47 paragraph 3, of the Code of Criminal Procedure establishes the possibility of a longer duration of the investigation when the fact is difficult to elucidate. 177. In the instant case the Court declared that the duration of the investigation did not correspond to a reasonable time and ordered that this procedure should be continued, respecting the provisions of Articles 8 and 25 of the Convention. In this regard, the State must conduct the recently re-opened Investigation in accordance with article 10 of the Code of Criminal Procedure and the other criteria mentioned by the Court in this judgment. Regarding compliance with the said provision in all investigative procedures opened in Brazil, the Court is unable to rule on possible investigations regarding which it knows nothing of their merits and circumstances; accordingly, it does not order this measure of reparation. vi) Other claims for reparation 178. The Commission alleged that, to prevent future human rights violations, the Court should order the State to adopt any measures that are: (a) necessary to ensure that human rights are observed in government policies on land occupation, in accordance with Article 28 in relation to Article 1(1) of the American Convention, and (b) appropriate for police and justice officials, in order to avoid the proliferation of armed groups carrying out violent and arbitrary evictions. 179. The representatives asked that the State be ordered: (a) to take the necessary measures to guarantee that there will be no violent evictions; (b) to adopt effective measures to protect the rights of rural workers creating an effective mechanism for mediating agrarian conflicts, and (c) not “to promulgate laws that prohibit verifying public or private rural properties that have been occupied for any period of time or for any other reason and that the existing norms in this regard should be revoked immediately.” 180. The State indicated that it had implemented measures to ensure that human rights were observed in government policies on land occupation issues to prevent agrarian conflicts; these included the establishment of the Ouvidoria Agrária Nacional, the Paz en el Campo program, and the National Plan to Combat Violence in Rural Areas. This illustrates the State’s interest in implementing a human rights protection system and respecting such rights in its government policies on land occupation. In addition, it had prepared a plan for execution of Mandados Judiciais de Reintegração de Posse Coletiva (judicial orders to restore collective ownership) and, within this framework, a manual of national guidelines for the execution of Mandados Judiciais de Manutenção e Reintegração de Posse Coletiva (judicial orders to maintain and restore collective ownership), the main purpose of which is to avoid land conflicts caused by compliance with judicial orders, as well as to assist the public authorities responsible for guaranteeing and applying the law in specific agrarian cases submitted to the consideration and hearing of the Judiciary. The State also alleged that there was no evident correlation between the representatives’ request concerning the non-promulgation of laws that prohibit verification in rural properties and the purpose of this case; moreover, it was not supported by any right established in the Convention. 181. The Court observes that the purpose of these measures of reparation requested by the Commission and the representatives is that the State should adopt a series of measure in relation to the situation of landless rural workers in Brazil, particularly in the context of land occupation and extrajudicial evictions. Even though the arguments concerning the alleged vulnerability of the landless workers are a cause of concern, the Court will not rule on the measures requested in relation to facts that were not examined in the instant case for the above-mentioned reasons, because of its lack of temporal competence with regard to the facts relating to the eviction that culminated in the death of Mr. Garibaldi.

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