38 139. Article 22(1) of the Convention recognizes the freedom of movement and residence.148 In this sense, the Court has established in other cases149 that this Article also protects the right to not be displaced forcibly within the territory of a State Party. 140. In this regard, the Tribunal has considered that the Guiding Principles on Internal Displacements of the United Nations150 are particularly relevant in order to define the content and scope of Article 22 of the American Convention,151 which define those forcibly displaced “as the persons or groups of persons that have been seen as forced or obligated to escape or run from their homes or their place of habitual residence, in particular as a result of or in order to avoid the effects of an armed conflict, of situations of generalized violence, of violations of their human rights […], and that have not crossed an internationally recognized State border.”152 141. This Tribunal has established that as a result of the complexity of the phenomenon of internal displacement and of the high range of human rights that are affected or put at risk, and in attention to the circumstances of special vulnerability or defenselessness in which the displaced are generally found, their situation can be understood as a de facto condition of vulnerability.153 This situation, in compliance to the American Convention, obligated the States to adopt measures of a positive character in order to help with the effects of their condition of weakness, vulnerability and defenselessness, including vis-à-vis, regarding the actions and practices of third parties.154 148 Regarding Article 22(1) of the Convention, it established that “[e]very person lawfully in the territory of a State Party has the right to move about in it, and to reside in it subject to the provisions of the law.” 149 Cf. Case of the Mapiripan Massacre V. Colombia, supra note 14, para. 188, and Case of the Ituango MassacreV. Colombia, supra note 24, para. 207. 150 Cf. Human Rights Commission, Guiding Principles on Internal Displacement of the United Nations, E/CN.4/1998/53/Add.2 of 11 of February of 1998, p. 5. Annex. Introduction: Reach and Purpose. Numeral 2. Available at http://www.hchr.org.co/documentoseReports/documentos/html/Reports/onu/resdi/E-CN-4-1998-53ADD-2.html. Said principles have been recognized by the international community. See also, United Nations, General Assembly, Protection and assistence for internally displaced, A/RES/64/162, of 17 of March of 2010, p.1. Available at http://daccess-dds-ny.un.org/doc/UNDOC/GEN/N09/471/58/PDF/N0947158.pdf?OpenElement; Cf. Council of Europe, Committee of Ministers, Recommendation Rec(2006)6 to member states on internally displaced persons, 5 April, 2006. Available at https://wcd.coe.int/ViewDoc.jsp?id=987573&BackColorInternet=9999CC&BackColorIntranet=FFBB55&BackColorLo gged=FFAC75; African Union, Convention for the Protection and Assistance of Internally Displaced Persons in Africa (Kampala Convention), 23 October 2009, article 1, K). Available at http://www.unhcr.org/4ae9bede9.html; Human Rights Council, Report presented by the representative of the General Secretariat on the human rights of internally displaced persons, Walter Kalin. A/HRC/13/21/Add.3, p. 4. II.4. Available at http://www2.ohchr.org/english/bodies/hrcouncil/docs/13session/A-HRC-13-21-Add.3.pdf. 151 Cf. Case of the Moiwana Community V. Suriname. Preliminary Exceptions, Merits, Reparations and Costs. Judgment 15 of June of 2005. Series C No. 124, para. 111; Case of the Mapiripan Massacre V. Colombia, supra note 14, para. 171, and Case of the Ituango Massacre V. Colombia, supra note 24, para. 209. 152 Cf. Guiding Principles on Internal Displacement of the United Nations, supra note 150, para. 2. In this regard, the Generaly Assembly of the OAS has recommended that the States use the Guiding Principles based on the development of their policies and to integrate them in their domestic legislation to promote implementation. Cf. AG/RES. 2508 (XXXIX-O/09) “Internal Displacement,” Approved by the fourth plenary session, on 4 of June of 2009, operatve paragraph 2 (available at: www.oas.org/dil/esp/AG-RES_2508-2009.doc). 153 Cf. Case of the Mapiripan Massacre V. Colombia, supra note 14, para. 177, and Case of the Ituango Massacre V. Colombia, supra note 24, para. 210. 154 Cf. Case of the Mapiripan Massacre V. Colombia, supra note 14, para. 179, and Case of the Ituango Massacre V. Colombia, supra note 24, para. 210.

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