A/HRC/34/62 matter; capacity for grass-roots engagement, including a thorough understanding of victims’ lives and immediate environment and, preferably, an active presence in the communities; and capacity to create regular and effective channels of communication between expert bodies and victim constituencies. 77. Human rights organizations and other NGOs have played a critical role as advocates for victim rights, but they may face challenges in ensuring effective communication with victim groups60 and, more seriously, there are cases in which NGOs advocate positions that do not exactly reflect those of victims. 61 Finally, some argue that this form of representation may create dependency, or at the very least delay the empowerment of the victim communities to speak for themselves. 78. In order to mitigate some of these risks, civil society organizations should ideally establish mechanisms of accountability to the relevant victim constituencies. Victim groups should be treated as primary stakeholders, with monitoring and oversight roles. Civil society organizations should also play a role in the capacity development of representatives and communities and have sustainability plans for the gradual transfer of responsibilities to victim groups. 79. There is no more urgent task in the domain of consultation and participation than the design of effective capacity-building for all stakeholders in such processes, victims included. If justification for consultation and participation is an epistemic argument grounded in the gains in information and insight that are achieved through the participation of victims, any potential contribution will be maximized by providing victims the wherewithal to participate fully and without mediation at all stages of the design, implementation and monitoring of transitional justice programmes. 80. In his last report to the General Assembly, the Special Rapporteur argued that given known constraints on short-term capacity-building, it is important to adopt a dynamic conception of consultation and, consequently, to design consultation processes that allow for ongoing participation rather than seeing it as a single event. This is the best way to guarantee that knowledge and expertise will accrete over time. Similarly, mechanisms for victim participation must be dynamic and allow for ongoing participation. 81. It is crucial to keep in mind, however, that victims are not merely resources for transitional justice processes. The legitimacy argument in favour of victim participation rests on the premise that participation in itself is a positive experience for victims, which in turn has the potential to support the sustainability of transitional justice measures. Participation provides a measure of recognition to victims not only as victims but as rights holders; this is one of the aims of transitional justice policies in general. 62 In addition, participation opens up space for victims in the public sphere, a space that has often been denied to them. 82. On the basis of these are two equalizing contributions that the process of participation can make to victims, it is easier to find commonalities of experiences, values and principles among the different stakeholders, victims included, commonalities that are important for the type of coalition- and consensus-formation on which sustainable transitional justice policies depend. 60 61 62 Ibid. See, e.g., Robbins and Bhandari, From Victims to Actors, p. 47; and Kieran McEvoy and Kirsten McConnachie, “Victims and transitional justice: voice, agency and blame”, Social and Legal Studies, vol. 22, No. 4 (November 2013), pp. 498-499. See A/HRC/21/46. 19