15 recourse.30 Thus, P. Mertens warned, more than three decades ago, that work had to be done in order for the right to an effective recourse (Article 13 of the European Convention) to generate all its effects in the domestic legislation of the States Parties. Actually, the “effectiveness” of that right is measured in the light of the criteria of the guarantees of the due process of law (Article 6 of the European Convention); thus the conclusion of P. Mertens, in the sense that Articles 6 and 13 of the European Convention – that correspond to Articles 8 and 25 of the American Convention – must be frequently “invoked jointly”. ("invoqués ensemble")31 46. In effect, with the passing of the years, the attention started turning to the relationships between Articles 13 and 6(1) of the European Convention, the latter (right to a fair trial) being the object of a very vast case-law of the European Court, next to a dense doctrinarian debate.32 In an emphatic decision in the case of Kudla versus Poland (Judgment of 10.18.2000), the European Court on Human Rights stated that the time had come to put an end to the uncertainties of the past and admit the direct relationship between Articles 6(1) and 13 of the European Convention (cf. paras. 146-149 and 151). And, in a meaningful obiter dictum, the European Court stated that "(...) Article 13, giving direct expression to the State's obligation to protect human rights first and foremost within their own legal system, establishes an additional guarantee for an individual in order to ensure that he or she effectively enjoys those rights. The object of Article 13, as emerges from the travaux préparatoires [of the European Convention on Human Rights], is to provide a means whereby individuals can obtain relief at national level for violations of their Convention rights before having to set in motion the international machinery of complaint before the Court. From this perspective, the right of an individual to trial within a reasonable time will be less effective if there exists no opportunity to submit the Convention claim first to a national authority; and the requirements of Article 13 are to be seen as reinforcing those of Article 6(1), rather than being absorbed by the general obligation imposed by that Article not to subject individuals to inordinate delays in legal proceedings" (para. 152). 47. And the European Court concluded, in this regard, in the mentioned case of Kudla versus Poland, that "the correct interpretation of Article 13 is that that provision guarantees an effective remedy before a national authority for an alleged breach of the requirement under Article 6(1) to hear a case within a reasonable time." (para. 156) Therefore, the Court determined that in the specific case "there has been a violation of Article 13 of the Convention in that the applicant had no domestic remedy whereby he could enforce his right to a hearing within a 'reasonable time' as guaranteed by Article 6(1) of the Convention." (para. 160) 48. In truth, in the last years (from the end of the seventies up to this date), the European Court has, in successive cases, taken into account the demands of the due process of law (Article 6 of the European Convention) in direct correlation with that of a right to an effective recourse (Article 13 of the Convention). 33 The right to an 30 P. Mertens, Le droit de recours effectif devant les instances nationales en cas de violation d'un droit de l'homme, Bruxelles, Éd. de l'Univ. de Bruxelles, 1973, pp. 19-20, 24-25 y 27-29, and cf. pp. 37-39. 31 Ibid., p. 93. 32 L.-E. Pettiti, E. Decaux and P.-H. Imbert, La Convention Européenne des droits de l'homme, Paris, Economica, 1995, pp. 455-474. 33 For examples, cf. M. de Salvia, Compendium de la CEDH - Les principes directeurs de la jurisprudence relative à la Convention européenne des droits de l'homme, Kehl/Strasbourg, Éd. Engel, 1998,