52 in the events referred to in the paragraphs above relating to the enjoyment of fundamental rights may be attributed to the State of Colombia and, consequently, compromise its responsibility in accordance with international law. For this, as the Inter-American Court has stated, it is sufficient to demonstrate that 247 there has been State support or tolerance of a breach of the rights recognized in the Convention. 225. In the first place, as the IACHR has established in its Third Report, it is right to point out that the State has played an important role in the spread of the so-called paramilitary or self-defense groups whom it has allowed to act with legal protection and legitimacy in the decades of the seventies 248 249 and eighties, and it is responsible in a general way for their existence and strength. 226. These groups, sponsored or tolerated by sectors of the Military Forces, were in large part 250 created in order to combat dissident armed groups. As a result of their counterinsurgent aims, the paramilitaries have established links with the Colombian Army which strengthened during more that two decades. Finally, on May 25, 1989, the Supreme Court of Justice declared paragraph 3 of Article 33 of Legislative Decree 3398 of 1968 unconstitutional, which gave a lawful platform for the creation of self251 defense groups, and withdrew the legal support for its links with national defense, after which the State enacted a series of legislative measures to criminalize the activities of these groups and those supporting 252 them. Despite this, the State has done little to dismantle the structure they created and fostered, particularly when these groups lead counterinsurgency activities, in fact, the links have endured at different levels, in some case, requesting or allowing the paramilitaries to undertake certain illegal acts on 253 the understanding that they would not be subject to investigation, trial or punishment. The acceptance 254 of these groups by certain sections of the Army has been denounced by entities of the State itself. 227. This situation has led the Commission, for the purpose of determining the international responsibility of the State in accordance with the American Convention, to establish that in those cases where paramilitaries and members of the Army perform joint operations with the knowledge of superior 247 I/A Court H.R. I/A Court H.R., Case of the “Mapiripán Massacre” v. Colombia. Judgment of September 15, 2005. Series C No. 134, para. 110, Case of Paniagua Morales et al., Judgment of March 8, 1998, para.91. IACHR Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 60. 248 In effect, Decree 3398 of 1965 (Law of National Defense) and Law 48 of 1968 authorized the creation of civilian patrols that would receive weapons for private use from the State security forces under authorization from the Ministry of Defense. Article 25 of Decree 3398 of 1965 established that "All Colombians, both men and women, not included in the call to obligatory military service, may be used by the Government in activities and work with which they may contribute to reestablishing normalcy". IACHR Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 61. 249 Annex 15. IACHR. Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999, Ch. IV, para. 236. At: http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm. IACHR Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 61. 250 Annex 15. IACHR. Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999, Ch. I, paras. 7-19. At: http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm. IACHR Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 62. 251 Articles 25 and 33 of Legislative Decree 3398 (Law of National Defense) and Law 48 of 1968 provided a legal basis for the creation of "self-defense groups". Cf. I/A Court H.R., Case of the 19 Tradesmen v. Colombia. Judgment of July 5, 2004. Series C No. 109, para. 84 g). 252 Decrees 1149 of June 8, 1989 and 2266 of 1991. IACHR. Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 62. 253 Annex 15. IACHR. Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999. Ch. I, paras. 17-19. At: http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm. See also Annex 14. Report of the UN High Commissioner for Human Rights (UNHCHR) on the Colombia Office, April 2000, para. 30. At: http://www.unhchr.ch/Huridocda/Huridoca.nsf/(Symbol)/E.CN.4.1998.16.En?Opendocument. See also IACHR. Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 62. 254 Annex 15. IACHR. Third Report on the Situation of Human Rights in Colombia. OEA/Ser.L/V/II.102 Doc. 9 rev. 1, February 26, 1999, Ch. IV, paras. At: http://www.cidh.org/countryrep/Colom99en/table%20of%20contents.htm. 37-239. IACHR. Report No. 75/06 Jesús María Valle Jaramillo of October 16, 2006, para. 62.