29 protected by the Convention, while those conducts persist.97 It also wishes to make some observations on this issue, in view of the characteristics of these human rights violations against children in a context of armed conflict. 81. On previous occasions, the Court has observed that the attention paid by the international community to the phenomenon of forced disappearance of persons is not a recent development.98 Since the 1980s, the United Nations Working Group on Enforced or Involuntary Disappearances has developed a working definition of the phenomenon, which stresses the illegal detention by agents, government agencies or organized groups of individuals acting in the name of the State or with its support, authorization, or consent.99 The conceptual elements established by this Working Group were later taken up in the definitions in different international instruments. 82. The characterization of forced disappearance as an act that includes multiple offenses with regard to the rights affected and as continuing or permanent has also emerged consistently from this Court’s case law since the first case it decided in 1988,100 which was even prior to the definition contained in the Inter-American Convention on Forced Disappearance of Persons.101 This characterization is consistent with other definitions contained in different international instruments102 that indicate the following as concurrent elements constituting forced disappearance: (a) deprivation of liberty; (b) direct involvement of State agents or their acquiescence, and (c) refusal to acknowledge the detention and to reveal the fate or whereabouts of the individual in question.103 On previous occasions, this Court has indicated that the case law of the European Court of Human Rights,104 the decisions of different bodies of the United Nations,105 and of several 97 Cf. Case of Radilla Pacheco, supra note 25, para. 138; Case of Gelman, supra note 16, para. 72, and Case of Gomes Lund et al. (Guerrilha do Araguaia) v. Brazil. Preliminary objections, merits, reparations and costs. Judgment of November 24, 2010. Series C No. 219, para. 101. 98 Cf. Case of Chitay Nech et al. v. Guatemala. Preliminary objections, merits, reparations and costs. Judgment of May 25, 2010. Series C No. 212, para. 82; Case of Gelman, supra note 16, para. 66, and Case of Gomes Lund et al. (Guerrilha do Araguaia), supra note 97, para. 102. 99 Cf. Report of the Working Group on Enforced or Involuntary Disappearances, Commission on Human Rights, thirty-seventh session, U.N. Doc. E/CN.4/1435, of 22 January 1981, para. 4, and Report of the Working Group on Enforced or Involuntary Disappearances, Commission on Human Rights, thirty-ninth session, U.N. Doc. E/CN.4/1983/14, of 21 January 1983, paras. 130 to 132. 100 Cf. Case of Velásquez Rodríguez, supra note 23, para. 155; Case of Gomes Lund et al. (Guerrilha do Araguaia), supra note 97, para. 104, and Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia. Merits, reparations and costs. Judgment of September 1, 2010. Series C No. 217, para. 60. 101 That Convention establishes that “forced disappearance is considered to be the act of depriving a person or persons of his or their freedom, in whatever way, perpetrated by agents of the state or by persons or groups of persons acting with the authorization, support, or acquiescence of the state, followed by an absence of information or a refusal to acknowledge that deprivation of freedom or to give information on the whereabouts of that person, thereby impeding his or her recourse to the applicable legal remedies and procedural guarantees.” Article II of the Inter-American Convention on Forced Disappearance of Persons, adopted at Belém do Pará, Brazil, on June 9, 1994, at the twenty-fourth regular session of the General Assembly. 102 Cf. Article 2 of the International Convention for the Protection of All Persons from Enforced Disappearance, U.N. Doc. A/RES/61/177, of 20 December 2006; Article 7(2)(i) of the Rome Statute of the International Criminal Court, U.N. Doc. A/CONF.183/9, of 17 July 1998, and Working Group on Enforced or Involuntary Disappearances, General Comment on Article 4 of the Declaration on the Protection of All Persons from Enforced Disappearance of 15 January 1996. Report to the Commission on Human Rights. U.N. Doc. E/CN. 4/1996/38, para. 55. 103 Cf. Case of Gómez Palomino v. Peru. Merits, reparations and costs. Judgment of November 22, 2005. Series C No. 136, para. 97; Case of Gelman, supra note 16, para. 65, and Case of Gomes Lund et al. (Guerrilha do Araguaia), supra note 97, para. 104. 104 Cf. Eur. Court HR, Case of Kurt v. Turkey (Application no. 15/1997/799/1002). Judgment of 25 May 1998, paras. 124 to 128; Eur. Court HR, Case of Çakici v. Turkey (Application no. 23657/94). Judgment of 8 July 1999, paras. 104 to 106; Eur. Court HR, Case of Timurtas v. Turkey (Application no. 23531/94). Judgment of 13 June