12 Salvador.58 34. In addition, although Article 16 of the American Convention establishes that “[e]veryone has the right to associate freely for […] labor […] purposes,” in general, associations are not formed only for labor purposes, but as this article of the Convention itself indicates, there are other types of associations – ideological, religious, political, economic, social, cultural, sports, or others. I believe that this clarification is of crucial importance, because although, to date, the Inter-American Court has declared the violation of the right to freedom of association for “labor” purposes (focused on labor unions), it has never ruled directly on the right to unionize as an autonomous rights under the Protocol of San Salvador, and the different facts that this right encompasses as delineated, to a great extent, in Advisory Opinion No. 22. 35. When Article 16 of the American Convention establishes “association for labor purposes,” the truth is that “the right to freedom of association” – lato sensu – is, in reality, the genus, so that it may have different species or associations stricto sensu (labor,59 trade union, ideological, religious, political, economic, social, cultural, sports, or others). This distinction provides greater specificity to the right that has been violated and the scope of the area of social rights. For example, while labor associations and trade unions may be protected by the content of social rights, religious or ideological associations would fall within the sphere of the content of civil and political rights. 36. In this regard, to illustrate the foregoing, it is important to mentioned the case of Kawas Fernández v. Honduras, where the Inter-American Court declared that Article 16 of the American Convention had been violated in a non-trade union context. At the time of the facts, “Blanca Jeannette Kawas Fernández was president of the PROLANSATE foundation, and in that capacity she promoted the establishment of public policies on environmental protection in the department of Atlántida, Honduras, as well as awareness regarding natural resource preservation through education, and reported environmental degradation in the area.”60 In this regard, it specified that “[t]he recognition of work in defense of the environment and its connection to human rights is becoming more prominent across the countries of the region, in which an increasing number of incidents have been reported involving murders and threats and acts of violence against environmentalists owing to their work.”61 In that case, the Inter-American Court considered that “Article 16 of the American Convention also includes the right of individuals to set up and participate freely in non-governmental organizations, associations or groups involved in human rights monitoring, reporting and promotion.”62 37. In the instant case, it has been proved that Mr. Lagos del Campo was dismissed owing to statements made in the context of an electoral process that he was called on to supervise as part of his responsibilities. In addition, as a result of his dismissal, the victim could not continue his work of representing the workers on the Electoral Committee. In addition, he was unable to continue his membership in the Industrial Community, since he no longer worked for the company, because the Second Labor Court of Lima determined that the victim’s dismissal was 58 See particularly the construct developed by the Inter-American Court in the case of Gonzales Lluy with regard to the right to education. Case of Gonzales Lluy et al. v. Ecuador, supra, paras. 233 to 291. There are nuances even in the area of labor matters: for example, there may be people who work in an organization or association who are prevented from performing their work, which would mean that their work-related right to freedom of association had been infringed. However, in the case of Lagos del Campos, the purpose was the defense and promotion of his labor-related interests, which made even more specific the right to labor-related freedom of association for labor-related contexts of non-trade union labor associations. 59 Cf. Case of Kawas Fernández v. Honduras. Merits, reparations and costs. Judgment of April 3, 2009. Series C No. 196, para. 151. 60 61 Cf. Case of Kawas Fernández v. Honduras, supra, para. 149. 62 Cf. Case of Kawas Fernández v. Honduras, supra, para. 146.