86 2011 Quebec Journal of International Law (Special Edition) in this case was sufficient to repair the non-pecuniary loss. 117 The State’s public recognition of its responsibility is also considered to be a form of reparation and may be ordered by the Court. 118 Similarly, the Court may order the State to publish extracts of its judgment in the State’s official newspaper and in various other national newspapers. 119 Moreover, the Court has developed an original case law of reparatory measures appropriate for different cases which go beyond the reparations limited to covering the victims’ non-pecuniary loss. Satisfaction ordered by the Court may include the obligation to re-open a school; 120 the creation of a non-profit foundation designed to assist the beneficiaries of reparation in the management of the sums handed out; 121 the exhumation of the victims’ bodies in order to allow the families to carry out appropriate funerals according to their traditions and religious beliefs; 122 the obligation to establish an educational grant for the victim to encourage the achievement of his or her “ life project”; 123 to name an educational centre in reference to the victims and to install a commemorative plaque listing the names of all victims; 124 to improve conditions for detainees; 125 to reform criminal law; 126 to name a school after a victim; 127 to organize an official and public ceremony to be attended by

117Cantos Case, supra note 14 at para. 70-71.

118Maritza Case, supra note 103 at para. 178 ; Myrna Mack Chang Case, supra note 32 at para. 278.

119Myrna Mack Chang Case, ibid. 280 ; Bulacio Case, supra note 54 at para. 145 ; Juan Humberto Sánchez Case, supra note 75 at para. 188. On this issue, see also the comments by Sergio García Ramírez, Separate opinion annexed to Bámaca-Velásquez Case (Guatemala) (2002), Inter-Am. Ct. H. R. (Ser. C) No. 91, Annual Report of the Inter-American Court of Human Rights : 2002, OEA/ Ser. L/ V/ III. 57/ doc. 5 (2003) 20 : “ In my opinion, the decision to publish the chapter on proven facts and the operative paragraphs of the judgment in the official gazette and another newspaper with nationwide circulation is pertinent. The former relates to the formal character of the jurisdictional decision and the latter to the advisability that public opinion should learn about the conclusions and the meaning of the jurisdictional decision in this case, as it did– or could have– of the facts that constituted the violation. Thus, the range of reparations that the Court can award is broadened, in accordance with the circumstances of each case. The purpose of publication and compensation is three-fold : a) on the one hand, the moral satisfaction of the victims or their successors, the recovery of honor and reputation that may have been sullied by erroneous and incorrect versions and comments ; b) on the other, the establishment and strengthening of a culture of legality in favor, above all, of the coming generations ; and c) lastly, serving truth, to the advantage of those who were wronged and of society as a whole. The foregoing is inserted in the broad regime of recognition and protection of rights and in the corresponding preservation of the values of a democratic society. In brief, the reparation of the harm in this case has compensatory and preventive effects ; as regards the latter, it considers the need to prevent the repetition of conduct such as that which gave rise to the proceedings before the international instances.”

120Aloeboetoe et al. Case, supra note 23 at para. 5.

121Ibid. at para. 103-08.

122Street Children Case No. 77, supra note 93 at para. 102. See Separate opinion annexed to Bámaca-Velásquez Case, supra note 20.

123Cantoral-Benavides Case, supra note 103 at para. 80. In this context, see also “ Juvenile Reeducation Institute” Case.(Paraguay) (2004), Inter-Am. Ct. H. R. (Ser. C) No. 112, at para. 321, Annual Report of the Inter-American Court of Human Rights : 2004, OEA/ Ser. L/ V/ III. 65/ doc. 1 (2004) 14 [ Juvenile Reeducation Institute Case].

124Street Children Case No. 77, supra note 93 at para. 103.

125López-Álvarez Case, supra note 76 at para. 209 ; Raxcacó-Reyes Case (Guatemala) (2005), Inter-Am. Ct. H. R. (Ser. C) No. 133, at para. 134, Annual Report of the Inter-American Court of Human Rights : 2005, at 25 online : Inter-Am. Ct. H. R. < http :// www. corteidh. or. cr/ docs/ informes/ Inf% 20anua% 202005% 20diag% 20ingles. indd. pdf> [ Raxcacó-Reyes Case].

126Blanco-Romero et al. Case, supra note 90 at para. 105 ; Raxcacó-Reyes Case, ibid. at para. 132.

127Baldeón-García Case, supra note 76 at para. 205.