2 "Not only because members of the Colombian law enforcement bodies participated actively, but also because [the events] were part of an agreed plan to combat the insurgents, which included terrorizing the civilian population in the zone in order to eliminate any real or alleged support for the guerrilla.” 2 5. The victims’ representatives also stated that there had been additional violations of Articles 8(1) and 25 of the American Convention on Human Rights, when they added that: “The Colombian State has not provided the victims and their next of kin with effective recourses that guarantee them the right to the truth, justice and the reparation of these grave human rights violations [...]. The Colombian State has organized its structures to keep the authors of these grave human rights violations beyond the reach of the law; and [...] the Colombian State has adopted domestic laws that prevent the victims of these grave facts from access to guarantees of the right to the truth and justice.” 3 6. In its final arguments brief before the Court, when asserting the international responsibility of the respondent State, the representatives concluded that: "The promotion, creation, support and actions of the paramilitary groups are part of a policy to confront the insurgent groups designed by the Colombian State towards the end of the 1960s and implemented since then by the Colombian law enforcement bodies. This counter-insurgency strategy was and is intended to attack individuals and groups that really or allegedly support the guerrilla groups in Colombia. [...] These paramilitary groups are appropriate for this purpose, insofar as, under the legal system, it is difficult for the regular forces (that is, the Colombian law enforcement bodies) to undertake direct combat activities against the civilian population. These attacks on the civilian population were classified as a ‘dirty war’ by the [United Nations] Special Rapporteur on extrajudicial, summary or arbitrary executions [S. Amos Wako,] who visited Colombia in 1989, and have also been acknowledged by the State itself in a report of October 25, 2002 (...). The operations of the paramilitary groups were conducted on a very large scale at the end of the 1980s. [...] Not only were no actions taken against the paramilitary movement in Colombia, but an alternative legal framework was organized to protect the activities of the paramilitary groups, as a fundamental element in the counterinsurgency strategy of the Colombian law enforcement bodies.” 4 7. In this judgment in the Case of the Ituango Massacres, the Court considered it had been proved that the facts of the case “took place in a generalized situation of internal forced displacement that affected Colombia, caused by the internal armed conflict” (para. 208). The Court also noted the State’s initiatives to prohibit, prevent and sanction the activities of the “self-defense” or paramilitary groups, which have, however, been ineffective “in dismantling the paramilitary structures” (paras. 134135). The Court indicated significantly (para. 133): "As the State has acknowledged (supra paras. 63 and 64), it has been proved that State agents were fully aware of the terrorist activities perpetrated by these paramilitary groups on the inhabitants of La Granja and El Aro. Far from taking actions to protect the population, members of the National Army not only acquiesced to the acts perpetrated by the paramilitary groups, but at times collaborated with and took part in them directly. Indeed, the participation of State agents in the armed raids was not limited to 2 . Ibid., p. 157 (internal document). 3 . Ibid., p. 158, and cf. p. 159 (statement of L.M. Monzón Cifuentes, internal document). 4 . Ibid., pp. 3-5 (final arguments, internal document).