10 48. The State says that at the time of the events in the instant case, "some Venezuelan landowners began to hire Colombian paramilitaries as hired killers to murder campesino leaders who sought to put into effect the Land and Agrarian Development Law.” 21 For its part, PROVEA said killings of campesino leaders occurred in various States in the country. The use of hired killers was the most common way of acting against the leaders. According an investigation carried out by the National Agrarian Coordinator, 20 campesino and indigenous leaders were murdered from January to September 2003. […] Raúl Yépez Chirinos, Deputy Director of the Criminal Investigation Police (CICPC), reported that 56 campesinos were murdered in the States of Zulia, Apure, Barinas, Guarico, Portuguesa, and Táchira, although he did not state how long they had been keeping a record. In addition to several leaders and campesino organizations, he said that landowners were involved in those acts, in particular in the Zulia region where it was corroborated that they hired paid killers to murder several people.22 49. Furthermore, in its Annual Report for 2006 the Commission noted that it has been “following with concern the situation of impunity in cases of contracted or paid killings [sicariato] perpetrated against campesinos or persons involved in land claims.”23 1.3 The situation of human rights defenders in Venezuela 50. In its 2003 Report on the Situation of Human Rights in Venezuela, the Commission said that it had been “receiving a considerable volume of complaints about different kinds of attacks and intimidatory acts against individuals working among the inhabitants of Venezuela to protect basic rights and promote their observance.”24 The Commission also said, Incidents in which human rights workers or human rights organizations are harassed occasionally escalate into attacks on defenders themselves; however, there has also been a series of cases in which human rights defenders have been targeted by vague forms of intimidation, by means of veiled threats perceivable in seemingly insignificant incidents that upset day-to-day routines and, seen as unusual or strange by the persons involved, convince them that they are being watched. One form of such intimidation is to have unidentified individuals make threats against places where human rights defenders work or to loiter in the vicinity.25 51. In that report, the IACHR noted that the violence and harassment aimed at human rights defenders worsened with the institutional crisis that affected Venezuela in 2002. 26 Subsequently, in its 2005 Annual Report,27 2006,28 2007,29 and 2008,30 the Commission expressed its ongoing concern with respect to 21 Note AGEV/000080 from the Ministry of Foreign Affairs of the Bolivarian Republic of Venezuela, January 21, 2008, pp. 12 and 13. 22 Programa Venezolano de Educación – Acción en Derechos Humanos (PROVEA). Annual Report October 2002 September 2003. Available at http://www.derechos.org.ve/proveaweb/wp-content/uploads/03_derecho_a_la_tierra.pdf. 23 IACHR. Annual Report 2006, http://www.cidh.oas.org/annualrep/2006eng/Chap.4f.htm. Chapter IV, Venezuela, par. 178. Available at 24 IACHR. Report on the Situation of Human Rights in Venezuela. Chapter II. B. The Situation of Human Rights Defenders. OEA/Ser.L/V/II.118. Doc. 4 rev. 1. October 24, 2003, par. 232. Available at http://www.cidh.oas.org/countryrep/Venezuela2003eng/chapter2.htm#B. 25 IACHR. Report on the Situation of Human Rights in Venezuela. Chapter II. B. The Situation of Human Rights Defenders. OEA/Ser.L/V/II.118. Doc. 4 rev. 1. October 24, 2003, par. 233. Available at http://www.cidh.oas.org/countryrep/Venezuela2003eng/chapter2.htm#B. 26 IACHR. Report on the Situation of Human Rights in Venezuela. Chapter II. B. The Situation of Human Rights Defenders. OEA/Ser.L/V/II.118. Doc. 4 rev. 1. October 24, 2003, par. 234. Available at http://www.cidh.oas.org/countryrep/Venezuela2003eng/chapter2.htm#B. 27 In its annual report for 2005 the IACHR mentioned, “In 2005 harassment and intimidation of human rights defenders continued. The Commission was informed that judicial proceedings were instituted against human rights defenders, whose purpose is allegedly to silence their reports. In addition, high-level officials continued to question the legitimacy of their work. The IACHR expresses its grave concern over the impact these statements could have on the security of human rights defenders.” IACHR.