85 existence of a generalized and systematic pattern of forced displacement under analysis. Therefore, it concludes that the forced displacement suffered by the Cacarica Afro-descendant communities represented a systematic violation against members of the Cacarica Afro-descendant communities, and therefore a crime against humanity. 6. Judicial Guarantees and Judicial Protection for the Members of CAVIDA, the Women Head of Household living in Turbo and the Family of Marino López (Arts. 8 and 25 of the ACHR in relation to Art. 1.1 and to Arts. 1, 6 and 8 of the Convention to Prevent and Punish Torture) 384. The Commission is including in the present report an analysis of Article 6 of the InterAmerican Convention to Prevent and Punish Torture, as it bears a connection with allegations relating to Articles 1 and 8, and with Articles 8 and 25 of the American Convention, included at the admissibility stage. 385. Article 8.1 of the American Convention establishes that: Every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, previously established by law, in the substantiation of any accusation of a criminal nature made against him or for the determination of his rights and obligations of a civil, labor fiscal, or any other nature. 386. Article 25.1 of the Convention establishes that Everyone has the right to simple and prompt recourse, or any other effective recourse, to a competent court of tribunal for protection against acts that violate his fundamental rights recognized by the constitution or laws of the state concerned or by this Convention, even though such violation may have been committed by persons acting in the course of their official duties 387. In determining a possible violation of Article 8 of the Convention, it is necessary to examine whether the procedural guarantees of the party affected were respected in the judicial 413 proceedings. Any obstruction of justice, impediment or lack of assistance by the authorities which have impeded or currently impede the clarification of the case, constitute a violation of Article 1.1 of the Convention. 388. For its part, Article 25.1 of the American Convention embodies the principle of the effectiveness of instruments or procedural means designed to guarantee human rights. 414 389. reinforcing: As the Inter-American Court has emphasized, Articles 8, 25 and 1.1 are mutually Article 25 in relation to Article 1.1 of the American Convention obliges the State to guarantee to every individual access to the administration of justice and, in particular, to simple and prompt recourse, so that, inter alia, those responsible for human rights violations may be prosecuted and reparations obtained for the damages suffered...Article 25 'is one of the fundamental pillars not only of the American Convention, but of the very rule of law in a democratic society in the terms of the Convention". That article is closely linked to Article 8.1, which provides that every person has the right to a hearing, with due guarantees and within a reasonable time, by a competent, independent, and impartial tribunal, for the determination of his rights, whatever their nature. 415 413 I/A Court H.R., Case of Genie Lacayo. Judgment of January 29, 1997. Series C No. 30, para. 74. 414 I/A Court H.R., Judicial Guarantees in States of Emergency (Arts. 27.2, 25 and 8 of the American Convention on Human Rights). Advisory Opinion OC-9/87 of October 6, 1987. Series A No. 9, para. 24. 415 I/A Court H.R., Case of Loayza Tamayo. Reparations (Art. 63.1 of the American Convention on Human Rights). Judgment of November 27, 1998. Series C No. 42, para. 169.