12 effectiveness.52 However, the Inter-American Court has considered that it is not in itself incompatible with the American Convention that a State limit its remedy of amparo to specific matters, as long as it provides another remedy of similar nature and scope for those same human rights that are not governed by the jurisdiction of amparo.53 In any case, what matters is that the legal remedy be suitable to combat the violation, and that its implementation by the competent authority be effective,54 as everyone should have access to a simple and prompt remedy before competent courts or tribunals that protect their fundamental rights.55 38. At times it has been interpreted that the effective remedy of which the InterAmerican Court speaks, can be offered within criminal proceedings, particularly in cases of serious human rights violations. Thus, the Inter-American Court has established that victims of human rights violations, or their next of kin, should have ample opportunities to be heard and carry out their respective processes, which in the Court's opinion may include both clarification of the facts and punishment of those responsible, as well as due reparation.56 39. The Inter-American Court has also understood that for a criminal investigation to constitute an effective remedy that ensures the right of access to justice for the alleged victims, and guarantees the rights that were affected, it must be carried out in a serious manner and not as a mere formality preordained to be ineffective; it must have a purpose and be assumed by the States as a legal obligation in itself and not as a measure taken by private interests that depends upon the initiative of the victim or his or her next of kin or the private provision of evidentiary elements.57 Similarly, the Inter-American Court in certain circumstances has examined the effectiveness of appeals filed within the administrative jurisdiction.58 In such cases, it has been analyzed whether the decisions therein have effectively contributed to put an end to a situation that violates rights, to 52 Cf. Judicial Guarantees in States of Emergency (Arts. 27(2), 25 and 8 of the American Convention on Human Rights) Advisory Opinion OC-9/87 of October 6, 1987. Series to No. 9, para. 24; Case of Castañeda Gutman V. México. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 6, 2008. Series C No. 184, para. 78; and Case of Escher et al. V. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of July 6, 2009. Series C No. 200, para. 196. 53 Cf. Case of Castañeda Gutman V. México. Preliminary Objections, Merits, Reparations and Costs. Judgment of August 6, 2008. Series C No. 184, para. 92. 54 Cf. Case of Tibi V. Ecuador. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 7, 2004. Series C No. 114, para. 131; Case of Acosta Calderón V. Ecuador. Merits, Reparations and Costs. Judgment of June 24, 2005. Series C No. 129, para. 93; and Case of Palamara Iribarne V. Chile. Merits, Reparations and Costs. Judgment of November 22, 2005. Series C No. 135, para. 184. 55 Cf. Case of the Mayagna (Sumo) Awas Tingni Community V. Nicaragua. Merits, Reparations and Costs. Judgment of August 31, 2001. Series C No. 79, para. 112; Case of Cantos V. Argentina. Merits, Reparations and Costs. Judgment of November 28, 2002. Series C No. 97, para. 52; and Case of Juan Humberto Sánchez V. Honduras. Preliminary Objections, Merits, Reparations and Costs. Judgment of June 7, 2003. Series C No 99, para. 121. 56 Cf. Case of de the “Street Children”(Villagrán Morales et al.) V. Guatemala. Merits. Judgment of November 19, 1999. Series C No. 63, paras. 225 and 227. 57 Cf. Case of Velásquez Rodríguez V. Honduras. Merits. Judgment of July 29, 1988. Series C No. 4, para. 177; and Case of Garibaldi V. Brazil. Preliminary Objections, Merits, Reparations and Costs. Judgment of September 23, 2009. Series C No. 203, para. 113. 58 Cf. Case of the Mapiripan Massacre V. Colombia. Merits, Reparations and Costs. Judgment of September 15, 2005. Series C No. 134, para. 210; Case of of the Rochela Massacre V. Colombia. Merits, Reparations and Costs. Judgment of May 11, 2007. Series C No. 163, para. 217; and Case of Manuel Cepeda Vargas V. Colombia. Preliminary Objections, Merits, Reparations and Costs. Judgment of May 26, 2010. Series C No. 213, para. 139.