reasonable time period, the right of the alleged victims or their relatives to know the truth about what happened and investigate what happened to try and punish those eventually found responsible.312 This obligation, which is one of means and not ends, must be assumed by the State as its own juridical duty and not a simple formality condemned beforehand to failure.313 228. Likewise, pursuant to Article 25 of the American Convention, the duty of States to provide judicial remedies is not limited to making them formally available to the victims. Rather, the remedies must be suitable and effective to redress the human rights violations reported.314 In this regard, the Inter-American Court has indicated: the absence of an effective remedy to violations of the rights recognized by the Convention is itself a violation of the Convention by the State Party in which the remedy is lacking. In that sense, it should be emphasized that, for such a remedy to exist, it is not sufficient that it be provided for by the Constitution or by law or that it be formally recognized, but rather it must be truly effective in establishing whether there has been a violation of human rights and in providing redress.315 229. The Court has also specified that the State can be responsible for failure to “order[...], practice[...], or evaluate[...]” evidence that could be fundamental for solving the facts, and the investigation must be aimed at exploring all possible lines of investigation to enable the identification of the perpetrators of the crime so they can be tried and punished.316 230. To comply with this duty to investigate and punish, States must combat impunity in human rights violations “using all the legal means at its disposal to [...] since impunity fosters chronic recidivism [...] and total defenseless of victims and their relatives “317 States therefore must remove all obstacles and mechanisms of fact and law that maintain impunity; grant appropriate security guarantees to witnesses, court [… continuation] v. Honduras. Preliminary Objections Judgment of June 26, 1987. Series C No. 1, para. 91, and Case of Human Rights Defender et al. v. Guatemala. Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 28, 2014. Series C No. 283, para. 199. 312 Inter-American Court. Case of Rodríguez Vera et al. (the Disappeared from the Palace of Justice) v. Colombia. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 14, 2014. Series C No. 287. Para. 435. Citing Case of Bulacio v. Argentina. Merits, Reparations, and Costs. Judgment of September 18, 2003. Series C No. 100, para. 114, and Case of Human Rights Defender et al. v. Guatemala. Preliminary Objections, Merits, Reparations, and Costs. Judgment of August 28, 2014. Series C No. 283, para. 199. 313 Inter-American Court, Case of Velásquez Rodríguez v. Honduras. Merits. Judgment of July 29, 1988. Series C No. 4, para. 177; Inter-American Court., Case of Cantoral Huamaní and García Santa Cruz v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of July 10, 2007. Series C No. 167, para. 131. 314 IACHR, Report No. 28/07. Case 12,496 Claudia Ivette González; Case 12,497 Laura Berenice Ramos Monárrez, Case 12,498 Esmeralda Herrera Monreal (Mexico), Merits, March 9, 2007, para. 210. 315 Case of the “Street Children” (Villagrán-Morales et al.). Judgment of November 19, 1999. Series C No. 63, para. 235 citing Inter-American Court, Case of Cesti Hurtado. Judgment of September 29, 1999. Series C No. 56, para. 121; Inter-American Court. Case of Castillo Petruzzi et al. v. Judgment of May 30, 1999. Series C No. 52, para. 185; Inter-American Court., Judicial Guarantees in States of Emergency (arts. 27(2) and 8 of the American Convention on Human Rights). Advisory Opinion OC-9/87 of October 6, 1987. Series A No. 9, para. 24. 316 Inter-American Court, Case of the “Street Children” (Villagrán-Morales et al.). Judgment of November 19, 1999. Series C No. 63, para. 230. In general, the Court has established certain “guiding principles” that must be observed in criminal investigations into human rights violations, for example: collecting and preserving evidence that may help with any potential criminal investigation of those responsible; identifying potential witnesses and collecting statements; and determining the cause, place, and time of the incident being investigated. It is also necessary to investigate the scene of the crime exhaustively, with rigorous analysis carried out by competent professionals using the most appropriate procedures. Inter-American Court, Case of J. v. Peru. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 27, 2013. Series C No. 275, para. 344, citing the Inter-American Court, Juan Humberto Sánchez v. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of June 7, 2003. Series C No. 99, para. 128. 317 Inter-American Court, Case of Loayza Tamayo v. Peru. Reparations (art. 63(1) American Convention on Human Rights). Judgment of November 27, 1998. Series C No. 42, para. 176, and Inter-American Court, Case of the “White Van” (Paniagua Morales et al.) v. Guatemala. Judgment of March 8, 1998. Series C No. 37, para. 173.

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