whereabouts of Nicholas Blake. Accordingly, there is no contradiction in this respect between the judgments on merits and on reparations. 26. With regard to the second issue on the reimbursement of the expenses incurred in processing the case before the inter-American system, the Court clarifies that Article 23 of its current Rules of Procedure recognizes locus standi to the victims, their next of kin or their representatives, and this condition allows them to submit their own arguments and evidence independently during the reparations stage and their right to reimbursement of representation-related expenses to be recognized. 27. This Court has said that “[i]n practice, the legal assistance provided to the victim does not begin with the reparations phase; instead, it begins with the proceedings before the domestic courts and continues throughout each phase of the proceedings under the inter-American system for the protection of human rights, in other words, in the proceedings conducted before the Commission and before the Court [...]”5. In its recent jurisprudence, since the entry into force of the current Rules of Procedure, the Court has recognizes that costs are one element to be considered under the concept of reparations to which Article 63.1 of the Convention refers since they are a natural consequence of the effort made by the victim, his or her beneficiaries, or representatives to obtain a court settlement recognizing the violation committed and establishing its legal consequences6. 28. In its judgment of January 22, 1999, the Court ordered the reimbursement of the expenses of processing the case before the institutions of the inter-American human rights system, by declaring the admissibility of the corresponding petition, which the victim’s next of kin or representatives presented to the Court, during the reparations phase. 29. This compensation could only be ordered in the judgment on reparations, as effectively occurred. Consequently, the judgment on merits could omit all reference to this, without the victim’s next of kin losing the right to reimbursement of their expenses related to representation before the inter-American system. 30. For the foregoing reasons, the Court considers that the contradiction alleged by the State between the provisions of the judgments on merits (of January 24, 1998) and on reparations (of January 22, 1999) does not exist, and that the compensation ordered in the first of these decisions for “expenses in representations to the Guatemalan authorities” does not exclude the possibility of the Court ordering the payment claimed by the victims’ next of kin for both “expenses of an extrajudicial nature” and the “reimbursement of expenses incurred in processing the case before the inter-American system for the protection of human rights”, as it did in the judgment on reparations. 5. Garrido y Baigorria case, Reparations (Article 63.1 of the Inter-American Convention on Human Rights), Judgment of August 27, 1998. Series C No. 39, para. 81. 6. Cfr. Garrido y Baigorria case, Reparations, supra note 5, para. 79; Loayza Tamayo case, Reparations (Article 63.1 of the Inter-American Convention on Human Rights), Judgment of November 27, 1998. Series C No. 42, para. 176; Suárez Rosero case, Interpretation of the Judgment on Reparations (Article 67 of the Inter-American Convention on Human Rights), Judgment of May 29, 1999. Series C No. 51, para. 40 and Loayza Tamayo case, Interpretation of the Judgment on Reparations (Article 67 of the Inter-American Convention on Human Rights), Judgment of June 3, 1999. Series C No. 53, para. 24.

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