To the extent that they obstruct the administration of justice for such heinous crimes, self-amnesties are contrary to jus cogens (cf. infra). 11. In this Judgment in the Case of Almonacid-Arellano et al., the Inter-American Court, following the precedent introduced in the Case of Barrios Altos, pointed out that self-amnesties such as Decree Law No. 2.191 of 1978 “leave victims defenseless and perpetuate impunity for crimes against humanity. Therefore, they are overtly incompatible with the wording and the spirit of the American Convention, and undoubtedly affect rights embodied in such Convention. This constitutes in and of itself a violation of the Convention and generates international liability for the State. Consequently, given its nature, Decree Law No. 2.191 does not have any legal effects and cannot remain as an obstacle for the investigation of the facts inherent to the instant case or for the identification and punishment of those responsible therefor. Neither can it have a like or similar impact regarding other cases of violations of rights protected by the American Convention which have occurred in Chile” (para. 119). 12. It is hardly surprising that Decree Law No. 2191 has been the target of severe criticism in specialized legal publications.10 After all, it was precisely during the period covered by the aforesaid self-amnesty that most State crimes were perpetrated by the Pinochet regime. The Inter-American Court has established in this Judgment that, precisely during the period between September 11, 1973 and March 10, 1978, the “military dictatorship” in Chile, “by developing a state policy intended to create fear, attacked massively and systematically sectors of the civilian population that were considered as opponents to the regime. This was achieved by a series of serious violations of human rights and of international law, among which there are at least 3,197 victims of summary executions and forced disappearances, and 33,221 detainees, of whom the great majority were tortured.” (para. 103) Mr. Almonacid-Arellano, extra-legally executed by State officials within a “systematic and generalized pattern” of crimes against the civilian population (para. 103), was among these many victims. 13. Stories and testimonies published in recent years agree that the dictatorship which seized power in Chile on September 11, 1973 opted for the “immediate elimination” through “collective executions.” Out of at least 3,197 dead and disappeared “1,823 were killed or disappeared during the first four months of the coup d’état.”11 Thus, on September 11, 1973, the “war [sic] against terrorism” began, just like on September 11, 2001: on each occasion the choice was to violate human rights and International Law by erroneously combating terrorism through State terrorism. 14. During the “total war” which began on September 11, 1973, suspects and political prisoners 10 . Cf., inter alia, B. Chigara, Amnesty in International Law - The Legality under International Law of National Amnesty Laws, Harlow/London, Longman, 2002, pp. 11 and 114; A. O'Shea, Amnesty for Crime in International Law..., op. cit. supra n. (2), pp. 68, 285-286 and 313. 11 . N.C. Mariano, Operación Cóndor - Terrorismo de Estado en el Cono Sur (Operation Condor, State Terrorism in the Southern Cone), Buenos Aires, Publ. Lohlé-Lumen, 1998, p. 87; and cf. A. Boccia Paz, M.H. López, A.V. Pecci, and G. Giménez Guanes, En los Sótanos de los Generales - Los Documentos Ocultos del Operativo Cóndor (In the Generals’ basements- The Hidden Documents of Operation Condor), Asunción, Expolibro/Servilibro, 2002, p. 187.