2 States has repeatedly mentioned, since 2009, “the important and constructive practice begun by the Inter-American Court of Human Rights to hold closed hearings on the monitoring of compliance with its judgments, and the outcomes 3 thereof.” In addition, it has encouraged “[t]he hearings held to monitor compliance with judgments as one of the most effective mechanisms to promote 4 compliance [therewith].” 3. As an illustration of the importance of this faculty of the Court, it is worth recalling the case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. In this case, as a consequence of a private hearing held and a meeting for dialogue at the Court’s seat, the State assumed a series of commitments aimed at executing the only operative paragraph of the Judgment pending compliance. This resulted in full compliance with the Judgment and the closing of the case seven months after the hearing, with the demarcation and titling of over 70,000 hectares, in conformity with the Order issued by the Court on April 3, 2009.5 Similarly, in the case of Valle Jaramillo v. Colombia, during the private hearing, the State and the representatives came together for dialogue and agreement towards the implementation of the reparation measure of granting of a scholarship to study or receive training in a trade, which led less than a month after to the joint presentation of an agreement for alternative compliance with the measure, 6 agreement that was subsequently deemed admissible by the Court. In addition, after the private hearing held in the case of Vargas Areco v. Paraguay, the Court recognized, with regard to the obligation to pay interest on the compensation for pecuniary and non-pecuniary damages and reimbursement of costs and expenses paid after the date due, “the will[ingness] of the parties to achieve progress on this point based on an agreement, and [indicated that it awaited] updated information on efforts and results achieved regarding the [State’s] compliance 7 with this aspect of the reparation.” 4. The confirmation of the occurrence of human rights violations by the InterAmerican Court, through the exercise of its contentious jurisdiction, has led the Court to order, in conformity with Article 63 of the American Convention on Human Rights (hereinafter the “American Convention” or the “Convention”), different types of measures that tend to satisfy the idea of integral reparation. This includes not only pecuniary compensation, but also measures of a different nature seeking restitution, rehabilitation, satisfaction, and non-repetition of the proven violations. The implementation of these measures entails, as indicated, a gradual process over time of a complex nature, in which, in many cases, all State 3 General Assembly, Resolution AG/RES. 2500 (XXXIX-O/09) approved in the fourth plenary session held on June 4, 2009, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights,” pg 3; Resolution AG/RES. 2587 (XL-O/10) approved in the fourth plenary session held on June 8, 2010, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights,” pg. 2, and Resolution AG/RES. 2652 (XLI-O/11) approved in the fourth plenary session held on June 7, 2011, entitled “Observations and Recommendations on the Annual Report of the Inter-American Court of Human Rights,” para. 6. 4 General Assembly, Resolution AG/RES. 2500 (XXXIX-O/09), supra note 3, operative paragraph five; Resolution AG/RES. 2587 (XL-O/10), supra note 3, operative paragraph five, and Resolution AG/RES. 2652 (XLI-O/11), supra note 3, operative paragraph six. 5 Cf. Case of the Mayagna (Sumo) Awas Tingni Community v. Nicaragua. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of April 3, 2009, Operative Paragraphs 1 and 2. 6 Cf. Case of Valle Jaramillo v. Colombia. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of February 28, 2011, Considering clauses 34 to 37; and Case of Valle Jaramillo v. Colombia. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of May 15, 2011, Considering clauses 6 to 11. 7 Cf. Case of Vargas Areco v. Paraguay. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of November 24, 2010, Considering clause 39.

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