68 217. As has been indicated on other occasions,226 when assessing the effectiveness of the domestic recourse provided by the national contentious administrative courts, the Court must decide whether the decisions effectively contributed to ending impunity, ensuring nonrepetition of the harmful acts and guaranteeing the free and full exercise of the rights protected by the Convention. 218. In establishing the State’s international responsibility for the violation of the human rights embodied in Articles 8(1) and 25 of the American Convention, a substantial element of the dispute before the Court is not whether judgments were delivered or settlement agreements reached concerning the administrative or civil responsibility of a State body in relation to the violations committed to the detriment of the victims of human rights violations or their next of kin, but rather whether the domestic proceedings ensured full judicial access, pursuant to the standards set forth in the American Convention.227 219. In the cases of the Ituango Massacres, the Pueblo Bello Massacre and the Mapiripán Massacre, all three against Colombia, the Court found that the comprehensive reparation of the violation of a right protected by the Convention cannot be reduced to the payment of compensation to the next of kin of the victim.228 The Court indicated that the compensations established in the contentious administrative proceedings could be considered when establishing the pertinent reparations, “on condition that the decisions taken in those proceedings are considered res judicata and are reasonable, considering the circumstances of the case.”229 220. The Court has indicated that, in cases of human rights violations, the State has the duty to provide reparations. This duty implies that while the victims or their next of kin should have ample opportunity to seek just compensation under domestic law, the State’s obligation cannot rest exclusively on their procedural initiative or on the submission of probative elements by private individuals. Thus, in the terms of the obligation to provide reparation that arises from a violation of the Convention (infra para. 226), the contentious administrative proceedings do not constitute per se an effective and adequate recourse to redress such violations comprehensively.230 221. Adequate redress, understood within the framework of the Convention, includes measures of rehabilitation and satisfaction and guarantees of non-repetition. The Court has indicated that recourse such as the action for direct reparation or the action for annulment and re-establishment of a right have a very limited scope and include some conditions of access that are not appropriate with regard to the reparation objectives established in the American Convention. The Court has indicated that the judgment of a judicial authority in a contentious 226 Cf. Case of the Mapiripán Massacres, supra note 12, para. 210. In the same sense, see Case of the Ituango Massacres, supra note 15, para. 338; and Case of the Pueblo Bello Massacre, supra note 12, para. 206. 227 Cf. Case of the Mapiripán Massacres, supra note 12, para. 211. In the same sense, see Case of the Ituango Massacres, supra note 15, para. 339; and Case of the Pueblo Bello Massacre, supra note 12, para. 206. 228 Cf. Case of the Mapiripán Massacres, supra note 12, para. 214. In the same sense, see Case of the Ituango Massacres, supra note 15, para. 339; and Case of the Pueblo Bello Massacre, supra note 12, para. 206 229 Cf. Case of the Mapiripán Massacres, supra note 12, para. 214. In the same sense, see Case of the Ituango Massacres, supra note 15, para. 339; and Case of the Pueblo Bello Massacre, supra note 12, para. 206 230 Cf. Case of the Ituango Massacres, supra note 15, para. 340; and Case of the Pueblo Bello Massacre, supra note 12, para. 209.

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