77 269. The Court has established that the right to movement and residence covered in Article 22.1 is an essential condition for the free development of the person358 and involves, inter alia, the right of those who are legally located within a State to freely circulate in that State, and choose their place of residence.359 This Article also “protects the right to not be forcibly displaced within a State Party to the Convention.”360 270. Regarding the content of the Colombian State’s obligations under Article 22, the Court has established that: Owing to the complexity of the phenomenon of internal displacement and the wide range of human rights affected and jeopardized, and taking into account the circumstance of special vulnerability and defenselessness in which those displace usually find themselves, their situation can be understood as a de facto situation of lack of protection. In the terms of the American Convention, this situation obliges the States to grant the displaced preferential treatment and to adopt positive measures to reverse the effects of this situation of vulnerability and 361 defenselessness, including vis-à-vis acts and practices of individual third parties. 271. The bodies of the Inter-American human rights system have cited the Guiding Principles on Internal Displacement in order to define the content and scope of Article 22 in the context of internal displacement in Colombia.362 The Principles define internally displaced persons as persons or groups of persons who have been forced or obliged to flee or to leave their homes or places of habitual residence, in particular as a result of or in order to avoid the effects of armed conflict, situations of generalized violence, violations of human rights or natural or human-made disasters, and who have not crossed an internationally recognized State border.363 Colombian law has established a similar definition to the one in the guiding principles.364 272. The IACHR has referred to forced displacement as one of the four major forms of violence that mainly affects women as part of the armed conflict in Colombia.365 It has identified as the 358 IA Court of HR, Case of the Massacres of Ituango v. Colombia. Preliminary Objections, Merits, Reparation and Costs. Judgment July 1, 2006 Series C No. 148, par. 206; IA Court of HR, Case of the Massacre of Mapiripán v. Colombia. Merits, Reparation and Costs. Judgment September 15, 2005. Series C No. 134, par. 168. 359 IA Court of HR, Case of the Massacres of Ituango v. Colombia. Preliminary Objections, Merits, Reparation and Costs. Judgment July 1, 2006 Series C No. 148, par. 206; IA Court of HR, Case of the Molwana Community v. Suriname. Preliminary Objections, Merits, Reparation and Costs. Judgment June 15, 2005. Series C No. 124, par. 110. 360 IA Court of HR, Case of the Massacre of Mapiripán v. Colombia. Merits, Reparation and Costs. Judgment September 15, 2005. Series C No. 134, par. 188. 361 IA Court of HR, Case of the Massacres of Ituango v. Colombia. Preliminary Objections, Merits, Reparation and Costs. Judgment July 1, 2006 Series C No. 148, par. 210; IA Court of HR, Case of the Massacre of Mapiripán v. Colombia. Merits, Reparation and Costs. Judgment September 15, 2005. Series C No. 134, par. 168. 362 United Nations Guiding Principles for Internal Displacement, E/CN.4/1998/53/Add.2 February 11, 1998, available at http://www.acnur.org/t3/fileadmin/scripts/doc.php?file=biblioteca/pdf/0022 363 United Nations Guiding Principles for Internal Displacement, Principle 2. 364 Law 387 of 1997, Article 1, available at http://www.gparlamentario.org/spip/IMG/pdf/Ley_387_de_24-71997_Personas_desplazadas_-_Colombia.pdf; IACHR, Third Report on the Human Rights Situation in Colombia, OEA/Ser.L/V/II.102, Doc. 9, rev. 1, February 26, 1999. 365 IACHR, Violence and Discrimination against Women in the Armed Conflict in Colombia, OEA/Ser.L/V/II. Doc. 67, October 18, 2006, par. 4.