16 International Human Rights Law has been unsatisfactory, because it “starts out from analogies with solutions of private law and, especially, of civil law, within the framework of domestic legal systems,” strongly influenced by merely patrimonial content and interest. This criterion is inadequate and insufficient in International Human Rights Law, in which “the determination of reparations must take into account the personality of the victim as a whole,” and the impact of the violation committed on the victim or the next of kin of the victim: the starting point must be a perspective that is not merely patrimonial, but rather focused on dignity of the human person. Nonpecuniary reparations are much more important than one might assume prima facie, even to make the violations cease and remove their consequences,58 pursuant to the terms of Article 63(1) of the American Convention. 49. While the concept of “punitive damages” is not foreign to comparative domestic case law, nor to the case law of international arbitration,59 it is not my intention to invoke it here in the sense in which it has been used –in other contexts- as exemplary reparation that is necessarily pecuniary (involving considerable amounts60). Far from it. In the current context of protection, which has its own specificity, other, nonpecuniary forms of reparation have commonly been identified as “obligations to do,” once again suggesting a reductionist analogy with civil law solutions. 50. These forms of reparation (such as those contained in operative paragraphs 7, 8, 9, 10, 11 and 12 of the instant Judgment in the Myrna Mack Chang versus Guatemala case) can well be deemed both compensatory and punitive in nature (containing both civil and criminal aspects). They have exemplary or dissuasive purposes, in the sense of preserving remembrance of the violations occurred, of providing satisfaction (a feeling of realization of justice) to the next of kin of the victim, and of contributing to ensure non-recidivism of said violations (even through human rights training and education). 51. “Punitive damages” may also be conceived in this sense, akin to the “obligations to do” that are both compensatory and punitive (thus overcoming the dichotomy between civil and criminal aspects, typical of the regime of responsibility under domestic law). I would like to mention certain significant examples from the rich case law of the Inter-American Court regarding reparations. In the Aloeboetoe versus Suriname case (Judgment of 10.09.1993), the Court ordered a school reopened and the creation of a foundation to assist the beneficiaries. In the Villagrán Morales et al. versus Guatemala case (the “Street Children” case, Judgment of 26.05.2001), the Court ordered that an educational center be named after the victims in the case; in a similar manner, in the Trujillo Oroza versus Bolivia case (Judgment of 27.02.2002), the Court ordered that an educational center be given the victim’s name. 52. Other examples may be added. In the Cantoral Benavides versus Peru case (Judgment of 03.12.2001), the Court ordered the State to provide a university-level educational scholarship to the victim. In the Barrios Altos case with respect to Peru 58 . Joint Separate Opinion of Judges A.A. Cançado Trindade and A. Abreu Burelli, paras. 6-8, 10-11, 14 and 17. 59 . Cf., e.g., inter alia, R.W. Hodgin and E. Veitch, "Punitive Damages Reassessed", 21 International and Comparative Law Quarterly (1972) pp. 119-132; J.Y. Gotanda, "Awarding Punitive Damages in International Commercial Arbitrations [...]", 38 Harvard International Law Journal (1997) pp. 59-105, respectively; and also cf. examples of the practice (both domestic and international) in D. Shelton, Remedies in International Human Rights Law, Oxford, University Press, 2000, pp. 74-75 and 288-289. 60 . And entailing the risk of a “commercialization” of justice.