2 These violations were perpetrated systematically and at the inter-state level. Thus, as the Court confirmed, “Dr. Goiburú’s disappearance is an example of the coordinated actions taken by the Paraguayan and Argentine security forces under “Operation Condor.” His disappearance fits within the modus operandi used to disappear Paraguayans in Argentina during the military dictatorship in that country” (para. 61(28). 5. On December 22, 1992, numerous documents were revealed that are kept today in the so-called “Terror Files” in Asunción, which is “one of the most important and irrefutable sources of evidence of the grave abuses committed during the dictatorship of General Stroessner. The documents provide an overview of the Stroessner regime and contain abundant evidence of human rights violations, including arbitrary detention, torture, extrajudicial executions and disappearances, as well as the repressive international cooperation” (para. 61(121)). In reality, the facts of the instant case speak for themselves. When determining the State’s international responsibility in the context of this case, the Court stated in its judgment that: “This case has unique historic importance: the facts occurred in the context of the systematic practice of arbitrary detention, torture, execution and disappearance perpetrated by the intelligence and security forces of the dictatorship of Alfredo Stroessner, under “Operation Condor,” whose characteristics and dynamics have been described in the proven facts […]. In other words, the grave acts took place in the context of the flagrant, massive and systematic repression to which the population was subjected on an inter-State scale, because State security agencies were let loose against the people at the transborder level in a coordinated manner by the dictatorial Governments concerned” (para. 62). 1 6. Following the embodiment of the grave violations in the four 1949 Geneva Conventions on international humanitarian law (and the two 1977 Additional Protocols), the current historic process in international law of criminalizing such grave violations of human rights and international humanitarian law was gradually initiated – and has intensified in recent years. The facts concerning “Operation Condor” confirm how appropriate it was to establish a hierarchy of both laws and international illegal acts, in order to determine the legal consequences and avoid the repetition of grave human rights violations. Just as jus cogens prohibitions (cf. infra) have been established on the normative level and, above and beyond this, on the level of substantive law, the establishment of a ranking of violations of law (some being particularly serious, and constituting, in my opinion, true State crimes - infra) is being sought, in order to determine their legal consequences. 7. Indeed, recent advances in the criminalization of grave violations of human rights and international humanitarian law2 have accompanied pari passu the 1 . The Court then observes that “during the 1970s, the fact that power in the region was held by a majority of dictatorial regimes, which shared the ‘doctrine of national security’ as their ideological basis allowed the repression of individuals considered to be ‘subversive elements’ to acquire a transborder nature through “Operation Condor” This was the code name give to the ‘alliance of security forces and intelligence services’ of the Southern Cone dictatorships” (para. 64). 2 . Cf. G. Abi-Saab, “The Concept of 'International Crimes' and Its Place in Contemporary International Law”, in International Crimes of State - A Critical Analysis of the ILC's Draft Article 19 on State Responsibility (eds. J.H.H. Weiler, A. Cassese and M. Spinedi), Berlin, W. de Gruyter, 1989, pp. 141-150; B. Graefrath, “International Crimes - A Specific Regime of International Responsibility of States and Its Legal Consequences”, in ibid., pp. 161-169; P.-M. Dupuy, “Implications of the Institutionalization of International Crimes of States”, in ibid., pp. 170-185; M. Gounelle, “Quelques remarques sur la notion de ‘crime