reparations benefits. Chile did not offer a particular justification for its own basic unit of $537. It is clear that these choices depend on the political bargaining that takes place and are made with an eye to feasibility rather than to questions of principle. This—and not only the generally low levels of compensation offered by most programmes—means that existing practice is of questionable value as precedent. Indeed, requiring future programmes to justify their decisions concerning compensation levels may in itself produce salutary results. There is a significant difference in the compensation offered as a result of judicial resolutions of individual, sporadic and isolated cases of violations, and that stemming from a massive reparations programme faced with a large number of potential beneficiaries. A judicial approach to the question, where to set levels of compensation, which simply expresses both articulate convictions as well as deep intuitions, appeals to the criterion of restitutio in integrum, of making victims whole, of compensating the victims in proportion to the harm they have suffered. As explained before, for individual cases, this is an unimpeachable criterion, for it tries to neutralize the effects of the violation on the victim and to prevent the perpetrator from enjoying the spoils of wrongdoing. Actual practice with massive reparations programmes, however, suggests that satisfying this criterion is rarely even attempted. However, it is too easy to draw the conclusion that reparations programmes have historically been manifestly unfair. This would tar all reparations programmes with the same brush, even those that have made an earnest effort to provide redress to victims—despite awarding less compensation than the same victims would have got if they had won a suit in a court trying their cases in isolation. Since the size of the monetary compensation is not merely a pragmatic question of affordability, but one of justice, it is important to clarify what justice requires. What does “adequate, effective and prompt reparation for harm suffered” mean?49 Principle 18 of the Basic Principles and Guidelines provides room for departures from the criterion of full compensation:50 In accordance with domestic and international law, and taking account of individual circumstances, victims of gross violations of international human rights law and serious violations of international humanitarian law should, as appropriate and proportional to the gravity of the violation and the circumstances of each case, be provided with full and effective reparation… (emphasis added) The Basic Principles and Guidelines themselves integrate a “margin of appreciation”51 which authorizes departures from “the principle of wiping out all the consequences [that 49 50 51 General Assembly resolution 60/147, annex, para. 11. See Heidy Rombouts, Pietro Sardaro and Stef Vandeginste, “The right to reparation for victims of gross and systematic violations of human rights”, in Out of the Ashes: Reparation for Victims of Gross and Systematic Human Rights Violations, K. De Feyter and others, eds. (Antwerp, Intersentia, 2006), pp. 345–500. Ibid, p. 455. 28