24 paramilitarism in Colombia, as well as its consequences for those human rights defenders who, like Jesús María Valle Jaramillo, denounced the violations committed by paramilitary elements and some members of the National Army. 75. For example, in the case of the “Mapiripán Massacre,” the Court referred to the “internal armed conflict in Colombia and to the unlawful armed groups called “paramilitary groups,” indicating that: 96(1) Various guerrilla groups began to operate in Colombia in the 1960s and, due to their activities, the State declared that there was a “disturbance of public order and established a state of siege in the territory of the country.” In the face of this situation, the State […] provided the legal basis for the establishment of the “self-defense groups” [and] stipulated that “[a]ll Colombians […] could be used by the Government in activities and work that contributes to reestablishing normality.” [It also…] provided that “[t]he Ministry of National Defense, through authorized command structures, may authorize, when it considers it appropriate, the use by private individuals of weapons whose use is restricted to the Armed Forces.” The “self-defense groups” were legally established under the said provisions, and therefore had the support of State authorities […]. 96(2) In the context of the struggle against the guerrilla groups, the State fostered the creation of the said “self-defense groups” among the civilian population, whose main aims were to assist the security forces in counterinsurgency operations and to defend themselves from the guerrilla groups. The State granted them permits to bear and possess weapons, as well as logistic support. 96(3) During the 1980s, especially after 1985, it became obvious that many “self-defense groups” had changed their objectives and had become criminal groups, commonly called “paramilitary” groups. They developed primarily near the middle course of the Magdalena River, and spread toward other regions of the country. […]28 76. From the foregoing, it is evident that the State encouraged the creation of “selfdefense” groups with specific objectives, but these were overstepped, and the self-defense groups began to function beyond the law. In this regard, the Court has observed that these paramilitary groups are responsible for numerous murders and many of the human rights violations committed in Colombia generally.29 In addition, numerous links between paramilitary groups and members of the armed forces have been demonstrated before this Court in relation to facts similar to those of the present case, as have omissive attitudes by members of the armed forces in relation to the acts of such groups.”30 In cases such as these, the Court has declared that the Colombian State bears international responsibility for the failure to comply with “its obligation to ensure human rights, [and, thus,] its duty of prevention and protection.” 31 77. In this regard, the Court has recognized that, within the framework of the State’s obligation to ensure respect for these rights between individuals, the State’s international responsibility may arise when human rights violations committed by third parties or individuals are attributed to it.32 Hence, the Court has found that: 28 The “Mapiripán Massacre” v. Colombia. Preliminary objections. Judgment of March 7, 2005. Series C No. 122, paras. 96(1) to 96(3). 29 Cf. Case of the “Mapiripán Massacre", supra note 21, para. 96(18), and Case of the Ituango Massacres, supra note 21, para. 125(23). 30 Cf. Case of the “Mapiripán Massacre," supra note 21, para. 96(19); the Pueblo Bello Massacre v. Colombia. Merits, reparations and costs. Judgment of January 31, 2006. Series C No. 140, para. 128, and Case of the Ituango Massacres, supra note 21, para. 125(24). 31 Cf. Case of the Pueblo Bello Massacre, supra note 30, paras. 126 and 140, and Case of the “Mapiripán Massacre,” supra note 21, para. 123. 32 Cf. Case of the Pueblo Bello Massacre, supra note 30, para. 113, and Case of La Rochela Massacre, supra note 21, para. 102.