been infringed and to redress the consequences of the violations that have occurred. 240
Therefore, the Court has found it necessary to grant diverse measures of reparation in order
to repair the harm fully, so that in addition to pecuniary compensation, measures of
restitution, rehabilitation and satisfaction and also guarantees of non-repetion have special
relevance for the harm caused.241
200. The Court has established that reparations should have a causal nexus to the facts of
the case, the violations declared, the harm proved, and the measures requrested to redress
the respective harm. Therefore, the Court must analyze whether these elements are present
in order to rule appropriately and in accordance with law.242
201. Based on the violations declared in the preceding chapters, the Court will proceed to
examine the claims presented by the Commission and the representatives, together with
the arguments of the State, in light of the criteria established in its case law concerning the
nature and scope of the obligation to make reparation, in order to establish the measures
aimed at redressing the harm caused to the victims.243
202. International case law and, in particular, that of the Court, has established
repeatedly that the judgment constitutes, in itself, a form of reparation.244 Nevertheless,
considering the circumstances of this case and the suffering that the violations commtted
caused to the victims, the Court finds it pertinent to establish other measures.
A. Injured party
203. The Court considers that “injured party,” in the terms of Article 63(1) of the
American Convention, refers to those who have been declared victims of the violation of any
right recognized therein.245 Therefore, the Court considers that the victims and their next of
kin are the “injured party”246 and, in their capacity as victims of the violations declared in
this judgement, they will be considered the beneficiaries of the reparations ordered by the
Court.
B. Measures of rehabilitation and satisfaction and guarantees of non-repetition
Cf. Case of Velásquez Rodríguez v. Honduras. Reparations and costs. Judgment of July 21, 1989. Series C
No. 7, para. 26, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits, reparations and costs.
Judgment of April 25, 2018. Series C No. 354, para. 467.
240
Cf. Case of the Las Dos Erres Massacre v. Guatemala. Preliminary objection, merits, reparations and costs.
Judgment of November 24, 2009. Series C No. 211, para. 226, and Case of Ramírez Escobar et al. v. Guatemala.
Merits, reparations and costs. Judgment of March 9, 2018. Series C No. 351, para. 266.
241
Cf. Case of Ticona Estrada et al. v. Bolivia. Merits, reparations and costs. Judgment of November 27,
2008. Series C No. 191, para. 110, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits,
reparations and costs. Judgment of April 25, 2018. Series C No. 354, para. 468.
242
243
Cf. Case of Andrade Salmón v. Bolivia. Merits, reparations and costs. Judgment of December 1, 2016.
Series C No. 330, para. 189, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits, reparations
and costs. Judgment of April 25, 2018. Series C No. 354, para. 469.
Cf. Case of Neira Alegría et al. v. Peru. Reparations and costs. Judgment of September 19, 1996. Series C
No. 29, para. 56, and Case of Amrhein et al. v. Costa Rica. Preliminary objections, merits, reparations and costs.
Judgment of April 25, 2018. Series C No. 354, para. 474.
244
Cf. Case of Gonzales Lluy et al. v. Ecuador. Preliminary objections, merits, reparations and costs.
Judgment of September 1, 2015. Series C No. 298, para. 233, and Case of Amrhein et al. v. Costa Rica.
Preliminary objections, merits, reparations and costs. Judgment of April 25, 2018. Series C No. 354, para. 470.
245
246
Both the direct victims and their next of kin are listed in Annex 2 to the judgment.
69