7. On that occasion, the concurring opinions of Judges García Ramírez and Cançado Trindade, whose reasoning I share, emphasized the contradiction between the “selfamnesty laws” and “the general obligations of the State under the American Convention on Human Rights.”2 It was affirmed that “[t]he so-called self-amnesties are, in sum, an inadmissible offence against the right to truth and the right to justice (starting with the very access to justice)”;3 that “[…] the perverse modality of the so-called laws of selfamnesty, even if they are considered laws under a given domestic legal order, are not so in the sphere of international human rights law of”;4 that “[…] ‘laws’ of this kind are devoid of a general nature, as they are measures of exception”5, and that “[…] the so-called "laws" of self-amnesty are not truly laws: they are nothing but an aberration, an inadmissible affront to the juridical conscience of humanity.”6 8. Since then, the Inter-American Court has had the opportunity to examine and rule on different cases on amnesty laws and their application. In these cases, the Court focused on the substantive incompatibility between the amnesty provisions and the State's obligations in relation to human rights violations. This was based on the underlying purpose of the law, its ratio legis: to leave these grave violations unpunished, rather than on the process of the adoption of the law or the authority that enacted it. These are the cases of Almonacid Arellano et al. v. Chile (2006), La Cantuta v. Peru (2006), Gomes Lund et al. v. Brazil (2010) and Gelman v. Uruguay (2011). In these cases, the Court followed its case law in the Barrios Altos case and further developed some aspects. In general, it reiterated what it had already indicated regarding the “the incompatibility of amnesty laws relating to serious human rights violations with international law and the international obligations of States”7 and that the provisions of amnesty laws that prevent the investigation and punishment of serious human rights violations have no legal effects and, therefore, cannot obstruct the investigation of the facts and the identification and punishment of those responsible for human rights violations.8 9. Each of the cases on amnesty laws examined by the Court up until the massacres of El Mozote and nearby places had its own characteristics, nuances and emphasis, either with regard to the context in which the law originated or its scope. However, they all had in common that none of these amnesty laws was created in the context of a process aimed at ending, through negotiations, a non-international armed conflict. 10. This amnesty case arises from a different context to all the previous ones. This has implications for the analysis and legal characterization of the facts, and for the Court’s concepts and considerations on this amnesty law enacted following an armed conflict and a peace negotiation process. That is why, according to the Court's reasoning, it has been necessary to take into account not only the norms and principles of international human rights law, but also the relevant provisions of international humanitarian law in view of the context in which the events occurred. 11. As described throughout this judgment, the facts of the massacres of El Mozote and nearby places occurred in the context of a non-international armed conflict. As it developed throughout the 1980s it had reached a point at which the global and regional 2 Concurring opinion of Judge Sergio García Ramírez, para. 1. 3 Concurring opinion of Judge Antonio A. Cançado Trindade, para. 5. 4 Ibid., para. 6. 5 Ibid., para. 7. 6 Ibid., para. 26. 7 Case of Gomes Lund et al. (Guerrilha do Araguaia) v. Brazil. Judgment of November 24, 2010, para. 147. 8 Case of Gelman v. Uruguay. Judgment of February 24, 2011, para. 232. 2