-5ways of accepting the contentious jurisdiction of the Inter-American Court that is numerus clausus (other restrictions not established in Article 62 of the Convention are inadmissible),11 rather than the process of attributing international responsibility to the defendant State. 12. This attribution should take into account the factual circumstances which vary from case to case. It is not, therefore, a mechanical process that can be regulated by numerus clausus. On this issue, I observed in my above-mentioned separate opinion in the Mapiripán Massacre case (2005) that: "International responsibility is attributed to a State following prudent assessment by members of the competent judicial body, after they have carefully determined the facts of each specific case; it is not merely the mechanical application of specific formulations of precepts that are, in any case, of a supplementary nature" (para. 10). 13. With these brief prior considerations in mind, I will now continue on to the substance of my observations in this separate opinion concerning the correct decision made by the Court in the Pueblo Bello Massacre case to rule on the violations of Articles 8 and 25 of the American Convention together, in keeping with its consistent case law. My reflections in this respect encompass the following aspects: (a) Articles 25 and 8 of the Convention at the ontological and hermeneutic levels; (b) the genesis of the right to an effective recourse before the national courts in the corpus juris of international human rights law; (c) the irrelevance of the allegation of difficulties arising from domestic law; (d) the right to an effective recourse in the case law of the Inter-American Court; (e) the indivisibility of access to justice (the right to an effective recourse) and the guarantees of due process of law (Articles 25 and 8 of the American Convention); (f) the indivisibility of Articles 25 and 8 of the American Convention in the consistent case law of the Inter-American Court; (g) the indivisibility of Articles 25 and 8 of the American Convention as an inviolable advance in case law; (h) overcoming the difficulties concerning the right to an effective recourse in the case law of the European Court; (i) the right of access to justice lato sensu; and (j) the right of access to justice as an imperative of jus cogens. II. Articles 25 and 8 of the American Convention at the ontological and hermeneutic levels 14. It is axiomatic that each of the rights protected by the human rights treaties has its own content, from which the different formulations arise - as is the case of Articles 25 and 8 of the American Convention. Here, we are on an essentially ontological level. Although they are endowed with their own material content, some of these rights have had to undergo a long jurisprudential evolution until they achieved autonomy. This is the case, for example, of the right to an effective recourse in Article 25 of the American Convention and Article 13 of the European Convention on Human Rights (cf. infra). It is also the case of Article 8 of the American Convention and Article 6 of the European Convention. 15. Nowadays, the meaning given to the treaty-based provisions is the result of the development of case law and they are understood and should be appreciated in light of this development, in keeping with the principle of inter-temporal law - and 11 . Cf. IACourtHR, judgments in Hilaire, Benjamin et al., and Constantine et al. v. Trinidad y Tobago (of September 1, 2001), separate opinions of Judge A.A Cancado Trindade, para. 21-33 (in the three opinions).