10 which took place or any situation which ceased to exist before the date of the entry into force of the treaty with respect to that party. 39. According to this principle of non-retroactivity, in the case of a continuing or permanent violation, which begins before the acceptance of the Court’s jurisdiction and persists even after that acceptance, the Tribunal is competent to examine the actions and omissions occurring subsequent to the recognition of jurisdiction, as well as their respective effects.2 40. The Commission has maintained throughout the present proceeding that the only violations which it attributes to Suriname before this Tribunal relate to “a series of acts and omissions,” starting from the date of the State’s acceptance of the Court’s jurisdiction, which has allegedly caused an ongoing denial of justice in violation of the terms of Articles 8, 25 and 1(1) of the American Convention. In its various submissions before the Court, the Commission has referred to several examples of “individual, autonomous violations of the State’s obligations under the Convention,” all of which have allegedly occurred subsequent to Suriname’s accession to the Convention and recognition of the Court’s jurisdiction. 41. These supposed State violations are based upon, inter alia, the following alleged facts cited by the Commission: the failure until 1989 to initiate an ex officio investigation into the November 29, 1986 occurrences at Moiwana Village; the army’s forceful releasing of suspects in police custody in 1989; the 1990 murder of the police officer in charge of the Moiwana investigation and, as a consequence, a suspension of further official inquiries; and the additional “chilling effect” upon the investigation brought about by the 1992 enactment of an amnesty law. 42. For their part, the representatives argued that “[t]he denial of justice alleged in this case is specifically linked to Suriname’s acts and omissions occurring in 1989, 1992, 1993, 1995 and 1996-97 and continues to the present day.” Furthermore, they have alleged other State violations of the Convention, in addition to those associated with Articles 8, 25 and 1(1), which also purportedly took place following Suriname’s recognition of the Court’s jurisdiction, such as alleged violations of Articles 5 and 21 of the Convention. 43. In the case sub judice, the Court distinguishes between alleged violations of the American Convention that are of a continuing nature, and those that occurred after November 12, 1987. With respect to the former, the Tribunal observes that the perpetration of a massacre in 1986 has been alleged; in consequence, an obligation arose for the State to investigate, prosecute and punish the responsible parties. In that regard, Suriname initiated an investigation in 1989. Yet, the State’s obligation to investigate can be assessed by the Court starting from the date when Suriname recognized the Tribunal’s competence. Thus, an analysis of the State’s actions and omissions with respect to that investigation, in light of Articles 8, 25 and 1.1 of the Convention, falls within the jurisdiction of this Court. On the other hand, it has been argued that the alleged victims were forcefully displaced from their ancestral lands. Although this displacement supposedly occurred in 1986, their inability to return to those territories has allegedly continued. The Court, then, has competence to rule upon these alleged facts and their legal implications. Finally, with regard to the 2 Cf. Case of the Serrano-Cruz Sisters. Preliminary Objections, supra note 1, para. 67; Case of Alfonso Martín del Campo Dodd. Preliminary Objections, supra note 1, para. 79; and Case of Blake. Preliminary Objections. Judgment of July 2, 1996. Series C No. 27, paras. 39 and 40.