74 293. The Tribunal finds that, following the standards established by this Tribunal (supra paras. 287 to 291), the obligation to investigate effectively has a wider scope when dealing with the case of a woman who is killed or, ill-treated or, whose personal liberty is affected within the framework of a general context of violence against women. Similarly, the European Court has said that where an “attack is racially motivated, it is particularly important that the investigation is pursued with vigor and impartiality, having regard to the need to reassert continuously society’s condemnation of racism and to maintain the confidence of minorities in the ability of the authorities to protect them from the threat of racist violence.”306 This criterion is wholly applicable when examining the scope of the obligation of due diligence in the investigation of cases of gender-based violence. 294. In order to determine whether the procedural obligation to protect the rights to life, personal integrity and personal liberty by means of a serious investigation into what happened was fully complied with in this case, the Tribunal must examine the different measures taken by the State after the bodies were found, as well as the domestic procedures to elucidate what occurred and to identify those responsible for the violations perpetrated against the victims. 295. The Court will analyze the dispute between the parties regarding the alleged irregularities concerning: (1) custody of the crime scene, collection and handling of evidence, autopsies, and identification and return of the victims’ remains; (2) actions taken against those presumed to be responsible and alleged ‘fabrication’ of suspects; (3) unjustified delay and absence of substantial progress in the investigations; (4) fragmentation of the investigations; (5) failure to sanction public officials involved in the irregularities, and (6) denial of access to the case file and delays or refusal of copies of this file. 4.2.2.1. Alleged irregularities in custody of the crime scene, collection and handling of evidence, autopsies, and identification and return of the victims’ remains 296. As previously indicated (supra para. 20), the State mentioned two stages of the investigations, the first from 2001 to 2003 and the second from 2004 to 2009. The State acknowledged its responsibility for some irregularities during the first stage, but alleged that, during the second stage, these deficiencies were corrected and it had promoted the “Human Identity Program”, with the participation of the EAAF. 297. The Court observes that on May 1, 2005, the Chihuahua Attorney General’s Office hired the EAAF to assist in the “identification of the remains of unidentified women in the cities of Juárez and Chihuahua,” and also in “the review of cases in which the victims’ next of kin have expressed doubts about the identity of the remains they received.”307 Based on the conclusions reached by the EAAF concerning this case, the evidence in the case file, and the State’s acknowledgement, the Tribunal will refer to the irregularities that occurred in (a) the discovery of the bodies, the custody of the crime scene, and the collection and handling of evidence; (b) the manner in which the 305 Cf. Case of Juan Humberto Sánchez v. Honduras. Preliminary Objection, Merits, Reparations and Costs. Judgment of June 7, 2003. Series C No. 99, para. 112; Case of Valle Jaramillo et al. v. Colombia, supra note 49, para. 97, and Case of Garibaldi v. Brazil, supra note 252, para. 23. 306 307 Cf. ECHR, Case of Angelova and Iliev v. Bulgaria, Judgment 26 July 2007, para. 98. Cf. Contract for professional services signed by the Office of the Attorney General for the state of Chihuahua and the Argentine Forensic Anthropology Team on May 1, 2005 (case file of attachments to the answer to the application, volume XLV, attachment 136, folios 16581 to 16586).

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