damages. The judgment established that the incident producing the harm never came to an end because it involved a forced disappearance. 191. In the court of second instance, on November 4, 2004, the Third Chamber of the Federal Court for Administrative Disputes partially ruled admissibility of the complaint in favor Victoria Larrabeiti Yáñez and declared that the action regarding her brother was subject to the statute of limitations because two years had elapsed since he had become of legal age. On October 30, 2007, the CSJN admitted the ordinary remedy filed by the national state against the judgment of second instance, declaring that the proceedings of both siblings were subject to the statute of limitations. The Court considered that the adoptive parents should have inferred the complaint at least since the publication in 1986 of the final report drafted by CONADEP, in whose annex appear the numbers of the docket corresponding to the biological parents. The judgment also established that the statute of limitations was applicable for civil lawsuits arising from crimes against humanity, as they involve a matter that is available and waivable. 192. The Commission observes that Article 2561 of the Civil Code adopted in 2015 established that civil lawsuits arising from crimes against humanity cannot be subject to a statute of limitations. Nevertheless, according to available information, to date the jurisprudential criterion of the CSJN is that this non-applicability of a statute of limitations does not govern cases of forced disappearances taking place during the dictatorship, because Article 2537 of this Code establishes that the delays for the statute of limitations in force at the time of the entry into force of the Code are governed by the previous law. As indicated in the section relative to the establishment of the facts, according to this interpretation, “the starting point for the delay regarding the statute of limitations can be situated—among other possibilities—on the date when, by means of a court judgment, the alleged decease of the victim of the crime is determined.” 193. Therefore, taking into account the above-mentioned inter-American standards in the matter, the Commission considers that there is clarity about the absence of any treaty-based applicability of the statute of limitations in civil proceedings filed in cases of grave human rights violations. Furthermore, in addition to the indefeasible nature of the facts of the instant case because they involve grave violations, the Commission notes that, because forced disappearance is continuous by its very nature, there is no starting point from which one can begin to calculate the delay for the statute of limitations, because the declaration of an alleged death, contrary to the criterion applied by the CSJN in its jurisprudence, does not bring an end to the crime. 194. Furthermore, the Commission deems that the requirement set by the CSJN that the adoptive parents should have inferred the complaint at least as of the publication of the final report drafted by CONADEP, excessively limits the access to justice, rendering the right to obtain redress illusory. The Commission observes that, according to official information, the first printing of the Final Report of CONADEP published in 1986 amounted to 40,000 copies and it was sold out within 48 hours after its release. In addition, it must be kept in mind that the adoptive family lived in Chile, so that they did not necessarily know what was happening in Argentina, all the more so because it was a time when information was not as accessible and did not circulate as quickly as when the judgment was issued. Therefore, the Commission considers that the applicability of a civil statute of limitations in the instant case violated Articles 8.1 and 25.1 of the American Convention, in connection with the obligations set forth in Articles 1.1 and 2 of the same instrument, to the detriment of the Larrabeiti Yáñez siblings. 3. General considerations about administrative reparation mechanisms in cases of grave human rights violations 195. The Commission reiterates that states have the obligation to offer full reparation to the victims of human rights violations. Regarding this, the Commission has recognized that “in grave, systematic, and prolonged situations of human rights violations, states may establish reparation programs that make it possible

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