CCPR/C/114/D/2134/2012 weapons and cover for the group’s actions. 25 The Committee observes that the State party provided no information refuting the involvement of paramilitary groups in the reported disappearances or the link of these groups with the military. It notes as well the failure of the investigative authorities to exercise due diligence i n response to the numerous complaints filed by the authors, as no investigation of Autodefensas Campesinas del Magdalena Medio was launched despite the fact that the events coincided with the area, time and mode of action of that group. In view of the foregoing, the Committee finds that the authors have provided sufficient evidence — and that the State party has not refuted — that the forced disappearances of Mr. Anzola and Mr. Molina are attributable to the Colombian State. 9.4 The authors allege that the enforced disappearance of Mr. Anzola and Mr. Molina is in itself a violation of numerous rights recognized under the Covenant, including the right not to be arbitrarily deprived of life, the right not to be subjected to torture and ill-treatment and the right to liberty and security of person. The Committee recalls that, while the Covenant does not explicitly use the term “enforced disappearance” in any of its articles, enforced disappearance constitutes a unique and integrated series of acts that represents continuing violation of various rights recognized in that treaty. 26 In the present case, 21 years have passed since the disappearance of Mr. Anzola and Mr. Molina without the State party making the least progress in its investigations into their fate and whereabouts or in determining who was criminally responsible. This is despite numerous reports and appeals presented by the authors and indications that the enforced disappearances took place at the hands of identified paramilitary groups operating in the area where the events occurred. In the light of the foregoing, and in the general context of violations of human rights that occurred, particularly in the form of enforced disappearance, at the time and place of the events, as indicated in the extensive information provided by the authors, the Committee considers that the State party has violated the rights of Mr. Anzola and Mr. Molina under articles 6, 7 and 9 of the Covenant. 9.5 The authors argue that enforced disappearance is also a violation of the rig ht of everyone to be recognized as a person before the law, as established in article 16 of the Covenant, since one of the elements characteristic of enforced disappearance is the placing of the person outside the protection of the law, as recognized inter alia under article 2 of the International Convention for the Protection of All Persons from Enforced Disappearance. The Committee is of the view that the intentional removal of a person from the protection of the law constitutes a refusal to recognize tha t person as a person before the law, in particular if the efforts of his or her relatives to obtain access to effective remedies have been systematically impeded. In the absence of information from the State party on this point, the Committee considers tha t there has been a violation of article 16 of the Covenant in respect of the disappeared persons. 9.6 The Committee notes the authors’ allegations regarding the lack of a thorough and effective investigation by the State into the disappearance of Mr. Anzol a and Mr. Molina, in violation of their right to an effective remedy as recognized in article 2, paragraph 3, of the Covenant. The Committee recalls its general comment No. 31 (CCPR/C/21/Rev.1/Add.13), according to which a failure by a State party to investigate allegations of violations could in and of itself give rise to a separate breach of the Covenant; cessation of an ongoing violation is an essential element of the right to an effective remedy (para. 15). These obligations arise notably in respect of those violations recognized as criminal, such as enforced disappearance (para. 18). __________________ 25 26 14/20 See the judgement of the Inter-American Court of Human Rights, Case of the 19 Merchants v. Colombia, paras. 84 (d) and 86 (b). Committee’s Views on communication No. 2000/2010, Yuba Kumari Katwal v. Nepal, adopted on 1 April 2015, para. 11.3. GE.15-15601