9 29. In recent years, the Inter-American Court has heard successive cases of massacres and has ruled on them (for example, the cases of the massacre of Barrios Altos, the Plan de Sánchez Massacre, the massacre of the 19 Tradesmen, the Mapiripán Massacre, the massacre of the Moiwana Community, the Pueblo Bello Massacre, the Ituango Massacres). It has also decided cases that occurred in the context of systematic human rights violations (for example, the Barrios Altos and Myrna Mack Chang cases, among others), planned (at the highest hierarchical level) and executed by the State. As I indicated in my opinions in all these cases, they reveal the urgency of promoting a greater approximation or convergence between international human rights law and international criminal law and, in particular, between the work of international human rights courts and international criminal courts. 30. In the abovementioned cases, among others, the Inter-American Court established the aggravated international responsibility of the State and its legal consequences in relation to reparations. I have referred to this in detail in my opinions in those cases. In the instant case, we are faced with a situation, in the extremely grave context of “Operation Condor,” of State terrorism on an international or, more precisely, an inter-State scale. In my opinion, this constitutes the State’s aggravated international responsibility for authentic State crimes, with all their legal consequences. 31. Aggravated international responsibility is also constituted owing to the State’s failure to comply with both the obligation to protect and the obligation to investigate the harmful facts, due to its failure to provide effective domestic recourses to prosecute and sanction the perpetrators of the atrocities. It should be recalled that, in its well-formulated application (of June 8, 2005), submitted to the Court in this case, the Commission indicated that: “More than 27 years have elapsed without the next of kin of the victims knowing, through final, executed judgments encompassing all the mastermind, perpetrators and accessories after the fact, what occurred to Agustín Goiburú, Carlos José Mancuello, Rodolfo Ramírez Villalba and Benjamín Ramírez Villalba, where there remains are, who was responsible for their forced disappearance, what punishment was imposed, and what reparation corresponds to them from the courts; all this constituting a context of impunity that affects their fundamental rights protected by the Convention.” (para. 152). 32. All these aggravating circumstances lead to a greater approximation between the international responsibility of the State and the international criminal responsibility of the individual (perpetrator of the atrocities), as I indicated in my separate opinion (paras. 38-40) in the Mapiripán Massacre v. Colombia (judgment of September 17, 2005). The responsibility of the criminal does not exempt the State from its own aggravated responsibility, owing to its criminal policies, because the State, endowed with its own legal status, can be accused, as any other subject of law.27 27 . Cf. A.A. Cançado Trindade, “Complementarity between State Responsibility and Individual Responsibility for Grave Violations of Human Rights: The Crime of State Revisited,” in International Responsibility Today - Essays in Memory of O. Schachter (ed. M. Ragazzi), Leiden, M. Nijhoff, 2005, pp. 253269.