65 c) Disciplinary Proceedings 205. The Commission did not submit allegations with regard to the disciplinary proceedings and their relationship to the violation of Articles 8 and 25 of the Convention. However, the representatives stated that, “[t]he operation of the statute of limitations in [the] disciplinary actions was due exclusively to the extreme negligence of the disciplinary body.” They further alleged that, “the fact that, in the 17 years that have elapsed since the massacre was perpetrated, no State agent has received a disciplinary sanction in relation to it, violates the right of the victims and their next of kin to judicial protection.” In this regard, the State indicated that “[e]ven though the disciplinary proceedings, which conducted as a result of shortcomings in the investigation, were not incorporated into the ordinary criminal proceedings, they complement the State’s investigative function.” 206. The Court assesses any decisions that the disciplinary proceedings may have produced, bearing in mind the symbolic value of the message of censure of public officials and members of the Armed Forces that this type of sanction may signify.214 Moreover, the Court stresses the importance of these proceedings in order to control the actions of these public officials, particularly in situations where the human rights violations occur within generalized and systematic patterns. 207. Regarding the relationship between this jurisdiction and the right of access to justice, the Colombian Constitutional Court has found that “although the general rule indicates that there are no victims under disciplinary law, because the offenses relate to breaches of function-related duties and do not harm rights, exceptionally there may be victims of a disciplinary offense when the infraction relates directly and inseparably to a violation of international human rights law or international humanitarian law.” In this regard, the Constitutional Court stated that: The victims or those injured as a result of a disciplinary offense which constitutes a violation of international human rights law or international humanitarian law may legitimately intervene in the disciplinary proceedings so that the truth of the events may be established. Thus, they have the right that the factual sequence of events be faithfully reconstructed, so that in these specific proceedings, the offenses do not remain in impunity. In other words, the said victims or individuals who have been prejudiced have the right to demand that the State conduct rigorous investigative activities to determine the circumstances in which the breach of the functional duty was committed that, inseparably, led to the violation of their rights and, once these circumstances have been clarified, they have the right that disciplinary justice be done.215 208. In this case, the disciplinary tribunals intervened by way of two investigations. Initially they intervened with regard to the soldiers accused of being involved in the events surrounding the massacre and, subsequently they intervened with regard to the judicial officials allegedly responsible for the unjustified delays in the investigation of the massacre (supra para. 176). 209. Regarding the first disciplinary investigation, on February 6, 1989, the Delegated Office of the Procurator for the Armed Forces started preliminary procedures based on criminal complaints brought against Lieutenant Oswaldo Prado and “Lieutenants Andrade 214 Cf. Case of the Pueblo Bello Massacre, supra note 12, para. 203; and Case of the Mapiripán Massacre, supra note 12, para. para. 215. 215 Cf. judgment C-014/2004, issued on January 20, 2004, by the Colombian Constitutional Court.