38 regarding the measure’s applicability need. The mere listing of all the norms that could be applicable does not satisfy the requirement of a sufficient justification that will allow an assessment of whether it is compatible with the American Convention.119 In this respect, the Court has established in its jurisprudence that those rulings of domestic bodies that may impair human rights, such as the right to personal liberty, and which are not duly substantiated, are arbitrary.120 117. Likewise, it does not spring forth from the rules invoked or the resolution adopted that such measure had a term of duration. On this aspect, the Working Group on Arbitrary Detention had established that in the case of the detention of a person due to his or her irregular immigration status, “a maximum period should be set by law and the custody may in no case be unlimited or of excessive length.”121 In sum, there were no clear limits to the powers of the administrative authority, which favors the undue duration of the detention of immigrants, thus becoming a punitive measure. 118. Consequently, the Tribunal considers that the arrest warrant issued in the instant case was arbitrary, given that it did not contain the grounds and reasons for the need to issue it, according to the facts of the case and the particular circumstances of Mr. Vélez Loor. On the contrary, it would seem that the arrest warrant of irregular immigrants was automatically issued after the initial arrest, without consideration of the particular circumstances.122 Therefore, the Tribunal considers that the State violated Article 7(3) of the Convention in relation to Article 1(1), to the detriment of Mr. Vélez Loor, by depriving him of his liberty during 25 days based on an arbitrary order. c) Effective remedies to challenge the lawfulness of the detention 119. The Commission sustained that although remedies for challenging the lawfulness of the detention did formally exist, “they were not effectively made available to the [alleged] victim,” considering that due to the absence of information, lack of judicial control and absence of procedural guarantees, Mr. Vélez Loor was prevented from filing a writ of habeas corpus on his own initiative. 120. The representatives alleged that even though the Panamanian legislation provides for the possibility of filing a writ of habeas corpus to challenge the lawfulness of the detention, in the instant case, Mr. Vélez Loor “never had the real possibility of doing so,” due to the fact that he was an irregular migrant; therefore, he was in a special vulnerable situation. Therefore, the representatives alleged that, due to the violation of several procedural guarantees, he was prevented from having access to the corresponding judicial remedy, namely: i) he was never notified of the proceeding instituted against him; ii) he was not provided with legal aid; iii) he was not informed of his rights; and iv) during the whole time the alleged victim was in Panamanian territory, he was held in custody by the State authorities and was never taken before a judicial authority. According to the representatives, all these omissions prevented 119 Cf. Case of García Asto and Ramírez Rojas, supra note 99, para. 128 and 143; Case of Barreto Leiva, supra note 96, para. 116, and Case of Yvon Neptune, supra note 97, para. 98. 120 Cf. Case of Yatama, supra note 38, para. 152; Case of Escher et al., supra note 110, para. 208, and Case of Tristán Donoso v. Panamá. Preliminary Objections, Merits, Reparations, and Costs. Judgment of January 27, 2009. Series C No. 193, para. 153. 121 United Nations, Working Group on Arbitrary Detention, Group Report, Annex II, Deliberation No. 5: Situation regarding immigrants and asylum-seekers, 1999, E/CN.4/2000/4, Principle 7. 122 According to the statement of the Chief of Investigations of the National Office of Immigration at the time of the events, whenever there was an irregular immigration “his or her identity was established […] and then, an Arrest Warrant was issued, which was signed by the Director and personally notified to the party involved.” Statement rendered by Carlos Benigno González Gómez before a public notary (affidavit) on August 13, 2010 (case file of the evidence, volume IX, affidavits, folio 3779).