and institutional mechanisms that allow those affected to claim reparation must exist. This generally relates the obligation to make reparation to the existence of appropriate administrative or judicial mechanisms and, therefore, to the right of the victims to have access to justice, 177 which has its treaty-based foundation in the rights to judicial guarantees and judicial protection established in Articles 8 and 25 of the American Convention. 178 Based on these articles, “States are obliged to provide effective […] judicial remedies to the victims of human rights violations that must be substantiated in accordance with the rules of due process of law.” 179 “This effectiveness presumes that, in addition to the formal existence of the remedies, these lead to results or responses to the violations of rights, which means that the remedy must be appropriate to combat the violation, and that its implementation by the competent authority should be effective.” 180 This should mean, according to the case, that the remedies are appropriate to achieve not only the ending of the violation or its threat, but also the reparation of the consequences of the violation, including, if possible, the restitution or re-establishment of the right. In this regard, the Court has indicated that “the effectiveness of the domestic remedies must be assessed comprehensively taking into account […] whether, in the specific case, domestic mechanisms existed that ensured real access to justice to claim the reparation of the violation.” 181 Justice indicated in paragraph 73 of the said decision that “[i]t is a principle of international law, and even a general conception of law, that any breach of an engagement involves an obligation to make reparation. […] Reparation is the indispensable complement of a failure to apply a convention, and there is no necessity for this to be stated in the convention itself.” Furthermore, the State obligation to provide reparation for violations of the rights established in binding American international instruments is revealed in view of the principle of “complementarity” on which the protection system formalized within the framework of the Organization of American States is based. In this regard, the Court has stated that “State responsibility under the Convention can only be required at the international level when the State has had the opportunity to declare the violation and make reparation for the harm caused by its own means. This is based on the principle of complementarity (subsidiarity) that crosscuts the inter-American human rights system, which is, as the Preamble to the American Convention states, ‘a convention reinforcing or complementing the protection provided by the domestic law of the American States.’ Thus, the State ‘is the main guarantor of the human rights of the people, so that, if an act is committed that violates these rights, it is the State itself that has the obligation to settle the matter at the domestic level and […] to make reparation, before having to respond before international organs, such as the inter-America system, which derives from the subsidiary nature of the international proceedings in relation to the domestic systems of human rights guarantees’” (Case of the Santo Domingo Massacre v. Colombia, supra, para. 142. The text in inverted commas at the end of this paragraph corresponds to the decision of the Court in the Case of Acevedo Jaramillo et al. v. Peru. Interpretation of the judgment on preliminary objections, merits, reparations and costs. Judgment of November 24, 2006. Series C No. 157, para. 66. 177 According to the International Commission of Jurists, “[a]ccess to justice requires the availability of effective remedies. All persons have a right to an effective remedy for any violation of their civil, cultural, economic, political, and social rights […].” Declaration of the International Commission of Jurists on Access to Justice and Right to a Remedy in international human rights systems. Adopted in Geneva on 12 December 2012, article 5. 178 The need for domestic remedies to be appropriate for the victims of human rights violations to claim reparation for the violations is inferred from the principle of complementarity under the inter-American system described above (supra footnote 175): if the appropriate “due process of law” did not exist, pursuant to Article 46(2)(a) of the Convention, the victims (or other persons or entities on their behalf) could, in the absence of reparation, resort to the inter-American system directly; in other words, without the need to exhaust domestic remedies. To the contrary, if the competent domestic organs, in application of the appropriate legal proceedings, declare and provide adequate reparation for the violation of a right, the intervention of the international organs established in the Convention would not be admissible (Cf. Case of the Santo Domingo Massacre v. Colombia. Preliminary objections, merits and reparations. Judgment of November 30, 2012. Series C No. 259, para. 171). 179 Cf. Case of Velásquez Rodríguez v. Honduras. Preliminary objections, supra, para. 91, and Case of the Santo Domingo Massacre v. Colombia, supra, para. 155. 180 Cf. Case of Velásquez Rodríguez v. Honduras. Merits, supra, paras. 63, 64 and 66, and Case of García and family members v. Guatemala, supra, para. 142. 181 Case of Goiburú et al. v. Paraguay, supra, para. 120. It should be explained that, in that specific case, which related to gross human rights violations, the Court determined that “the international responsibility of the State was aggravated”; indicated that the obligation to provide reparation “should not depend exclusively on the 56