8 June 28, 2009.”17 In that communiqué the Court stated that, “as defenders of the Constitution, the Armed Forces have taken action to defend the Rule of Law, enforcing the provisions of the law to those who have made public statements and taken public actions against the provisions of the Constitution.” 18 In a subsequent communiqué and in a communiqué released on July 20, 2009, the SCJ described the judicial case brought against President Zelaya in connection with the popular consultation 19 and reported on the orders given to court authorities to continue the case.20 In documents published on July 31 and August 21, 2009, the SCJ again made the point that what was happening was being done within the law.21 Media outlets reported that, against this backdrop, de facto President Roberto Micheletti met with the full membership of the Supreme Court.22 31. As for the role of the SCJ, the report of Honduras’ Truth and Reconciliation Commission concluded that “this branch of government was unable to rise above the crisis; it abandoned its role as arbiter and became instead a protagonist in the ouster of José Manuel Zelaya as constitutional president of the Republic.”23 The report goes on to recount the disproportionate number of rejected petitions of amparo brought against the de facto government, by comparison to the only two petitions of amparo filed on behalf of the general who refused to obey the order to guard the ballot boxes, which the court granted.24 Another factor considered was the speed and diligence with which these petitions of amparo were considered.25 32. For its part, in the Report of the Working Group on the Universal Periodic Review, the following recommendation was made to the Honduran State: 17 Annex 2. Judicial Branch of the Nation. Communiqué dated June 28, 2009. Attachment to the petitioners’ communication of January 20, 2011. 18 Annex 2. Judicial Branch of the Nation. Communiqué dated June 28, 2009. Attachment to the petitioners’ communication of January 20, 2011. 19 Annex 3. Supreme Court. Special Communiqué. No date. Attachment to the petitioners’ communication of January 20, 2011. 20 Annex 4. SCJ. Communiqué dated July 20, 2009. Attachment to the petitioners’ communication of January 20, 2011. 21 Annex 5. SCJ. Communiqué dated July 31, 2009. Annex **. SCJ Institutional Opinion of the SCJ. August 21, 2009. Attachments to the petitioners’ communication of January 20, 2011. 22 Anex 6. Press releases: “Corte Suprema opuesta a la restitución de Manuel Zelaya” [Supreme Court opposed to the reinstatement of Manuel Zelaya]; “Micheletti consulta a la Corte opinión sobre Polémico Decreto” [Micheletti consults the Court for an opinion on controversial decree], and “Micheletti y magistrados discuten decreto” [Micheletti and justices discuss decree]. Attachments to the petitioners’ communication of January 20, 2011. 23 Truth and Reconciliation Commission, Para que los hechos no se repitan: Informe de la Comisión de la Verdad y Reconciliación” [So That Events Are Not Repeated: Report of the Truth and Reconciliation Commission], July 2011, p. 402. 24 Truth and Reconciliation Commission, Para que los hechos no se repitan: Informe de la Comisión de la Verdad y Reconciliación” [So That Events Are Not Repeated: Report of the Truth and Reconciliation Commission], July 2011, pp. 369-370. 25 Truth and Reconciliation Commission, Para que los hechos no se repitan: Informe de la Comisión de la Verdad y Reconciliación” [So That Events Are Not Repeated: Report of the Truth and Reconciliation Commission], July 2011, p. 372. Available in Spanish at: http://www.sjdh.gob.hn/recomendacionesCVR/sites/default/files/Primer%20Informe%20de%20Estado%20de%20Cumplimient o%20de%20las%20Recomendaciones%20de%20CVR.pdf