4 8. On the other hand, inasmuch as Guatemala, as a State Party to the American Convention on Human Rights (since 25 May 1978), only accepted the jurisdiction of the Court in contentious matters on 09 March 1987, we are led, by the application of a rigid postulate of the law of treaties, to introduce an artificial fragmentation in the consideration of that crime of forced disappearance, taking into account - in an atomized and not integral way - only some of its components, subsequent to this last date, - with direct consequences for the phase of reparations. 9. Such situation is, in my understanding, unsatisfactory and worrisome, since forced disappearance of person is, first of all, a complex form of violation of human rights; secondly, a particularly grave violation; and thirdly, a continuing or permanent violation (until the fate or whereabouts of the victim is established). In fact, the continuing situation (cf. infra) is manifest in the crime of forced disappearance of persons. As pointed out in this respect, in the travaux préparatoires of the Inter-American Convention on Forced Disappearance of Persons, "This crime is permanent in so far as it is committed not in an instantaneous way but permanently, and is prolonged as long as the person 9 remains disappeared" . . Such consideration was duly reflected in Article III of the Convention (supra). 10. The same conception can be found in the United Nations Declaration on the Protection of All Persons against Forced Disappearances of 1992, which, after pointing out the gravity of the crime of forced disappearance of person (Article 1(1)), likewise warns that this latter ought to be "considered a permanent crime while its authors continue concealing the fate or whereabouts of the disappeared person and while the facts have not been clarified" (Article 17(1)). 11. Long before the typification of the forced disappearance of person in the International Law of Human Rights, the notion of "continuing situation" found support in the international case-law in the domain of human rights. Thus, already in the De Becker versus Belgium case (1960), the European Commission of Human Rights, for example, recognized the existence of a "continuing situation" (situation 10 continue/situación continuada) . Ever since, the notion of "continuing situation" has marked presence in the case-law of the European Commission, on numerous 11 occasions . The continuity of each situation appears - as the European Commission 9. OEA/CP-CAJP, Informe del Presidente del Grupo de Trabajo Encargado de Analizar el Proyecto de Convención Interamericana sobre Desaparición Forzada de Personas, doc. OEA/Ser.G/CP/CAJP-925/93 rev.1, of 25.01.1994, p. 10. 10. Cf. Cour Européenne des Droits de l'Homme, Affaire De Becker (Série B: Mémoires, Plaidoiries et Documents), Strasbourg, C.E., 1962, pp. 48-49 (Rapport de la Commission, 08.01.1960). 11. Cf., e.g., the decisions of the European Comission concerning the petitions ns. 7202/75, 7379/76, 8007/77, 7742/76, 6852/74, 8560/79 y 8613/79, 8701/79, 8317/78, 8206/78, 9348/81, 9360/81, 9816/82, 10448/83, 9991/82, 9833/82, 9310/81, 10537/83, 10454/83, 11381/85, 9303/81, 11192/84, 11844/85, 12015/86, and 11600/85, among others.