20 73. Regarding the obligation to continue to implement and, if applicable, develop permanent human rights education programs within the Colombian armed forces, and guarantee their effective implementation (operative paragraph twelve of the Judgment), Colombia requested the Court to “take into account the information provided by the State in the procedure to monitor compliance with the Judgment in the case of the “Mapiripán Massacre” in which it gave details of the different activities carried out to implement programs on human rights education, and international humanitarian law, within the armed forces of the country." In that respect, it requested the Tribunal to declare that Colombia had complied with operative paragraph twelve of the Judgment “bearing in mind that the obligation ordered in this case is similar to the one ordered in the case of the ‘Mapirián Massacre’ and 'Ituango Massacre,' in which the Court has already declared compliance therewith.” 74. The representatives did not present observations on the compliance with this reparation measure. 75. The Commission indicated that “as in the case of Mapiripán, […] it value[d] that the State [was] implementing, within its armed forces, the courses on human rights and international humanitarian law [...]." 76. The Court notes that the reparation measure ordered in the instant case22 related to human rights training within the Colombian armed forces is similar to the training measures that Colombia was ordered to implement in the cases of the Mapiripán Massacre and the Ituango Massacre. In the three judgments, the Tribunal ordered the implementation of permanent programs on human rights within the Colombian armed forces. In fact, in the cases of the Mapiripán Massacre and the Ituango Massacre, the Court has already declared compliance with this measure by means of Orders issued in July 2009.23 77. Based on the similarity of the training measures ordered by the Court and taking into account the State's request to admit, in this case, the information presented on compliance with the training measure in the case of the Mapiripán Massacre, which was not objected to by the representatives, the Tribunal considers it useful, based on the principle of procedural economy, to admit such information into the case file, taking into account that the Commission as well as the representatives have had the opportunity to present observations on the matter in the case of the Mapiripan Massacre.24 22 In operative paragraph twelve and paragraph 303 of the Judgment, the Court ordered: […] the State must adopt measures designed to educate and train members of security forces on the principles and rules governing the protection of human rights and international humanitarian laws, including limitations that constrain them. To that end, the State [should] effectively implement, within a reasonable time, permanent training programs on human rights for the Colombian armed forces. The program sh[ould] place particular stress on this Judgment and the State [should] guarantee its effective implementation. 23 See Case of the Ituango Massacres V. Colombia; supra note 8, Considering Clauses 45 to 50; Case of the Mapiripan Massacre V. Colombia; supra note 8, Considering Clauses 62 to 64. 24 In a similar sense, see Case of the Ituango Massacres V. Colombia; supra note 8, Considering Clauses forty-nine.

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