29. In 2009, the Supreme Court of Uruguay admitted an action for unconstitutionality in a specific case against Articles 1, 3, and 4 of the Expiry Law. In its decision, it stated: (...) "to declare the expiration of criminal prosecutions, in any case, exceeds the powers of the legislators and invades the forum of a function constitutionally assigned to judges, so that, for whatever reason, the legislature could not arrogate to itself the power of deciding that the period had expired regarding prosecution for certain crimes. To summarize, the unlawfulness of an amnesty law enacted for the benefit of military and police officials who committed [serious violations of human rights], who enjoy impunity during de facto regimes, has been declared by courts, of both the international community and the States that went through similar processes experienced by Uruguay during the same period in time. Such rulings, given the similarity with the issue under analysis and the relevance they have had, could not be ignored in the examination of the constitutionality of Law [No.] 15.848 and have been taken into account by the Corporation to issue the present ruling."16 30. For its part, the Inter-American Court considered, in its judgment in the Gelman case v. Uruguay, n 2011, that "the provisions of the Expiry Law that impede the investigation and punishment of serious violations of rights have no legal effect and, therefore, cannot continue to obstruct the investigation of the facts of this case and the identification and punishment of those responsible, nor can they have the same or similar impact on other cases of serious violations of human rights enshrined in the American Convention that may have occurred in Uruguay."17 31. On November 1, 2011, Uruguay promulgated Law 18,831, which amended Law 15.848. That law states: Article 1. Full exercise of the punitive claims of the State are restored for crimes committed in the implementation of State terrorism up to March 1, 1985 and included in Article 1 of Law No. 15.848 of December 22, 1986. Article 2. No time limits of any kind shall be set -- procedural, prescriptive, or expiry-related -- in the period between December 1986 and the entry into force of this law, for the crimes referred to in Article 1 of this law. Article 3. Let it be hereby declared that the crimes referred to in the foregoing Articles are crimes against humanity in accordance with international treaties to which the Republic is party.18 32. Likewise, the Executive issued Decree No. 323/2011, which revoked “for reasons of legitimacy, all administrative acts and communications issued by the Executive Branch in application of Article 3 of the Expiry Law, considering that the facts denounced were included in the provisions of Article 1 of the above-mentioned law."19 33. Subsequently, on February 22, 2013, the Supreme Court of Justice of Uruguay declared the unconstitutionality of Articles 2 and 3 of Law 18.831 of 2011 in a concrete case, with one judge dissenting. That same Court also dismissed the action for unconstitutionality brought against Article 1 of law 18.831.20 34. In its monitoring of compliance with judgment resolution in the Gelman case, in 2013 the Inter-American Court stated that " the issuance of the aforementioned Decree and Law appears to have little practical utility if, owing to subsequent court rulings, such crimes are declared expired, which would open up the possibility that enforced disappearances and other gross human rights violations committed in this case, and during the dictatorship in Uruguay, would go unpunished. Thus, beyond declaring the “re-establishment of the State’s punitive claims” through said Law, certain Supreme Court of Justice. Judgment No. 365, Sabalsagaray Curutchet, Blanca Stela. Complaint. Unconstitutionality objection, Articles 1, 3, and 4of Law No.15.848, File card 97-397/2004; see also I/A Court H.R. Case of Gelman v. Uruguay, Merits and Reparations. Judgment of February 24, 2011. Series C No. 221, par. 219. 17 I/A Court HR. Case of Gelman v. Uruguay, Merits and Reparations. Judgment of February 24, 2011. Series C No. 221, par. 232. 18 Law No. 18.831 of November 1, 2011, promulgated by the Eastern Republic of Uruguay. 19 I/A Court of H.R. Resolution by the Inter-American Court of Human Rights, Case of Gelman v. Uruguay, of March 20, 2013, Monitoring Compliance with Judgment, par. 43. 20 Supreme Court of Justice of the Eastern Republic of Uruguay, Judgment No. 20 of February 22, 2013. 16 6