remains are not known. Disappearance as such only ceases when the victim appears or his or her remains are found,87 in such a way that their identity can be determined with certainty.88 67. As regards the rights violated, forced disappearance violates the right to personal liberty and places the victim at grave risk of suffering irreparable harms to his rights to personal integrity and life. The Court has pointed out that forced disappearance violates the right to personal integrity because "prolonged isolation and deprivation of communication are in themselves cruel and inhuman treatment." 89 The Commission and the Court have determined that it is clear that in the case of a forced disappearance, the victim’s personal integrity is affected in all its dimensions.90 The Court has likewise stated that even assuming that the torture or murder of a victim of disappearance cannot be demonstrated in a particular case, the subjection of detainees to State agents or private individuals acting with their acquiescence or tolerance who with impunity practice torture or murder in itself represents a violation of the rights to personal integrity and life.91 68. According to the case law of both organs of the Inter-American system, the practice of disappearances has frequently involved the secret execution of those detained, without trial, followed by concealment of the corpse in order to eliminate any material evidence of the crime and to ensure absolute impunity, which entails a brutal violation of the right to life, established in Article 4 of the Convention.92 The jurisprudence of the Inter-American system has also determined that when a person has disappeared in violent circumstances and remained disappeared for a long time it is reasonable to presume that he has been killed.93 69. In addition, the Commission has consistently pointed out that in cases of forced disappearance, given the multiple and complex nature of this serious human right violation, the forced disappearance entails a specific violation of the right to recognition of juridical personality.94 This has also been recognized by the Inter-American Court.95 This is because, apart from the disappeared person no longer being able to exercise and enjoy the rights to which he or she is entitled, his or her disappearance "is not only one of the most serious forms of placing the person outside the protection of the law but it also entails denying that person's existence and placing him or her in a kind of limbo or uncertain legal situation before society and the State."96 The Commission considers that forced disappearance also implies a violation of the rights to judicial guarantees and judicial protection of the disappeared victim, given the lack of actions designed to ascertain his IACHR. Application before the Inter-American Court, Case No. 12.529, Rainer Ibsen Cárdenas and José Luis Ibsen Peña, Bolivia, Mayo12, 2009, para. 106. 88 Cf, inter alia, Velásquez Rodríguez Case v. Honduras. Merits, supra, paras. 155 to 157; and Case of Osorio Rivera and Family v. Peru, supra, para. 31. 89 I/A Court H.R. Case of Chaparro Álvarez and Lapo Íñiguez v. Ecuador. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 21, 2007. Series C No. 170, para. 171; and Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, para. 85. 90 I/A Court H.R. Case of Ticona Estrada et al. v. Bolivia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 191, para. 58; and IACHR, Report No. 5/16, Cases 11.053, 11.054, 12.224, 12.225, and 12.823. Merits. Peru. April 13, 2016, para. 167. 91 I/A Court H.R. Case of Ticona Estrada v. Bolivia. Merits, Reparations, and Costs. Judgment of November 27, 2008. Series C No. 191, para. 59; Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, para. 85; and Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 23, 2009. Series C No. 209, para. 92 I/A Court H.R., Case of the 19 Merchants. Judgment of July 5, 2004. Series C No. 109, para 154; I/A Court H.R., Case of Bámaca Velásquez. Judgment of November 25, 2000. Series C No. 70, para 130; and IACHR, Report No. 44/00. Case 10.820, Américo Zavala Martínez. Peru. April 13, 2000, para. 41. 93 I/A Court H.R., Velásquez Rodríguez Case. Judgment of July 29, 1988. Series C No. 4, para. 188 and IACHR. Application before the InterAmerican Court in Case 12.529 Rainer Ibsen Cárdenas and José Luís Ibsen Peña vs. Bolivia. May 12, 2009, para. 248. 94 IACHR. Applications before the Inter-American Court in the cases: Renato Ticona Estrada et al. (12.527), paras. 153-165; Rosendo Radilla Pacheco (12.511), paras. 138-145; Kenneth Ney Anzualdo Castro (11.385), paras. 167-176; Julia Gómez Lund et al (11.552), paras. 208220; Florencio Chitay Nech (12.599), paras. 136/-146, Rainer Ibsen Cárdenas and José Luís Ibsen Peña, (12.529), paras. 251-262; and Narciso González Medina et al (11.324), paras. 138-149. 95 I/A Court H.R. Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, paras. 91-92; Case of Radilla Pacheco v. Mexico. Preliminary Objections, Merits, Reparations and Costs. Judgment of November 23, 2009. Series C No. 209, para. 157. 96 I/A Court H.R. Case of Anzualdo Castro v. Peru. Preliminary Objection, Merits, Reparations, and Costs. Judgment of September 22, 2009. Series C No. 202, para. 90. See also: IACHR, Report No. 5/16, Cases 11.053, 11.054, 12.224, 12.225, and 12.823. Merits. Peru. April 13, 2016, para. 166. 87 19