Escué Zapata v. Colombia

Escué Zapata v. Colombia

In 1988, Colombian Military Forces murdered Germán Escué-Zapata, a leader in the indigenous Paez or Nasa community. Interestingly, the State acknowledged international responsibility for violating Articles 4(1) (Prohibition of Arbitrary Deprivation of Life), 5 (Right to Humane Treatment), and 7 (Right to Personal Liberty) in relation to Article 1(1) (Obligation to Respect Rights) of the American Convention on Human Rights. In the Court’s decision, it discussed whether violations of Article 1(1) (Obligation to Respect Rights) may be invoked separately from violations of other Articles of the Convention, and found that killing a community leader is not, per se, a violation of Article 23 (Right to Participate in Government). The Court found, however, that the State violated the American Convention on Human Rights.  

Case Summary: Escué Zapata v. Colombia, Case Summary

Did the State Accept International Responsibility?: 
Partial Acceptance
Did the State Raise Preliminary Objections?: 
Case Summary: 

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Loyola Law School
919 Albany St.
Los Angeles, CA 90015


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