considerations; 198 conduct a risk analysis; and implement protection measures that consider the
aforementioned risk faced by women journalists as a result of gender-based violence. 199 In particular,
in addition to the standards on gender-based violence and non-discrimination already developed by
this Court, States must also observe the following positive obligations: a) identify and investigate
with due diligence the special, differentiated risks they face 200 because they are female journalists, 201
as well as the factors that increase the possibility that they are victims of violence, 202 and b) adopt
a gender approach when adopting measures to guarantee the safety of women journalists 203—
including those of a preventive nature—when requested, 204 as well as those aimed at protecting them
from reprisals. 205 The Court finds, in view of the specific circumstances of this case, that the State's
duty of prevention required enhanced diligence. Indeed, in view of the facts and the context at the
time they occurred, the Court notes, from an intersectional perspective, that Ms. Bedoya was in a
doubly vulnerable situation, due to her work as a journalist and for being a woman. 206
92. In this case, the Court observes, first, that the State had been aware since at least May 27,
1999, that Ms. Bedoya was the target of numerous threats that endangered her life and/or personal
integrity, in connection with the work she performed as a journalist. Indeed, the Court notes that on
May 27, 1999, Ms. Bedoya experienced an attack that ended up putting her mother in the hospital.
In August of that same year, the Administrative Security Department (DAS) decided to provisionally
assign Ms. Bedoya security after she provided evidence "of vulnerability to her freedom, her life, and
her personal integrity." 207 However, this security arrangement was withdrawn on November 24,
1999 208—that is, only months before the facts that are the subject of this analysis took place. In this
198
Cf. United Nations Human Rights Council, Resolution adopted by the Human Rights Council on 27 September 2018,
A/HRC/RES/39/6, and United Nations General Assembly, Resolution adopted by the General Assembly on 18 December 2019,
A/RES/74/157.
199
Cf. IACHR, Women Journalists and Freedom of Expression: Discrimination and Gender-Based Violence Faced by
Women Journalists in the Exercise of their Profession, para. 169.
Cf. United Nations. Report of the Special Rapporteur on violence against women, its causes and consequences,
A/HRC/44/52, May 6, 2020, para. 84.
200
201
Cf. United Nations. Report of the Special Rapporteur on the situation of human rights defenders, A/74/159, July 16,
2019, paras. 105-111.
202
The United Nations Special Rapporteur on violence against women, its causes and consequences, in her report
“Combating violence against women journalists” A/HRC/44/52 of May 6, 2020, concluded and recommended that States
“Address factors that increase the likelihood of violence and harassment in the world of work for women journalists, including
discrimination, abuse of power relations and cultural and social norms that support violence and harassment, and create
internal mechanisms against sexual harassment in the workplace.” Also see United Nations, Committee on the Elimination of
Discrimination against Women, General Recommendation No. 30 on women in conflict prevention, conflict and post-conflict
situations, CEDAW/C/GC/30, of November 1, 2013, para. 17.
Cf. United Nations General Assembly, Resolution 72/175, “The safety of journalists and the issue of impunity,” 29
January 2018, A/RES/72/175. Also see United Nations, Committee on the Elimination of Discrimination against Women,
General Recommendation No. 30 on women in conflict prevention, conflict and post-conflict situations, CEDAW/C/GC/30, of
November 1, 2013, para. 17.
203
204
Cf. United Nations, Report of the Special Rapporteur on violence against women, its causes and consequences,
Combating violence against women journalists, A/HRC/44/52, May 6, 2020, paras. 80 to 82, and Committee of Ministers of
the Council of Europe, Recommendation CM/Rec(2016)4, April 13, 2016, para. 9.
205
Cf. United Nations, Committee against Torture, Concluding observations on the second periodic report of Afghanistan,
CAT/C/AFG/CO/2, 12 June 2017, paras. 43 and 44, and United Nations, Committee against Torture, Concluding observations
on the initial report of Pakistan, CAT/C/AFG/CO/1, 1 June 2017, paras. 22 and 23.
206
For these purposes, a statement made by Ms. Bedoya at the hearing held before this Court sheds light on this, when
she indicated that “If what happened to me on May 25 had happened to Pedro Pérez instead of Jineth Bedoya, for Pedro Pérez,
they would have sent a hit man and they would have killed him. But they tortured and raped Jineth Bedoya.” Cfr. Statement
from Jineth Bedoya Lima given at the public hearing held on March 15, 22, and 23, 2021 within the framework of the 140th
regular sessions.
207
Cf. Communication from the Administrative Security Department [DAS], of August 25, 1999 (evidence file, folio 95).
208
Cf. Official Letter from the Coordinator of the Protection Area, General Office of the Special Administrative Unit for
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