of “the enemy within,” fostered by the so-called “national security doctrine” endorsed in Decree 3398 of 1965 and adopted by the Armed Forces since the early 1960s, and set out in a number of counterguerrilla military regulations and manuals.44 At least some of these regulatory provisions were in force in May 1993.45 In the Isaza Uribe et al. v. Colombia case, the Court was made aware of information indicating that different governments, and especially the Armed Forces, perceived the trade union movement as a manifestation of “international communism” and an integral part of “the enemy within.”46 In a 1994 Joint Report of two United Nations Special Rapporteurs on Colombia, it was documented that, since the establishment of a confederation of a wide variety of unions in 1986, more than 1700 of its members had been murdered and/or had been victims of threats or attacks.47 63. The doctrine of national security was implemented from the 1960s onwards in a number of Latin American countries. It entailed the repression of sectors labelled as “the enemy within” and justified as part of the fight against the communist threat and subversion. Then, during the 1990s, Colombia applied the military doctrine on the political “enemy within,” which condoned the use of irregular practices and targeted social dissidents” and “leftist political parties,”48 including PCC-ML militants. The National Center for Historical Memory affirmed that “the concept of ‘the enemy within’ under the National Security Doctrine employed by the Colombian Armed Forces went far beyond the spectrum of guerrilla groups and extended to all forms of political or social opposition and dissidence, including the trade union movement.”49 64. According to information highlighted by United Nations rapporteurs, between July 1993 and June 1994 more than 4000 people were killed for political or ideological reasons. They also Case of Isaza Uribe et al. v. Colombia. Merits, reparations and costs. Judgment of November 20, 2018. Series C No. 363, paras. 124, 127 and 128. The documentation referred to by the Court on that occasion (cited in footnote 129, paragraph 127), was as follows: Joint Report of the Special Rapporteur on the question of torture, Mr. Nigel S. Rodley, and the Special Rapporteur on the question of extrajudicial, summary or arbitrary executions, Mr. Bacre Waly Ndiaye. E/CN.4/1995/111 of January 16, 1995. In the Case of Rodríguez Vera et al. (Disappeared from the Palace of Justice) v. Colombia, the Court took note that, according to a judgment of the Superior Court of Bogotá, before and after 1985 the so-called “national security doctrine” was still in force in Colombia, under which the military took action against leftist citizens, who were to be eliminated because they were regarded as “the enemy within” (cf. Case of Rodríguez Vera et al. (Disappeared from the Palace of Justice) v. Colombia. Preliminary objections, merits, reparations and costs. Judgment of November 14, 2014. Series C No. 287, footnote 568). In the Villamizar Durán et al. v. Colombia case, the Court noted the figures that confirmed, for 1992, the practice of homicides and massacres against civilians, because, according to the Inspector General’s Office, the Armed Forces regarded them as “enemies or allies of the enemy” (cf. Case of Villamizar Durán et al. v. Colombia. Preliminary objection, merits, reparations and costs. Judgment of November 20, 2018. Series C No. 364, para. 59). Furthermore, in the case of Cepeda Vargas v. Colombia, acts of violence were shown to have been committed against members of a political group simply because they were members of the group. This occurred over a number of years, including 1993 (cf. Case of Cepeda Vargas v. Colombia, supra, paras. 74 to 87). 45 This emerged from a communication from the State received during the proceedings (supra para. 57). And from the oral testimony of expert Alberto Yepes Palacio during the public hearing on February 15, 2022. 46 Cf. Case of Isaza Uribe et al. v. Colombia, supra, para. 125 and footnote 123. 47 United Nations Economic and Social Council. Human Rights Commission. Report of the Special Rapporteur on the question of torture, Mr. Nigel S. Rodley, and the Special Rapporteur on extrajudicial, summary or arbitrary executions, Mr. Bacre Waly Ndiaye, of January 19, 1995. Doc E/CN.4/1995/111 (evidence file, Annex 11 to the pleadings and motions brief, folios 3046 to 3091). 48 Oral testimony of expert Alberto Yepes Palacio during the public hearing on February 15, 2022. According to the expert, the “irregular practices” included the objectives and methods, so that “civil organizations (including political parties, trade unions and social organizations were identified as agents of the insurgent movement and, therefore, the target of military operations,” and attacks even involving the use of “clandestine and secret methods.” He affirmed that “counterinsurgency” actions were also “noted for the emphasis on intelligence as essential to confront the enemy,” with the involvement of the “intelligence sector,” which was poorly regulated and controlled, in “offensive” actions, including clandestine and “dirty” ones. He also pointed out that “since the mid-1980s, and particularly since the failure of the peace process under the government of Belisario Betancur, which culminated in the events of the violent taking and retaking of the Palace of Justice, Colombia has seen an increase in the growing practice of eliminating political militants and activists from leftist organizations.” 49 National Center for Historical Memory. Desaparición forzada Tomo II: Huellas y rostros de la desaparición forzada (1970-2010). Bogotá: Imprenta Nacional, 2013 (evidence file, Annex 32 to the answering brief, folios 8635 to 9081). 44 18