115 288. In this regard, the Court has indicated that domestic law provides for many recourses, but not all of them are applicable in all circumstances. When the recourse is not adequate in a specific case, it is evident that there is no need to exhaust it,233 without prejudice to the possibility that, in certain circumstances, all the recourses available under domestic laws may, collectively, satisfy the requirements established in Articles 8 and 25 of the Convention, even if none of them, individually, comply integrally with these provisions.234 289. In addition, the Court has indicated that the right of access to justice must ensure, within a reasonable time, the right of the alleged victim or his next of kin to every effort being made to learn the truth of what happened and to sanction those responsible.235 With regard to the principle of reasonable time established in Article 8(1) of the American Convention, the Court has established that three elements must be taken into account in order to determine the reasonableness of the time within which the proceedings are held: (a) the complexity of the case; (b) the procedural activity of the party concerned, and (c) the conduct of the judicial authorities.236 However, the pertinence of applying these three criteria to determine the reasonableness of the time of the proceedings depends on the circumstances of each case.237 Thus, the Court will examine the reasonableness of the duration of each of the proceedings, when this is possible and pertinent, bearing in mind the characteristics of this case. 290. In the case sub judice it has been verified that proceedings were opened in the criminal, administrative and disciplinary jurisdictions (supra paras. 125(41) to 125(54) and 125(87) to 125(103)). 291. In this chapter the Court will therefore examine whether these official investigatory actions were executed with due diligence, as well as other elements, in order to determine whether the proceedings and procedures were conducted respecting the right to a fair trial and within a reasonable time, and whether they have constituted an effective recourse to ensure the rights of access to justice and the truth about the facts, and reparation for the next of kin. a) Ordinary criminal jurisdiction 292. As stated above, the Court will now refer to findings applicable to the facts of La Granja and El Aro in relation to the proceedings opened in the ordinary criminal jurisdiction and will then examine the investigations conducted with regard to each of them. 233 Cf. Velásquez Rodríguez case. Judgment of July 29, 1988. Series C No. 4, para. 64. 234 Cf. mutatis mutandis, Eur.C.H.R., Öneryildiz vs. Turkey, No. 48939/99, Judgment of 18 June 2002, para. 100. 235 Cf. Case of Baldeón García, supra note 5, para. 166; Case of the Pueblo Bello Massacre, supra note 9, para. 171; and Case of the “Mapiripán Massacre”, supra note 8, para. 216. 236 Cf. Case of Baldeón García, supra note 5, para. 151; López Álvarez case, supra note 232, para. 132; and Case of the Pueblo Bello Massacre, supra note 9, para. 171. 237 Cf. Case of the Pueblo Bello Massacre, supra note 9, para. 171.

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