-120investigation into the facts and in view of the limitations inherent in this type of procedure – owing to the nature of the offences investigated and the mandate of the body in charge of the investigations – this procedure did not constitute a sufficient or effective recourse for the respective purposes. Administrative proceedings 205. Since 2001, the next of kin of 39 of the victims of the Pueblo Bello massacre have filed claims for direct reparation before the Administrative Court of Antioquia, in Medellín, in relation to the facts of the instant case. The purpose of these claims is for the court to declare “the Colombian Nation - Ministry of National Defense – National Army […] administratively responsible” for pecuniary and non-pecuniary damage, “including the damage arising from alterations in family, social and affective life,” caused to the next of kin as a result of the violation of “the rights to life, humane treatment, security, liberty, [to effective judicial protection, judicial guarantees, to the truth and to justice] arising from the collective forced disappearance of the victims […].” 206. In the “Mapiripán Massacre” case, the Court found that the comprehensive reparation of a violation of a right protected by the Convention cannot be reduced to the payment of compensation to the next of kin of the victim. Hence, it took into account some of the results obtained in the administrative proceedings instituted by the next of kin of the victims in that case, considering that the compensation established by those instances for pecuniary and non-pecuniary damage was included in the broadest concepts of pecuniary and non-pecuniary reparations. Thus, the Court indicated that those results could be considered when establishing the pertinent reparations, “on the condition that what was decided in those proceedings has been considered res judicata and is reasonable in the circumstances of the case.”239 When establishing the international responsibility of the State for the violation of the human rights embodied in Articles 8(1) and 25 of the American Convention, a substantial aspect of the dispute before the Court is not whether judgments were delivered at the national level or whether settlements were reached on the civil or administrative responsibility of a State body with regard to the violations committed to the detriment of the next of kin of the persons disappeared or deprived of life, but whether the domestic proceedings allowed real access to justice to be ensured, according to the standards established in the American Convention.240 207. In this respect, the European Court of Human Rights examined the scope of civil responsibility in relation to the requirements of international protection in Yasa v. Turkey, and found that: An administrative-law action is a remedy based on the strict liability of the State, in particular for the illegal acts of its agents, whose identification is not, by definition, a prerequisite to bringing an action of this nature. However, the investigations which the Contracting States are obliged [...] to conduct in cases of fatal assault must be able to lead to the identification and punishment of those responsible [...t]hat obligation cannot be satisfied merely by awarding damages [...] Otherwise, [...] the State’s obligation to seek those guilty of fatal assault might thereby disappear.241 239 Cf. Case of the “Mapiripán Massacre”, supra note 7, para. 214. 240 Cf. Case of the “Mapiripán Massacre”, supra note 7, para. 211. 241 Cf. European Court of Human Rights. Yasa v. Turkey [GC], judgment of 2 September 1998, Reports of Judgments and Decisions 1998-VI, § 74.