specified in the Judgment of Albán Cornejo v. Ecuador, criteria that consists in that “[n]otwithstanding the aforementioned, the statute of limitations is inadmissible in connection with and inapplicable to a criminal action where gross human rights violations in the terms of International Law are involved. So has been held in the Court’s constant and consistent decisions.” 125 In the instant case, the inapplicability of the statute of limitations was not declared because it involved medical negligence and for not complying with the Court’s criteria. In a more recent manner, in the Judgment of the Court in the case of Ibsen Cárdenas and Ibsen Peña v. Bolivia, said criteria was established upon stating that “in some circumstances, International Law considers the statute of limitations to be inadmissible and inapplicable, as well as amnesty provisions and the establishment of exceptions to responsibility, in order to maintain the States punishing authority in force against conduct where the gravity makes repression necessary in order to avoid repeated commission of said conduct.” 126 This criteria, specifically, the non-admissibility of a statute of limitations, was applied in the mentioned case in regard to “the torture and murder committed during a context of massive and systematic human rights violations.”127 Now, though this did not regard a case in which the criminal statute of limitations had been argued, in the Judgment also issued recently, in the case of Gomes Lund et al. (Guerrilha do Araguaia) v. Brazil, the Court reiterated that “[…] the statute of limitation provisions […] that are intended to prevent the investigation and punish those responsible for serious violations to human rights such as torture, summary, extrajudicial, or arbitrary executions, and enforced disappearance are not admissible, all of which are prohibited for contravening irrevocable rights recognized by International Law of Human Rights.”128 This jurisprudence was also maintained in the last case before the Court wherein serious violations were alleged, namely, Gelman v. Uruguay.129 From the foregoing, it is evident that the inadmissibility of statutes of limitations in the Court’s jurisprudence has usually been declared due to the particularities of cases that involve serious human rights violations, such as forced disappearance, the extrajudicial killing of persons, and torture. In some of those cases, the human rights violations occurred in a context of massive and systematic violations. 118. In relation to point b), the Court deems that any human rights violation involves a level of severity by its own nature, because it implies a breach of certain State obligations to respect and guarantee the rights and freedoms for people. However, this should not be confused with what the Court throughout its jurisprudence has deemed to be “serious violations of human rights” which, as is clear from the provisions above (supra para. 117), have their own connotation and consequences. To accept the point made by the Commission, in the sense that by its nature this case involves a level of gravity for which the statute of limitations is inapplicable, would imply that any case before the Court, as all cases involve violations of human rights in 125 Case of Albán Cornejo et al. V. Ecuador, supra note 38, para. 111. 126 Cf. Case of Ibsen Cárdenas and Ibsen Peña V. Bolivia, supra note 94, para. 207. 127 Cf. Case of Ibsen Cárdenas and Ibsen Peña V. Bolivia, supra note 94, para. 208. 128 Cf. Case of Gomes Lund et al. (Guerrilha do Araguaia) V. Brazil, supra note 4, para. 171. 129 Cf. Case of Gelman V. Uruguay, supra note 12, para. 225. 46