272. Regarding the publication and dissemination of the Judgment, the representative
asked the Court to order the State “[t]o publish opportunely and repeatedly in the
newspapers El Espectador, El Tiempo and El Colombiano, as well as in the Official Gazette,
the pertinent parts of the Court’s Judgment, in particular the section on proven facts and
the operative paragraphs,” and that the State make the said publication, “translated into
the English language, “in a newspaper with widespread circulation in the United States,
specifically in the area where the family lives.”
273. The State indicated that “it will respect the decision of the […] Court in this regard, in
keeping with the criteria of reasonableness and proportionality and the causal nexus with
the violations that have really been proved.” However, it observed “that the [Court’s]
practice reveals that it is sufficient to publish the important [parts] of the Judgment in a
single national newspaper.”
274. The Court determines, as it has in other cases,257 that the State must publish within
six months of notification of this Judgment: (a) the official summary of this Judgment
prepared by the Court, once, in once, in the official gazette; (b) the official summary of this
Judgment prepared by the Court, once, in a national newspaper with widespread circulation,
and (c) this Judgment in its entirety, available for one year, on an official website.
B.5) Guarantees of non-repetition: training for the Armed Forces
275. The Commission and the representative both asked the Court to order the State “to
provide training to the armed forces on the role of journalists in a democracy, and their
right to cover, freely and safely, situations of public order and armed conflict.” In its brief
submitting the case, the Commission referred to the undertaking made by the State “to
promote, in the coming months, training for the armed forces.” It added that States have a
“special obligation to protect journalists at risk,” which entails the adoption of certain
measures such as the training of security forces so they are aware of the importance of
journalists and social communicators in a democratic society. For his part, the
representative added that the said training should also cover the role played by “other
human rights defenders in a democracy.”
276. The State asked the Court to reject this measure because it has been complying with
it and demonstrated its commitment to continue to comply with it. In its response to the
Merits Report, it undertook to promote the said training for the armed forces. It stressed
that this recommendation is “of gradual short and medium-term implementation and
impact.” In this regard, the State forwarded “Directive No. 19/2010 of the Office of Human
Rights and International Humanitarian Law of the National Army, which includes the
command policies to enhance respect for journalists and social communicators [in order to]
‘supervise, respect, and protect, […] according to the circumstances, the means and
resources available to those who exercise the profession of journalists and social
communicators’ and ‘acknowledge the plausible work [they] perform in Colombia.’” It
indicated that this is complemented “by a copy of the leaflet that each Colombian soldier
carries in his equipment entitled: ‘Respect, attention, recognition, protection, prevention,
application and dissemination of human rights and international humanitarian law with
regard to special groups,’ which emphasizes the work of journalists and the importance of
protecting them.”
257
Cf. Case of Cantoral Benavides v. Peru. Reparations and costs, para. 79, and Case of the Kichwa
Indigenous People of Sarayaku v. Ecuador. Merits and reparations, para. 307.
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