convictions270 and “significant and constant progress in the cases that remain open.”271 The State affirmed, indicating that it had done so on the basis of the suggestions of the Special Prosecutor, that all the cases of serious human rights violation are on track to be clarified in the short term.” 243. The State added that it had requested, in order to present its answering brief, a Report of the Supreme Court, the hierarchical judicial body, and that that Court had maintained that “notwithstanding judgments 20/2013 and 680/2017,272 at the present time the Supreme Court’s jurisprudence demonstrates that there is no legal obstacle that would impede the investigation, prosecution and punishment of crimes that might have been committed during the dictatorship and, therefore, the investigations into the human rights violations committed during that time have continued.” 244. Uruguay also referred to comments regarding dilatory strategies employed by the accused. It alleged, in its final written arguments, that “the existence of due process is an unavoidable and necessary consequence of the Rule of Law [and that the] legal order of Uruguay has the necessary tools to detect abuses of law.” The State did not offer details on which “tools.” 245. The State also referred to the “perspective of gender” with respect “to the judicial system of Uruguay and to society as a whole.” It noted that “the matter” was brought up for the first time in the public hearing and that it is not part of the petition of the Inter-American Commission as set out in its Merits Report.273 Nonetheless, Uruguay referred to policies that it had adopted with respect to gender violence and the research on a perspective on gender. It pointed out that it “had ratified all the existing 270 The State highlighted that, since its creation, the Office of the Special Prosecutor has obtained 12 firm convictions; two convictions at the second instance, pending resolution of appeals of cassation, and indictments in 9 cases. As an example, the State mentioned a judicial decision of June 3, 2021, which does not refer to the facts of this case, which ordered the imprisonment pending trial of several persons accused of offenses that occurred during the civil-military dictatorship. The State emphasized that the decision of the Twenty-seventh Criminal Court of the Capital alluded to the decision of the Inter-American Court in the Gelman case, acknowledging that it is binding, and it noted that crimes against humanity were not subject to a statute of limitations. The State asserted that the judicial decision reflects “the current trend in the matter.” (The State presented a copy of that decision: Judgment N539/2021 of the Twenty-seventh Criminal Court of the Capital, of June 3, 2021 (evidence file, fs. 7561 to 7639)). 271 The State did not provide information on those cases. The Court’s order of monitoring compliance of judgment in the Gelman case, of March 20, 2013, stated that “the Supreme Court held, in its decision of February 20, 2013 that ‘for crimes committed during the dictatorship and protected by the Expiry Law, there was no special prescription, but only the same discontinuance terms as that for any other crime, and consequently, there will be no application of the conviction imposed by the Inter-American Court in terms of eliminating the statute of limitations established especially for those cases, given that no laws of this nature were passed.’” The Inter-American Court considered that “it is incompatible with the international obligations of a State Party to the Convention to cease investigating, prosecuting and, where appropriate, punishing those responsible for gross violations of human rights, which by their very nature are not subject to the statute of limitations, and which impair the victims’ right to have access to justice and maintain a situation of impunity that the States own authorities and organs have fostered through the creation of de jure and de facto obstacles that prevented efforts to carry out investigations or move forward with proceedings during a certain period.” (Case of Gelman v. Uruguay. Monitoring compliance of judgment. Order of the Inter-American Court of March 20, 2013, footnote 77 and considering paragraph 94, respectively.) 272 The State alleged that “any reference to the issue of gender in a broader and more structured context was never presented as such either by the Commission or by the representative of the alleged victims.” 273 63