institution of criminal proceedings, 139 in response to the victim’s and/or her family members repeated contacts with the authorities. 4.7.4 Non-Discrimination Non-discrimination is an important principle for women as noted by several regional and international instruments. It is linked to the international recognition that the due diligence duty of States to protect and prevent violence has special connotations in the case of women, due to the historical discrimination they have faced as a group. 140 Nondiscrimination is articulated in instruments as ‘equality before law,’ ‘equal protection of law,’ or ‘equal access to justice’ and sex is listed as one of the prohibited grounds of discrimination. Discrimination, while being a violation of a fundamental right to equality by itself, is also the root of all other forms of violence against women. Indeed, it is the lack of State’s due diligence to end structural discrimination that leads to violence against women. The IACHR report on Maria Eugenia Morales de Sierra underscores the link between discrimination, violence against women and due diligence, highlighting that the States’ duty to address violence against women also involves measures to prevent and respond to the discrimination that perpetuates this problem. 141 Such measures are required to modify the social and cultural patterns of conduct of men and women and to eliminate prejudices, customary and other practices based on the idea of the inferiority or superiority of either of the sexes, and on stereotyped roles for men and women. Indeed, the applicant, Maria Eugenia Morales de Sierra’s case was typical of discrimination based on stereotyped roles for men and women. The applicant complained that the Code, by treating women and men differently on the basis of sex, violated her right to equal protection of and before the law under Article 24 of the American Convention. The IACtHR laid out its interpretation of the meaning of ‘equal protection of the law’ under Article 24. At paragraph 31, it stated that: [T]he right to equal protection of the law set forth in Article 24 of the American Convention requires that national legislation accord its protections without discrimination. Differences in treatment in otherwise similar circumstances are not necessarily discriminatory … A distinction which is based on ‘reasonable and objective criteria’ may serve a legitimate State interest in conformity with the terms of Article 24... It may, in fact, be required to achieve justice or to protect persons requiring the application of special measures ... A distinction based on reasonable and objective criteria (1) pursues a legitimate aim and (2) employs means which are proportional to the end sought … The international and regional systems have also identified certain groups of women as being at particular risk for acts of violence due to having been subjected to discrimination based on more than one factor, among these girl-children, and women pertaining to ethnic, racial, and minority groups; a factor which must be considered by States in the adoption of measures to prevent all forms of violence,142 including sexual violence. 139 Opuz v. Turkey (Application no. 33401/02) Judgment, European Court of Human Rights, Strasbourg, 9 June 2009. 140 See, e.g., UN General Assembly, Human Rights Council, Accelerating efforts to eliminate all forms of violence against women: ensuring due diligence in prevention, A/HRC/14/L.9/Rev.1, 16 June 2010; UN General Assembly, Intensification of efforts to eliminate all forms of violence against women, A/RES/64/137, 11 February 2010 and A/RES/63/155, January 30, 2009; UN, Declaration on the Elimination of Violence against Women, General Assembly resolution 48/104, 20 December 1993, A/RES/48/104, 23 February 1994; UN, Beijing Declaration and Platform for Action, Fourth World Conference on Women, 15 September 1995, A/CONF.177/20 (1995) and A/CONF.177/20/Add.1 (1995); CEDAW, General Recommendation 19: Violence against Women, (11th Session 1992), U.N. Doc.A/47/38 (1993). 141 IACHR, Report Nº 4/01, Maria Eugenia Morales de Sierra (Guatemala), 19 January 2001, para. 44. 142 UN General Assembly, Human Rights Council, Accelerating efforts to eliminate all forms of violence against women: ensuring due diligence in prevention, A/HRC/14/L.9/Rev.1, 16 June 2010, para. 10; IACHR, Violence and REDRESS | REGIONAL MECHANISMS 39