The Inter-American Court of Human Rights: The Ambassador of Universalism 87 the victim’s family; 128 to create an online database to facilitate research on victims of armed conflicts; 129 to create an information system containing genetic information facilitating the identification of kidnapped children; 130 to create and update a register of all detained individuals as well as of information regarding the reasons for detention and the criminal procedure to which they are subject; to organize a Chair or a course in human rights; 131 to dedicate a national holiday to the memory of children who disappeared during armed conflict which has taken place in the State in question; 132 and to erect a bust in memory of a deceased victim133. Finally, in Barrios Altos Case (Peru) (2001), the agreement made by the parties and approved by the Court included, alongside pecuniary compensation, the State’s commitment to carry out a series of “ educational services” (educational grants, distribution of educational material and so on) 134 and of “ health services” 135 (free access to healthcare and so on) for the beneficiaries. 136 In another case, a similar type of agreement included a duty imposed on the State to publicly apologise to the victims for the violations committed and the damage caused, and the duty to co-finance the construction of a building belonging to the beneficiaries. 137 These examples show that, with these reparatory measures, the Court intends to give the State responsibility in the context of its public policies or to enforce symbolic measures with a moral connotation. Again, the Court shows itself to be paternalistic and pedagogical by giving, to an extent, a moral lesson to the violating State with a view to educating it on human rights and reprimanding it for its bad conduct.
II. Inter-American Universalism
These different aspects of the Inter-American distinctiveness render the conventional Inter-American system exceptional, and, in our opinion, remarkable in both senses of the word. They attest to the fact that the Court has established case law and a “ system” which are based on a very particular conception of international human rights law. This design was not planned, but rather results from a “ hand-
128Trujillo-Oroza Case, supra note 92 at para. 122.
129Serrano-Cruz Sisters Case, supra note 91 at para. 191.
130Ibid. at para. 191-92.
131Huilca-Tecse Case (Peru) (2005), Inter-Am. Ct. H. R. (Ser. C) No. 121, at para. 113 Annual Report of the Inter-American Court of Human Rights : 2005, at 8 online : Inter-Am. Ct. H. R. < http :// www. corteidh. or. cr/ docs/ informes/ Inf% 20anua% 202005% 20diag% 20ingles. indd. pdf> [ Huilca-Tecse Case].
132Serrano-Cruz Sisters Case, supra note 91 at para. 196.
133Huilca-Tecse Case, supra note 132 at para. 115.
134Juvenile Reeducation Institute Case, supra note 123 at para. 321.
135In this context, see also Durand and Ugarte Case (Peru) (2001), Inter-Am. Ct. H. R. (Ser. C) No. 89, at para. 36-27, Annual Report of the Inter-American Court of Human Rights : 2001,
OEA/ Ser. L/ V/ III. 54/ doc. 4 (2000) 26 [ Durand and Ugarte Case].
136Barrios Altos Case (Peru) (2001), Inter-Am. Ct. H. R. (Ser. C) No. 87, at para. 41-43, Annual Report of the Inter-American Court of Human Rights : 2001, OEA/ Ser. L/ V/ III. 54/ doc. 4 (2000) 22. See also Plan de Sánchez Massacre Case (Guatemala) (2004), Inter-Am. Ct. H. R. (Ser. C) No. 116, at para. 110-111,
Annual Report of the Inter-American Court of Human Rights : 2004, OEA/ Ser. L/ V/ III. 65/ doc. 1 (2004) 6.
137Durand and Ugarte Case, supra note 135 at para. 38-39.