70 relations between women and men,” that “pervades every sector of society regardless of class, race or ethnic group, income, culture, level of education, age or religion and strikes at its very foundations.” 327 191. In keeping with international case law and taking into account the provisions of the Convention of Belém do Pará, the Court has considered that sexual violence is constituted by acts of a sexual nature that, in addition to encompassing the physical invasion of the human body, may include acts that do not involve penetration or even any physical contact. 328 Thus, in another case, the Court established that subjecting women to forced nudity while they were constantly observed by armed men who were apparently members of the State’s security forces, constituted sexual violence. 329 192. Also, pursuant to the jurisprudential and normative standards of both international criminal law and comparative criminal law, the Court has considered that rape does not necessarily entail vaginal sexual intercourse as considered traditionally. Rape should also be understood to include acts of vaginal or anal penetration using other parts of the perpetrator’s body or objects, as well as oral penetration by the male organ. 330 In this regard, the Court clarifies that, for an act to be considered rape, it is sufficient that penetration occurs, however slight this may be, in the terms described above. 331 Furthermore, it should be understood that vaginal penetration refers to penetration with any part of the perpetrator’s body or any object, of any genital opening, including the labia majora or minora, as well as the vaginal orifice. This interpretation is in keeping with the concept that any type of penetration, however slight, is sufficient for an act to be considered rape. The Court understands that rape is a form of sexual violence. 332 327 Inter-American Convention on the Prevention, Punishment and Eradication of Violence against Women, Preamble. 328 Cf. Case of the Miguel Castro Castro Prison v. Peru, supra, para. 306, and Case of J. v. Peru, supra, para. 358. See also, International Criminal Tribunal for Rwanda, The Prosecutor v. Jean-Paul Akayesu, case No. ICTR-96-4T, Judgment of 2 September 1998, para. 688. 329 Cf. Case of the Miguel Castro Castro Prison v. Peru, supra, para. 306. 330 Cf. Case of the Miguel Castro Castro Prison v. Peru, supra, para. 310, and Case of J. v. Peru, supra, para. 359. 331 This is confirmed by the normative and case law of the International Criminal Court and of the ad hoc international criminal tribunals. The first element of the crime against humanity of rape (Rome Statute, Article 7(1) (g)) and of the war crime of rape (Rome Statute, Articles 8(2)(b)(xxii) and 8(2)(e)(vi)) is “The perpetrator invaded the body of a person by conduct resulting in penetration, however slight, of any part of the body of the victim or of the perpetrator with a sexual organ, or of the anal or genital opening of the victim with any object or any other part of the body.” Elements of Crimes, Available on the website of the ICC, http://www.icc-cpi.int/nr/rdonlyres/336923d8a6ad-40ec-ad7b-45bf9de73d56/0/elementsofcrimeseng.pdf. The case law of the ad hoc international criminal tribunals is consistent with this. Cf. International Criminal Tribunal for the former Yugoslavia, The Prosecutor v. Anto Furundzija, Judgment of 10 December 1998, case No. IT-95-17/1-T, para. 185; International Criminal Tribunal for the former Yugoslavia, The Prosecutor v. Kunarac and Others, Judgment of 22 February 2001, case No. IT-96-23-T and IT-96-23/1-T, paras. 437 and 438; International Criminal Tribunal for the former Yugoslavia, The Prosecutor v. Kunarac and Others, Appeal judgment of 12 June 2002, case No. IT-96-23-T and IT-96-23/1-T, para. 127. Cf. Special Court for Sierra Leone, The Prosecutor v. Issa Hassan Sesay and Others, Judgment of 2 March 2009, case No. SCSL04-15-T, paras. 145 and 146. This interpretation was also used by the CVR in its report that “understands rape to be a form of sexual violence that occurs when the perpetrator has invaded the body of a person by a conduct resulting in penetration, however slight, of any part of the body of the victim or of the perpetrator with a sexual organ, or of the anal or genital opening of the victim with any object or any other part of the body. This invasion should occur by force, or by the threat of force or by coercion caused, for example, by the fear of violence, intimidation, detention, psychological oppression or abuse of power, against this or another person or taking advantage of a climate of coercion, or that has been carried out against a person who is unable to give their free consent.” Cf. Informe Final de la Comisión de la Verdad y Reconciliación, Volume VI, Chapter 1.5, p. 265. 332 Cf. Case of J. v. Peru, supra, para. 359. See, in this regard, Article 2 of the Convention of Belém do Pará, and International Criminal Tribunal for Rwanda, The Prosecutor v. Jean-Paul Akayesu, Judgment of 2 September 1998, case No. ICTR-96-4-T, para. 688. The Rome Statute of the International Criminal Court enumerates rape and other specific crimes and adds, in general, in the case of crimes against humanity, “any other form of sexual violence of