A. Non-applicability of the statute of limitations on actions to obtain redress for serious human rights violations A.1. Arguments of the parties and of the Commission 226. The Commission argued that civil actions in cases of serious human rights violations are not subject to the statute of limitations, as provided for in article 2561 of the Argentine Civil and Commercial Code. It noted that the Supreme Court had found that civil actions in cases of serious human rights violations were in fact eligible for application of the statute of limitations with respect to forced disappearances that occurred during the dictatorship. This ruling has limited the alleged victims' access to justice, and the State has violated Articles 8(1) and 25(1) of the Convention, read in conjunction with Articles 1(1) and 2 thereof. 227. The representative stated that it “fully shares the conclusion set forth” by the Commission in the Report on the Merits. 228. The State argued that in its judgment finding that the civil action could lapse under the statute of limitations, the Supreme Court indicated that the ruling “did not deny plaintiffs’ right to the compensation recognized in the special laws.” It added that analysis of international responsibility “cannot focus exclusively on considering ordinary civil action and its declaration that the statute of limitation was not applicable, while omitting from consideration the reparations channel provided for in the system of special laws, that the representative had disregarded” and that was “not subject to extinguishment.” " It requested that the Court find that Argentina is not responsible for the alleged violations. A.2. Considerations of the Court 229. The Court recalls that in the case of Órdenes Guerra et al. v. Chile, it ruled that judicial actions brought to obtain reparations for serious human rights violations are not subject to the statute of limitations. It reiterates the same view herein, as international human rights law is understood to robustly support these considerations. 230. The case points to several statements by international bodies in support of the concept that the statute of limitations shall not apply to actions for obtaining redress for serious human rights violations. Among other examples, it quoted then UN Rapporteur on the Right to Restitution, Compensation and Rehabilitation for Victims of Gross Violations of Human Rights saying, “the principle should prevail that claims relating to reparations for gross violations of human rights shall not be subject to a statute of limitations,” as they are linked to “the most serious crimes.” 257 It also mentions the Updated Set of Principles for the protection and promotion of human rights through action to combat impunity, adopted in 2005 by the then United Nations Commission on Human Rights. Principle 23 expressly provides that prescription shall not apply to “civil or administrative actions brought by victims seeking reparation for their injuries,” and this is reiterated in Principle 32. 258 231. Accordingly, “[i]nsofar as the facts that gave rise to the civil actions for damages or acts characterized as crimes against humanity, such actions should not be subject to the statute Cf. Commission on Human Rights, Study concerning the right to restitution, compensation and rehabilitation for victims of gross violations of human rights and fundamental freedoms: final report submitted by Mr. Theo van Boven, Special Rapporteur, E/CN.4/Sub.2/1993/8, July 2, 1993, par. 135. 258 Cf. Commission on Human Rights, Report of the independent expert to update the Set of principles to combat impunity, Diane Orentlicher, E/CN.4/2005/102/Add.1, February 8, 2005, Principles 23 and 32. Also see United Nations General Assembly, Basic Principles and Guidelines on the Right to a Remedy and Reparation for Victims of Gross Violations of International Human Rights Law and Serious Violations of International Humanitarian Law, A/RES/60/147, March 21, 2006, Principle IV. 257 60