52 acknowledged that “an action for slander was filed [against Jesús María Valle Jaramillo] at the request of members of the Army” (supra para. 30(a)). The Court also emphasizes that, regarding paragraph 39 of the application, the State: Questioned the contents of the testimony of Carlos Fernando Jaramillo Correa […] to the effect that “the Governor of Antioquia at the time declared publicly that ‘Dr. Valle appeared to be an enemy of the Army,’” because it was not supported by any other evidence attached to the application. 176. Regarding the first allegation concerning the complaint against Valle Jaramillo for slander, the Court considers that a judicial proceeding does not, in itself, constitute unlawful harm to the honor or dignity of the individual. Despite the fact that it can indirectly cause difficulties to those who must undergo a trial, its purpose is to settle a dispute. Maintaining otherwise would completely exclude settling litigations by administrative proceedings.128 Consequently, the Court finds that, in the instant case, it has not been proved that the State violated Article 11(1) and 11(2) of the Convention with regard to Jesús María Valle Jaramillo and his next of kin, based on the complaint filed against him for slander. 177. Regarding the second allegation concerning the supposed statement made by the Governor of Antioquia at the time (supra para. 171), the Court observes that neither the Commission nor the representatives submitted sufficient probative elements to corroborate the testimony of Carlos Fernando Jaramillo Correa, who is a victim in these proceedings (supra para. 54). Although the representatives provided a newspaper article as a means of proving this alleged fact,129 the Court observes that it refers to a communiqué issued by “eleven non-governmental organizations that comprise the ‘Semillas de Libertad’ Human Rights Collective (CODEHSEL),” in which these organizations indicate that “the Governor of the Department […] referred to [… Jesús María] Valle as ‘enemy of the Armed Forces.’” Since there are no other elements that support the information contained in this newspaper article, the Court finds that the latter lacks sufficient probative value (supra para. 53) and, therefore, considers that the fact being examined has not been proved. 178. The allegation of the representatives concerning the alleged violation of Article 11 of the Convention to the detriment of Carlos Fernando Jaramillo Correa and his next of kin is partially supported by the contents of paragraph 52 of the Commission’s application. The pertinent part of this paragraph, as well as the State’s acknowledgement of the facts (supra para. 134), indicate that Carlos Fernando Jaramillo Correa had possessions and properties that he had to abandon owing to his alleged forced displacement. 179. The Court considers that the facts and consequences alleged by the representatives with regard to the supposed violation of Article 11 of the Convention to the detriment of Carlos Fernando Jaramillo Correa and his next of kin are related to the complex violation of Article 22 thereof that has already been declared in this judgment (supra paras. 133 to 144). Moreover, taking into account the allegations of the representatives, the Court observes that, although the Court declared that Article 11(2) of the Convention had been violated in the case of the Ituango Massacres, it did so based on facts that differ from those indicated in the instant case, owing to the arson and destruction of the houses of the victims in the former case, and in order to “protect private life and home from arbitrary or abusive interference”;130 consequently, that case law precedent is not applicable. 128 Cf. Cesti Hurtado v. Peru. Merits. Judgment of September 29, 1999. Series C No. 56, para. 177, and Bueno Alves v. Argentina. Merits, reparations and costs. Judgment of May 11, 2007. Series C No. 164, para. 122. 129 Note published in the El Colombiano newspaper on July 12, 1997, entitled: “Lo de Ituango evidencia unión paramilitares-Ejército” (file of attachments to the pleadings and motions brief, attachment H-1 No. 39, folio 1310). 130 Cf. Case of the Ituango Massacres, supra note 21, para. 193.