B.1. Obligation to investigate, prosecute, and, where appropriate, punish the forced disappearance of persons within a reasonable time 103. The Court has stated that everyone, including the relatives of victims of human rights violations, has the right to learn the truth about what happened. 142 Finally, the right to access to justice must ensure, within a reasonable time, the right of the alleged victims or their relatives to have the necessary measures adopted to know the truth and to investigate, judge, and, where appropriate, punish those responsible. 143 104. The obligation to investigate, prosecute, and punish serious violations has been recognized by international treaty bodies for the protection of human rights. Specifically, the United Nations Human Rights Committee established from its first cases that States have the obligation to investigate, in good faith, violations of the International Covenant on Civil and Political Rights, and that investigation and prosecution through criminal proceedings constitute the appropriate and necessary way to clarify human rights violations. 144 The Committee also concluded that, in cases of forced disappearance, States must establish what happened to the victims and prosecute those responsible. 145 105. In the exercise of its intervening and complementary jurisdiction, the Court may examine domestic proceedings in order to evaluate compliance with the obligation to investigate, prosecute, and punish 146 commission of the forced disappearance of persons. Among the aspects to be examined are the jurisdiction of the intervening authorities and the proceedings followed, provided that errors are alleged that may have impaired the possibility of obtaining and presenting evidence to clarify the facts and determine responsibilities, and thus affect the investigation as a whole. 147 106. With regard to speed of the proceedings in general, this Court has pointed out that the "reasonable time" referred to in article 8(1) of the Convention must be assessed in relation to the total duration of the proceedings that take place until the final judgement is issued. The right to access to justice requires that the dispute be resolved within a reasonable time, since prolonged delay may constitute a violation of judicial guarantees. 148 In this sense, the Court has generally considered the following elements to determine the reasonableness of the term: a) complexity of the matter; b) procedural activity of the interested party; c) conduct of the judicial authorities, and d) affects caused to the legal situation of the person involved in the process. The Court recalls that the State is responsible for justifying—based Cf. Case of Carpio Nicolle et al. v. Guatemala. Merits, Reparations, and Costs. Judgment of November 22, 2004. Series C No. 117, para. 262, and Case of the Los Josefinos Village Massacre v. Guatemala, supra, para. 100. 143 Cf. Case of Bulacio v. Argentina. Merits, Reparations, and Costs. Judgment of September 18, 2003. Series C No. 100, para. 114, and Case of Sales Pimenta v. Brazil, supra, para. 83. 144 Cf. UN, Human Rights Committee, Cases Larrosa v. Uruguay, Communication No. 88/1981, UN Doc. CCPR/C/OP/2 at 176 (1990), Views adopted on March 29, 1983, para. 11.5, and Gilboa v. Uruguay, Communication No. 147/1983, expert opinion of November 1, 1985, para. 7.2. 145 Cf. UN, Human Rights Committee, Sathasivam v. Sri Lanka, Communication No. 1436/2005, expert opinion of July 8, 2008, para. 6.4; Amirov v. Russian Federation. Communication No. 1447/2006, Expert opinion of April 2, 2009, para. 11.2, and Felipe and Evelyn Pestaño v. Philippines. Communication No. 1619/2007, Expert opinion of March 23, 2010, para. 7.2. 146 Cf. Case of the “Street Children” (Villagrán Morales et al.) v. Guatemala. Merits. Judgment of November 19, 1999. Series C No. 63, para. 222, and Case of Sales Pimenta v. Brazil, supra, para. 32. 147 Cf. Case of Ibsen Cárdenas and Ibsen Peña v. Bolivia. Merits, Reparations, and Costs. Judgment of September 1, 2010. Series C No. 217, para. 172, and Case of the Los Josefinos Village Massacre v. Guatemala, supra, para. 103. 148 Cf. Case of Hilaire, Constantine, and Benjamin et al. Trinidad and Tobago. Merits, Reparations, and Costs. Judgment of June 21, 2002. Series C No. 94, para. 145, and Case of Sales Pimenta v. Brazil, supra, para. 106. 142 33