38 96.3 During the 1980s, especially after 1985, it became obvious that many “selfdefense groups” had changed their objectives and had become criminal groups, commonly called “paramilitary.” They developed primarily near the middle course of the Magdalena River, and spread toward other regions of the country.20 96.4 On January 27, 1988, Colombia issued Legislative Decree 0180 “which complemented certain provisions of the Criminal Code and issued other provisions for reestablishment of public order.” This Decree defined as crimes, inter alia, membership in, fostering of and direction of groups of hired assassins, as well as manufacturing of or trafficking in weapons and munitions whose use was restricted to the Military Forces or the National Police. This Decree subsequently became permanent legislation by means of Decree 2266 of 1991.21 96.5 Decree 0815 was issued on April 19, 1989, suspending the enforcement of paragraph 3 of Article 33 of Legislative Decree 3398 of 1965 (supra para. 96(1)), which empowered the Ministry of National Defense to authorize private citizens to bear weapons whose use was restricted to the Armed Forces. The Whereas section of Decree 0815 stated that “interpretation of [Legislative Decree 3398 of 1965, adopted as permanent legislation by means of Law 48 of 1968] by certain sectors of public opinion has generated confusion regarding its scope and purpose, in the sense that it could be considered a legal authorization to organize armed groups of civilians who act disregarding the Constitution and the law.” Subsequently in its May 25, 1989 ruling, the Supreme Court of Justice declared that said paragraph 3 of Article 33 of Legislative Decree 3398 of 1965 was “constitutionally unenforceable”.22 96.6 On June 8, 1989 the State issued Decree 1194 “that adds to Legislative Decree 0180 de 1988, to punish new types of crime, because this is necessary for the reestablishment of public order.” The Whereas section of this law stated that “the events that have been taking place in the country have shown that there is a new type of crime that consists of committing atrocious acts carried out by armed groups, mistakenly called ‘paramilitary,’ functioning as death squads, groups of hired assassins, self-defense groups or private justice groups, whose existence and actions gravely affect the country’s social stability, and which must be repressed to attain the reestablishment of public order and peace.” This decree defined the crimes of promoting, funding, organizing, directing, fostering and carrying out acts “that seek to attain the establishment or the entry of individuals into armed groups commonly called death squads, groups of hired assassins or private justice groups, mistakenly Departamento Administrativo de Seguridad (DAS) on March 15, 1989, and expert opinion of Federico Andreu rendered before the Inter-American Court during the public hearing held on March 7, 2005. 20 See Decree 0180 of January 27, 1988, which “complements certain provisions of the criminal code and issues other provisions for the reestablishment of public order;” Decree 0815 of April 19, 1989; Decree 1194 of June 8, 1989, which “established new types of crime pertaining to the activities of armed groups, commonly known as death squads, groups of hired assassins, or private justice,” and judgment issued by the High Military Court on March 17, 1998, and report by the United Nations Special Rapporteur on summary or arbitrary executions regarding the visit to Colombia from October 11 to 20, 1989, E/CN.4/1990/22/Add.1 of January 24, 1990. 21 See Decree 0180 of January 27, 1988, which “complements certain provisions of the criminal code and issues other provisions for the reestablishment of public order;” and Decree 2266 of October 4, 1991. 22 See Decree 0815 of April 19, 1989; judgment issued by the Supreme Court of Justice on May 25, 1989, and expert opinion of Federico Andreu rendered before the Inter-American Court during the public hearing held on March 7, 2005.