the State must continue to report in a detailed and complete manner on the measures adopted to comply with this obligation. f) Regarding the obligation to include, as part of the education and training courses for the members of the Armed Forced and the Intelligence and Prevention Services Sectoral General Directorate, a program on the principles and laws for the protection of human rights, particularly the prohibition of forced disappearance, torture and the disproportionate use of force, taking into consideration the case law of the inter-American system for the protection of human rights, as a way of preventing the recurrence of events such as those of the instant case (eleventh operative paragraph of the judgment) 26. The State forwarded a copy of the “Program of Human Rights and International Humanitarian Law Courses for Educational Establishments of the Bolivarian National 14 Case of Blanco Romero et al. v. Venezuela, supra note 11, eighth considering paragraph, subparagraph (f). 15 Cf. Case of Blanco Romero et al. v. Venezuela, supra note 8, para. 105. 8

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