- 69 - 197. The Court has indicated that the right to freedom of movement and residence, established in Article 22(1) of the Convention, is an essential condition for the free development of the individual.288 This article includes, inter alia, the right of the individual to enter, to remain in and to leave the territory of the State without unlawful interference. Hence, the enjoyment of this right does not depend on any particular objective or motive of the individual who wishes to move or to remain in one place.289 Furthermore, the Court has considered that the right to freedom of circulation and residence can be violated by de facto restrictions if the State has not established the conditions, or provided the means that allow it to be exercised.290 In this regard, the right to freedom of circulation and residence may be violated when an individual is the victim of threats or harassment and the State fails to provide the necessary guarantees to enable him or her to move about and reside freely in the territory in question, even when the threats and harassment are executed by non-state actors.291 198. It should be mentioned that, as Claudia Girón explained, she and Iván Cepeda Castro had considered returning to Colombia in 2002. However, their return to the country was prevented by the publication of the book “Mi Confesión” in which they were both denounced as leaders of a FARC unit allegedly named after Manuel Cepeda, because they considered that this would place them in renewed danger.292 Following their return to Colombia, the pressure and threats increased, as of 2005.293 Hence, on June 26, 2006, at the request of the Corporación Colectivo de Abogados,294 the InterAmerican Commission ordered urgent precautionary measures to protect the life and personal integrity of Iván Cepeda, Claudia Girón and Emberth Barrios Guzmán,295 because “the beneficiaries have allegedly been threatened and followed, which increases the risk for their life in light of the context of accusations and acts of violence against members of the [UP],” and that “an attempt had been made on the life” of Iván Cepeda Castro’s escort.296 288 Cf. Ricardo Canese v. Paraguay. Merits, reparations and costs. Judgment of August 31, 2004. Series C No. 111, para. 115; Case of Valle Jaramillo et al. v. Colombia, supra note 16, para. 138; Case of the Ituango Massacres v. Colombia, supra note 16, para. 206; and Moiwana Community v. Suriname. Preliminary objections, merits, reparations and costs. Judgment of June 15, 2005. Series C No. 124, para. 110. 289 Cf. United Nations, Human Rights Committee, General Comment No. 27, of November 2, 1999, paras. 1, 4, 8 and 19. Also, Cf. Case of Ricardo Canese v. Paraguay, supra note 288, para. 115; Case of Valle Jaramillo et al. v. Colombia, supra note 16, para. 138; Case of the Ituango Massacres v. Colombia, supra note 16, para. 206; Case of the Moiwana Community v. Suriname, supra note 288, para. 110, and Case of the “Mapiripán Massacre.” Merits, reparations and costs, supra note 22, para. 168. 290 Cf. Case of the “Mapiripán Massacre.” Merits, reparations and costs, supra note 22, para. 170; Case of Valle Jaramillo et al. v. Colombia, supra note 16, para. 139; Case of the Moiwana Community v. Suriname, supra note 288, paras. 119 and 120, and Case of the Ituango Massacres, supra note 16, para. 210. 291 Cf. Case of Valle Jaramillo et al. v. Colombia, supra note 16, para. 139. 292 Sworn statement made before notary public (affidavit) by Claudia Victoria Girón Ortiz, supra note 257, folio 8300. 293 Cf. Opinion provided before notary public (affidavit) by expert witness Carlos Martín Beristain, supra note 208, folio 8241. 294 Cf. brief of the Corporación de Abogados José Alvear Restrepo addressed to the Inter-American Commission on Human Rights on June 6, 2006 (evidence file, tome XII, attachment 182 to the brief with pleadings, motions and evidence of the representatives, folios 5306 to 5317). 295 Cf. letter of the Inter-American Commission on Human Rights of June 26, 2006, concerning the request for precautionary measures MC 125-06 (evidence file, tome IV, attachment 40 to the application, folio 2001). 296 Inter-American Commission on Human Rights, Annual Report, Chapter III, C.1. Precautionary measures granted by the IACHR during 2006, para. 17.