Forced sterilization in Peru

Alberto Fujimori's government used forced sterilization as part of a broader population control initiative under the National Population Program. Targeting impoverished and predominantly indigenous women in rural Andean regions, this program became the largest state-sponsored sterilization effort in the Americas.[1] Though publicly framed as a progressive measure for reproductive health and economic modernization, it has been widely condemned for its coercive methods and long-term human rights violations.

Under Alberto Fujimori's rule (1990–2000), 300,000 peasants were sterilised

The sterilization campaign was rooted in decades-old eugenic ideologies and neo-Malthusian theories that linked overpopulation to poverty and national instability. Under Fujimori, these ideas were operationalized into a systematic program purportedly aimed at alleviating poverty and curbing high birth rates. Women were frequently sterilized without informed consent, often under duress, or in exchange for food and healthcare. Between 1996 and 2000, an estimated 300,000 sterilizations were performed, disproportionately affecting indigenous communities and leaving lasting social, economic, and medical repercussions.

International and domestic organizations have criticized the campaign as a crime against humanity, with some labeling it as ethnic cleansing or genocide. Legal and political efforts to address the abuses have faced significant obstacles, with accountability remaining limited. In recent years, victims and advocacy groups have pursued recognition and justice, yet challenges persist in achieving comprehensive reparations or holding the perpetrators fully accountable.

Background

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Andean woman with child

Radical eugenic measures, though previously proposed,[2] were not enacted until the Fujimori regime,[3] affecting peasant populations in the Peruvian highlands considered 'unfit' for reproduction according to the imperatives of racial hygiene.[4]

Eugenics in Peru

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In the 20th century, population control measures in Peru were closely tied to ethnicity.[5] Public discourse on the so-called "Indian problem" portrayed indigenous populations as obstacles to national progress, while associating racial improvement with increased whiteness. These views were primarily promoted by the country's white and mestizo elites.[6][7]

Eugenics, a theory that aims to improve the genetic quality of a human population, gained influence in Peru during the first half of the 20th century, reaching its apogee in the 1920s and 1930s.[8][9] The government introduced pre-marriage examinations designed to prevent unions between individuals deemed "unfit".[9] In the 1930s, the Peruvian government encouraged the immigration of white Europeans as part of efforts to alter the country's racial composition.[9]

Although concerns over population control persisted after the decline of the eugenics movement in the 1930s and 1940s, practices such as forced sterilization and eugenic abortion were not formally implemented during this period.[10] However, there were also Peruvian authors who defended them, inspired by the policies applied in the United States and even in Nazi Germany.[8] By the 1970s, after the atrocities of World War II, eugenics had largely fallen out of favor in both scientific and political discussions in Peru, becoming a taboo subject.[11]

Demographic changes and population control

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In post-colonial Peru, public health interventions primarily targeted marginalized groups, including women, the poor, and indigenous populations.[12] This focus led to a perception of the health system as catering mainly to these disadvantaged groups. Early pro-natalist policies in the republic emphasized mother-child health, viewing population growth as beneficial to the economy.[12] Women were often seen in terms of their reproductive roles, with their contribution to economic progress tied to their potential as mothers and caregivers.[12]

However, by the 1970s, large families were increasingly seen as "culturally primitive", harmful to women's health, and a threat to democratic stability.[12] At that time, Peru was a deeply divided society, with a powerful oligarchy ruling over a largely impoverished majority.[13] Rapid urbanization occurred, healthcare improved, and mortality rates declined, but the birth rate remained high—around six children per woman in 1972.[14]

As the sexual revolution unfolded in the United States and globally, calls for better access to birth control grew in Peru, particularly among middle-class, urban women.[14] Feminist movements advocated for reproductive health services, but access remained unequal, with middle-class women enjoying more resources compared to poor, rural, and predominantly indigenous women.[14]

Following the collapse of the military regime in the 1980s, the government of Fernando Belaúnde made the first attempts to expand access to birth control.[15] The 1981 census indicated that women in regions with high birth rates did not desire more children. In response, the government created a national population council and introduced family planning services in hospitals, although these efforts were largely confined to urban areas and did not reach rural, indigenous populations.[16]

These efforts were continued by President Alan García, with support from both the political left and the Catholic Church. However, while the Church endorsed population control, it opposed modern contraceptive methods, promoting instead "responsible parenthood" through traditional means.[16] Due to the Church's influence, the 1985 legislation did not legalize voluntary sterilization or abortion, a decision that disappointed many feminist activists.[16]

Plan Verde and National Population Program

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Elaboration of Plan Verde

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In the 1980s, the Peruvian Armed Forces grew increasingly frustrated with President Alan García's inability to address the country's economic and political crises, including the civil war. In response, the military began drafting a plan to overthrow his government and implement a neoliberal economic system under an authoritarian regime.[17][18] The military saw overpopulation of ethnic Others as a possible cause of social problems,[19] as in neo-Malthusian theory, and shaped this thought into Plan Verde.[20][21]

Business elites, who maintained close relations with military planners, supported this agenda, providing economic ideas that aligned with the military's goals.[22] One key aspect of this plan, detailed in a volume titled Driving Peru into the XXI Century (Spanish: Impulsar al Perú al siglo XXI), involved a population control strategy aimed at impoverished citizens.[23][18]

According to Peruvian analyst Fernando Rospigliosi, the military proposed sterilizing economically disadvantaged and indigenous groups,[18] which they described as "culturally backward" and "unnecessary burdens" on the country.[18][23][24] The plan explicitly called for the widespread use of sterilization as a means to reduce the population of these groups, which were deemed detrimental to Peru's progress.[25][23] Rospigliosi likened these ideas to those of the Nazis, noting the extreme language used in the plan,[18] including references to the "total extermination" of certain populations due to their perceived incorrigibility and lack of resources.[26]

The Peruvian magazine Oiga reported that on 18 June 1990, the military finalized several scenarios for a coup, one of which was planned for 27 July 1990, the day before Alberto Fujimori's inauguration as president.[24] In this scenario, titled "Negotiation and Agreement with Fujimori: Bases of Negotiation—Concept of Directed Democracy and Market Economy," Fujimori would be pressured to accept the military's agenda at least 24 hours before taking office.[24]

Rospigliosi suggested that an agreement was reached between Fujimori, his intelligence chief Vladimiro Montesinos, and key military officers involved in Plan Verde prior to Fujimori's inauguration.[18][22] As a result, many of the policies outlined in Plan Verde were later adopted during Fujimori's administration.[22][27]

Implementation of sterilization policies

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We were required to perform a certain number of sterilizations each month. This was obligatory and if we did not comply, we were fired. Many providers did not inform women that they were going to be sterilized – they told them that the procedure was something else. But I felt this was wrong. I preferred to offer women a bag of rice to convince them to accept the procedure and explained to them beforehand what was going to happen.

— Ministry of Health physician[28]

In the 1990s, the government of Alberto Fujimori implemented a state-led sterilization program as part of broader population control efforts under the National Population Program. This initiative, framed as a tool for economic development,[29] disproportionately targeted impoverished and indigenous women, particularly in rural areas. A media controversy orchestrated by Fujimori during his first term (1990–1995) created a conducive environment for his future sterilisation campaign.

The sterilization campaign stemmed from earlier military plans, including Plan Verde, which advocated for population control measures to alleviate economic burdens. By 1991, Fujimori's administration had integrated these ideas into its policies. In 1992, following Fujimori's self-coup, a civilian-military regime was established, and many of the objectives outlined in Plan Verde were set into motion.[30][24] The Family Planning Program (1991–1998) was initially supported by national and international organizations due to the historical neglect of comprehensive reproductive health policies in Peru.[7]

In 1993, the government expanded the program, citing the need for population control to ensure the provision of basic social services. The prime minister's report, Basic Social Policy Guidelines, and the document Social Policy: Situation and Perspectives both influenced the direction of the sterilization campaign, emphasizing permanent birth control for the poor as a critical element of economic recovery.[29] The program director, Eduardo Yong Motta, demanded increased quotas for sterilizations, and Fujimori, known for his micromanagement, personally pressured regional leaders to comply.[31]

Before the program's expansion, fewer than 15,000 sterilizations were performed annually, primarily for women with specific health risks or those with multiple children. However, after 1995, sterilizations were increasingly performed without prior medical conditions, targeting women from poor and marginalized communities. By 1996, the number of sterilizations had increased to 67,000, and by 1997, it reached 115,000.[7]

Many of the healthcare personnel involved in the program lacked proper training, and the equipment used was often outdated or insufficient. Counselling services were inadequate, with many women not receiving full information about the procedures. A common strategy of health workers was to offer food incentives, such as bags of rice, to convince women to undergo the procedure, often under coercion.[7]

The program was presented using progressive rhetoric, with Fujimori framing population control as essential for modernization and economic growth.[7] He criticized the Catholic Church, which opposed the use of modern contraceptive methods, as an obstacle to family planning efforts. Notably,[7] many of the rural areas targeted by the program were not overpopulated, but were located in inaccessible, poor and marginalized areas.[7]

Between 1996 and 2000, an estimated 300,000 Peruvians were sterilized, the vast majority of whom were indigenous, poor, and illiterate women. The program's use of intimidation and coercion led to severe medical complications for many women, social ostracism, and in some cases, death.[32] Fujimori's government used feminist discourse to legitimize the campaign, framing it as a progressive step toward women's empowerment and family planning, even as human rights violations occurred. The sterilization program has since been condemned as a violation of human rights and a case of state-led abuse of vulnerable populations.[1]

Methods of coercion

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During the implementation of sterilization programs in Peru, many procedures were carried out under coercion, deceit, or serious threats.[33] Indigenous women were often targeted while seeking routine healthcare services, such as treatment for common illnesses, vaccinations, or general health inquiries. In some cases, women who presented with minor conditions, like the flu, were anesthetized and sterilized without their knowledge or consent. A significant number of sterilizations were also performed following cesarean sections, without informed consent.[33]

By 1998, 8% of the Peruvian population was illiterate, with the highest rates of illiteracy found in regions populated by rural and Indigenous communities.[34] These areas were also heavily affected by the forced sterilization campaign. Coercion was frequently linked to economic incentives, as impoverished women were offered food and clothing in exchange for agreeing to the procedure.[34] For many women and their families, these material benefits—essential for survival in conditions of poverty—manipulated their decision-making. Many of the women targeted did not speak Spanish fluently or were illiterate, making them especially vulnerable. Healthcare workers would often have women sign or place their fingerprint on consent forms they could not understand, with the threat of cutting off access to food programs if they refused.[34]

Other methods of coercion included threats of police involvement, the potential loss of healthcare services, and, in extreme cases, threats of imprisonment. These tactics were used to pressure women into undergoing sterilization procedures, often without full understanding or genuine consent.[33]

Analysis

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Ethnic cleansing and genocide

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Forced sterilization in Peru, carried out under the National Population Program, has been analyzed by numerous scholars and organizations as a form of systemic violence against indigenous and rural women. The sterilization practices, which occurred predominantly during the 1990s, have been compared to ethnic cleansing and, in some instances, labeled as genocide.[25][23][33][35] Scholars such as Michele Back and Virginia Zavala emphasize that the program's focus on marginalized groups, particularly indigenous communities, aligns with the characteristics of ethnic cleansing due to its targeted nature.[36]

Jocelyn E. Getgen from Cornell University argues that the systemic implementation of these sterilizations, combined with the documented intent of officials associated with Plan Verde—a military strategy devised during the Peruvian Civil War (1980–2000)—meets the criteria for genocide.[23] Plan Verde's architects reportedly perceived the reproductive capabilities of indigenous populations as a threat to national stability, linking these communities to communist insurgencies, such as the Shining Path guerrilla group.[1]

The Amazonian Center of Anthropology and Practical Application has characterized the sterilization campaign as an act of genocide unparalleled since the colonization of Peru.[37] The policy's long-term effects included a significant demographic impact, particularly a reduction in the younger generation. This generational decline contributed to the economic stagnation of rural areas, which became increasingly impoverished without a sufficient labor force to support agricultural and economic development.[38]

Alejandra Ballón Gutiérrez, a Peruvian researcher, asserts that forced sterilization served as "a weapon of war and an instrument of torture" aimed at indigenous women.[39][25] The military, operating under counterinsurgency objectives during the civil conflict, viewed rural populations as potential supporters of insurgent groups. Consequently, the sterilizations were part of a broader strategy to suppress perceived insurgent threats by reducing the birth rates of communities deemed subversive or destabilizing.[40][39][25][20]

Official figures

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Under Ollanta Humala's administration, the Registry of Victims of Forced Sterilizations (Reviesfo) within the Peruvian Ministry of Justice was created in 2016.[41] While not all sterilized persons can be registered with Reviesfo due to procedural problems,[41] this agency was able to identify at least 5,000 women who underwent sterilization against their will. Therefore, the actual number is estimated to be higher.[41][42]

Foreign involvement

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According to Peru's congressional subcommittee investigations, United States Agency for International Development (USAID), the United Nations Population Fund (UNFPA) and the Nippon Foundation supported the sterilization efforts of the Fujimori government.[43][44] However, a US congressional investigation led by members of the religious right, who were deeply opposed to sterilization, found no evidence USAID was funding forced sterilizations.

USAID

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For three decades, USAID has been the principal foreign donor to family planning in Peru. Until the 1990s, the Peruvian government's commitment to providing family planning services was limited.[45]

In 1998, concerns arose regarding the involvement of the United States Agency for International Development (USAID) in forced sterilization campaigns in Peru. Some far-right politicians in Washington opposed USAID's funding of family planning initiatives in the country.[45] In January 1998, David Morrison, from the U.S.-based NGO Population Research Institute (PRI), traveled to Peru to investigate claims of human rights abuses related to these programs. During his visit, Morrison gathered testimony from Peruvian politicians and other figures opposed to family planning but did not meet with USAID officials in Peru.[45] Upon his return to the United States, the PRI submitted its findings to U.S. Congressman Chris Smith, a member of the Republican Party, urging for the suspension of USAID's family planning efforts in Peru. Smith subsequently dispatched a member of his staff to Peru for further investigation.[45]

In February 1998, another far-right U.S. organization, the Latin American Alliance for the Family, sent its director to Peru to examine the situation, again without consulting USAID officials. On February 25, 1998, a subcommittee of the U.S. House Committee on International Relations, chaired by Smith, held a hearing on "the Peruvian population control program".[45] Allegations that USAID was funding forced sterilizations in Peru prompted Congressman Todd Tiahrt to introduce the "Tiahrt Amendment" in 1998.

However, the subcommittee concluded that USAID's funding had not supported the abuses committed by the Peruvian government.[46][45]

Aftermath

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Investigations

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Efforts to address the forced sterilizations have been pursued by both civil society and the government. The Truth and Reconciliation Commission (TRC) was established in 2001 to investigate two decades of civil war between the Shining Path, rondas campesinas (peasant militias), and the Peruvian military. Its final report, published in 2003, concluded that Vladimiro Montesinos had taken the Plan Verde military conspiracy beyond what its original plotters had envisaged.[47]

Decree 2906, introduced to expand the definition of sexual violence during the conflict to include practices such as forced pregnancy, abortion, prostitution, and sexual slavery, faced strong opposition from the Ministry of Justice.[48] The Ministry argued that this broadened definition would implicate the state, particularly the Ministry of Health, as the primary perpetrator of sexual violence during the war. While Decree 2906 was eventually passed in 2012, it excluded the sterilization campaign from the expanded definition of reparable sexual violence.[48]

Peruvian Catholic Church and NGOs

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The Peruvian Catholic Church and human rights organizations played an important role in denouncing forced sterilizations during the Fujimori regime.[42] Catholic leaders were among the earliest to condemn the sterilization campaign, even before feminist and other activist groups.[42] However, their motivations differed from those of human rights organizations. The Church's opposition was framed by a conservative agenda, yet it adopted elements of human rights and public health frameworks to strengthen its stance against family planning. A strong metaphor used by Catholic leaders to describe the sterilizations was the "mutilation of the poor".[42]

In their critique, the Catholic Church argued that the family planning campaign infringed upon individual freedom, particularly women's rights, and violated the public's autonomy. This position was often articulated through the defense of women's "right to motherhood." The Church's opposition gained international attention through media statements that emphasized concerns about violations of personal freedoms.[42]

Feminist organizations, such as the NGO Flora Tristán, in contrast, contributed to the discourse with reports on the government's sterilization practices. Giulia Tamayo [es], herself one of Flora Tristán's key figures, published a detailed report on the Fujimori government's "Health Festivals," (Spanish: festivales de salud) where mass sterilizations took place. According to Tamayo's findings, only 10% of the 314,967 women sterilized gave their free, prior and informed consent.[42]

Reports also revealed that health professionals were incentivized with bonuses ranging from $4 to $30 for each woman they "persuaded" and sterilized, and promotions were given based on meeting sterilization quotas. Professionals who did not meet these targets could lose their career advancement.[42]

Denial

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Publicly, the Fujimori administration and Fujimorists denied the existence of a forced sterilization program,[49] attributing the allegations to an "international conspiracy" and accusing local critics of disregarding the health needs of the poor.[34] In a speech at the United Nations General Assembly, President Alberto Fujimori mocked the human rights organizations that condemned the sterilizations, suggesting that their discontent stemmed from not receiving state funding. This narrative was echoed by numerous Peruvian and international institutions aligned with Fujimori's government.[34]

During this period, the Fujimori regime systematically distanced itself from independent institutions, including the media, judiciary, and Congress. Opposition to government policies was often labeled as "anti-nationalist," disruptive to political stability, or even linked to terrorism.[50] Despite this atmosphere of repression, feminist groups, journalists, non-governmental organizations (NGOs), and human rights activists amplified the voices of affected women.[50]

The concept of informed consent, or respecting the reproductive choices of women, was largely limited to middle-class, educated, urban, and predominantly white individuals. In contrast, the Fujimori government fostered a climate of fear, marked by ongoing concerns about terrorism and economic instability, which silenced many voices and created tacit support for the regime among broader segments of Peruvian society.[50]

Fujimori was succeeded by Alejandro Toledo in 2001. While the Toledo administration condemned the practice of forced sterilizations, it also faced criticism for other reproductive rights violations. The Peruvian Medical Association acknowledged that the sterilization procedures were state policy and violated patients' rights, but defended doctors, arguing that they were pressured by the state and forced to perform sterilizations without consent under the threat of losing their jobs.[42] This stance was criticized for portraying medical professionals as victims of the system, thereby minimizing their personal and professional accountability for the violations.[42]

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The actions of the Fujimori government have been condemned by various international bodies, including the International Criminal Court, which categorized the regime's forced sterilization campaign as crimes against humanity.[51] In 1999, human rights organizations brought a case to the Inter-American Commission on Human Rights concerning Mamerita Mestanza Chavez, a woman who was coerced into sterilization without adequate medical care, leading to her death.[51] Despite the magnitude of the issue, the Peruvian government has been criticized for its lack of response and for obstructing investigations, particularly during periods when Fujimorists held influence in Congress during the 2010s.[51][52]

In 2016, a public prosecutor argued that former President Alberto Fujimori and his administration should not be prosecuted for the sterilizations, asserting that any coercive sterilizations were isolated actions taken by individual medical personnel. A legal case involving thousands of women, initiated in 2002, has faced numerous delays.[52] Fujimori, already convicted for other crimes against humanity, was scheduled to face trial for the sterilization program. However, Peruvian judge Rafael Martinez ruled against the trial, stating that forced sterilizations were not part of the extradition request when Fujimori was extradited from Chile.[52] In 2024, Chilean Justice Andrea Muñoz Sánchez, of the Supreme Court of Chile, approved the addition of the forced sterilization charges to the extradition request, allowing the prosecution to proceed.[53]

In 2023, the Inter-American Commission on Human Rights accepted the case of Edith Ramos, a victim of forced sterilization under the Fujimori government, for a new trial against the Peruvian state in the Inter-American Court of Human Rights.[54]

See also

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References

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  1. ^ a b c Ballón Gutiérrez 2023, p. 210.
  2. ^ Stucchi-Portocarrero 2018, p. 98. "[R]adical practices such as forced sterilization and eugenic abortion were never formally implemented."
  3. ^ Stucchi-Portocarrero 2018, p. 105. "Although the official discourse never used the words 'eugenics' or 'race' ... [there was an] obvious ethnic bias in the population affected, which was almost entirely made up of illiterate peasants from the Peruvian highlands, who were clearly judged as 'unfit' to procreate."
  4. ^ Chaparro-Buitrago et al. 2023, p. 173.
  5. ^ Ewig 2006, pp. 637–638.
  6. ^ Stavig 2017, pp. 61–74.
  7. ^ a b c d e f g Ewig 2006.
  8. ^ a b Stucchi-Portocarrero 2018, p. 106.
  9. ^ a b c Ewig 2006, p. 637.
  10. ^ Stucchi-Portocarrero 2018, p. 98.
  11. ^ Stucchi-Portocarrero 2018, p. 105.
  12. ^ a b c d Vasquez Del Aguila 2022, p. 103.
  13. ^ Gorman 1980, p. 292.
  14. ^ a b c Boesten 2007, p. 4.
  15. ^ Boesten 2007, pp. 4–5.
  16. ^ a b c Boesten 2007, p. 5.
  17. ^ Burt 1998, p. 5.
  18. ^ a b c d e f Rospigliosi 1996, pp. 28–40.
  19. ^ Theidon 2022, p. 229.
  20. ^ a b Stavig 2017, p. 16.
  21. ^ Ballón Gutiérrez 2023, p. 211.
  22. ^ a b c Avilés 2009, p. 60.
  23. ^ a b c d e Getgen 2008, pp. 27–28.
  24. ^ a b c d Oiga 1993.
  25. ^ a b c d Gaussens 2020, p. 186.
  26. ^ Theidon 2022, p. 237.
  27. ^ Infobae 2024.
  28. ^ Coe 2004, p. 62.
  29. ^ a b Ewig 2006, p. 643.
  30. ^ Cameron 1998, p. 228.
  31. ^ Ewig 2006, p. 644.
  32. ^ Vasquez Del Aguila 2022, p. 100.
  33. ^ a b c d Kravetz 2017, p. 740.
  34. ^ a b c d e Vasquez Del Aguila 2022, p. 106.
  35. ^ Carranza Ko 2020, pp. 90–103.
  36. ^ Back, Michele; Zavala, Virginia (2018). Racialization and Language: Interdisciplinary Perspectives From Perú. Routledge. pp. 286–291. Retrieved 4 August 2021. At the end of the 1980s, a group of military elites secretly developed an analysis of Peruvian society called El cuaderno verde. This analysis established the policies that the following government would have to carry out in order to defeat Shining Path and rescue the Peruvian economy from the deep crisis in which it found itself. El cuaderno verde was passed onto the national press in 1993, after some of these policies were enacted by President Fujimori. ... It was a program that resulted in the forced sterilization of Quechua-speaking women belonging to rural Andean communities. This is an example of 'ethnic cleansing' justified by the state, which claimed that a properly controlled birth rate would improve the distribution of national resources and thus reduce poverty levels. ... The Peruvian state decided to control the bodies of 'culturally backward' women, since they were considered a source of poverty and the seeds of subversive groups
  37. ^ CAAPA 2016.
  38. ^ BBC News 2002.
  39. ^ a b Ballón Gutiérrez 2023, p. 219.
  40. ^ Theidon 2022, p. 239.
  41. ^ a b c Carranza Ko 2023, pp. 14–15.
  42. ^ a b c d e f g h i Vasquez Del Aguila 2022, p. 109.
  43. ^ McMaken, Ryan (2018-10-26). "How the U.S. Government Led a Program That Forcibly Sterilized Thousands of Poor Peruvian Women in the 1990s | Ryan McMaken". Foundation for Economic Education. Retrieved 2021-08-04.
  44. ^ "Informe final sobre la aplicación de la anticoncepción quirúrgica voluntaria (AQV) en los años 1990-2000" (PDF). Congress of Peru. June 2002.
  45. ^ a b c d e f Chávez et al. 2007, p. 109.
  46. ^ "The Peruvian Population Control Program". commdocs.house.gov. Retrieved 2024-10-01.
  47. ^ 'Final Report of the Truth and Reconciliation Commission'. Available at: https://www.cverdad.org.pe/ifinal/pdf/TOMO%20II/CAPITULO%201%20-%20Los%20actores%20armados%20del%20conflicto/1.3.%20LAS%20FUERZAS%20ARMADAS.pdf. pp. 328–305. Retrieved 5 Oct 2024.
  48. ^ a b Theidon 2022, p. 235.
  49. ^ Molina Serra 2017, p. 39.
  50. ^ a b c Vasquez Del Aguila 2022, pp. 106–107.
  51. ^ a b c DW 2021.
  52. ^ a b c France 24 2021.
  53. ^ "Ministra Andrea Muñoz acoge solicitud de ampliación de extradición de ex presidente de Perú Alberto Fujimori" [Justice Andrea Muñoz accepts request to extend extradition of former Peruvian president Alberto Fujimori]. www.pjud.cl (in Spanish). Retrieved 2024-09-25.
  54. ^ Potenziano 2023, p. 51.

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