reason to believe the disappeared person might be found including places that are subject to military jurisdiction.” The Inter-american Regional System 3 Both the Court and the Commission consider unresolved enforced disappearances to constitute an ongoing violation of Article 5 of the ACHR, together with several other articles of the ACHR, in particular Articles 4 (the right to life), 7 (the right to personal liberty) and 8 (the right to a fair trial).542 Enforced disappearances carried out by or with the tolerance of State agents frequently involve concealment of evidence, so if it has been proven that the State promotes or tolerates the practice, “circumstantial or indirect evidence, or … pertinent logical inference” will suffice to prove that an enforced disappearance has occurred in a particular case.543 Similarly, where there is a systematic practice of ill-treatment and the State fails to investigate particular cases, the Court may infer that the disappeared experienced, at minimum, “deep feelings of fear, anxiety and defenselessness in violation of Article 5.”544 3.3.6 Relatives of victims of human rights violations The Court frequently considers the suffering of relatives of victims at the reparations stage, after a violation has been found as regards the direct victim of ill-treatment.545 But the Court has gone further, showing an increasing willingness to consider the suffering of the direct victim’s relatives as coming within the scope of Article 5 of the ACHR. This tendency has been most apparent in cases involving enforced disappearances and extrajudicial killings perpetrated by State security forces. In Gómez-Paquiyauri Brothers v Peru, for example, the Court found that the “suffering and powerlessness” of the immediate next of kin of the murder victims vis-à-vis the State authorities amounted to cruel, inhuman and degrading treatment.546 This applies especially where the State See Bamaca-Velásquez v Guatemala (2000), op. cit., §128; Blake v Guatemala, IACHR (Series C) No. 36, judgement of 24 January 1998, §65; Godínez-Cruz v Honduras (1989), op. cit., §§163, 166; Fairén-Garbi and Solís-Corrales v Honduras, IACHR (Series C) No. 6, judgement of 15 March 1989, §147; Velásquez-Rodríguez v Honduras (1982), op. cit., §§155, 158. 543 Bamaca-Velásquez v Guatemala (2000), op. cit., §130. See also Villagrán Morales and Others v Guatemala (1999), op. cit., §69; Castillo Petruzzi and Others v Peru (1999), op. cit., §62; Paniagua Morales and Others v Guatemala (1998), op. cit., §72; Blake v Guatemala (1998), op. cit., §§47, 49; Gangaram-Panday v Suriname, IACHR (Series C) No. 16, judgement of 21 January 1994, §49; Fairén-Garbi and Solís-Corrales v Honduras (1989), op. cit., §130–133; GodínezCruz v Honduras (1989), op. cit., §§127, 130, 133–136; Velásquez-Rodríguez v Honduras (1982), op. cit., §124, 127–130. 544 La Cantuta v Peru (2006), op. cit., §113. 545 See, for example, Suárez-Rosero v Ecuador (1997), op. cit., §102. 546 Gómez-Paquiyauri Brothers v Peru (2004), op. cit., §118. See also Sánchez v Honduras (2003), op. cit., §101; Bamaca-Velásquez v Guatemala (2000), op. cit., §160; Cantoral-Benavides v Peru (2000), op. cit., §105; Villagrán Morales and Others v Guatemala (1999), op. cit., §§175–176; 542 120