5 has expressly warned in the Cyprus versus Turkey case (1983) - as an aggravating 12 circumstance of the violation of human rights proven in the cas d'espèce . IV. The Undue Fragmentation of the Crime of Forced Disappearance. 12. All this jurisprudential construction is, nevertheless, left without effect in the circumstances of the present Blake case, by reason of the limitation ratione temporis to the competence of the Court. The changing reality of the facts, definitively, always requires from legal rules a dynamic renewal, in order to ensure their constant adequacy to the new needs of protection and, hence, their efficacy. This naturally applies to the capacity of response and struggle against new forms of violation of human rights. 13. In the cas d'espèce, the limitation ratione temporis to the competence of the Inter-American Court, in restricting the extent of the judicial settlement, leads to the almost decharacterization of the crime of forced disappearance in the Blake case. Such limitation breaks down that complex crime, retaining for consideration, as to the rights protected by the Convention, the elements pertaining only to the judicial guarantees (Article 8(1) of the American Convention) and to the right to psychic and moral integrity (Article 5 of the Convention), both in relation to the relatives of the disappeared person. 14. There are other disturbing aspects in the "fragmentation" of the crime of forced disappearance of persons in successive violations of human rights over time: beyond the artificiality of such decharacterization lies the fact that, in the forced disappearance of persons, we are before the violation of rights of a non-derogable character, such as the fundamental right to life itself, in the framework of a continuing situation. This is what the preamble of the Inter-American Convention on Forced Disappearance of Persons aptly warns, adding - as does the preamble of the United Nations Declaration on the Protection of All Persons against Forced Disappearances - that the systematic practice of such disappearance constitutes a crime against humanity. 15. We are, definitively, before a particularly grave violation of multiple human rights. Among these are non-derogable fundamental rights, protected both by 13 human rights treaties as well as by International Humanitarian Law treaties . The more recent doctrinal developments in the present domain of protection disclose a 14 tendency towards the "criminalization" of grave violations of human rights , - as 12. In its Report of 04 October 1983 in the Cyprus versus Turkey case (petition n. 8007/77) the European Commission concluded that the continuing separation of families (as a result of the refusal of Turkey to allow the return of Greek Cypriots in order to reunite themselves with their next of kin in the North) constituted an "aggravating factor" of a continuing situation in violation of Article 8 of the European Convention of Human Rights. European Commission of Human Rights, Decisions and Reports, vol. 72, pp. 6 and 41-42. 13. Cf., e.g., the provisions on fundamental guarantees of Additional Protocol I (of 1977) to the Geneva Conventions on International Humanitarian Law (of 1949), Article 75, and of the Additional Protocol II (of the same year), Article 4. 14. As exemplified by the recognition of the individual responsibility (cf. the InterAmerican Convention to Prevent and Punish Torture, besides the Convention on the Prevention and Punishment of the Crime of Genocide of 1948) parallel to the international responsibility of the State, and the consolidation of the principle of universal jurisdiction (as one of the legal consequences of the typification itself of the crime of forced disappearance of persons); cf. OEA/CP-CAJP, Informe..., op. cit. supra n. (9), p. 9.