...In cases such as forced disappearance - and others... the State has be�er possibili�es of assuming the func�on of proving what it denies, than the individual to prove what he affirms” 67.2. Godinez Cruz v Honduras23, the Inter-American Court of Human Rights held: “141. In contrast to domes�c criminal law, in proceedings to determine human rights viola�ons the State cannot rely on the defense that the complainant has failed to present evidence when it cannot be obtained without the State's coopera�on. 142. The State controls the means to verify acts occurring within its territory. Although the Commission has inves�gatory powers, it cannot exercise them within a State's jurisdic�on unless it has the coopera�on of that State.”24 67.3. Varnava & Ors v Turkey25 , the European Court of Human Rights held: "184. As a logical development of this approach, in the situa�on where persons are found injured or dead, or who have disappeared, in an area within the exclusive control of the authori�es of the State and there is prima facie evidence that the State may be involved, the 23 IACHR Series C no 10 (Official Cita�on); IHRL 1391 (IACHR 1990) (OUP reference) See also Velasquez-Rodriguez v Honduras Inter-Am.Ct.H.R. (Ser. C) No. 4 (1988), Inter-American Court of Human Rights (IACrtHR), 29 July 1988 25 Appl. nos. 16064/90, 16065/90, 16066/90, 16068/90, 16069/90, 16070/90, 16071/90, 16072/90 and 16073/90, Council of Europe: European Court of Human Rights, 18 September 2009 24 105 AMRI CHE MAT "As this Court has o�en repeated, in cases of forced disappearance, the State's defense cannot rely on the impossibility of the plain�ff to present evidence in the proceedings since, in such cases, it is the State that controls the means to clarify the facts that have occurred in its jurisdic�on and, therefore, in prac�ce, it is necessary to rely on. the coopera�on of the State itself in order to obtain the required evidence.