8 has not been able to generate any awareness in the minds of international jurists, who are mentally hostages of statism. Although most contemporary legal doctrine continues to suffer from an apparent mental lethargy in this respect, some voices are gradually being raised that maintain the existence and occurrence of State crime in certain circumstances. I have spoken out in this regard in my separate opinions in the following cases before the Court: Myrna Mack v. Guatemala (judgment of November 25, 2003), the Plan de Sánchez Massacre v. Guatemala (judgments of April 29, 2004, and November 19, 2004), the Mapiripán Massacre v. Colombia (judgment of March 7, 2004), and the massacre of the Moiwana Community v. Suriname (judgment of June 15, 2005). 26 26. It is not my intention to reiterate here the legal arguments developed in those opinions to sustain my position; I merely wish to refer to them and add some additional elements and reflections. In a study published in 2003, J. Verhaegen, Professor Emeritus of the Catholic University of Louvain, systematically used the expression “State crime” (crime d'État) 27 when referring to certain systematic practices of grave human rights violations as part of a State policy. 28 Other studies identify a tendency towards the necessary criminalization of grave human rights violations in the recent application of certain human rights treaties and international humanitarian law. 29 27. Further studies have identified the criminality of the State and the need to determine its juridical consequences (for example, punitive damages). 30 The determination of State responsibility for grave human rights violations responds to a legitimate concern of the international community as a whole. 31 Studies published from 2002 to 2004 on the succession of genocides 32 and crimes against humanity committed throughout the twentieth century affirm that the massive human rights violations were accompanied by a State policy of “dehumanization” of the victims, in 26 . I also referred to the aggravating circumstances in the cases of massacres submitted to the consideration of the Court in my separate opinion in Baldeón García v. Peru (Judgment of April 6, 2006). 27 . Cf. J. Verhaegen, Le Droit international pénal de Nuremberg: acquis et régressions, Brussels, Bruylant, 2003, pp. 10-11, 22 and 62. 28 . Cf. ibid., pp. 51-53 and 86. 29 . Cf., e.g., S.R. Ratner and J.S. Abrams, Accountability for Human Rights Atrocities in International Law, Oxford, Clarendon Press, 1997, pp. 11, 13-15 and 22-23. 30 . Cf., e.g., N.H.B. Jorgensen, The Responsibility of States for International Crimes, Oxford, University Press, 2003, pp. 231, 264 and 278-283. 31 . Cf., e.g., R. Besné Mañero, El Crimen Internacional - Nuevos Aspectos de la Responsabilidad Internacional de los Estados, Bilbao, Universidad de Deusto, 1999, pp. 78-79, 186, 215, 218, 221 and 230-231. – Unfortunately, there is still a lack of clarity in contemporary international legal doctrine concerning the implications of the complementarity between the State’s international responsibility and the international criminal responsibility of the individual; an illustration of this is to be found in the inadequate treatment, by more than one contemporary international tribunal, of the case of the bombing of Kosovo by NATO (1999); for a critical version, cf., e.g., P. Benvenuti, "The ICTY Prosecutor and the Review of the NATO Bombing Campaign against the Federal Republic of Yugoslavia", 12 European Journal of International Law (2001) pp. 526-527, and cf. pp. 503-529. 32 . Armenia, Soviet Russia, the Holocaust, Cambodia, the former Yugoslavia, Rwanda.