Part II Means of Protection, Ch.VIII Inter-American Court of Human Rights, s.2 Jurisdiction and Functions, Article 65

This chapter details Article 65 of the American Convention on Human Rights (ACHR), which holds a special place in the inter-American human rights system. The provision does not formally establish a procedure for monitoring the judgments of the Inter-American Court. It establishes relations between the Court and the General Assembly of the Organization of American States (OAS), which is the recipient of the Court's annual reports (first sentence) and its possible recommendations when a State does not comply with its judgments. However, practice has shown that Article 65 is actually modest. It only requires the Court to send its report to the General Assembly and to draw its attention to recalcitrant States. The provision does not confer any particular role on the General Assembly, and the inter-American litigation illustrates that the main organ of the OAS has remained largely passive in this area of monitoring the compliance with its of judgments.