identity of the witness and be able to observe his demeanor under questioning in order to form its own impression of the reliability of the witness and of his testimony,271 and (b) the defense must be granted every opportunity to examine the witness directly at some stage of the proceedings on matters that are not related to his identity or actual residence; this is so that the defense may assess the demeanor of the witness while under cross-examination in order to be able to dispute his version or, at least, raise doubts about the reliability of the testimony.272 247. Even when counterbalancing procedures have been adopted that appear to be sufficient, a conviction should not be based either solely or to a decisive extent on anonymous statements.273 To the contrary, it would be possible to convict the accused by the disproportionate use of a probative measure that was obtained while impairing this right of defense. Since this is evidence obtained in conditions in which the rights of the accused have been limited, the testimony of anonymous witnesses must be used with extreme caution,274 must be assessed together with the body of evidence, the observations and objections of the defense, and the rules of sound judicial discretion.275 The decision as to whether this type of evidence has weighed decisively in the judgment convicting the accused will depend on the existence of other types of supportive evidence so that, the stronger the corroborative evidence, the less likely that the testimony of the anonymous witness will be treated as decisive evidence.276 a. Criminal proceedings against Messrs. Norín Catrimán and Pichún Paillalao 248. The Court will now examine the judicial control exercised with regard to the adoption of the mechanism of witness anonymity, the counterbalancing measures taken to offset the effects on the right of defense of the accused and, lastly, whether the testimony of the anonymous witnesses, in the specific circumstances of the proceedings, had a decisive impact on the sentencing and conviction of Messrs. Norín Catrimán and Pichún Paillalao. 249. The judicial control of the anonymity of witnesses was insufficient. The judicial decision that ordered it does not contain any explicit justification, and merely admits a request of the Public Prosecution Service that only refers to the “nature,” the “characteristics,” and “seriousness” of the case, without specifying the objective criteria, the reasoning, and the verifiable evidence that, in the specific case, would substantiate the alleged risk for the witnesses and their families (supra paras. 232 and 233). The Court understands that this 271 Cf. ECHR, Case of Kostovski v. The Netherlands (no. 11454/85), Judgment of 20 November 1989, para. 43; ECHR, Case of Windisch v. Austria, (no. 12489/86), Judgment of 27 September 1990, para. 29, and ECHR, Case of Doorson v. The Netherlands, para. 73. 272 Cf. International Criminal Tribunal for the Former Yugoslavia (ICTFY), Prosecutor v. Dusko Tadic a/k/a “Dule”, Decision on the Prosecutor’s Motion Requesting Protective Measures for Victims and Witnesses, 10 August 1995, paras. 67 and 72; ECHR, Case of Kostovski v. The Netherlands, No. 11454/85. Judgment of 20 November 1989, para. 42; Case of Windisch v. Austria, No. 12489/86. Judgment of 27 September 1990, para. 28; Case of Doorson v. The Netherlands, para. 73; Case of Van Mechelen and Others v. The Netherlands, Nos. 21363/93, 21364/93, 21427/93 and 22056/93. Judgment of 23 April 1997, paras. 59 and 60. 273 Cf. ECHR, Case of Doorson v. The Netherlands, para. 76, and Case of Van Mechelen and Others v. The Netherlands, Nos. 21363/93, 21364/93, 21427/93 and 22056/93. Judgment of 23 April 1997, paras. 53 a 55. 274 Cf. ECHR, Case of Doorson v. The Netherlands, para. 76, and Case of Visser v. The Netherlands, No. 26668/95. Judgment of 14 February 2002, para. 44. 275 Mutatis mutandis, Case of Velásquez Rodríguez v. Honduras. Merits, para. 146, and Case of the Santo Domingo Massacre v. Colombia. Preliminary objections, merits and reparations. Judgment of November 30, 2012. Series C No. 259, para. 44. 276 Cf. ECHR, Case of Al-Khawaja and Tahery v. The United Kingdom, Nos. 26766/05 and 22228/06. Judgment of 15 December 2011, para. 131. 87