measure which it considers should be adopted in the interests of the parties or of the proper conduct of the proceedings before it […]."6 7. Although the European Court previously considered that the provisional measures it ordered were not legally enforceable since they were not explicitly referred to in the European Convention, from 2005 onwards, the European Court has maintained that a State is obliged to comply with such measures and to avoid any act or omission that undermines the authority and effectiveness of the final ruling. It also set forth that the breach of provisional measures may constitute a violation of Article 34 of the European Convention, which enshrines the right of individual complaint.7 8. It can be concluded from the above that the European Court no longer characterizes provisional measures as an institution that stems —or should stem— from a provision expressly provided for in a convention, and it now considers it to come from the actual protection object of the treaty. II. 9. The Inter-American Court of Human Rights and its competence to order provisional measures. In Article 63(2) of the Convention it sets forth that: [i]n cases of extreme gravity and urgency, and when necessary to avoid irreparable damage to persons, the Court shall adopt such provisional measures as it deems pertinent in matters it has under consideration. With respect to a case not yet submitted to the Court, it may act at the request of the Commission. 10. In turn, Article 27 of the existing Rules of Procedure of the Court states: 1. At any stage of the proceedings involving cases of extreme gravity and urgency, and when necessary to avoid irreparable damage to persons, the Court may, on its own motion, order such provisional measures as it deems appropriate, pursuant to Article 63(2) of the Convention. 2. With respect to matters not yet submitted to it, the Court may act at the request of the Commission. 3. In contentious cases before the Court, victims or alleged victims, or their representatives, may submit to it to a request for provisional measures, which must be related to the subject of the case. […] 6 “The Chamber or, where appropriate, its President may, at the request of a party or of any other person concerned, or of its own motion, indicate to the parties any interim measure which it considers should be adopted in the interests of the parties or of the proper conduct of the proceedings before it […].” 7 Mamatkulov and Askarov. v. Turkey, supra note 2 , para. 128. 3