40 recognition, enjoyment or exercise by women, irrespective of their marital status, on a basis of equality of men and women, of human rights and fundamental freedoms in the political, economic, social, cultural, civil or any other field.”177 According to the Committee on the Elimination of All Forms of Discrimination against Women, the definition of discrimination includes gender-based violence, that is, violence that is directed against a woman because she is a woman or that affects women disproportionately. It includes acts that inflict physical, mental or sexual harm or suffering, threats of such acts, coercion and other deprivations of liberty.178 158. The close nexus between violence and discrimination is widely recognized in international and regional instruments for the protection of women’s rights. In the case of María Eugenia Morales de Sierra, the IACHR expressed its concern over the serious consequences of discrimination against women and the stereotyped notions of their roles; it also made reference to how discrimination, subordination and violence are interrelated.179 It also observed that the traditional attitudes that regard women as subordinate to men or lock them into stereotyped roles, serve to perpetuate widespread practices involving violence or coercion, such as family violence and abuse.180 Thus, violence against women is a form of discrimination that seriously impairs women’s ability to exercise and enjoy their rights and freedoms on an equal footing with men.181 159. The Commission also finds that violence against women, discrimination and due diligence are also closely related. The CEDAW Committee has observed that violence against women is a form of discrimination and that discrimination is not limited to acts committed by governments or on their behalf; States may also be held accountable for the acts of private persons if they fail to act with due diligence in investigating and punishing the acts of violence and making reparations to the victims.182 According to the United Nations Commission on Human Rights, “all forms of violence against women occur within the context of de jure and de facto discrimination against women and the lower status accorded to women in society and are exacerbated by the obstacles women often face in seeking remedies from the State.”183 160. The Inter-American Court has found that the lack of due diligence that leads to impunity, engenders further incidents of the very violence that was to be targeted, and is itself a form of 177 United Nations, Convention on the Elimination of All Forms of Discrimination against Women. Guatemala ratified the Convention on August 12, 1982. Article 1 of the Convention on the Elimination of All Forms of Discrimination against Women. 178 179 United Nations, CEDAW, General Recommendation 19. IACHR, Report on Merits No. 4/01, María Eugenia Morales de Sierra (Guatemala), January 19, 2001. 180 IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20,2007, Section I, Introduction, Obstacles women encounter when seeking redress for acts of violence: An analysis of the present situation, par. 65. 181 See, IACHR, Report No. 80/11, Case 12.626, Jessica Lenahan (Gonzales) et al. (United States), July 21, 2011, IACHR, Access to Justice for Women Victims of Violence in the Americas, OEA/Ser. L/V/II. doc.68, January 20,2007, Section I, Introduction, Obstacles women encounter when seeking redress for acts of violence: An analysis of the present situation, par. 65. 182 183 United Nations, CEDAW, General Recommendation 19. United Nations Commission on Human Rights, Resolution 2003/45. European Court of Human Rights, Case of Opuz v. Turkey, Application No. 33401/02 of June 9, 2009.