6 protection requires the Court to make a more rigorous evaluation of the persistence of the situation that gave rise to them.6 If a State requests the lifting or modification of the provisional measures ordered, it must present sufficient evidence and arguments to allow the Court to assess that the risk or threat no longer complies with the requirements of extreme gravity and urgency to avoid irreparable damage. In addition, the burden of proof and argument on the beneficiaries and on the Commission will increases as time passes and there are no new threats. Evidently, the fact that there are no new threats may be due, precisely, to the effectiveness of the protection provided or the dissuasive effects of the Court’s orders. Nevertheless, the Court has considered that the passage of a reasonable period of time without threats or intimidation, added to the absence of an imminent risk, may lead to the lifting of the provisional measures.7 16. In addition, the Court must take into account that, according to the Preamble of the American Convention, international protection in the form of a convention “reinforces or complements the protection provided by the domestic law of the American States.” Therefore, should there be evidence that the State in question has developed effective mechanisms or measures of protection for the beneficiaries of the provisional measures, the Court could decide to lift the provisional measures, delegating the obligation to protect to the principal body responsible for them; namely, the State.8 Should the Court lift the provisional measures for this reason, the State would be bound, in keeping with its obligation to guarantee human rights, to maintain any protective measures it might have adopted and that the Court had considered effective, for as long as the circumstances require them. 17. In recent years, the present provisional measures have been maintained owing to the connection that the representatives made between the information presented by the State on the investigations in the domestic criminal proceedings with the increase in the risk that this created for the beneficiary owing to her participation in those investigations. However, this presumed risk has been alleged before the Court on successive occasions as a potential danger, unrelated to specific risk factors. 18. In this regard, the Court observes that, after having reported merely the said potential danger in the context of the procedure of monitoring compliance with the judgment in this case, the representatives indicated that “death threats had been made against Mrs. […] Parra shortly after she testified in the criminal proceedings on Prisons. Provisional measures with regard to the Argentine Republic. Order of the Inter-American Court of Human Rights of November 26, 2010, thirty-ninth considering paragraph. 6 Cf. Matter of the Kankuamo Indigenous People. Provisional measures with regard to Colombia. Order of the Inter-American Court of Human Rights of April 3, 2009, seventh considering paragraph; Case of the Mapiripán Massacre. Provisional measures with regard to Colombia. Order of the Inter-American Court of Human Rights of September 2, 2010, twenty-sixth considering paragraph, and Matter of Eloisa Barrios et al, supra note 2, fourth considering paragraph. 7 Cf. Matter of Gallardo Rodríguez. Provisional measures with regard to Mexico. Order of the InterAmerican Court of Human Rights of July 11, 2007, eleventh considering paragraph; Case of the Mapiripán Massacre, supra note 6, twenty-eighth considering paragraph, and Matter of the Mendoza Prisons, supra note 5, thirty-ninth considering paragraph. 8 Cf. Matter of Luis Uzcátegui. Provisional measures with regard to Venezuela. Order of the InterAmerican Court of Human Rights of February 20, 2003, thirteenth considering paragraph; Case of the Plan de Sánchez Massacre. Provisional measures with regard to Guatemala. Order of the Inter-American Court of Human Rights of July 8, 2009, sixth considering paragraph, and Case of Mack Chang et al. Provisional measures with regard to Guatemala. Order of the Inter-American Court of Human Rights of November 16, 2009, sixth considering paragraph.

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