judgments, providing participatory opportunities for dialogue and consensus-building with the State authorities and the victims or their representatives. This new momentum has been well received by the different actors involved in cases before the Court. In this regard, it is worth recalling the observations of the General Assembly of the Organization of American States, which, since 2009, has repeatedly indicated “the importance and constructive nature of the private hearings on monitoring compliance with the judgments delivered by the Inter-American Court and 3 their positive results.” It has also encouraged “the holding of hearings on monitoring compliance with judgments, as one of the most effective mechanisms implemented to 4 make progress in compliance with them.” 3. To illustrate the relevance of this power, it is worth recalling what happened in the case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. In this case, as a result of holding a private hearing and a meeting for discussions at the seat of the Court, the State made a series of commitments addressed at implementing the only operative paragraph of the judgment that remained pending. This resulted in full compliance with the judgment and the closing of the case, seven months after the hearing, with the demarcation and titling of more than 70,000 hectares, in accordance with the order issued by the Court on April 3, 2009.5 Also, in the case of Valle Jaramillo v. Colombia, there was a rapprochement between the State and the representatives during the private hearing towards dialogue and consensus-building to implement the measure of reparation concerning the award of a grant to study or to obtain vocational training, which was provided less than a month later following the joint presentation of an agreement on an alternative way to comply with this 6 measure, which was subsequently found admissible by the Court. Similarly, after a private hearing had been held in the case of Vargas Areco v. Paraguay, the Court recorded, with regard to the obligation to pay the interest on arrears corresponding to the amount of the compensation for pecuniary and non-pecuniary damage, and reimbursement of costs and expenses, “the willingness revealed by the parties to make progress on this point based on an agreement and await[ed] updated information on the steps taken and the results achieved as regards compliance with 7 this aspect of the reparations.” 3 General Assembly, Resolution AG/RES. 2500 (XXXIX-O/09) approved at the fourth plenary session held on June 4, 2009, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights”, p. 3; Resolution AG/RES. 2587 (XL-O/10) approved at the fourth plenary session held on June 8, 2010, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights”, p. 2, and Resolution AG/RES. 2652 (XLI-O/11) approved at the fourth plenary session held on June 7, 2011, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights”, para. 6. 4 General Assembly, Resolution AG/RES. 2500 (XXXIX-O/09), supra note 3, fifth operative paragraph; Resolution AG/RES. 2587 (XL-O/10), supra note 3, fifth operative paragraph, and Resolution AG/RES. 2652 (XLI-O/11), supra note 3, sixth operative paragraph. 5 Cf. Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Monitoring compliance with judgment. Order of the Inter-American Court of Human Rights of April 3, 2009, first and second operative paragraphs. 6 Cf. Case of Valle Jaramillo v. Colombia. Monitoring compliance with judgment. Order of the InterAmerican Court of Human Rights of February 28, 2011, considering paragraphs 34 to 37, and Case of Valle Jaramillo v. Colombia. Monitoring compliance with judgment. Order of the Inter-American Court of Human Rights of May 15, 2011, considering paragraphs 6 to 11. 7 Case of Vargas Areco v. Paraguay. Monitoring compliance with judgment. Order of the Inter-American Court of Human Rights of November 24, 2010, considering paragraph 39. 2

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