do Pará.” The case related to the context of gender-based violence in Mexico, and the InterAmerican Court examined Articles 4, 5 and 7 of the American Convention and the obligations arising from Articles 7(b) and 7(c) of the “Convention of Belém do Pará” in relation to the general obligation to ensure rights (Art. 1(1) of the American Convention) and the obligation to adopt domestic legal provisions (Art. 2 of the Pact of San José) to the detriment of the three women victims in the case. Consequently, in its judgment in that case, the Court established that the State had not acted with “the due diligence required to adequately prevent the attacks on the victims and their deaths,” an omission that had resulted in non-compliance with its obligation to ensure rights – placing the women victims in a situation of vulnerability – and the enhanced obligations imposed in cases of violence against women by Article 7(b) of the “Convention of Belém do Pará.”14 Furthermore, with regard to Article 7(c) of this instrument, it determined that the State had not proved that it had adopted legislation or implemented the necessary measures, “pursuant to Article 2 of the American Convention and Article 7(c) of the “Convention of Belém do Pará” that would have allowed the authorities to provide an immediate and effective response to the missing person reports and adequately prevent violence against women”; moreover, it had not proved that it had “adopted norms or taken measures to ensure that the officials responsible for receiving reports had the capacity and the sensitivity to understand the seriousness of the phenomenon of violence against women and the willingness to act immediately.”15 10. The same year, the Court again invoked the “Convention of Belém do Pará” in the judgment in the case of the Las Dos Erres Massacre v. Guatemala,16 as a result of the violations of life, torture and acts of violence against women victims perpetrated during the massacre;17 considering that Articles 8(1) and 25(1) of the American Convention, and Articles 1, 6 and 8 of the Inter-American Convention to Prevent and Punish Torture, and 7(b)) of the “Convention of Belém do Pará” had been violated to the detriment of 155 victims, owing to the impediment for the victims to obtain access to justice and full reparation, as a result of the failure to investigate, prosecute and punish those presumed to be responsible for the massacre.18 11. In 2010, in the cases of Fernández Ortega et al.19 and Rosendo Cantú et al.,20 both against Mexico, the Court, for the first time, declared the violation of paragraph (a) of Article 7 of the “Convention of Belém do Pará” as a result of rape perpetrated by soldiers. 21 In both cases, the Court also declared the violation of Articles 8(1) and 25(1) in relation to Article 1(1) of the Convention and Article 7(b) of the “Convention of Belém do Pará,” due to I/A Court HR, Case of González et al. (“Cotton Field”) v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of November 16, 2009. Series C No.205, para. 284. 15 I/A Court HR, Case of González et al. (“Cotton Field”) v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of November 16, 2009. Series C No.205, para. 285. 16 I/A Court HR, Case of the Las Dos Erres Massacre v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of November 24, 2009. Series C No. 211. 17 I/A Court HR, Case of the Las Dos Erres Massacre v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of November 24, 2009. Series C No. 211, para. 139 a 141. 18 I/A Court HR, Case of the Las Dos Erres Massacre v. Guatemala. Preliminary objection, merits, reparations and costs. Judgment of November 24, 2009. Series C No. 211, para. 153. 19 I/A Court HR, Case of Fernández Ortega et al. v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of August 30, 2010 Series C No. 215. 20 I/A Court HR, Case of Rosendo Cantú et al. v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of August 31, 2010 Series C No. 216. 21 I/A Court HR, Case of Fernández Ortega et al. v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of August 30, 2010 Series C No. 215, para. 131, and Case of Rosendo Cantú et al. v. Mexico. Preliminary objection, merits, reparations and costs. Judgment of August 31, 2010 Series C No. 216, para. 121. 14 4