context of impunity (supra para. 51) that persists to this day, 234 in addition to the context of violence and murders against human rights defenders, particularly in the area of rural conflicts. In this regard, expert witness Carlos Eduardo Gaio asserted that: In the last 20 years of available data, from 2001–2020, the context of violence and murder remained constant or worsened in some periods. During that period, 269 murders of land rights defenders were documented in the state of Pará alone, out of a total of 762 activists murdered in the entire country during the same period. It is undoubtedly the state in which the lives of rural workers and human rights defenders are most at risk. 235 170. As it has in other cases, 236 the Court deems it necessary for the State to create and implement nationally, within three years, a unified, comprehensive protocol of investigation focused specifically on crimes against human rights defenders, which takes into account the risks inherent in their work. This initiative will ultimately help improve access to justice, 237 in light of the context of impunity for murders of human rights defenders in Brazil (supra, para. 51). To that end, this protocol shall (i) follow due diligence principles to identify all those responsible for such crimes and follow the guidelines that “complement and reinforce due diligence in the investigation of human rights violations against human rights defenders” established by Special Rapporteur on the situation of human rights defenders, Michel Forst; 238 (ii) set clear and uniform criteria for investigations; (iii) include parameters for all investigatory stages; (iv) comprehensively regulate the specific functions and responsibilities of the Public Prosecutor's Office, the police, the judiciary, expert institutes, and other bodies involved in the investigation of serious human rights violations; and it shall also give consideration to: 1) The concept of a human rights defender; 2) Standards on the development of investigatory tools for due diligence, including international best practices and due diligence standards according to the type of crime (for example, extrajudicial killings, murders, torture, threats, etc.); 3) The risks inherent to the work of defending human rights in Brazil, including regional specifics; 4) The context in which human rights defenders work and the interests they challenge in the country and in each region; 5) The existence of threat patterns and any methods used to frighten, threaten, intimidate, or attack human rights defenders in their work; 6) Criteria and techniques for investigating whether the criminal acts are related to the work of the human rights defenders; 234 According to the Institute for Applied Economic Research, “the institutional roots of rural violence in Brazil—profound social and economic inequality between rural and urban areas, a high concentration of land ownership, a lack of mechanisms for mediating and resolving rural conflicts, and high levels of impunity for crimes against traditional communities, rural workers, and small farmers—have persisted throughout the country's history and remain entrenched to this day.” Institute for Applied Economic Research. Atlas da Violência no Campo no Brasil: Condicionantes socioeconômicos e territoriais. Brasília, 2020, p.10. Available in Portuguese at: https://ipea.gov.br/portal/images/stories/PDFs/relatorio_institucional/200717_relatorio_institucional_atlas_da_violencia.pdf See also expert opinion of Carlos Eduardo Gaio, supra (evidence file, folios 7287 and 7295–7296). 235 Cf. Expert opinion of Carlos Eduardo Gaio, supra (evidence file, folio 7293). See, for example: Case of Acosta et al. v. Nicaragua. Preliminary objections, merits, reparations, and costs. Judgment of March 25, 2017. Series C No. 334, para. 223–224; Case of Escaleras Mejía et al. v. Honduras, supra, para. 102; and Case of Digna Ochoa and family members v. Mexico, supra, para. 178 and 179. 236 237 Cf. Expert opinion of Laurel E. Fletcher, supra (evidence file, folio 7343). Cf. UN, Report of the Special Rapporteur on the situation of human rights defenders, Michel Forst. Doc. A/74/159, July 15, 2019. 238 43