14 obstacles of the dogmas of the past, as well as the current inadequacies and ambiguities of the law of treaties, so as to bring us closer to the plenitude of the international protection of the human being. 41. Within the legal situation created in the Blake versus Guatemala case before the Inter-American Court, this latter has, however, succeeded, in the present Judgment on reparations as well as in the previous Judgment on the merits of the case, to contribute - in relation to a specific aspect - to the jurisprudential treatment of the crime of forced disappearance of person, to the extent that it gives precision to, and consolidates, the position of the relatives of the disappeared person also as victims and titulaires of the rights protected by the American Convention on Human Rights. All those who were withdrawn from the protection of the law - the disappeared person as well as his relatives - form, thus, the "injured party", in the sense of Article 63(1) of the American Convention, as recognized in the present Judgment on reparations of the Court. 42. This position finds full support in contemporary doctrine and case-law. The Declaration of Basic Principles of Justice for Victims of Crime and Abuse of Power (United Nations, 1985)36 affirms that "the term `victim' also includes, where appropriate, the immediate family or the dependents of the direct victim and the people injured by interceding to give assistance to the suffering victims or to prevent the victimization" (paragraph 2 in fine). In the African continent, in the K. Achuthan (on behalf of A. Banda) versus Malawi case (1994), the African Commission on Human and Peoples' Rights accepted that the petitioner acted on behalf of his fatherin-law, and established a violation of Articles 4, 5, 6, 7(1)(a)(c) and (d), and 26, of the African Charter on Human and Peoples' Rights37. 43. In the European continent, already in 1970 the old European Commission of Human Rights sustained, in the X versus Federal Republic of Germany case, that the term "victim" meant "not only the direct victim or victims of the alleged violation but also any person who would indirectly suffer prejudice as a result of such violation or who would have a valid personal interest in securing the cessation of such violation"38. This understanding was also advanced by the Commission in other Recueil des Cours de l'Académie de Droit International de La Haye (1971) pp. 320-324. E. Suy, "The Concept of Jus Cogens in Public International Law", Papers and Proceedings of the Conference on International Law (Lagonissi/Greece, 03-08.04.1966), Geneva, C.E.I.P., 1967, pp. 17-77; Ch. de Visscher, "Positivisme et jus cogens", 75 Revue générale de Droit international public (1971) pp. 5-11; A. Verdross, "Jus Dispositivum and Jus Cogens in International Law", 60 American Journal of International Law (1966) pp. 55-63; U. Scheuner, "Conflict of Treaty Provisions with a Peremptory Norm of International Law", 27 and 29 Zeitschrift für ausländisches öffentliches Recht und Völkerrecht (1967 and 1969) pp. 520-532 and 28-38, respectively; H. Mosler, "Ius Cogens im Völkerrecht", 25 Schweizerisches Jahrbuch für internationales Recht (1968) pp. 1-40; K. Marek, "Contribution à l'étude du jus cogens en Droit international", Recueil d'études de Droit international en homage à P. Guggenheim, Geneva, IUHEI, 1968, pp. 426-459. 36. Adopted by resolution 40/34 of the General Assembly of the United Nations, of 29.11.1985. 37. Communication n. 64/92, in ACHPR, Decisions of the African Commission on Human and Peoples' Rights, 1986-1997, Series A, vol. I, Banjul, 1997, pp. 63 and 68. 38. Application n. 4185/69, decision of 13.07.1970, in: Collection of Decisions of the European Commission of Human Rights, vol. 35, pp. 140-142; la applicant - wife of a person detained in an asylum for the mentally ill - considered herself an "indirect victim" of the detention of her husband pursuant to decisions of the German tribunals.