-924. Almost 10 years ago, in my dissenting opinion in Genie Lacayo v. Nicaragua (Request for review of judgment, order of September 13, 1997),19 I analyzed the material content and the scope of Article 25 (right to an effective recourse) of the American Convention on Human Rights, in relation to Article 8(1) (due process of law) of the Convention, and also to the general obligations (to guarantee the exercise of the protected rights and to harmonize domestic law to international treaty-based law) embodied, respectively, in Articles 1(1) and 2 of the Convention (paras. 18-23 of the said opinion). Contrary to the Court's ruling in that case - which looked at these treaty-based provisions from the viewpoint of formal and not material justice - I concluded that the defendant State had violated Articles 25, 8(1), 1(1) and 2 of the Convention "considered jointly" (para. 28). 25. Following the same reasoning, in my dissenting opinion in Caballero Delgado and Santana v. Colombia (reparations, Judgment of January 29, 1997),20 I also developed a hermeneutics that integrated Articles 8, 25, 1(1) and 2 of the American Convention, once again considering them together (paras. 2-4 and 7-9 of the said opinion), and maintained, contrary to the Court, that the defendant State had violated these four interrelated treaty-based provisions. Regarding the right to an effective recourse under Article 25 of the Convention, in particular, I indicated the following in my said dissenting opinion in Genie Lacayo v. Nicaragua: “The right to a simple, prompt and effective remedy before the competent national judges or tribunals, enshrined in Article 25 of the Convention, is a fundamental judicial guarantee far more important than one may prima facie assume,21 and which can never be minimized. It constitutes, ultimately, one of the basic pillars not only of the American Convention on Human Rights, but of the rule of law (État de Droit) itself in a democratic society (in the sense of the Convention). Its correct application has the sense of improving the administration of justice at national level, with the legislative changes necessary to the attainment of that purpose. The origin - little-known - of that judicial guarantee is Latin American: from its insertion originally in the American Declaration of the Rights and Duties of Man (of April 1948),22 it was transplanted to the Universal Declaration of Human Rights (of December 1948), and from there to the European and American Conventions on Human Rights (Articles 13 and 25, respectively), as well as to the United Nations Covenant on Civil and Political Rights (Article 2(3)). Under the European Convention on Human Rights, in particular, it has generated a considerable case-law,23 apart from a dense doctrinal debate. 19 . Inter-American Court of Human Rights, Series C, No. 45, Application for judicial review of the judgment on merits, reparations and costs, of January 29, 1997, Order of September 13, 1997, pp. 3-25. 20 . 21 ICourtHR, judgment of January 29, 1997 (reparations), Series C, No. 31, pp. 3-43. . Its importance was pointed out, for example, in El Informe de la Comisión de Juristas de la OEA para Nicaragua, of February 4, 1994, pp. 100 and 106-107, paragraphs 143 and 160, published six years later, cf. A.A Cançado Trindade, E. Ferrero Costa and A. Gomez Robledo “Gobernabilidad Democrática y Consolidación Institucional: El Control Internacional y Constitucional de los Interna Corporis – Informe de la Comisión de Juristas de la OEA para Nicaragua (February 4, 1994)” (Boletín de la Academia de Ciencias Políticas y Sociales) (2000) n. 137, p. 603-669. 22 . At a moment when, in parallel, the United Nations Commission on Human Rights was still preparing the draft Universal Declaration (from May 1947 until June 1948), as recalled in a memoir by the rapporteur of the Commission (René Cassin); the insertion of the provision on the right to an effective remedy before national jurisdictions in the Universal Declaration (Article 8), inspired by the corresponding provision of the American Declaration (Article XVIII), took place in subsequent discussions (1948) of the Third Committee of the United Nations General Assembly. Cf. R. Cassin, "Quelques souvenirs sur la Déclaration Universelle de 1948", 15 Revue de droit contemporain (1968) No. 1, p. 10. 23 . Cf. infra. In its beginnings, such case-law maintained the "accessory" nature of Article 13 of the European Convention, considered – as of the 1980s - as guaranteeing a subjective individual substantive right. Gradually, in its judgments in Klass v. Germany (1978), Silver and Others v. United Kingdom (1983), and Abdulaziz, Cabales and Balkandali v. United Kingdom (1985), the European Court of Human