circumstances of each child, his or her stage of development or maturity,118 and so on.119 In the case of girls, that vulnerability to human rights violations may be shaped and exacerbated by historically discriminatory factors120 that have led to women and girls suffering higher sexual violence indices (...).121 100. General Recommendation No. 28 of the CEDAW Committee regarding Article 2 of the Convention for the Elimination of All Forms of Discrimination against Women stated: States parties in particular are obliged to promote the equal rights of girls since girls are part of the larger community of women and are more vulnerable to discrimination in such areas as access to basic education, trafficking, maltreatment, exploitation and violence. All these situations of discrimination are aggravated when the victims are adolescents. All these situations of discrimination are aggravated when the victims are adolescents. Therefore, States shall pay attention to the specific needs of (adolescent) girls by providing education on sexual and reproductive health and carrying out programmes that are aimed at the prevention of HIV/AIDS, sexual exploitation and teenage pregnancy. 122. 101. For its part, the European Court has maintained that cases of sexual assaults against children have a particularly profound impact, especially when the aggressor is in a position of authority and control over the victim.123 That exacerbates the vulnerability of a child by depriving her or him of protection. 124 102. Moreover, the Commission has stressed that, as indicated in Article 9 of the Convention of Belém do Pará, States must pay special heed to the needs and rights of girls who, as females, pertain to a vulnerable group. 125 Along those same lines, the Inter-American Court has pointed out: Here, it is pertinent to point out that the Convention of Belem do Para itself found it relevant to stress that state policies designed to prevent, punish, and eradicate violence against women had to take into account the vulnerability to violence of girls or adolescents. Article 9 of the Convention establishes that States Parties shall pay special heed to the vulnerability to violence of women under 18 years of age, so that n cases in which a girl or an adolescent is a victim of violence against women, especially sexual violence or rape, State authorities shall take special care in the course of investigations and internal processes, as well as when it I/A Court H.R. Case of V.R.P., V.P.C. et al v. Nicaragua. Preliminary Objections, Merits, Reparations, and Costs. Judgment of March 8, 2018. Series C No. 350, par. 156. Citing: The Committee on their Rights of the Child has pointed out that: " At a universal level all children aged 0- 18 years are considered vulnerable until the completion of their neural, psychological, social and physical growth and development. Babies and young children are at higher risk due to the immaturity of their developing brain and their complete dependency on adults Both girls and boys are at risk, but violence often has a gender component." Committee on the Rights of the Child, General Comment Nº 13. The right of the child to freedom from all forms of violence, 2011, par. 72(f). 119 I/A Court HR. Case of V.R.P., V.P.C. et al v. Nicaragua. Preliminary Objections, Merits, Reparations, and Costs. Judgment of March 8, 2018. Series C No. 350, par. 156. Citing: Cf. Juridical Condition and Human Rights of the Child. Advisory Opinion OC-17/02, supra, par. 61, and Rights and Guarantees of Children in the Context of Migration and/or in Need of International Protection. Advisory Opinion OC-17/14, supra, par. 71. 120 I/A Court HR. Case of V.R.P., V.P.C. et al v. Nicaragua. Preliminary Objections, Merits, Reparations, and Costs. Judgment of March 8, 2018. Series C No. 350, par. 156. Citing: Report of the Special Rapporteur on violence against women, its causes and consequences, 13 June 2017, United Nations Document A/HRC/35/30, paras. 21 and 100, and Committee on the Elimination of Discrimination against Women, General recommendation No. 35 on gender-based violence against women, updating general recommendation No. 19, 26 July 2017, United Nations document CEDAW/C/GC/35, para. 10. 121 I/A Court HR. Case of V.R.P., V.P.C. et al v. Nicaragua. Preliminary Objections, Merits, Reparations, and Costs. Judgment of Thursday, March 08, 2018. Series C No. 350, par. 156. 118 Committee on the Elimination of Discrimination against Women (CEDAW), General Recommendation No. 28, 2010, para 21. Likewise, according to CEDAW, "States parties must legally recognize such intersecting forms of discrimination and their compounded negative impact on the women concerned and prohibit them." Committee on the Elimination of Discrimination against Women (CEDAW), General Recommendation No. 28, 2010, para 18. 123 ECHR, O’Keeffe v. Ireland. Judgment of January 28, 2014, par. 153. 124 ECHR, C.A.S. and C.S. v. Romania. Judgment of September 24, 2012, par. 71. 125 IACHR Report No. 170/11, Case 12.578, Merits, María Isabel Véliz Franco et al, Guatemala, November 3, 2011, par. IACHR, Report 4/16, Case 12.690, Merits, VRP and VCP, Nicaragua, August 25, 2016, par. 104. 122

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