7 rendered by the Court (supra Having Seen clause No. 1). In this regard, they noted that, even though there is a judgment whereby three persons were convicted, no punishment has yet been dealt to “the high-ranking officers or the commanders that led [the] operation” that caused the death of seven people in the instant case, “even though [the State] is in possession of all the information needed to identify [them].” Lastly, they considered that the State’s designing “a special mechanism to move forward” the investigations would be a “very interesting proposal showing good disposition.” 18. That the Inter-American Commission stated at the private hearing (supra Having Seen clause No. 7) that “really, in connection with the investigation, there are no new actions other than the ones reported by the date of the Court’s Order [of August 4, 2008], which established that the proceeding would be kept open so that the State would report on the aspects [compliance with which] was still pending.” 19. That, on the one hand, the Tribunal notes that the State referred to the statute of limitations barring criminal action for the crimes of malfeasance of public office, cover-up, personal injury and perjury in connection with the facts of the instant case (supra Considering Clause No. 16). The Court finds it appropriate to repeat that, earlier during the monitoring compliance stage of the instant case, it had already held that the State “must guarantee internal proceedings intended to investigate all facts in the case and punish those responsible [in accordance with the Judgment on reparations].”10 In this regard, the Tribunal has noted that, even though the statute of limitations is a due process safeguard that must be duly observed by the courts in connection with every person accused of a crime,11 its assertion and application are unacceptable where it is a clearly established fact that the lapse of time has been the result of procedural acts or omissions which, in a clear display of bad faith or negligence, were aimed at facilitating or allowing impunity.12 The res judicata status of a decision could potentially be challenged before this Tribunal where the decision impairs the rights of individuals protected by the Convention and there is an established ground for challenging the res judicata status.13 20. That, on the other hand, the Court notes that the representatives referred once again to the estoppel, in 2002, of an investigation opened by the Human Rights Unit in May 1998. This aspect of the investigations is addressed in the Judgment on reparations rendered by the Tribunal in the instant case (supra Having Seen clause 10 Case of Las Palmeras v. Colombia. Monitoring Compliance with Judgment. Order of the InterAmerican Court of Human Rights of November 17, 2004, Considering clause No. 8. 11 Cf. Case of Albán-Cornejo et al. v. Ecuador. Merits, Reparations and Costs. Judgment of November 22, 2007. Series C No. 171, para. 111; Case of the Gómez-Paquiyauri Brothers v. Peru. Monitoring Compliance with Judgment. Order of the Inter-American Court of Human Rights of May 3, 2008, Considering clause No. 13, and Case of Ivcher-Bronstein, supra note 3, Considering clause No. 17. 12 13 Cf. Case of Ivcher-Bronstein, supra note 3, Considering clause No. 17. Cf. Case of Genie-Lacayo v. Nicaragua. Request for Review of the Judgment on Merits, Reparations and Costs. Order of the Inter-American Court of Human Rights of September 13, 1997. Series C No. 45, paras. 10 to 12; Case of La Cantuta v. Peru. Merits, Reparations and Costs. Judgment of November 29, 2006. Series C No. 162, para. 153, and Case of Ivcher-Bronstein, supra note 3, Considering clause No. 18.