behind the facts 284 or the identities of other co-perpetrators who may have participated in them. This Court recalls that the investigation of complex cases requires “direct[ing] the efforts of the State apparatus towards unraveling the structures that permitted these violations, the causes, the beneficiaries, and the consequences.” 285 The Court notes that the representatives and the Commission have noted the existence of evidence of possible State participation in these facts and that, in the preceding chapter, it determined the State was responsible for breaching its duty to respect with regard to the facts of May 25, 2000. In this regard, the State has argued that Colombian courts continue to pursue criminal investigations into the aforementioned facts and that, specifically, it is currently pursuing a line of investigation seeking to determine whether State agents participated in the facts under analysis. 286 However, the Court observes that although more than 21 years have passed since the facts, this line of investigation remains open and has yet to yield any results. 133. Therefore, the Court concludes that based on the actions of the State’s investigative and forensic authorities in charge of delivering justice in this specific case, the State of Colombia did not act with the enhanced due diligence required in the investigations and criminal proceedings related to the violence and torture suffered by Ms. Bedoya on May 25, 2000. b.1.2 Gender discrimination 134. The Court recalls that in cases of violence against women, the general obligations established in Articles 8 and 25 of the American Convention are supplemented and enhanced for those States that are party to the Convention of Belém do Pará by the obligations derived from this specific interAmerican treaty. Article 7(b) of this Convention specifically requires the States parties to apply due diligence to prevent, punish and eradicate violence against women. Thus, when an act of violence is committed against a woman, whether by a State agent or a private party, it is particularly important for the authorities in charge of the investigation to conduct it with determination and efficacy, taking into account their duty to society to reject violence against women and the State’s obligation to eradicate it and ensure that victims have confidence in the institutions established by the State for their protection. 287 135. Likewise, the Court has found in its settled case law that the criminal investigation must include a gender perspective and be conducted by officials trained in similar cases and in attending to victims of discrimination and gender-based violence. 288 The Court recalls that judicial ineffectiveness in individual cases of violence against women fosters an environment of impunity that facilitates and promotes the repetition of acts of violence in general and sends a message that violence against women can be tolerated and accepted, fostering the perpetuation and social acceptance of the phenomenon, the feeling and impression of insecurity among women, and persistent mistrust of the 284 During the public hearing, Ms. Bedoya stated as follows: The investigation into the masterminds is completely dead, despite the fact that they have been named, there is evidence, there is testimony, and my attorneys have consistently asked for an investigation to be opened and responsibility established.” Cfr. Statement from Jineth Bedoya Lima given at the public hearing held on March 15, 22, and 23, 2021 within the framework of the 140th regular sessions. Cf. Case of Rodríguez Vera et al. (the Disappeared from the Palace of Justice) v. Colombia, supra, para. 500, and Case of Isaza Uribe et al. v. Colombia. Merits, Reparations, and Costs. Judgment of November 20, 2018. Series C No. 363, para. 153. 285 286 Cf. Final arguments of the State presented on April 23, 2021 (merits file, folio 1551). Cf. Case of Fernández Ortega et al. v. Mexico, supra, para. 193, and Case of V.R.P., V.P.C et al. v. Nicaragua, supra, para. 152. 287 Cf. Case of González et al. (“Cotton Field”) v. Mexico, supra, para. 455, and Case of Guzmán Albarracín et al v. Ecuador, supra, para. 177. 288 50

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