97 322. The Court appreciates the efforts made by the State to assess the possibility of effectively delivering the requested scholarships to the next of kin of the victims in this case. It also notes that the representatives referred - at least before this Court - to the specific cases of the relatives of Gregorio Hilario Quispe, Zenón Cirilo Osnayo Tunque and Marino Huamaní Vergara, and that with the information available, these requests can be effectively channeled by the State. The Court takes note of this request, and of the efforts and good faith expressed by Peru, aimed at repairing the harm caused to the families of the disappeared victims. However, it considers that it is not necessary to order said measure. 323. The Commission requested measures to keep alive the memory of the disappeared victims. The representatives requested, in their final written arguments, that a monument be erected in the community of Santa Bárbara as a measure to keep alive the memory of the disappeared victims. The State did not make any comment in this regard. 324. The Court considers that the request to erect a monument is time-barred since it was presented only in the final arguments of the representatives; furthermore, it is not necessary to order this measure since, in accordance with paragraph 309 supra, the publication of this judgment is sufficient to keep alive the memory of the disappeared victims in this case. 325. The representatives requested that the Court reiterate to the State its obligation to bring the criminal definition of forced disappearance into line with international standards. In particular, they pointed out that “the adaptation of Article 320 of the Criminal Code (“forced disappearance”) to Article II of the Inter-American Convention on Forced Disappearances, would be crucial to the present case, “given that said reform constitutes an essential measure to obtain justice.” The State argued that although the facts of this case do not fall within the framework of acts that constitute a disappearance, to date there are draft laws whose purpose is to modify the criminal regulations in force regarding this and other crimes against human rights regulated in national legislation. In this regard, it reported that the Justice and Human Rights Commission of the Peruvian Congress has been discussing several bills that propose to reform the definition of the crime of forced disappearance, in line with the provisions of international human rights law, international humanitarian law and international criminal law. The Commission did not refer to this point. 326. In the instant case, the Court did not declare a violation of Article 2 of the American Convention or of Article III of the Inter-American Convention on Forced Disappearance of Persons in relation to the alleged application of Article 320 of the Criminal Code; thus, there is no causal link between the violations declared in this judgment and the measure of reparation requested. Nevertheless, the Court recalls that in the judgments issued in the cases of Gómez Palomino, 372 Anzualdo Castro 373 and Osorio Rivera, 374 the State was ordered to adapt its domestic legislation, and that these cases are at the stage of monitoring compliance with their respective judgments. Therefore, the Court urges the State to continue with the legislative process and to adopt, within a reasonable time and in accordance with its obligation under Article 2 of the American Convention, the measures necessary to define the crime of forced disappearance of persons in accordance with inter-American standards. D. Compensation Cf. Case of Gómez Palomino v. Peru. Merits, reparations and costs. Judgment of November 22, 2005, para. 149 and operative paragraph 12. 373 Cf. Case of Anzualdo Castro v. Peru. Preliminary objection, merits, reparations and costs. Judgment of September 22, 2009, para. 191 and operative paragraph 8. 374 Cf. Case of Osorio Rivera and Family Members v. Peru, supra, para. 271 and operative paragraph 12. 372

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