Gigi Scoles and Anupama Selvam 15 tial and must be followed by prosecutions where there is a legitimate finding to do so.49 To ensure that investigations of gender-based violence are prompt and impartial, training of the actors con­ ducting the investigations is integral. Again, law enforcement must not only have knowledge of the laws that may protect victims, but they must also approach each case without bias—something that may be difficult where cultural biases and stereotyping exist.50 The Justice Institute provides participants with concrete examples of how to investigate and prosecute cases involving gender-based violence through various exercises designed for specific communities. Role plays, multi-media, lectures, discussions and other types of activities that bring together law enforcement, prosecutors, judges, social workers, and other State actors facilitate the exploration and deconstruction of biases surrounding gender-based violence, while providing spe­ cific instructions on how individuals within the justice system can improve their investigation methods and gather the best evidence for prosecution. Punishment. Where a fair investigation and prosecution finds that an individual has perpe­ trated gender-based violence, States are required to hold perpetrators accountable for their actions. Without punishment, prosecution lacks an enforcement mechanism and fails to create a State that protects victims of gender-based violence. If a victim reports abuse and an investigation and pros­ ecution find that gender-based violence occurred but perpetrators fail to be held accountable, then the victim fails to be made whole, effectively blocking them from accessing justice. Therefore, the development and application of adequate punishment must be part of fulfilling due diligence. The Justice Institute provides guidance for judges to sentence perpetrators to proportionate pun­ ishment. Trainers facilitate activities that give context to the offense and allow judges to think more broadly about what remedies would be in the best interests of all parties involved. Fact-finders are encouraged to consider power differentials and social influences that provide the backdrop to the offenses committed. This can result in a more tailored and appropriate sentence in each individual case. More appropriate and effective sentencing leads to fair punishment allowing the State to move toward meeting this prong of its due diligence obligation. Reparations. States can provide reparations in five ways: (1) restitution or measures to restore victims to their original situations, (2) compensation for economic assessable damage, (3) rehabil­ itation, (4) satisfaction, (5) guarantees of non-repetition. Reparations are necessary for victims of gender-based violence to be made whole, to heal and move forward with their lives. Providing victims of torture and other serious international crimes is a well-established principle in interna­ tional law.51 The benefits of the Justice Institute to the provision of reparation is not as obvious as the other prongs of due diligence, however, there are several concrete ways that the Justice Institute con­ tributes to a State’s ability to provide each of these types of reparations. First, in order to pro­ vide proportionate restitution or compensation to victims, judges and other State actors must be knowledgeable about the harm suffered by victims. Deciding the amount and type of restitution necessary to restore a victim to their previous situation or to compensate for assessable damage, means understanding the underlying power dynamics of gender-based violence. More specifically, a judge that holds gender-based stereotypes or does not grasp the harm caused by gender-based 49 See Convention against Torture and Other Cruel, Inhuman or Degrading Treatment or Punishment Art. 5 and 7, Dec. 10, 1984, 1465 U.N.T.S. 85. 50 See Rebecca J. Cook and Simone Cusack, Gender Stereotyping: Transnational Legal Perspectives 26 (University of Pennsylvania Press, 2010). 51 See Abdul Aziz and Moussa, supra note 6 at 13.