cease in non-international armed conflicts to enable the return to peace, provided they do not cover up war crimes and crimes against humanity, which cannot remain unpunished. 298 281. In the universal sphere, the United Nations Secretary-General, in his report to the Security Council entitled The rule of law and transitional justice in conflict and post-conflict societies indicated that “United Nations-endorsed peace agreements can never promise amnesties for genocide, war crimes, crimes against humanity or gross violations of human rights.” 299 Similarly, the United Nations High Commissioner for Human Rights has concluded that “amnesties and other juridical arrangements of comparable effect […] promote impunity [and] pose a major obstacle to efforts to uphold the right to the truth by inhibiting the conduct of full inquiries,” 300 and are, therefore, incompatible with State obligations by virtue of different sources of international law. 301 282. Also, in the universal sphere, the human rights treaty bodies have maintained the same standard on the prohibition of amnesties that prevent the investigation and punishment of those who commit grave human rights violations. 302 283. Amnesties or similar measures have also been considered inadmissible under international criminal law. The International Criminal Tribunal for the Former Yugoslavia considered that it would be senseless to argue, on the one hand, to maintain the prohibition of grave human rights violations and, on the other, to allow State measures that authorize or condone them, or amnesty laws that absolve the perpetrators. 303 It also affirmed that an amnesty enacted under domestic law with regard to the crime of torture, “would not be accorded international legal recognition.” 304 Similarly, the Special Court for Sierra Leone considered that the amnesty laws of that country were not applicable to serious international crimes. 305 This universal trend has been incorporated into the Agreement between the United Nations and the Lebanese Republic and the Agreement between the United Nations and the Kingdom of Cambodia, and also into the Charters that created the Special Tribunal for the Lebanon, the Special Court for Sierra Leone, and the Extraordinary Chambers of the Courts of 298 Cf. Case of the Massacres of El Mozote and neighboring placesv. Guatemala. Merits, reparations and costs, paras. 286. United Nations Security Council. Report of Secretary-General. The rule of law and transitional justice in conflict and post-conflict societies. S/2004/616, August 3, 2004, para. 10. Available at: https://undocs.org/S/2004/616. 299 Cf. Human Rights Council of the United Nations. Report of the Office of the United Nations High Commissioner for Human Rights. Right to the Truth. A/HRC/5/7, June 7, 2007, para. 20. Available at https://undocs.org/A/HRC/5/7. 300 301 Cf. Office of the United Nations High Commissioner for Human Rights. Rule-of-Law Tools for Post-conflict States. Amnisties. HR/PUB/09/1, Publication of the United Nations, New York and Geneva, 2009, pp. 11 to 31. Available at https://www.ohchr.org/Documents/Publications/Amnesties_en.pdf. Additionally, regarding the false dilemma between peace or reconciliation and justice, it stated that “[a]mnesties that exempt from criminal sanction those responsible for atrocious crimes in the hope of securing peace have often failed to achieve their aim and have instead emboldened their beneficiaries to commit further crimes. Conversely, peace agreements have been reached without amnesty provisions in some situations where amnesty had been said to be a necessary condition of peace and where many had feared that indictments would prolong the conflict.” 302 For a detailed analysis of the interventions of the Human Rights Committee, the Committee against Torture, the Working Group on Enforced Disappearances, the Committee for the Elimination of Discrmination against Women, and the Committee for the Elimination of Racial Discrimination, see, inter alia, Case of Gelman v. Uruguay, paras. 205 to 208. Several State have enacted domestic laws that prohibit amnesties and similar measure with regard to crimes against humanity. 303 Cf. ICTY. Prosecutor v. Furundžija. Judgment of December 10, 1998, Case No. IT-95-17/1-T, para. 155. 304 ICTY. Prosecutor v. Furundžija. Judgment of December 10, 1998, Case No. IT-95-17/1-T, para. 155. Cf. SCSL. Prosecutor v. Gbao, Decision No. SCSL-04-15-PT-141 of May 25, 2004, para. 10; SCSL. Prosecutor v. Sesay, Callon and Gbao, Judgment of March 2, 2009, Case No. SCSL-04-15-T, para. 54, and SCSL. Prosecutor v. Sesay, Callon and Gbao, Sentencing Judgment of April 8, 2009. Case No. SCSL-04-15-T, para. 253. 305 72