On December 15, 1997, the United Nations General Assembly adopted the International Convention for the Suppression of Terrorist Bombings (Convention or Terrorist Bombing Convention). The Convention sets forth a broad regime of jurisdiction for international cooperation in connection with the unlawful and intentional use of explosives and other lethal devices, in, into or against various defined public places, with intent to kill or cause serious bodily injury or to cause extensive destruction of the defined public place. It will fill an important gap in international law by expanding the legal framework for states to cooperate in the investigation, prosecution and extradition of persons who engage in such international terrorism. While generally patterned after prior counterterrorism conventions, the Convention contains several important innovations.

The Inter-American Commission on Human Rights (Commission) brought this action in 1986 against the Government of Honduras in the Inter-American Court of Human Rights. The Commission alleged that Honduras had violated Articles 4, 5 and 7 of the American Convention on Human Rights (Convention) with respect to the 1981 detention and subsequent disappearance of a Honduran student, Angel Manfredo Velásquez Rodríguez. The Court ruled for the Commission and unanimously held: (1) that domestic Honduran legal remedies were ineffective and did not bar the Court’s jurisdiction; (2) that a systematic pattern of disappearances was carried out or tolerated by Honduran government officials from 1981 to 1984; (3) that Honduras had violated the victim’s rights as part of that practice; and (4) that Honduras must therefore compensate the family of the victim and that any agreement on the form and amount of compensation must be approved by the Court. The Court further held, by six to one, that it would decide the form and amount of compensation if Honduras and the Commission were unable to negotiate an agreement within 6 months. Judge Piza filed a dissenting opinion.