A/HRC/25/49 35. Memorialization is now part of the international agenda, as is also evident in international days recalling past wrongs. One still has to enquire, however, how effective those international days are and whether they have a powerful societal resonance in those States and societies that celebrate such commemorative days. C. Rulings of the Inter-American Court of Human Rights 36. The trend of memorialization has influenced judicial processes, especially in Latin America, with the Inter-American Court of Human Rights ordering the construction of public memorials for past crimes in several judgments. 37. In its ruling on a monument dedicated to the victims of the Peruvian civil war, the Court stipulated that Peru “must guarantee, within a one-year period, that all persons declared as deceased in the present Judgment are represented in the monument called The Eye that Cries”.17 Similarly, the verdict of the Court on the killing of 19 traders in Colombia stated the need for the State to proceed with the construction of a memorial.18 In its judgment on the Rio Negro massacre in Guatemala, the Court requested the establishment of a museum to honour the victims of the internal armed conflict. 19 38. Thus, courts may also see their role as memorial facilitators and national authorities may see their approach contested by new actors actively engaged in shaping the memorial landscape. D. Recommendations of truth and reconciliation commissions 39. An exhaustive list of all truth and reconciliation commissions that have advocated the construction of memorials is beyond the scope of this document. Nevertheless, one should mention the recommendations of the truth and reconciliation commissions in El Salvador, Germany, Guatemala, Peru, Morocco and South Africa and the commission of inquiry in Chad, even though not all their recommendations were implemented. 40. The Commission on the Truth for El Salvador clearly called in its report for the construction of a national monument in El Salvador bearing the names of all victims of the conflict, recognition of their good name and the serious crimes of which they were the victims and the institution of a national holiday in memory of the victims of conflict as a symbol of reconciliation (S/25500, p. 186). 41. Similarly, the Commission for Historical Clarification in Guatemala recommended, among other things, that monuments and parks be constructed and the names of victims assigned to public buildings and highways in memory of the victims.20 The Commission stated that “the historical memory, both individual and collective, forms the basis of national identity. Remembrance of the victims is a fundamental aspect of this historical memory and permits the recovery of the values of, and the validity of the struggle for, human dignity.” Specific attention was drawn to the need to take into consideration the multicultural nature of the Guatemalan nation and to promote and authorize the raising of monuments and the creation of communal cemeteries in accordance with the forms of Mayan collective memory. 17 18 19 20 Miguel Castro-Castro Prison v. Peru, judgment of 25 November 2006, para. 463. 19 comerciantes v. Colombia, judgment of 5 July 2004, para. 273. Masacres de Río Negro v. Guatemala, judgment of 4 September 2012, paras. 279 and 280. Report of the Commission for Historial Clarification, conclusions and recommendations, p. 49, available from https://hrdag.org/wp-content/uploads/2013/01/CEHreport-english.pdf. 9