S.L. v Venezuela

S.L. (a pseudonym given to her to protect her identity) is a UK national who, whilst being held in prison in Venezuela, died on 13 March 2001 following a lack of medical care for her diabetic condition.

S.L.’S STORY

On 8 August 2000, S.L. was sentenced to prison in Venezuela. Although the prison staff at the Instituto Nacional de Orientación Femenina (INOF) in Los Teques, were aware that S.L. was suffering from type I diabetes, they failed to provide her with due medical care when she went into diabetic shock in March 2001.

Likewise, S.L. received no proper medical attention during the hours after her diabetic shock at the medical centres to which she was taken. This lack of immediate and proper medical treatment resulted in S.L.’s death on 13 March 2001, a week after she was first taken ill.

Instead of investigating the events promptly and with due diligence, a criminal investigation into S.L.’s death was not launched for nearly 12 months after her death. Indeed, it took the Venezuelan judicial system more than 9 years to make a final ruling on S.L.’s case.

This unjustified delay effectively protected those responsible for the alleged crimes, who on 29 October 2010 were found not guilty due to the operation of statutes of limitation.

ACTION FOR JUSTICE

On 19 April 2011, REDRESS, on behalf of S.L.’s parents, filed a petition at the Inter-American Commission on Human Rights, and this petition was declared admissible by the Commission on 5 December 2019.

A full submission on the merits of the case was filed by REDRESS on 12 June 2020 which further developed the arguments that the lack of proper medical attention constituted a violation of Articles 4 (right to life), 5 (prohibition of torture and cruel, inhuman and degrading treatment) and Article 26 (right to health) of the American Convention on Human Rights. Further, it argued that undue delay in investigating the events that led to S.L.’s death violated her and her parent’s right to a fair trial of those responsible and judicial protection (Articles 8 and 25 of the American Convention).

On behalf of S.L.’s parents, REDRESS sought an effective investigation of the events that led to S.L.’s death and the delays in the judicial process, along with a prosecution of those responsible; an official apology from the President of Venezuela to S.L.’s parents; compensation for the economic and emotional damage suffered; and measures to try to ensure that these issues are not repeated, including the guarantee of urgent medical treatment to those inmates who need it.

THE OUTCOMES

On 5 December 2019, the Inter-American Commission on Human Rights declared the petition admissible. In it’s final Report on the Merits of the case, published on 19 December 2025, the Commission found Venezuela internationally responsible for violations of the rights to life, personal integrity, health, fair trial, and judicial protection arising from S.L.’s detention and death.

The Commission concluded that the State failed to provide adequate medical care to S.L., and that these failures led to her death. They also concluded that these failures breached the State’s obligations to ensure adequate health care to detainees, and that the State then failed to investigate her death with due diligence and within a reasonable time.  

Beyond the loss of life, the IACHR highlighted the profound harm suffered by S.L.’s parents. It found that prolonged judicial inaction, lasting more than nine years, denied them truth, accountability, and effective remedies, compounding their suffering, and violating their rights to due process, judicial protection, and personal integrity. 

The Commission ordered Venezuela to provide financial compensation, rehabilitation measures for S.L.’s parents, and to effectively investigate the facts of this case and prosecute those responsible for the excessive delays in the criminal proceedings. Crucially, it also mandated structural reforms at INOF where she was held, including improved access to health care, new emergency medical protocols, and adequate medical staffing for detainees with chronic and mental-health conditions. 

QUICK FACTS

Case name: S.L. v. Venezuela.

Court/Body: Inter-American Commission on Human Rights (IACHR).

Date filed: 19 April 2011.

Report on the Merits: 19 December 2025.

Photo by Mitchell Haindfield (CC BY 2.0)