measures should be avoided or limited; additional administrative burdens placed on the applicant with regard to the enforcement of a return order (such as the need for a formal application for enforcement or for any additional requirements or authorizations, the need for a new application for legal aid, etc.) should be avoided or limited; where the return order needs to be served upon the respondent before coercive measures may be applied, consideration should be given to the possibility, in appropriate cases, of serving it at the moment that the enforcement officer proceeds to enforcement; no legalization or similar formality may be required in the context of the Convention, including for a power of attorney or other similar document authorizing a person designated by the applicant to take the child. 103. Finally, Article 11 of the Convention on the Rights of the Child108 provides: 1. States Parties shall take measures to combat the illicit transfer and non-return of children abroad. (…). 2. To this end, States Parties shall promote the conclusion of bilateral or multilateral agreements or accession to existing agreements. 104. In addition, Article 9.3 of the Convention on the Rights of the Child provides: 9.3 States Parties shall respect the right of the child who is separated from one or both parents to maintain personal relations and direct contact with both parents on a regular basis, except if it is contrary to the child's best interests. b) Special protection of the rights of children and adolescents in connection with procedures affecting them. The right to be heard, the right to participation, and the best interests of children and adolescents 105. The Inter-American Court has considered that children are beneficiaries of the rights enshrined in the American Convention, as well as enjoying special protective measures set out in Article 19 thereof. 109. It has likewise held that that adoption of special measures to protect children is "a responsibility both of the State and of the family, community, and society to which they belong."110 And that "the effects of this provision extend to the interpretation of all the other rights when the case has to do with minors, because of their nature as such. The Court is of the view that due protection of the rights of children, as holders of rights, must take the characteristics proper to children into account and the need to foster their development, by providing them with the conditions they need to live and develop their skills and make the most of their potential. Children themselves exercise their rights progressively, as they develop higher levels of personal autonomy. For that reason, the Convention provides that appropriate protection measures for children are special or more specific than those declared for adults. The protection measures to be adopted under Article 19 of the Convention must, in each concrete case, be defined in accordance with the particular circumstances."111 106. The I/A Court of H.R, has held that in any situation involving children certain guiding principles must be applied and observed across the board, notably: i) nondiscrimination; ii) the best interests of the child; iii) the right to be heard and to participate; and iv) the right to life, survival, and development. Any state, social, or family decision curtailing the exercise of any right of a child must take into account the best interests of the child and abide strictly by the provisions in force in that regard.112 For its part, the IACHR has referred to a broad spectrum 108 Convention on the Rights of the Child, Adopted and opened for signature and ratification by the General Assembly in its resolution 44/25 of 20 November 1989. 109 I/A Court H.R. Case of Ramírez Escobar et al. v. Guatemala. Merits, Reparation, and Costs Judgment of March 9, 2018. Series C No. 351, paragraph 150. 110 I/A Court H.R. Case of Fornerón and daughter v. Argentina. Merits, Reparation, and Costs Judgment of April 27, 2012. Series C No. 242, par. 45. 111 I/A Court H.R. Case of Ramírez Escobar et al. v. Guatemala. Merits, Reparation, and Costs Judgment of March 9, 2018. Series C No. 351, paragraph 150. 112 I/A Court H.R. Case of Ramírez Escobar et al. v. Guatemala. Merits, Reparation, and Costs Judgment of March 9, 2018. Series C No. 351, paragraph 152; I/A Court H.R., Case of V.R.P., V.P.C. et al v. Nicaragua. Preliminary Objections, Merits, Reparations, and Costs. Judgment of [continues …]