The IACtHR has adopted the broadest approach on the right to family life in the context of ED, by considering that the crime engaged the rights of the family under Article 17 of the American Convention, which enshrines the right to family life.209 When it was relevant, the IACtHR also found a violation of the rights of the child under Article 19 of the American Convention.210 Thus, in the case of the disappearance of two young children, the Serrano-Cruz Sisters, in El Salvador, the Court stated that the “lack of diligence in the investigation and determination of the whereabouts [of the victims] constitutes a violation of the rights protected by Article 17 of the Convention.”211 The Court also found a violation of Article 19 for failing to take any measure to return the children to their family. Pursuant to Article 8 of the UDHR, “[e]veryone has the right to an effective remedy by the competent national tribunals for acts violating the fundamental rights guaranteed him by the constitution or law.”215 Other human rights treaties codify this right, including the ICCPR and the CAT,216 and regional bodies have also endorsed the right to a remedy in their charters.217 The ICPPED stipulates in Article 24(4) that: “[E]ach State Party shall ensure in its legal system that the victims of enforced disappearance have the right to obtain reparation and prompt, fair and adequate compensation.”218 The main State obligations in relation to the right to an effective remedy include: ensuring that victims have effective remedies through appropriate judicial and administrative mechanisms; promptly and effectively investigating allegations of violations through independent bodies; prosecuting those responsible for the violations; and providing reparation to victims, including reparation.219 In Gelman v. Uruguay, the IACtHR dealt with the rights of stolen/abducted children and noted that States were obligated to ensure the protection of the family and guard against unlawful or arbitrary interference in the family life of the children.212 The ECtHR has found violations of Article 8 in several ED cases. In the case of El-Masri v. The Former Yugoslav Republic of Macedonia, the ECtHR held that “the interference with the applicant’s right to respect for his private and family life was not in ‘accordance with the law’”.213 The ECtHR recognised that the broad notion of private life extended to situations of deprivation of liberty, and that an essential objective of Article 8 is the protection from arbitrary interference by public authorities.214 The HRCt has systematically found a violation of the right to an effective remedy, either alone or read in conjunction with the ICCPR.220 Blanket amnesties for gross human rights violators have also been considered by the HRCt as a contravention of Article 2(3) of the ICCPR, which stipulates the State’s duty to provide an effective remedy to victims of human rights violations. 221 Most ED entails a violation of the right to effective remedy in respect of both the disappeared persons and the relatives. The ECtHR has repeatedly held that ED constitutes a violation of the right to an effective remedy under Article 13 of the Convention (Right to an effective remedy), read in conjunction with Articles 2 and 3. The ECtHR has made clear that: “where Right to an effective remedy The right to a remedy for gross human rights violations is a well-established norm of international law. 209 ACHR, supra note 139, Article 17. 210 ACHR, supra note 139, Article 19. 211 IACtHR, Serrano-Cruz Sisters v El Salvador, Serie C No. 118, 23 November 2004, para. 90; See also IACtHR, Gelman v Uruguay, 24 February 2011, para. 312. 212 IACtHR, Gelman v Uruguay, Judgment, Series C No. 221, 24 February 2011. 213 ECtHR, El-Masri v the Former Yugoslav Republic of Macedonia, Appl. No. 39630/09, 13 December 2012, para. 249. 214 ECtHR, El-Masri v the Former Yugoslav Republic of Macedonia, supra note 213, para. 249; ECtHR, Raninen v Finland, Appl. No. 152/1996/771/972, 16 December 1997, para. 63; ECtHR, Kroon and Others v the Netherlands, Appl. No. 18535/91, 27 October 1994, para. 31. 215 Universal Declaration of Human Rights ("UDHR"), Article 8. 216 ICCPR, Articles 2(3), 9(5), 14(6); CAT, supra note 153, Article 14. 217 ECHR, Article 13; ACHR, Article 25; African Charter, Articles 7, 21. 218 ICPPED, Article 24. 219 OHCHR, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, Resolution 60/147, 16 December 2005, para. 3. 220 See e.g. Tharu et al. v. Nepal, Communication No. 2038/2011, CCPR/C/114/D/2038/2011, 21 October 2015; Dovadzija et al. v. Bosnia and Herzegovina, Communication No. 2143/2012, CCPR/C/114/D/2143/2012, 10 November 2015; Icić et al. v. Bosnia and Herzegovina, Communication No. 2028/2011, CCPR/C/113/D/2028/2011, 20 August 2015; Zarzi (on behalf of Aouabdia and ors) v Algeria, Merits, Communication No. 1780/2008, CCPR/C/101/D/1780/2008, 22 March 2011, 221 ICCPR, Article 2(3). 34