D.2 Arguments regarding non-pecuniary damages ...................................................................................... 39 D.3 Considerations of the Court ................................................................................................................... 39 E. Costs and expenses ........................................................................................................................... 40 F. Method of compliance of the payments ordered............................................................................... 41 X OPERATIVE PARAGRAPHS ................................................................................................... 41 I INTRODUCTION OF THE CASE AND THE CAUSE OF ACTION 1. The case submitted to the Court. – On July 17, 2020, the Inter-American Commission on Human Rights (hereinafter “the Commission”) submitted to the Court the case of Carlos Benites Cabrera et al. v. Peru. The Commission stated that the case involves the alleged violations of Articles 8(1), 25(1) and 26 of the Convention, read in conjunction with Articles 1(1) and 2 thereof, to the detriment of 192 employees who had been dismissed as part of the so-called “streamlining of personnel” program implemented during the government of Alberto Fujimori. These employees were also barred from filing applications of constitutional relief (hereinafter “writs of amparo” or “amparo”) regarding their dismissals and they challenged the results of the competitive examinations that were held to fill the positions left vacant after the “streamlining” process. 2. The following proceedings took place before the Commission: a. Petition. – On December 19, 2000, Javier Mujica Petit, as common intervenor, lodged a petition before the Commission in which he alleged the international responsibility of Peru (hereinafter also “the State”) for the dismissal of a group of employees of the Congress of Peru.1 On September 9, 2003, the Commission received another petition on the same facts concerning a second group of alleged victims, represented by Elizabeth Elisa Ledesma Rojas.2 On August 7, 2017, the Commission notified the parties of its decision to join the petitions, under the terms of Article 29(5) of its Rules. b. Report on Admissibility and Merits. – On August 7, 2017, the Commission notified the parties of its decision to defer the decision on admissibility to that on the merits. On May 4, 2019, the Commission adopted its Report on Admissibility and Merits (No. 64/19) (hereinafter “Report on the Merits” or “Merits Report”), pursuant to Article 50 of the Convention.. c. Notification to the State. – On July 17, 2019, the Commission notified the Merits Report to the State, granting it a period of two months to report on its compliance with the recommendations contained therein. It subsequently granted three extensions of three months each. In considering the request for a fourth extension, the Commission took into account that the State had not made substantive progress in complying with the only recommendation in the Report and, therefore, decided to submit the case to the Court. 3. Submission to the Court. – On July 17, 2020, the Commission submitted to the Court all the facts and the alleged human rights violations described in the Merits Report due to 1 Petition 728-00, which was transmitted to the State on October 24, 2016. 2 Petition 725-03, which was transmitted to the State on June 30, 2011. 4