were conducted and supervised by the Universidad Nacional Experimental de la Seguridad
(UNES).
155. In this regard, the Court appreciates the creation of UNES and establishes that the State
should continue the actions taken to date and implement, within a reasonable time, a
compulsory program or course as part of the general and on-going training of all ranks of the
Police of Aragua state. Among other aspects, this program should refer to the Inter-American
Court’s case law on the prohibition of torture, personal integrity and liberty, the use of force,
and the international human rights obligations derived from the treaties to which Venezuela
is a party.
E.2. Other measures of reparation requested
a) Measures to ensure the effective accountability of state agents
156. The Commission asked the Court to require the State to take measures to ensure
effective accountability in the criminal, disciplinary or administrative jurisdiction, in cases of
alleged abuse of power by the State’s law enforcement agents. The representatives did not
refer to this measure of reparation in their pleadings and motions brief. However, the Court
takes notes that, in their final written arguments, they indicated the need to reiterate to the
State the need to continue making an effort to monitor the actions of the police and the use
of lethal force. The State indicated that, in recent years, it had also been taking measures to
ensure the social auditing and accountability of police actions. It specified that it had adopted
various regulatory instruments in this regard and supported the creation and functioning of
community organizations for police control throughout national territory.
157. In this regard, the Court reiterates that, in the judgment in the case of the Barrios
Family v. Venezuela, it had noted that the State had established principles for the use of force
in the “Manual on differentiated and progressive use of force by the police”; that Venezuelan
law regulated the control, storage and distribution of firearms, established a quarterly
accountability procedure, and specified the circumstances in which police officers were
authorized to carry such weapons. In addition, it noted that the State had created a reporting
system entitled “Report to the immediate superior on use of force,” to be prepared, inter alia,
when a police officer fired a weapon at any individual or group of individuals and, in such
cases, an immediate investigation by trained personnel had to be conducted, and the official
concerned assigned to administrative tasks until the investigation has taken a decision on his
responsibility. Lastly, it indicated that Venezuelan law had established the obligation of police
accountability and, to implement this obligation, a special periodic reporting system on police
activities had been created.180 Consequently, as in the said case, the Court does not find it
necessary to order a measure of reparation such as the one requested.
b) Measures to ensure due diligence in investigations, in keeping with the relevant
international standards
158. The Commission asked that the Court order the State to adopt legislative,
administrative and other measures to ensure that investigations on the need for and
proportionality of the use of lethal force by police agents are conducted with due diligence
and in keeping with the relevant international standards. The victims’ representatives did
not refer to this measure of reparation. The State found it pertinent to underscore that it had
complied fully with the adoption of measures such as those contemplated by the Commission
in its request.
180
Cf. Case of Barrios Family v. Venezuela, para. 346.
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