30 GENDER PERSPECTIVES ON TORTURE: Law and Practice appeal, one count of rape committed against Khadidja Zidane by Habré himself was thrown out on procedural grounds, as it was added to the charge sheet once the trial was already underway. In the Bemba case before the International Criminal Court, Pulchérie Makiandakama, the first victim appearing before the Chamber, who was raped by two soldiers, testified without the usual protection measures, such as face and voice distortion, because, as she said, “I cannot ask for my voice or image to be distorted. I want it to be natural, be myself and say before the Judges and before the whole world what I suffered.” When her counsel asked her what she was expecting from the ICC, she replied: “I am a human being. Judges need to pay attention to my situation. Judges have to rule on this case and give me justice. This is all I want from the ICC.”56 The Basic Principles and Guidelines make it clear that access to remedies must be fair and non-dis­ criminatory, and procedures must be accessible and suitable to take account of victims’ particular needs. In practise, discrimination and marginalisation can inhibit access to justice or associated reparations processes. Often, key documents are not translated into local languages, and informa­ tion dissemination does not reach remote areas or those who cannot read. Outreach and awareness-raising activities are necessary preconditions for victim participation in justice processes, whether before courts or administrative programmes.57 Structures to ensure safety, privacy, and dignity are needed but are not usually in place, which can discourage women and others who experience stigma from coming forward.58 The Basic Principles and Guidelines underscore that mea­ sures should be taken to “minimize the inconvenience to victims and their representatives, pro­ tect against unlawful interference with their privacy as appropriate and ensure their safety from intimidation and retaliation, as well as that of their families and witnesses, before, during and after judicial, administrative, or other proceedings that affect the interests of victims.”59 In a post-conflict context, the regular justice institutions may not be functioning or will be under extreme strain. Even in the best of circumstances they would be ill-equipped to deal with a flood of conflict victims that have experienced multiple harms. Practically, this has meant that in such circumstances specialist judicial or administrative structures are needed to give effect to victims’ rights to lodge claims for reparations. The Basic Principles and Guidelines recommends courts to refer to such possibilities, indicating that “[i]n addition to individual access to justice, States should endeavour to develop procedures to allow groups of victims to present claims for reparation and to receive reparation, as appropriate.”60 VI. Implementation: How far have we come? The rights framework has become much clearer with respect to victims of gender-based vio­ lence, their right to reparations, and what reparations should entail, particularly for sexual violence perpetrated during conflict. This has led to this phenomena being considered by claims commis­ sions and other transitional justice processes as well as a small number of courts. Nonetheless, the implementation of this framework remains piece-meal and largely inadequate. As noted, the challenges for victims to achieve reparations are multiple and include a variety of practical access As reported in Victims’ Rights Working Group, Victim testifies publicly in the Bemba trial: “I lost my dignity”, Issue 20 (Spring 2012). 57 OHCHR, Analytical Study, supra note 49, at ¶ 47. 58 Catherine O’Rourke et al. Transforming Reparations for Conflict-Related Sexual Violence: Principles and Practice, 28 harvarD hum . r. J. 97, 137-139 (2015). 59 Basic Principles and Guidelines, supra note 9, at art. 12(b). 60 Id. at art. 13. 56