In its judgement in the Videla case in 1994 concerning the abduction, torture and murder of Lumi Videla in Chile in 1974, Chile’s Appeal Court of Santiago stated that common Article 3 of the 1949 Geneva Conventions obliged parties to non-international armed conflicts “to extend humanitarian treatment to persons taking no active part in the hostilities or who have placed themselves hors de combat for various reasons, and prohibits at any time and in any place … mutilation”.