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Disappearances in Honduras: The Need for Direct Victim Representation in Human Rights Litigation

28 Pages Posted: 22 Mar 2009 Last revised: 25 Mar 2009

Claudio Grossman

American University - Washington College of Law

Date Written: Spring 1992


Honduran national Manfredo Angel Velasquez Rodriguez was taken to a detention center in Tegucigalpa on September 12, 1981, and was never seen again. He was thirty-five years old when he disappeared, and left a wife and four small children. Without any judicial process he was detained, interrogated and tortured, and then disappeared. A petition concerning the disappearance of Velasquez Rodriguez was filed with the Inter-American Commission on Human Rights (Commission) in October of 1981. On July 29, 1988, an historic day in the fight against governmental human rights abuses in Latin America, the Inter-American Court of Human Rights held that the Government of Honduras was responsible for the disappearance of Manfredo Angel Velasquez Rodriguez. In this decision, the Court exercised for the first time its compulsory jurisdiction in a contested case and became the first international tribunal to find a State responsible for disappearances. Although the Court is empowered with compulsory jurisdiction under Article 62 of its Convention, prior to this case the Court had only once exercised its compulsory jurisdiction, and then in an uncontested case. The State concerned, Costa Rica, submitted the case against itself, and agreed to be bound by the ruling, but the case was dismissed before a final ruling was reached. Although other OAS member states were accused of resorting to disappearances of political dissidents, Honduras, which had acceded to the Court's binding jurisdiction, was the first state subjected to liability.

Keywords: inter-american system, Honduran government, Velazquez case

Suggested Citation

Grossman, Claudio, Disappearances in Honduras: The Need for Direct Victim Representation in Human Rights Litigation (Spring 1992). Hastings International and Comparative Law Review, p. 363, 1992. Available at SSRN:

Claudio Grossman (Contact Author)

American University - Washington College of Law ( email )

4300 Nebraska Avenue, NW
Washington, DC 20016
United States
2022744004 (Phone)

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