freely in the territory in question. 197 Furthermore, the Inter-American Court has held that the lack of an effective investigation into violent acts may lead to or prolong forced exile or displacement. 198 100. In this case, the IACHR considers that the journalist’s temporary exile is one of the foreseeable consequences of the threats against her and the lack of protection attributable to the State. The IACHR therefore considers that, in the present case, there were de facto restrictions on journalist Jineth Bedoya's right to freedom of movement and residence. 101. In conclusion, the IACHR finds the Colombian State responsible for the violation of Articles 4.1, 5.1, 5.2, 7, 11, 13, and 24 of the American Convention, in relation to Article 1.1 thereof, Article 7b of the Convention of Belém do Pará, and Articles 1 and 6 of the IACPPT, to the detriment of Jineth Bedoya Lima. The duty to protect through an effective investigation of the threats and risks facing Jineth Bedoya 102. In its decisions in the cases of Vélez Restrepo and Family v. Colombia and Carvajal Carvajal et al. v. Colombia, the Inter-American Court found that the failure to comply with the obligation to investigate acts of violence against a journalist amounts to a breach of the obligations to respect and guarantee the right to freedom of thought and expression as well as the rights to life and/or humane treatment, depending on the consequences of the act of violence. 199 In this regard, the Inter-American Court has emphasized that in order to determine whether the obligation to protect the rights to life, to humane treatment, and personal liberty by means of a serious investigation of the events has been fully met, it is necessary to examine the domestic proceedings initiated to establish the facts of those events. 103. As has been established, Jineth Bedoya was the victim of continuous threats before her abduction on May 25, 2000, and State authorities were aware of these threats. However, the IACHR has no information on the opening of criminal investigations aimed at identifying the source of the threats or that may have linked them to each other. In fact, the Commission notes that there is no evidence in the case file that any investigation was carried out to establish the origin of the threats reported prior to the events of May 25, 2000 and to punish those responsible, and that this contributed to the failure to protect the victim. Moreover, as discussed in the following section, the IACHR is of the opinion that the measures taken to advance the investigation into the kidnapping, torture, and sexual violence against Jineth Bedoya were inadequate and insufficient to satisfy its obligation to conduct a thorough and diligent investigation, given the seriousness of the crime under investigation and the enhanced obligations in this area. 104. The Commission finds that the lack of effective investigations into these events constitutes a breach of the duty to guarantee the rights of Jineth Bedoya protected in Articles 4.1, 5.1, 5.2, 7, 11, and 13 of the American Convention, in relation to Article 1(1) thereof, Article 7(b) of the Convention of Belém do Pará, and Articles 1 and 6 of the IACPPT. B. Analysis of the rights to a fair trial, judicial protection, and the duty to investigate I/A Court H.R. Case of Vélez Restrepo and Family v. Colombia. Merits, Reparations and Costs. Judgment of September 3, 2012. Series C, No. 248. para. 220; I/A Court H.R. Case of Valle Jaramillo et al. v. Colombia. Merits, Reparations and Costs. Judgment of November 27, 2008. Series C, No. 192. Para. 140-144; I/A Court H.R. Case of Manuel Cepeda Vargas v. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 26, 2010. Series C, No. 213. 198 I/A Court H.R. Case of Vélez Restrepo and Family v. Colombia. Merits, Reparations and Costs. Judgment of September 3, 2012. Series C, No. 248. para. 220; and I/A Court H.R. Case of Carvajal Carvajal et al. v. Colombia. Merits, Reparations and Costs. Judgment of March 13, 2018. 199 I/A Court H.R. Case of Vélez Restrepo and Family v. Colombia. Preliminary Objection, Merits, Reparations and Costs. Judgment of September 3, 2012. Series C, No. 248. Para. 215. 197 26

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