85 a) the State has incurred international responsibility for violation of the right to humane treatment of the inmates burned or injured as a result of the three fires, of all the inmates incarcerated at the Center between August 14, 1996 and July 25, 2001, and those who were subsequently sent to adult prisons. Its international responsibility has been engaged by its failure to take the minimum and most elementary measures necessary to ensure the free and full exercise of that right to personal integrity and to prevent its violation; b) the injured and burned inmates who survived the fires clearly sustained physical and emotional harm; the State is therefore responsible for violation of those former inmates’ right to humane treatment; and c) time and time again, the State transferred inmates from the Center to adult penal institutions, particularly after each fire, thereby placing these transferred children’s personal safety at risk. That practice violated international standards on the treatment of children deprived of their liberty. Pleadings of the representatives 138. Concerning the violation of Article 19 of the Convention, in relation to Article 1(1) thereof, the representatives argued that: a) the State violated Article 19 to the detriment of the three thousand seven hundred forty-four children detained at the Center at one time or another in the period from August 14, 1996 to July 25, 2001, and those who were subsequently sent to adult prisons; b) the children interned in the Center were in constant danger and at high risk on three counts: they were children, they were deprived of their liberty and, from the socioeconomic standpoint, they were all very poor; c) the special measures of protection for children imply not only an obligation to respect their rights, but also to guarantee those rights and to take positive measures, informed by the principles of nondiscrimination and the best interests of the child, to ensure that the children are protected from any form of abuse, whether in their relations with the public authorities, in their inter-personal relations or their relations with non-State entities; d) at the time of the events, not one of the alleged victims had reached the age of majority. Under the law in effect in Paraguay at that time, the age of majority was 20, not 18; e) the State did not cultivate public policies for the comprehensive protection of the child: it never adapted its local laws and denied children certain benefits. The new Child and Adolescent Code took effect in 2001 and was randomly enforced. The legal counsel that the Public Ministry provided to the inmates at the Center was in general substandard; f) the State did not devise a system for children in conflict with the law that was tailored to their status as children and that was commensurate with international principles of juvenile justice;

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