deprivation of rights and the intersectionality increased the State’s obligations to respect and to ensure her rights (Art.1(1) of the Convention) and determined that, pursuant to Article 2, the State must adopt “ the legislative or other measures” required to overcome the numerous rights’ violations. III. Importance of the gender perspective in relation to access to justice in cases such as that of Manuela 24. The positive obligation of the State, on verifying a pattern of intersectional and structural discrimination such as that described, consists in the development of lines of action by implementing systematic policies that act on the origins and causes of its existence. Therefore, it is necessary to mention that the State is especially obliged to ensure the right to the presumption of innocence and the right to defense in cases such as this one in which, in a context of structural discrimination against women, several factors of discrimination coalesce intersectionally.24 25. In this regard, the Committee for the Elimination of Discrimination against Women has indicated that “discrimination against women is compounded by intersecting factors that affect some women to degrees or in ways that differ from those affecting men or other women”25 Thus, “these intersecting factors make it more difficult for women from those groups to gain access to justice.”26 26. In this context, the guarantee of the right to a professional defense with a gender perspective and awareness of gender issues, competent, efficient and provided from the first interrogation and during the subsequent procedures was essential. This was a specific duty of the State in this case, in which a special situation of vulnerability existed caused by the intersectionality of various factors of discrimination, such as Manuela’s condition of being a poor illiterate rural women, which exacerbated the structural discrimination against women in general, and severely limited her access to justice.27 27. The convergence of all these elements constitutes a specific form of discrimination,28 in which the different factors are interrelated and mutually reinforcing, 29 and this exacerbates the structural discrimination against women and creates a special situation of vulnerability, such as that of Manuela. The Court has considered, in this regard, that when victims belong to a group in a special situation of vulnerability, the State’s obligations to respect and ensure rights are increased.30 28. Accordingly, I consider it essential to elaborate on the measure of non-repetition linked to the verified intersectionality of violations in order to address the structural pattern of discrimination against women. This State obligation signifies that the authorities in charge of the investigation, such as the police and the prosecutors must act with enhanced 24 Amicus Curiae, Fundación para el Debido Proceso, p. 3. 25 CEDAW. General recommendation No. 33 on women’s access to justice, CEDAW/C/GC/33, August 3, 2015, para. 8. CEDAW. General recommendation No. 33 on women’s access to justice, CEDAW/C/GC/33, August 3, 2015, para. 8. 26 27 Amicus Curiae Fundación para el Debido Proceso, p. 15 Cf. Case of the Workers of the Fireworks Factory of Santo Antônio de Jesus and their families v. Brazil. Preliminary objections, merits, reparations and costs. Judgment of July 15, 2020. Series C No. 407, para. 191, and Case of Gonzales Lluy et al. v. Ecuador. Preliminary objections, merits, reparations and costs. Judgment of September 1, 2015. Series C No. 298, para. 290. 28 Cf. Human Rights Council. Report of the Working Group on the issue of discrimination against women in law and in practice. Women deprived of liberty. A/HRC/41/33, May 15, 2019, para. 15. 29 Cf. Case of the Workers of the Fireworks Factory of Santo Antônio de Jesus and their families v. Brazil. Preliminary objections, merits, reparations and costs. Judgment of July 15, 2020. Series C No. 407, para. 198. 30 6