Tibu massacre v. Columbia (Admissibility Decision) IACHR (19 March 2010) Report No. 51/2010

A group of 250 paramilitary members made a three-day overland journey to a town near the Venezuelan border.  Along the way, the military acquiesced and permitted their passage through numerous checkpoints and following a confrontation with the FARC they murdered several community activists.  Fearing an imminent attack on their village, more than 3,000 people fled their homes, many crossing over into Venezuela.  The State invoked the context that the area was subject to insurgencies fueled by coca cultivation.  The Commission contended they had jurisdiction ratione personae  despite the large claim of 600 unidentified individuals because the rules of procedure permit groups of persons to file complaints and the geographical and temporal scope of the allegations is clear.  The Commission separately held their jurisdiction ratione materiae to utilize the laws of armed conflict in an examination of forced displacement.  The Commission held the case was overall admissible.