32 c) the forced disappearance places the disappeared person outside the protection of the law.115 98. The independent Expert, of the United Nations on Enforced or Involuntary Disappearance of Persons has held that the forced disappearance may involve the recognition as a person before the law, which derives from the fact that with the acts of forced disappearance, the victim is intentionally removed from the protection of the law.116 Furthermore, in accordance with the content of Article 1(2) of the Declaration on Enforced Disappearance, the United Nations Working Group has sustained that any act of forced disappearance places the person outside the protection of the law.117 99. Moreover, apart from its allegations in this case, the Inter-American Commission has, in several precedents, constantly considered that the persons who were detained and then disappeared “were excluded from the legal and institutional framework of the State”, which constituted the negation of their very existence as human beings recognized as persons before the law”,118 and as a result, it has declared the violation of Article 3 of the Convention. 100. In turn, at the domestic level of the States of the region, it has been necessary to provide a response to the consequences of the phenomenon of forced disappearance of several people in different contexts and periods, which were not contemplated in the legal system. In particular, the States have adopted several acts and established case-law in light of the lack of specific rules regarding the absence of a person due to forced disappearance and the corresponding inability to exercise his or her rights and obligations and the effects that such situation produces on his or her next-of-kin and third parties.119 In the instant case, for example, before the lack of information in this regard, after nine years, the next-of-kin of Mr. Anzualdo 115 Cf. United Nations Human Rights Committee, case of Zohra Madoui v. Algeria, Communication No. 1495/2006, 94º period of sessions, CCPR/C/94/D/1495/2006 (2008), October 28, 2009, paras. 7.7 and 7.8; case of Messaouda Kimouche V. Algeria, Communication No. 1328/2004, 90º period of sessions, CCPR/C/90/D/1328/2004 (2007), July 10, 2007, paras. 7.8 and 7.9. 116 United Nations, Report submitted by Mr. Manfred Nowak, independent expert charged with examining the existing international criminal and human rights framework for the protection of persons from enforced or involuntary disappearances, pursuant to paragraph 11 of Commission resolution 2001/4, E/CN.4/2002/71, January 8, 2002, para. 70. 117 United Nations, Working Group on Enforced or Involuntary Disappearances, General Comment on the definition on forced disappearance. In a similar sense, Reports of the Working Group on Enforced or Involuntary Disappearance, E/CN.4/2001/68, December 18, 2000, para. 31, and E/CN.4/1996/38, January 15, 1996, para. 43. 118 Cf. among others, CIDH, Report N° 11/98 (case 10.606- Guatemala), para. 57; Report Nº 55/99 (Cases 10.815, 10.905, 10.981, 10.995, 11.042, 11(1)36 – Perú), para. 111; Report Nº 56/98 (Cases 10.824, 11.044, 11(1)24, 11(1)25, 11(1)75 – Perú), para. 110; Report Nº 3/98 (Case 11.221 – Colombia), para. 64; Report Nº 30/96 (Case 10.897 – Guatemala), para. 23; and Report Nº 55/96 (Case 8076 - Guatemala), para. 24. 119 In Argentina, Act 24.321 was enacted on June 8, 1994 on absence due to forced disappearance; in Brazil, Act 9.140/95 was enacted on December 4, 1995 which “reconhece como mortas pessoas desaparecidas em razão de participação, ou acusação de participação, em atividades políticas, no período de 2 de setembro de 1961 a 15 de agosto de 1979, e dá outras providências”; in Colombia, there is a decision of the Open Court of the Constitutional Court of May 23, 2007 (Judgment C-394/07) by which it was ruled about the discriminatory treatment of Act 986 of 2005, since it failed to include the victims of forced disappearance without giving any valid and constitutional justification; in Chile, Act 20.377 was enacted and it was published on September 10, 2009, on "Declaration of Absence due to Forced Disappearance of People" and in the case of Uruguay, Act 17.894 was enacted and published on September 19, 2005, on “Persons whose forced disappearance was confirmed by Appendix 3.1 of the Final Report of the Peace Commission.”