mentioned data suggesting that, between January 1993 and March 1994, members of the State
security forces (50.28 per cent) and paramilitary groups (18.98 per cent) together accounted
for nearly 70 per cent of the alleged extrajudicial, summary or arbitrary executions. 50 In 1994,
in its Third Report on Human Rights, the Inspector General’s Office pointed out that the violations
had been so numerous, frequent and serious in recent years that they could not be treated as if
they were merely isolated or individual cases of misconduct by middle or lower ranking police
officers, without attributing any political responsibility to the civil and military hierarchy. 51
A.2 Forced disappearances
65.
As part of the application of the doctrine of national security, forced disappearance was
used as a means of repression against sectors targeted as “the enemy within,” since it was a
repressive method designed to leave no traces, even making it appear that there were no
victims.52
66.
The Observatory of Memory and Conflict of the National Center for Historical Memory has
estimated that 60,630 people disappeared in Colombia between 1970 and 2015.53 In 1988, the
Working Group on Forced or Involuntary Disappearances announced that it had informed the
Government that it had received regular reports from non-governmental sources asserting that
forced disappearances continued to occur in the country. 54
67.
Those singled out for particular attention included members of the Marxist-Leninist
Communist Party of Colombia (PCC-ML) and a guerrilla group with links to it, the Popular
Liberation Army (EPL).55 Although the EPL reached a peace agreement with the government in
1991, during the 1990s many former combatants were victims of human rights violations,
including forced disappearance. In addition to State agents and paramilitary groups, the
guerrillas themselves, especially the FARC, committed acts of deprivation of liberty or
disappearance.56 In 1993, insurgent organizations remained active that were responsible for acts
of various kinds, including “disappearances,” during the armed conflict.57
A.3 Situation of impunity
68.
The Commission pointed out that in its 1996 Annual Report it had warned that, despite
the fact that more than 60,000 disappearances had been reported in Colombia since 1970, there
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 a 3091).
51
Cf. Case of Villamizar Durán et al. v. Colombia, supra, para. 59.
52
Oral testimony of expert Alberto Yepes Palacio during the public hearing on February 15, 2022.
53
National Center for Historical Memory (2016), Hasta encontrarlos. El drama de la desaparición en Colombia
(documentary evidence incorporated ex officio, supra para. 56). Expert Yepes, citing data from a 2013 publication of
the National Center for Historical Memory, pointed out that “information on the alleged perpetrators is hard to come by,
but [...] of the cases in which it has been possible to document the alleged perpetrator, 42.1 per cent are police officers,
41.8 per cent paramilitaries, 19.9 per cent other armed groups and 2.3 per cent guerrillas” (written version of the expert
testimony of Alberto Yepes Palacio (evidence file, folios 10506 to 10553).
54
United Nations. Economic and Social Council. Commission on Human Rights. Report of the Working Group on
Enforced or Involuntary Disappearances. January 12, 1998. Doc. E/CN.4/1998/43 (evidence file, Annex 15 to the
pleadings and motions brief, folios 3369 to 3471).
55
The parties commented that “the Popular Liberation Army (EPL) guerrilla group emerged [from the PCC-ML],”
but clarified that that did not mean that the members of the political party and the guerrilla group were one and the
same.
56
Cf. Written statement rendered by expert Álvaro Villagra Sarmiento (evidence file, folios 10703 to 10732).
57
Cf. Oral testimony of expert Alberto Yepes Palacio during the public hearing of February 15, 2022.
50
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