76 GENDER PERSPECTIVES ON TORTURE: Law and Practice Women (Convention of Belém do Pará) and the Inter-American Convention to Prevent and Punish Torture (IACPPT). The IACPPT107 holds that the commission of torture is a grave violation that must be investi­ gated and punished, providing under Article 6 paragraph 2 that States “shall ensure that all acts of torture and attempts to commit torture are offenses under their criminal law and shall make such acts punishable by severe penalties.” Additionally, the Convention Belém do Para states in article 7b that States parties have the duty to 2b apply due diligence to prevent, investigate and impose penalties for violence against women. In light of these requirements, the Inter-American system has established standards in its jurisprudence for the interpretation of the principle of due diligence in cases of sexual violence and gender-based violence. The IACHR Court has written that “the duty to investigate is a compulsory obligation of the State embodied in international law, which cannot be mitigated by any domestic legislation or act whatsoever.”108 Similarly, in the case of the “Las Dos Erres” Massacre v. Guatemala, the Court found that “the lack of investigation of grave facts against humane treatment such as torture and sexual violence in armed conflicts and/or systematic patterns, constitutes a breach of the State’s obligations in relation to grave human rights violations, which infringe non-revocable laws (jus cogens) and generate obligations for the States such as investigating and punishing those practices, in conformity with the American Convention and in this case in light of the [IACPPT] and the Convention of Belém do Pará.”109 The case of González et al. (“Cotton Field”) v. Mexico, in which the IACHR Court analyzed viola­ tions of rights in the case of three young women who were killed in Ciudad Juárez, is particularly relevant to the investigation of cases of violence against women because of the Court’s interpreta­ tion of the concept of gender discrimination. In its judgment, the Court wrote that “the obligation to investigate effectively has a wider scope when dealing with the case of a woman who is killed or, ill-treated or, whose personal liberty is affected within the framework of a general context of violence against women.”110 It further indicated that the State’s actions were characterized by a pat­ tern of indifference to the chronic violence against women and children in Ciudad Juárez, perpet­ uating the situation of discrimination and sending a message of tolerance and tacit acceptance.111 Notwithstanding these encouraging findings, the IACHR Court did not find the violence commit­ ted against women by non-State agents in this case to be torture. In this judgment, the Court was clear in indicating that States must take comprehensive mea­ sures to prevent violence against women and girls in accordance with the American Convention on Human Rights and the Convention of Belém do Pará.112 This means having an appropriate legal 107 Convención Interamericana Para Prevenir Y Sancionar La Tortura, Article 6. http://www.oas.org/juridico/ spanish/tratados/a-51.html. 108 IACHR Court. Case of Vargas Areco v. Paraguay: Merits, Reparations and Costs. Judgment of September 26, 2006, Series C No. 155, para. 81; Case of Gutiérrez Soler v. Colombia, Judgment of September 12, 2005, Series C. No. 132, para. 54. 109 IACHR Court. Case of the “Las Dos Erres” Massacre v. Guatemala. Preliminary Objections, Merits, Reparations, and Costs. Judgment of November 24, 2009, para. 140. 110 IACHR Court. Case of González et al. (“Cotton Field”) v. Mexico. Judgment of November 16, 2009. Preliminary Objections, Merits, Reparations, and Costs, para. 293. 111 Cotton Field, op. cit., para. 400. 112 The obligation to carry out investigations with gender perspective is strengthened by Article 7 of the Convention of Belém do Pará, which establishes that States must “apply due diligence to prevent, investigate and impose penalties for violence against women.” OAS Department of International Law. Inter-American Convention on the Prevention, Punishment and Eradication of Violence against Women “Convention of Belém do Pará.” Article 7, c. Brazil: 1994.