disappearance. Even without that hypothesis, it is necessary that penitentiary personnel be trained to prevent possible forced disappearances [...].127 this becomes vital in cases such as the one addressed here in which the detention and subsequent disappearance of Mr. Vásquez Durand constituted a grave violation of his rights, characterized by concealment and denial of his detention, which result, inter alia, in the victim being deprived of judicial protection and guarantees. 131. The Inter-American Court has considered the content of the right to the truth in its case-law, especially in cases of forced disappearances. In the case of Velásquez Rodríguez the Court confirmed the existence of “the right to inform the relatives of the fate of the victims and, if they were killed, the location of their remains.”128 In this type of cases, it is considered that the relatives of the disappeared victims are victims of the deeds constituting forced disappearance, by which they are entitled to have the facts investigated and those responsible prosecuted and punished.129 The Court has recognized that the right to the truth of the relatives of victims of serious human rights violations is framed within the right to access to justice.130 132. The right to know the truth has been also recognized by several treaties of the United Nations and recently, by the General Assembly of the Organization of American States (OAS).131 133. According to the case-law of the Inter-American Court: …the right to know the truth represents a necessary effect for it is important that a society knows the truth about the facts of serious human rights violations. This is also a fair expectation that the State is required to satisfy, on the one hand, by means of the obligation to investigative human rights violations and, on the other hand, by the public dissemination of the results of the criminal and investigative procedures. The right to know the truth requires from the State the procedural determination of the patterns of joint action and of all those who participated in various ways in said violations and their corresponding responsibilities. Moreover, in compliance with the obligation to guarantee the right to know the truth, States may establish Truth Commissions, which can contribute to building and safeguarding historical memory, to clarifying the events and to determining institutional, social and political responsibilities at certain periods of time in a society.132 134. With respect to the rights of the next-of-kin of victims of human rights violations to obtain justice and reparation, the Court has found that [f]rom Article 8 of the Convention it is evident that the victims of human rights violations, or their next-of-kin should have substantial possibilities to be heard and to act in the respective proceedings, both to clarify the facts and punish those responsible, and to seek due reparation.133 127 IACHR, Report on the Human Rights of Persons Deprived of Liberty in the Americas. OEA/Ser.L/V/II. Doc 64. December 31, 2011, paragraph 203. 128 I/A Court H.R., Velásquez Rodríguez v. Honduras. Merits. Judgment of July 29, 1988. Series C. No. 4 paragraph 181. 129 I/A Court H.R., Case of Blake v. Guatemala. Judgment of January 24, 1998. Series C No. 36, paragraph 97. 130 I/A Court H.R, Case of Anzualdo Castro v. Peru. Judgment of September 22, 2009, Series C No. 202, paragraph 118. Set of principles for the protection and promotion of human rights through action to combat impunity (E/CN.4/2005/102/Add.1). Report of Professor Diane Orentlicher on the updating of the set of principles for the protection and promotion of human rights through action to combat impunity (E/CN.4/2005/102, of February 18, 2005). Study by the Office of the United Nations High Commissioner for Human Rights on the right to the truth (E/CN.4/2006/91 of January 9, 2006). OAS General Assembly Resolutions on the Right to the Truth, AG/RES. 2175 (XXXVI-O/06), AG/RES. 2267 (XXXVIIO/ 2267, and AG/RES. 2406 (XXXVIII-O/08) 131 132 I/A Court H.R, Case of Anzualdo Castro v. Peru. Judgment of September 22, 2009, Series C No. 202, paragraph 119. I/A Court H.R., Case of García-Prieto et al. v. El Salvador. Preliminary Objection, Merits, Reparations and Costs. Judgment of November 20, 2007. Series C No. 168, paragraph 102; The “Street Children” Case (Villagrán Morales et al.) v. Guatemala. Judgment of [continues …] 133 31