5 regrettable that since then, despite such acknowledgement, there has not been sufficient commitment to exercise the required due diligence [in the] investigation process.” 11. That, in cases of extrajudicial executions, it is essential for States to conduct an effective investigation regarding the deprivation of the right to life enshrined in Article 4 of the Convention and to punish all those responsible therefor, especially when State officials are involved.5 12. That the duty to investigate is an imperative obligation of the State that derives from international law and, as previously pointed out by this Court, in cases of gross violation of fundamental rights the pressing need to prevent the recurrence of such violations depends, to a great extent, on tackling impunity and satisfying the right of both the victims and society as a whole to know the truth about what happened.6 13. That the Court has defined impunity as the overall lack of investigation, arrest, prosecution and conviction of those responsible for violations of the rights protected by the American Convention.7 Furthermore, the fight against impunity extends beyond criminal justice insofar as, depending on each specific case, other legal consequences may arise for both the State and the perpetrators. 14. That impunity may result from many circumstances, whether from failing to organize the government apparatus to investigate crimes8 or conducting domestic proceedings in a manner that causes undue delay or hindrance;9 from failing to statutorily define an independent crime, which prevents the effective conduct of a criminal proceeding;10 from enacting self-amnesty laws;11 from failing to execute an 5 Cf. Case of Myrna Mack-Chang v. Guatemala. Merits, Reparations and Costs. Judgment of November 25, 2003. Series C No. 101, para. 156; Case of Valle-Jaramillo et al. v. Colombia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 192, para. 101, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala. Monitoring Compliance with Judgment. Order of the President of the Court of January 27, 2009, Considering clause No. 17. 6 Cf. Case of Vargas-Areco v. Paraguay. Merits, Reparations, and Costs. Judgment of September 26, 2006. Series C No. 155, para. 81; Case of Escué-Zapata v. Colombia. Merits, Reparations, and Costs. Judgment of July 4, 2007. Series C No. 165, para. 75, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala, supra note 5, Considering clause No. 18. 7 Cf. Case of the “White Van” (Paniagua-Morales et al.) v. Guatemala. Merits. Judgment of March 8, 1998. Series C No. 37, para. 173; Case of Tiu-Tojín v. Guatemala. Merits, Reparations and Costs. Judgment of November 25, 2008. Series C No. 190, para. 69, and Case of Bámaca-Velásquez v. Guatemala. Monitoring Compliance with Judgment. Order of the Court of January 27, 2009, Considering clause No. 24. Cf. Case of Velásquez-Rodríguez v. Honduras. Merits. Judgment of July 29, 1988. Series C No. 4, paras. 176 and 177, Case of Tiu-Tojín v. Guatemala, supra note 7, para. 69, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala, supra note 5, Considering clause No. 20. 8 9 Cf. Case of Bulacio v. Argentina. Merits, Reparations and Costs. Judgment of September 18, 2003. Series C No. 100, para. 115; Case of Bayarri v. Argentina. Preliminary Objection, Merits, Reparations and Costs. Judgment of October 30, 2008. Series C No. 187, para. 116, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala, supra note 5, Considering clause No. 20. 10 Cf. Case of Heliodoro-Portugal v. Panama. Merits, Reparations, and Costs. Judgment of August 12, 2008. Series C No. 186, para. 183, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala, supra note 5, Considering clause No. 20. 11 Cf. Case of Barrios Altos v. Peru. Merits. Judgment of March 14, 2001. Series C No. 75, para. 43, and Case of Cantoral-Huamaní and García-Santa Cruz v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of July 10, 2007. Series C No. 167, para. 190, and Case of the “Street Children” (Villagrán-Morales et al.) v. Guatemala, supra note 5, Considering clause No. 20.