199. Similarly, the Human Rights Committee has indicated that the deterioration in health that a person may suffer “in custody must be held to be attributable to the State,” 236 so that the burden of proof does not rest exclusively on the complainant, especially considering that the complainant and the State “do not always have equal access to the evidence and that, frequently, the State […] alone has access to relevant information” in circumstances of detention. “The State has the duty to investigate in good faith all allegations of violations of [human rights] made against it […], especially when such allegations are corroborated by evidence submitted by the [complainant. …] When further clarification of the case depends on information exclusively in the hands of the State, the Committee may consider such allegations as substantiated in the absence of satisfactory evidence and explanations to the contrary” to refute the claims of the complainants. 237 200. In this regard, the Court noted that the report on autopsy No. 1018-96 performed on Eduardo Landaeta’s body found other injuries, in addition to the bullet wounds, namely: (a) the partial detachment of the skin of the right buttock “as if it had been burned,” with similar characteristics on both elbows; (b) fairly deep, but incomplete circular marks on the wrists of both hands, and (c) bruising on the lower lip (supra paras. 102 and 191). In addition, as already indicated, according to the statements made by Eduardo’s parents, they advised a State official of the danger faced by their son (supra para. 70). 201. Based on this evidence, it is reasonable to infer the existence of injuries with different characteristics to those that caused Eduardo Landaeta’s death while in State custody. Despite this evidentiary material, the case file does not include other indications that could corroborate his state of health when he entered the police station and before his transfers, as well as other more convincing evidence that could establish the type of injuries, when they were caused, and the circumstances. 238 Therefore, in principle, it is not incumbent on the Court to determine a direct violation of Article 5(2) of the Convention, arising from possible cruel, inhuman or degrading treatment or torture that can be attributed to the State. 236 Cf. United Nations, Human Rights Committee, Case of Sathasivam and Saraswathi v. Sri Lanka. Communication No. 1436/2005, UN Doc. CCPR/C/93/D/1436/2005, 8 July 2008, para. 6.2. 237 Cf. United Nations, Human Rights Committee. Case of Irene Bleier Lewenhoff and Rosa Valiño de Bleier v. Uruguay. Communication No. 30/1978, UN Doc. CCPR/C/OP/1 at 109, 29 March 1982, para. 13.3; Case of Albert Womah Mukong v. Cameroon. Communication No. 458/1991, UN Doc. CCPR/C/51/D/458/1991, 21 July 1994, para. 9.2, and Case of Turdukan Zhumbaeva v. Kyrgyzstan. Communication No. 1756/2008, UN Doc. CCPR/C/102/D/1756/2008, 29 July 2011, para. 8.7. 238 In this regard, to avoid situations that endanger juvenile detainees, the Court deems it pertinent to take into account Rule 21 of the “United Nations Rules for the Protection of Juveniles Deprived of their Liberty,” which establishes that: “[i]n every place where juveniles are detained, a complete and secure record of the following information should be kept concerning each juvenile received: (a) Information on the identity of the juvenile; (b) The fact of and reasons for commitment and the authority therefor; (c) The day and hour of admission, transfer and release; (d) Details of the notifications to parents and guardians on every admission, transfer or release of the juvenile in their care at the time of commitment; (e) Details of known physical and mental health problems, including drug and alcohol abuse.” In addition Rule 22 stipulates that: “[t]he information on admission, place, transfer and release should be provided without delay to the parents and guardians or closest relative of the juvenile concerned.” Cf. United Nations. Rules for the Protection of Juveniles Deprived of their Liberty (The Havana Rules), adopted by General Assembly Resolution 45/113, of 14 December 1990. Meanwhile, Article 40(1) of the Convention on the Rights of the Child establishes the right of every child accused of, or recognized as having infringed the penal law to be treated in a manner consistent with the promotion of the child’s sense of dignity and worth; as well as the principle of innocence (Art. 40(2) (b)(i)), and the right to be informed promptly of the charges against him or her (Art. 40(2) (b)(ii)). Lastly, Rule 10 of the Beijing Rules on “Initial Contact” should be mentioned; in particular Rule 10.1 which stipulates the obligation to immediately notify any “apprehension of a juvenile [to] her or his parents or guardian,” and Rule 10.3 which regulates the contacts between the law enforcement agencies and a juvenile offender, “in such a way as to respect the legal status of the juvenile, promote the well-being of the juvenile and avoid harm to her or him.” 52

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