-1954. Allow me to illustrate this point with an example taken from the experience, trial and error of the European system for the protection of human rights. Initially, the case law of the European Court of Human Rights supported the “accessory” nature of Article 13 (right to an effective recourse) of the European Convention on Human rights, understood, as of the 1980s, as guaranteeing a subjective individual substantive right. Gradually, in its judgments in Klass v. Germany (1978), Silver and Others v. United Kingdom (1983), and Abdulaziz, Cabales and Balkandali v. United Kingdom (1985), the European Court began to recognize the autonomous nature of Article 13. Finally, after years of hesitation and indecisiveness, in its judgment of December 18, 1996, in Aksoy v. Turkey (paragraphs 95 to 100), the European Court decided that there had been an “autonomous” violation of Article 13 of the European Convention. 55. In a pioneering study on the issue published in 1973, Pierre Mertens criticized the “poverty” of the initial case law of the European Court, as well as the vague nature of the European legal writings on the issue at the time – very different from the more advanced Latin American legal writings and practice, following the adoption of the 1948 American Declaration; the first international instrument to enshrine the right to an effective recourse.42 Thus, P. Mertens stated more than 30 years’ ago that it was necessary to pave the way to ensuring that the right an effective recourse (Article 13 of the European Convention) gave rise to all its effects in the domestic law of the States Parties. In reality, the “effectiveness” of that right is measured in light of the criteria of the guarantees of due process of law (Article 6 of the European Convention); thus, the conclusion of P. Mertens that Articles 6 and 13 of the European Convention - which correspond to Articles 8 and 25 of the American Convention – should frequently “be invoked together.”43 56. Indeed, as time has passed, attention has again been paid to the relationship between Articles 13 and 6(1) of the European Convention, the latter (the right to a fair trial) constituting the object of extensive case law of the European Court, together with intense doctrinal debate.44 In an emphatic ruling in Kudla v. Poland (judgment of October 18, 2000), the European Court of Human Rights stated that the time had come to end the uncertainty of the past and to accept the direct relationship between Articles 6(1) and 13 of the European Convention (cf. paras. 146-149 and 151). And, in a significant obiter dictum, the European Court indicated that: "(...) Article 13, giving direct expression to the State's obligation to protect human rights first and foremost within their own legal system, establishes an additional guarantee for an individual in order to ensure that he or she effectively enjoys those rights. The object of Article 13, as emerges from the travaux préparatoires [of the European Convention on Human Rights], is to provide a means whereby individuals can obtain relief at national level for violations of their Convention rights before having to set in motion the international machinery of complaint before the Court. From this perspective, the right of an individual to trial within a reasonable time will be less effective if there exists no opportunity to submit the Convention claim first to a national authority; and the 42 . P. Mertens, Le droit de recours effectif devant les instances nationales en cas de violation d'un droit de l'homme, Bruxelles, Éd. de l'Univ. de Bruxelles, 1973, pp. 19-20, 24-25 and 27-29, and cf. pp. 37-39. 43 . 44 Ibid., p. 93. . L.-E. Pettiti, E. Decaux and P.-H. Imbert, La Convention Européenne des droits de l'homme, Paris, Economica, 1995, pp. 455-474.